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Home My WebLink AboutEnvironmental Audit of the AK Power Administration 1992DOE/EH-0284 Environmental Audit of the Alaska Power Administration U.S. Department of Energy Office of Environmental Audit October 1992 This report has been reproduced directly from the best available copy Available to DOE and DOE contractors from the Office of Scientific and Technical Informa- tion, P.O. Box 62, Oak Ridge, TN 37831; prices available from (615) 576-8401, FTS 626-8401 Available to the public from the National Technical Information Service, U.S. Department of Commerce, 5285 Port Royal Rd., Springfield, VA 22161 Environmental Audit of the Alaska Power Administration U.S. Department of Energy Office of Environmental Audit Washington, DC 20585 October 1992 PREFACE U.S. Department of Energy Environmental Audit Conducted at the Alaska Power Administration (APA) On June 27, 1989, the Secretary of Energy announced a 10-point Initiative to strengthen environmental protection within the U.S. Department of Energy (DOE). Consistent with this Initiative, the Secretary emphasized and strengthened independent internal oversight as a management reform in Secretary of Energy Notice (SEN)-11-89, which would monitor the effectiveness of DOE management in complying with operational, environmental, safety, health, and security standards established by law, regulation, and DOE policy. As part of the internal oversight responsibilities within DOE, the Office of Environment, Safety and Health (EH) has established a program within the Office of Environmental Audit (EH-24) to conduct multidisciplinary environmental audits at DOE’s operating facilities. The initial audits in this program are designed to gather baseline information on environmental compliance and management at facilities that have not undergone a DOE Headquarters Environmental Survey or Tiger Team Assessment. The objective of the Environmental Audit is to provide the Secretary with information on the compliance status of DOE facilities with regard to environmental requirements, root causes for noncompliance, adequacy of DOE environmental management programs, and response actions necessary to address the identified problem areas. This document contains the findings identified during the Environmental Audit of the Alaska Power Administration (APA), conducted from August 24 to September 8, 1992. The Audit included all APA generation, transmission, and support facilities associated with both the Eklutna and Snettisham Power Projects. The scope of this Environmental Audit was comprehensive, covering all areas of environmental activities and waste management operations, with the exception of the National Environmental Policy Act (NEPA), which is the responsibility of the DOE Headquarters Office of NEPA Oversight. Compliance with Federal, state, and local regulations; DOE Orders; and internal facility requirements was addressed. October 1992 Washington, D.C. iii Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G LIST OF APPENDICES Biographical Sketches of the Environmental Audit Team... . Environmentall||Audse || Pian |i el (MC (UMM Mel AAO Rte PCIe Piet [alte Environmental Audit Team Schedule of Onsite Activities List of Site Documents Reviewed by the Environmental (Audit! team ee EMMI MGIIPSLICI AL MGI ALeN List of Contacts and Interviews Conducted by the Environmental Audit Team ..............202.. Definitions of Causal Factors and Contributing Factors Listiiot ‘Acronyms|-and|Abbrevaattonsiil || cus eile le InleIhI AI CeHI ere vii A-1 C-1 D-1 E-1 F-1 Figure 1-1. Figure 1-2. Figure 1-3. Figure 2-1. Figure 2-2. Table 2-1 Table 2-2 Table 3-1 Table 3-2 Table 3-3 Table 3-4 Table 3-5 Table 3-6 Table 3-7 Table 3-8 LIST OF FIGURES Alaska Power Administration Facilities Location Map .... 2... 2... 2. eee eee ee ee 1-4 Eklutna Project Location Map .............0.. 1-6 Snettisham Project Location Map .............. 1-7 Summary of Findings by Discipline ............. 2-4 Summary of Apparent Causal Factors and Contributing Factors ................00. 2-13 LIST OF TABLES Environmental Audit Team Findings .............. 2-2 Summary of Apparent Causal Factors and Contributing Factors Identified by Audit Finding ............. 2-9 List of Air Regulations, Requirements, and Guidelines .... 3-2 List of Surface Water/Drinking Water Regulations, Requirements, and Guidelines... 2... .........00. 3-8 List of Groundwater Regulations, ° Requirements, and Guidelines ................. 3-22 List of Waste Management Regulations, Requirements, and Guidelines... 2... .........0. 3-28 List of Toxic and Chemical Materials Regulations, Requirements, and Guidelines .......... 3-44 List of Quality Assurance Regulations, Requirements, and Guidelines ...........0....0.. 3-58 List of Inactive Waste Sites Regulations, Requirements, and Guidelines .......... 3-64 List of Environmental Management Regulations, Requirements, and Guidelines... 2... 2... ee ee eee 3-82 vi 1.0 2.0 3.0 ENVIRONMENTAL AUDIT Alaska Power Administration (APA) TABLE OF CONTENTS INTRODUCTION. ©. 2. ee le 1-1 1.1 Purpose .. 2... ee ee ee 1-1 1.2 Scope... ... ee 1-2 1.3 Approach... 2... 2 ee le 1-2 1.4 Historical Background and Facility Description ...... 1-3 SUMMARY OF ENVIRONMENTAL AUDIT RESULTS .........2..... 2-1 2.1 Key Findings — 3. eS 2-5 2.2 Findings Summary ............0......004824 2-6 2.3 Causal Factor Summary .................0.. 2-7 ENVIRONMENTAL AUDIT FINDINGS .................0.. 3-1 3.1 Air == + 9 6 906 9 44s #4 ews se se sega 3-1 3.1.1 Overview . 2... 2... ee 3-1 3.1.2 Compliance Finding .............0.., 3-3 3.1.3 Best Management Practice Findings ......... 3-4 3.2 Surface Water/Drinking Water... 2... .....02.. 3-7 3.2.1 Overview 2... 2... . ee 3-7 3.2.2 Compliance Findings ................ 3-10 3.2.3 Best Management Practice Findings ......... 3-18 3.3 Groundwater ... 2... 2... 2. ele 3-21 3.3.1 Overview 2... ... 2. ee 3-21 3.3.2 Compliance Finding .............04. 3-25 3.4 Waste Management .............0.0.2..00040. 3-27 3.4.1 Overview 2... . 2... 3-27 3.4.2 Compliance Findings .............0.2. 3-31 3.4.3 Best Management Practice Findings ......... 3-40 3.5 Toxic and Chemical Materials .............0.. 3-43 3.5.1 Overview ... 2... . ee 3-43 3.5.2 Compliance Finding .............0.2, 3-47 3.5.3 Best Management Practice Findings ......... 3-49 3.6 Quality Assurance .. 2... 2.2... ....02.202020804. 3-57 3.6.1 Overview . 2... 3-57 3.6.2 Compliance Findings .............0.. 3-59 3.7 Inactive Waste Sites ..........0.0.2..2.2.0.2.,. 3-63 3.7.1 Overview . 2... 2... 3-63 3.7.2 Compliance Findings ................, 3-67 3.7.3 Best Management Practice Findings ......... 3-75 3.8 Environmental Management ................. 3-81 3.8.1 Overview 2... . le 3-81 3.8.2 Compliance Findings ................ 3-84 3.8.3 Best Management Practice Findings ......... 3-93 EXECUTIVE SUMMARY This report documents the results of the Comprehensive Baseline Environmental Audit of the Alaska Power Administration (APA) headquartered in Juneau, Alaska. This Audit was conducted by the U.S. Department of Energy’s (DOE’s) Office of Environmental Audit (EH-24) from August 24 to September 8, 1992. The scope of the Audit was comprehensive, covering all environmental programs and activities with the exception of those relating to the National Environmental Policy Act (NEPA). Specifically considered was the compliance status of APA regarding Federal, state, and local statutes and regulations, DOE Orders and Directives, and best Management practices. The technical disciplines addressed by the Audit were: air, surface water/drinking water, groundwater, waste management, toxic and chemical materials, quality assurance, inactive waste sites, and environmental Management. Due to the nature of the activities carried out at the two Federal hydroelectric projects operated by APA, the area of radiation was not investigated during the Audit. APA sites investigated during the Audit included: ° Eklutna Powerplant (and support facilities) ; e Palmer Substation; e Reed Substation; e Anchorage Substation; ° Snettisham Powerplant (and support facilities); e Taku Cable Transfer Terminals; e Thane Substation; and ° APA Headquarters. Also included within the scope of the Environmental Audit were the interactions of APA with the Office of the Assistant Secretary for Conservation and Renewable Energy (CE). The Audit Team reviewed documents, including APA internal assessments and appraisals; interviewed APA staff and representatives from the Alaska Department of Environmental Conservation (ADEC); and conducted field investigations. Using these sources of information, the team developed findings which fall into two categories: compliance and best Management practice. Each finding also contains the probable causal factors to assist APA in developing "root causes" for implementing corrective actions. APA has significantly enhanced its environmental programs over the past 2 years through the addition of two environmental professionals, the formation of a formalized hazardous waste Management program, and the initiation of house cleaning activities throughout APA. Other initiatives are underway and in varying stages of completion and formalization. Awareness of environmental issues is high among APA staff and management, although perceived risk ix associated with these issues is not. Perhaps as a result of perception, the commitment to environmental excellence and the resetting of priorities to place environment, safety, and health (ES&H) issues on an equal basis with production goals has not been totally embraced at all levels within the organization. The overall conclusion of the Audit is that APA has not kept pace with DOE’s increasing expectations for environmental performance. The Audit Team identified nine instances where APA activities did not, in the judgment of the team, meet the requirements of Federal, state, and local regulations. Additionally, APA has not fully identified and addressed many of the environmental requirements contained within DOE Orders. There is a clear need for the development of effective management systems in order to institutionalize APA’s increased environmental commitment. The Environmental Audit Team identified 25 compliance findings associated with regulations and DOE Orders, and 17 best management practice findings. None of the findings identified by the Audit Team appear to pose significant near term threats to public health and the environment. The key findings, which cross environmental disciplines, are as follows: Informality of Operations: An overall tendency toward not "institutionalizing" the way work is carried out; this is seen at all levels of the organization and is reflected in a lack of formal APA environmental policies, procedures, and guidance. Risk Perception: The potential for environmental risk associated with APA facilities is low relative to many other DOE facilities; the perception of "de minimis" risks has served as an impediment for APA in seeing a need for, and reaching full compliance with, the Department’s high standards. Operating Envelope: APA has not formally determined the set of environmental statutes, regulations, and DOE requirements associated with all facets of its operations. Without the definition of this operating envelope, APA can not expect to attain compliance with all such environmental requirements. SECTION 1.0 1.0 INTRODUCTION The Environmental Audit covered in this report is a comprehensive baseline audit of the Alaska Power Administration (APA), headquartered in Juneau, Alaska. APA is a government-owned, government-operated Power Marketing Administration (PMA) within the U.S. Department of Energy (DOE). The Office of Conservation and Renewable Energy (CE) in Washington, D.C. is the responsible DOE program office. APA’s primary mission is the operation, maintenance, transmission, and power marketing for the two Alaskan Federal hydroelectric projects. These are the 30,000 kilowatt (kW) Eklutna Project, which has served the Anchorage and Matanuska Valley areas since 1955; and the 78,210 kW Snettisham Project, which has been Juneau’s main power source since 1975. Secretary of Energy Notice (SEN)-6E-92, "Departmental Organization and Management Arrangements," assigns the Office of Environment, Safety and Health (EH) the responsibility to conduct independent internal assessments to ensure compliance with laws related to environmental protection. SEN-20-90, "Interaction with Internal and External Oversight Organizations," emphasizes the concept that the responsibility for ensuring environmentally sound activities starts with line management at the facility level and moves up through DOE line management. The goal of the Environmental Audit Program, as conducted by the Office of Environmental Audit (EH-24), is to provide a continuing program of internal independent oversight of line management’s environmental performance, in support of DOE’s broader goal of achieving full compliance and excellence in the environmental area. 1.1 PURPOSE The purpose of the Environmental Audit of APA is to provide the Secretary of Energy with concise information on the following issues: ° Current compliance status with environmental regulations (with the exception of the National Environmental Policy Act (NEPA) requirements) ; e Application of best management practices (BMPs) ; e Adequacy of environmental management programs and organizational structure within APA; ° Identification of causal factors associated with each deficiency to determine root causes; and e Determination of DOE vulnerabilities and liabilities associated with compliance status, environmental conditions, and management practices. This information will assist DOE in determining the patterns and trends in environmental performance, and will provide APA Management with information to identify root causes and determine necessary corrective actions. 1-1 1.2 SCOPE The scope of the APA Environmental Audit was comprehensive, covering all relevant environmental media, Federal and state regulations and requirements, BMPs, and DOE Orders. The environmental disciplines addressed in the Audit include: air; surface water/drinking water; groundwater; waste management; toxic and chemical materials; quality assurance; and inactive waste sites. In addition, the Audit included a review of the effectiveness of the environmental management program. Because auditing NEPA activities is the responsibility of the U.S. Department of Energy Headquarters (DOE-HQ), Office of NEPA Oversight (EH-25), NEPA compliance issues were not audited and are not part of this report. 1.3 APPROACH The APA Audit was conducted in accordance with the DOE Environmental Audit Program Guidance (DOE/EH-0232), Performance Objectives and Criteria for Conducting DOE Environmental Audits (DOE/EH-0229), and the Environmental Audit Manual (DOE/EH-0125), and followed accepted audit techniques. The Environmental Audit was conducted by a team of professionals managed by a Team Leader and Deputy Team Leader from EH-24, with technical contractor support personnel from the Argonne National Laboratory. The names, responsibilities, affiliations, and biographical sketches of the team members are provided in Appendix A. The APA Environmental Audit included three phases: planning, onsite activities, and reporting. During the planning phase, EH-24 sent a memorandum to APA announcing the Audit and requesting information. A pre-Audit site visit was conducted from June 23 to 25, 1992. Information gathered in response to the information request and site visit formed the basis for the Environmental Audit Team’s Audit Plan, which is provided in Appendix B. As more information was obtained and additional areas of interest were identified, the onsite agenda was modified. The final daily Environmental Audit agenda is contained in Appendix C. Onsite activities for the APA Audit took place from August 24 to September 8, 1992. Onsite activities included document reviews, interviews with APA personnel and personnel from state agencies, reviews of previous audits, and observation of actual operations. The Audit also included interviews with personnel within CE with regard to their responsibilities for oversight of APA. The team held periodic debriefs, which were open to both APA and regulatory personnel. No regulatory agencies actively participated in the audit process. The list of documents reviewed and interviews conducted are provided in Appendices D and E, respectively. Using these sources of information, the team developed the findings as discussed in the following sections. Each concern identified by the Environmental Audit Team has been categorized as either a compliance finding (CF) or a best management practice finding (BMPF). CFs are conditions that, in the judgment of the Environmental Audit Team, do not satisfy environmental laws or regulations, DOE Orders and Directives, SENs, internal environmental site policies, and operation standards. BMPFs are derived from regulatory agency guidance, accepted industry practice, best professional judgment, and draft DOE Orders. Within these categories, the findings are prefaced by a statement of the performance 1-2 objective. The performance objectives specify the standards that were not being met. The findings are not arranged in order of relative significance. Site operations and management were also reviewed for noteworthy practices, which are activities or programs that have general application to other DOE facilities and warrant documentation for information transfer among DOE facilities. The presence or absence of noteworthy practices should not be viewed as a measure of performance. The identification of noteworthy practices provides the opportunity to identify innovative and cost-efficient solutions, thereby improving the effectiveness of DOE in meeting production goals in a way that is consistent with environmental goals. The intent of the Environmental Audit is to go beyond the identification of individual findings and to identify causal factors which suggest root causes. Root causes are the most basic fundamental cause, which, if corrected, will Prevent recurrence. When developing root causes, an identification of causal factors contributing to the finding is conducted. Definitions of the commonly used causal factors are presented in Appendix F. If one or more of these causal factors can be identified as contributing to a finding, it is included in the supporting information for that finding. The observed causal factors are to be further evaluated by the APA to determine the root causes and to design a comprehensive corrective action plan to rectify each individual finding and overall deficiencies. 1.4 HISTORICAL BACKGROUND AND FACILITY DESCRIPTION APA has responsibility for operation, maintenance, transmission, and power marketing for two Alaskan Federal hydroelectric projects. These are the 30,000 kW Eklutna Project, which has served the Anchorage and Matanuska Valley areas since 1955; and the 78,210 kW Snettisham Project, which has been Juneau’s main power source since 1975 (see Figure 1-1). The projects presently provide about 8 percent of the energy requirements for Alaska’s electric utilities (about 80 percent for Juneau and about 5 percent for the Eklutna market area). The projects were authorized to encourage economic and industrial development in Alaska. The authorizations direct that project power be sold so as to encourage widespread use at lowest possible rates to consumers, consistent with sound business principles, with all costs, including investment costs, to be recovered from power sale revenue. Following several years of informal discussions, sale of the APA projects was included in the fiscal year (FY) 1986 budget request of the President of the United States. Divestiture of APA has been included in the President’s budget annually since that time. APA signed a purchase agreement with the Alaska Power Authority, a corporate entity of the State of Alaska, on February 10, 1989, for the Snettisham Project. A similar agreement was signed with Chugach Electric Association, Inc., Matanuska Electric Association, Inc., and Anchorage Municipal Light and Power on August 2, 1989, for the purchase of the Eklutna Project. These agreements were updated by formal amendment on January 25 and July 31, 1991, respectively. Actual transfer of the projects and closeout of APA can not occur until authorizing legislation is passed by the U. S. Congress. 1-3 o-1 ™ ™ yy =~ AQ xs i? 8 & = / get WA / pk a q ' \ —-— ey \ mf he f 7 UNITED STATES DEPARTMENT OF ENERGY / s ALASKA POWER ADMINISTRATION i {fe les, q ~~ ox ; a err He i | i) | APA. FACILITIES / gy ~ Fairbanks Ms fo i? Ly \v / vv? — ~ i = seca = =, $ , ~gh 4 . puta PROJECT C Anchorage Lf Ly 2 ad Gi es / / aX (KF pot] s a : / hl A NEAU HEADOTRS ! po RY 4 (pe / / oF Soe PROJECT ~A / Pee | a é : : 935 / a , G% X TA ' i } pel i GULF OF ALASKA, en SENN, ; eM a Ss \ \ MA 7} . FIGURE 1-1. ALASKA POWER ADMINISTRATION FACILITIES LOCATION MAP Eklutna Project The Eklutna Project is located about 34 miles northeast of Anchorage, and about 8 miles south of Palmer, Alaska (see Figure 1-2). It lies within the Matanuska Susitna Borough, which has a widely dispersed population of approximately 40,000, while the entire service area, which includes Anchorage, has an approximate population of 340,000. Using Lower-48 standards, the setting for the Eklutna Project can be described as "rural." Environmentally speaking, the facility is located in zones that are transitional from sub-arctic forest and wetlands to alpine-glacial lake. The project was built by the U.S. Bureau of Reclamation and has been in service since 1955. Major project features include a low earthfill dam at Eklutna Lake, a 4.5 mile tunnel through Goat Mountain, two generating units with a capacity of 15 megawatts (MW) each, 44 miles of 115,000 volt transmission line extending to Palmer and Anchorage, three substations, various shops, warehouses, and maintenance facilities. Non-power users of the project include: the Municipality of Anchorage with its 35 million gallons per day (mgd) Eklutna water project, the Chugach State Park of which Eklutna Lake is a major feature, and a privately-owned and operated (non-profit) salmon hatchery that is located just downstream from the powerplant and takes its water from the plant’s tailrace. Snettisham Project The Snettisham Project is located approximately 35 air miles southeast of the City of Juneau (see Figure 1-3) at the northeastern end of Speel Arm, which is a northern terminus of Port Snettisham (a fjord which is fed by rivers emanating from glacial ice fields to the east and north). It lies within the boundaries of the unified city and borough, which has a population of approximately 30,000. The setting for the project can be described as "wild and remote." Environmentally, the Project is located in zones that are transitional from sub-arctic marine and coastal rain forest to alpine glacial lake. The project is accessible only by boat or smal] plane. APA employees live and work onsite for 10 days and are then flown to Juneau for 4 days of off time. The Snettisham Project was constructed by the U.S. Corps of Engineers as a staged project. The initial phase (Long Lake) was completed in 1975, and the second phase (Crater Lake) went on-line in 1990. Final construction of all components of the Crater Lake phase is anticipated during late 1992. The Snettisham Project taps two lakes, Long Lake and Crater Lake. Water is conveyed through two tunnels to an underground powerhouse. Two generating units, rated at 23.5 MW each and a third rated at 31 MW, generate the energy which is transmitted to the Juneau area over 41 miles of overhead 138,000 volt transmission line and 3 miles of underwater cable. Other features of the project include: Thane Substation which serves as the operations and dispatch center for the local utility system and the Federal project, two submarine cable terminals, and a State of Alaska operated salmon hatchery that is downstream of the powerplant and utilizes water from the tailrace. 1-5 PALMER SUBSTATION & —e ' ANCHORAGE EAGLE RIVER TAP x ANCHORAGE SUBSTATION A 77 ERLUTNA POWER PLAN ne A115 Kv oA LINE SCALE IN —_ 4, 0 FIGURE 1-2. EKLUTNA PROJECT LOCATION MAP This page intentionally left blank. 1-8 L-1 SNETTISHAM } POWERPLANT; CRATER LAKE \ pana Sa UNOERWATER CABLE ANO TERMINALS : UNEAU$ SUBSTATI Ej SCALE IN MILES FIGURE 1-3. SNETTISHAM PROJECT LOCATION MAP SECTION 2.0 2.0 SUMMARY OF ENVIRONMENTAL AUDIT RESULTS This section of the report summarizes the results and conclusions of the Office of Environmental Audit’s (EH-24’s) Comprehensive Baseline Environmental Audit of the Alaska Power Administration (APA) which occurred from August 24 to September 8, 1992. APA has significantly enhanced its environmental programs over the past 2 years through the addition of two environmental professionals, the formation of a formalized hazardous waste management program, and the initiation of house cleaning activities throughout APA. Other initiatives are underway and in varying stages of completion and formalization. Awareness of environmental issues is high among APA staff and management, although perceived risk associated with these issues is not. Perhaps as a result of perception, the commitment to environmental excellence and the resetting of priorities to place environment, safety, and health (ES&H) issues on an equal basis with production goals has not been totally embraced at all levels within the organization. The overall conclusion of the Audit is that APA has not kept pace with the Department of Energy’s (DOE’s) increasing expectations for environmental performance. The Audit Team identified nine instances where APA activities did not, in the judgment of the team, meet the requirements of Federal, state, and local regulations. Additionally, APA has not fully identified and addressed many of the environmental requirements contained within DOE Orders. There is a clear need for the development of effective Management systems in order to institutionalize APA’s increased environmental commitment. The Audit identified programmatic deficiencies in many areas of environmental management. Most significant is the lack of formalized systems within APA for internal environmental oversight, including line Management self-assessment. Compounding this concern is a lack of effective line Management oversight of APA by the Office of the Assistant Secretary for Conservation and Renewable Energy (CE). The challenge of all small organizations in meeting the vast array of environmental requirements is enormous. The looming divestiture presents APA management with even greater challenges. A relatively large turnover in management and staff in the face of divestiture has occurred, and will likely increase in the future. The inclination to allow the proposed divestiture to distract APA from completing the development of an effective APA environmental program must be resisted. History has shown that the APA divestiture has appeared "imminent" since it was first proposed in 1986. A total of 42 findings were identified in this Audit. Twenty-five of these represent conditions which, in the opinion of the Audit Team, do not meet the requirements of Federal, state or local regulations, DOE Orders, or internal APA procedures. Seventeen findings reflect a lack of adherence to "best management practices" (BMPs). None of the findings identified by the Audit Team appear to pose significant near term threats to public health and the environment. The findings titles are listed in this report in Table 2-1 and the number of findings per Audit discipline is shown in Figure 2-1. 2-1 TABLE 2-1 ENVIRONMENTAL AUDIT TEAM FINDINGS | | faycr-1 Gasoline Pump Labels | A/BMPF-1 Asbestos Management Program : A/BMPF-2 Written Procedures for the Snettisham Solid Waste Incinerator |S [310 | 3-1 SW/CF-2 Spill Prevention Control and Countermeasures Plans 3-11 SW/CF-3 Public Water Supply Requirements -3 -4 Labeling of Nonpotable Water Supply [SW/CF-A [Water Disinfection Procedures Sid SW/cF-5 | Environmontal SurvetVlance Program aS SWF 1 SW/BMPF -2 Oil Water Separator Inspection 3-19 GW/CF-1 -25 Ss ene Groundwater Protection Management Program Hazardous Waste Determination | 3-31 | WM/BMPF -2 Waste Spill Containment 3-41 Identification, Labeling, and Leak Containment for TCM/CF-1 Polychlorinated Biphenyl Transformer TCM/BMPF-1 Material Safety Data Sheet Inventory 2-2 TCM/BMPF -2 Chemical Storage | 3-50 | TCM/BMPF-3 Chemical Hazard Labels TCM/BMPF -4 Secondary Containment 3-53 TCM/BMPF-5 Acid Spill Response Equipment | 3-54 | TCM/BMPF-6 Chemical Procurement Procedures QA/CF-1 Quality Assurance Program for Environmental Monitoring and Surveillance Programs QA/CF-2 Environmental Sampling Procedures QA/CF-3 Procurement of Environmental Technical Support Services IWS/CF-1 Assessment and Characterization of Former Landfills at the Eklutna and Snettisham Projects IWS/CF-2 Remediation of the Snettisham Construction 3-70 Contractor’s Disposal/Boneyard Area IWS/CF-3 Notices and Reports of Spills and Responses to 3-72 . Spills and Leaks IWS/BMPF-1 Tenant Activities IWS/BMPF -2 Information Disclosures Relating to the Sale of 3-77 Federal Property IWS/BMPF-3 Submission of SARA Title III Reports EM/CF-1 Environmental Performance Responsibilities EM/CF-2 Environment, Safety, and Health Self-Assessment and Appraisal Programs EM/CF-3 General Environmental Protection Program EM/CF-4 Organizational Structure EM/CF-5 Environmental Oversight of Alaska Power 3-91 Administration EM/BMPF -1 Environmental Protection Training EM/BMPF -2 Environmental Compliance Management System 3-94 2-3 -2 AIR SW/DW GW WM a Compliance Findings TCM QA Iws EM Best Management Practice Findings FIGURE 2-1. SUMMARY OF FINDINGS BY DISCIPLINE 2.1 KEY FINDINGS Key Findings presented below are, in the judgment of the Audit Team, findings or groups of findings that are integral to understanding the nature and scope of the environmental issues existing at APA. The Key Findings identified during the Audit are: Informality of Operations: An overall tendency toward informality of operations is a common thread woven throughout the activities and attitudes seen by the Audit Team at APA. This informality is seen at all levels of the project and is reflected in the lack of policy, formal procedures, and operating guidance. Recent efforts on the part of APA management, and especially the ES&H Branch, to develop necessary environmental programs, procedures, and guidance are noted throughout many of the individual findings presented in Section 3.0 of this report. However, much more progress is needed throughout the APA organization. Formal policies, directives, and guidance on environmental protection requirements are absent for many of the day-to-day activities of APA Management and staff. The risks associated with actual or potential environmental problems at APA facilities are much Tower than those encountered at many DOE Operations. However, the environmental risks and potential liability for DOE are nonetheless real, and require a degree of formality of operations not currently in place at APA. Development and full implementation of environmental programs and procedures are critical to achieving full compliance with DOE requirements, and can ultimately result in achieving the environmental excellence expected within the Department. Risk Perception: During many of the interviews, briefings, and general conversations that occurred during the Audit, readily apparent was the perception and attitude that APA environmental programs and issues are in better shape than the majority of private sector operations in Alaska. This was even noted during interviews with regulators who stated that the Snettisham active landfill (see Finding WM/CF-4) is considered state-of- the-art for remote locations within Alaska. This feeling that "we are doing much better than many of our neighbors," can result in complacency and ultimately in falling short of meeting DOE requirements. The Department has its own high standards for its operations based on real and perceived risks. Full compliance with DOE requirements and the attainment of environmental excellence are difficult, if not impossible, to achieve if an organization inappropriately perceives the potential environmental risks of its activities as so minimal that full attention to compliance is not necessary. Operating Envelope: Without clear and concise guidance from CE (see Finding EM/CF-5), APA remains responsible for determining the set of environmental statutes, regulations, and DOE requirements associated with all facets of its operations. Without defining the limits of this operating envelope, APA can not expect to obtain compliance with all environmental requirements. In conjunction with the perception of low potential risk to the environment from APA activities, potential divestiture, and limited resources, the formal development of a clear understanding of the operating envelope has been slow. Although this approach is understandable, it also leaves APA in a position of vulnerability regarding compliance issues. This fact is reflected in a large number of the findings identified during this Audit. 2-5 2.2 FINDINGS SUMMARY The following paragraphs describe the conclusions of the Audit Team with respect to APA programs for each of the Audit Disciplines. A summary of concerns identified for each discipline is provided. Air - Although the scope and levels of potential air quality impacts at APA are minimal, the Audit Team identified a programmatic deficiency with regard to APA’s management of asbestos, and procedural deficiencies with regard to the operation of the solid waste incinerator at Snettisham. Additionally, it was determined that APA gasoline dispensing facilities lacked necessary labels and notices. Surface Water/Drinking Water - Overall, normal APA operations would result in a low potential for surface water contamination. Catastrophic releases of oi] from electrical equipment or storage tanks could discharge significant amounts of oi] to surface waters. APA programs for spill containment have not fully addressed this contingency for all sites. APA has not prepared Spill Prevention Control and Countermeasures (SPCC) Plans for the Eklutna Powerp] ant and Thane and Snettisham substation facilities, and has not adequately implemented the terms of the SPCC Plan for the fuel farm at Snettisham. Other concerns regarding APA’s surface water program include: unauthorized discharges from an oil/water separator; outdated wastewater/septic design maps; lack of an inspection program for oil/water separators at Snettisham; and lack of an environmental surveillance program for surface water contaminants. With regard to drinking water, APA has not collected necessary data, nor provided data to the Alaska Department of Environmental Conservation (ADEC) to formally certify operation of either the Snettisham or Thane water systems. Additionally, the Audit Team observed that APA has not adequately labeled as "nonpotable" the water distribution system at Eklutna, and has not demonstrated the proper operation of the Thane water treatment system. Groundwater - Activities and operations conducted by the APA have the potential to impact local groundwater quality in the vicinity of the Eklutna Powerplant, Anchorage Substation, Snettisham Powerplant, and the Taku Cable Terminals. APA has not conducted formal characterizations of any of its facilities and is unable to determine whether these activities have had an impact on the groundwater. Because the local geologic and hydrologic conditions are not well understood, contaminant migration pathways are also not known. The Audit Team determined that APA has not developed a groundwater protection program, required by DOE Order 5400.1, to address these and other concerns. Waste Management - Through the development and implementation of the hazardous waste program, APA has clearly exhibited its ability to establish formalized environmental protection programs. Although a number of specific deficiencies within APA’s hazardous waste management program exist, the program is viewed by the Audit Team as sound. Specific concerns were identified in the following areas: assignment of responsibilities; identification of waste storage areas; procedures for the segregation of incompatible wastes; identification of waste streams; and implementation of procedures. Other hazardous waste management deficiencies observed by the Audit Team involve the characterization of two solid waste streams, formalized on-the-job training, and spill containment. 2-6 With regard to solid waste and underground storage tank (UST) management, APA activities are less formalized. The Audit Team noted that APA has not developed a solid waste management program; is not meeting permit requirements for management of the Crater Cove solid waste landfill at Snettisham; has not registered an exempt UST; and has not developed a management program for both regulated and unregulated USTs. Toxic and Chemical Materials - APA has initiated a program to obtain test results for oil-filled electrical equipment, both APA and tenant-owned. Currently, it is known that APA owns three transformers which contain polychlorinated biphenyls (PCBs) above regulatory limits. Of these, only one is currently in service (at Eklutna). APA has not performed the necessary notification, labeling, and containment for this PCB transformer that showed indications of previous leakage. Concerns regarding APA’s procurement, use, and storage of chemicals include: incomplete Material Safety Data Sheet (MSDS) files; storage of incompatible chemicals; inconsistent hazard labeling; a lack of secondary containment of stored chemicals; inadequate acid spill response equipment; and a lack of sufficient guidance or procedures for the Procurement of hazardous materials. Quality Assurance - To date, APA has not formally developed the quality assurance component of its environmental protection programs. Specific concerns regarding quality assurance measures at APA include: the lack of a quality assurance program for environmental monitoring and surveillance activities; lack of environmental sampling procedures; and insufficient oversight of procured environmental technical support services. Inactive Waste Sites - APA does not have a formal, implemented program to effectively deal with characterization, evaluation, remediation, and reporting requirements related to inactive waste sites and releases. Specific concerns include: a lack of characterization of two inactive waste sites; deficiencies in APA response actions observed at the Snettisham boneyard; inadequate responses to spills and leaks (including notification and reporting); lack of an inventory of hazardous substance activity relating to the sale or transfer of Federal real properties; incomplete submission of Tier I and/or Tier II hazardous material notification; and a lack of formal agreements with tenants having equipment and activities at APA facilities. Environmental Management - The Audit Team identified a number of programmatic management deficiencies within APA. These involve: internal environmental self-assessment and oversight; formalized environmental training program; documentation, communication, and tracking of environmental deficiencies; definition of environmental responsibilities and performance measures; establishment of formalized environmental Protection programs; and the organizational structure of APA. An additional concern identified during the Audit relates to CE’s oversight of APA’s environmental programs. 2.3 CAUSAL FACTOR SUMMARY In an effort to understand why a finding occurred, a systematic approach was initiated to perform a "probable root cause" analysis. This analysis is a two-step process which first identifies causal factors and then identifies the root cause which is the basic, fundamental cause, which if corrected will prevent recurrence. 2-7 The cause(s) and rationale(s) in support of the causal factors are identified by the Audit Team in the discussion of each finding. The majority of these probable causal factors are judgment calls by the Team members. APA Management and staff should make the final detailed causal factor analysis as a necessary step in correcting all causal factors which have contributed to the findings. Additionally, APA needs to complete a root cause analysis and address the root causes in its Corrective Action Plan. It is the responsibility of APA to address all causal factors in the Action Plan, even if the list of causal factors identified by the Audit Team is incomplete. The Environmental Audit identified 12 probable causal factors which contributed to the occurrence of the findings (see Table 2-2 and Figure 2-2). The six factors that appeared most frequently are risk, policy implementation, training, policy, procedures, and supervision. Each of these causal factors is discussed below. Definitions of causal factors typically used in the audit process are presented in Appendix F. Risk - appeared most frequently, in 40 percent of the Audit Team’s findings, and was evident in nearly every Audit discipline. APA’s apparent failure to recognize, comprehend, or appreciate the risk associated with a particular set os contributed to the occurrence of 17 of the Audit Team’s indings. Policy Implementation - appeared as a causal factor in approximately 38 percent of the Audit Team’s findings. In 15 of the 16 instances where policy implementation was identified, APA’s failure to implement established Federal, state and local regulations, DOE Orders, or internal procedures was associated with additional causal factors. Training - appeared as a causal factor in approximately 36 percent of the Audit Team’s findings. Instances of insufficient training of APA personnel were identified in seven of the eight Audit disciplines, and was most prevalent in the areas of air, toxic and chemical materials, quality assurance, and inactive waste sites. Policy - appeared as a causal factor in approximately 31 percent of the Audit Team’s findings. Instances where APA failed to establish formal policies were identified in six of the eight Audit disciplines and was most frequently observed in the air, waste management, and inactive waste sites areas. Procedures - appeared as a causal factor in approximately 29 percent of the Audit Team’s findings. The Audit Team identified 12 specific instances where observed deficiencies were apparently related to missing or inadequate APA operating procedures. Supervision - appeared as a causal factor in approximately 19 percent of the Audit Team’s findings. A lack of adequate supervision by APA managers was identified in the areas of surface water, toxic and chemical materials, and environmental management. Section 3.0 of this report presents the 42 compliance and best management practice findings identified during the Audit by discipline, and discusses in greater detail the probable causal factors that contributed to the findings. 2-8 2 CONTRIBUTING FACTORS IDENTIFIED BY AUDIT FINDING TABLE 2 SUMMARY OF APPARENT CAUSAL FACTORS AND 2-9 1 A/BMP! 3 SW/CF- a a = 2 Ss a 01-2 TABLE 2-2 SUMMARY OF APPARENT CAUSAL FACTORS AND CONTRIBUTING FACTORS IDENTIFIED BY AUDIT FINDING See ae ses Sie 3 gas Sa ‘ II-2 TABLE 2-2 SUMMARY OF APPARENT CAUSAL FACTORS AND CONTRIBUTING FACTORS IDENTIFIED BY AUDIT FINDING TCM/CF-1 TCM/BMPF-2 TCM/BMPF-3 TCM/BMPF-4 TCM/BMPF-1 TCM/BMPF-6 TCM/BMPF-6 QA/CF- QA/CF-2 QA/CF-3 Se ee 1 21-2 IWS/CF-1 IWS/CF-2 IWS/CF-3 |WS/BMPF-1 IWS/BMPF-2 |WS/BMPF-3 EM/CF-1 EM/CF-2 EM/CF-3 EM/CF-4 TABLE 2-2 SUMMARY OF APPARENT CAUSAL FACTORS AND CONTRIBUTING FACTORS IDENTIFIED BY AUDIT FINDING v v v v v v v v v v v v v €1-2 EM/CF-6 EM/BMPF-1 TABLE 2-2 SUMMARY OF APPARENT CAUSAL FACTORS AND CONTRIBUTING FACTORS IDENTIFIED BY AUDIT FINDING vI-2 ooo 5072 -m fC O00 20 15 |- 10 | Policy Policy Implementation Risk Procedures Personnel Resources Training Appraisals, Design Barriers Super- Quality Audits, and vision Assurance/ Reviews Controls Control FIGURE 2-2. SUMMARY OF APPARENT CAUSAL FACTORS AND CONTRIBUTING FACTORS SECTION 3.0 3.0 ENVIRONMENTAL AUDIT FINDINGS 3.1 AIR 3.1.1 Overview The purpose of the air portion of the Environmental Audit was to assess the current operational practices of the Alaska Power Administration (APA) with respect to Federal and state regulations, DOE Orders, and Executive Orders (see Table 3-1). Also considered were best Management practices that pertain to, or help establish and maintain compliance with DOE Orders and other Federal and state air quality requirements. The general approach to the air portion of the Audit included the following activities: (1) inspection of APA facilities, (2) identification and inspection of all stationary air emission sources located at APA facilities, (3) review of documents, and (4) interviews with APA personnel regarding the operation of all air emission sources. This review was coordinated with the waste management and environmental management specialists. Significant air pollutant emission sources identified at APA include: diesel-fueled emergency power generators at the Eklutna and Snettisham Projects, a solid waste incinerator at the Snettisham Project, and gasoline dispensing facilities (without vapor recovery features) at the Eklutna and Snettisham Projects. None of these stationary sources are subject to permit requirements under Alaska Administrative Code (AAC) air quality control regulations. However, the solid waste incinerator, rated at a capacity of 85 pounds per hour, is subject to the opacity standards specified in Chapter 50 of the AAC. Some asbestos containing material is known, or suspected to be, present within APA facilities and equipment. Although the levels of asbestos appear to be minimal, formal inventories, inspections, or removal activities have not been conducted. The scope and levels of air quality impacts at APA are minimal. The air quality portion of the Environmental Audit identified one comp]iance finding and two best management practice findings. The compliance finding pertains to required notices and labels at gasoline dispensing facilities and the two best management practice findings relate to comprehensive asbestos Management and incinerator operation. 3-1 TABLE 3-1 LIST OF AIR REGULATIONS, REQUIREMENTS, AND GUIDELINES DOE Order 5400.1 General Environmental Protection Program | DOE 40 CFR Parts 50-88 |Clean Air Act Implementing Regulations ema 1 18 AAC Chapter 50 |Alaska Air Quality Control Regulations ADEC 3-2 3.1.2 Compliance Finding A/CF-1: Gasoline Pump Labels Performance Objective: 40 CFR Part 80, "Regulation of Fuels and Fuel Additives," Section 22(d), requires that, after January 31, 1975, every wholesale purchaser-consumer of gasoline shall prominently and conspicuously display in the immediate area of each pump stand, the following notice: Federal law prohibits the introduction of any gasoline containing lead or phosphorus into any motor vehicle labeled "UNLEADED GASOLINE ONLY." In addition, this notice must be of a certain minimum size and be readily visible to the wholesale purchaser-consumer’s employees and persons operating vehicles into which gasoline is to be dispensed. Additionally, 40 CFR Part 80.22(e)(1) requires that gasoline pumps for introduction of unleaded gasoline into motor vehicles bear a permanent, legible label stating: "Unleaded gasoline." Finding: The required notice and pump labels are not present at the gasoline dispensing stations at the Eklutna and Snettisham Projects. Discussion: Gasoline pumps at Eklutna are used exclusively to dispense fuel to Alaska Power Administration (APA) vehicles and gasoline-powered equipment. At Snettisham, fuel is dispensed for APA and Alaska Fish and Game vehicles and equipment. APA personnel have indicated that APA uses only unleaded gasoline, but they were apparently not aware of the Federal notice and labeling requirements (I-A-5). The probable causal factors for this finding are incomplete policy for ensuring compliance with regulations, and a lack of training of APA personnel. 3-3 3.1.3 Best Management Practice Findings A/BMPF-1: Asbestos Management Program Performance Objective: Best management practice suggests that an asbestos management program that establishes procedures for the identification, inspection, collection, and disposal of asbestos-containing material (ACM) be developed and implemented. The goal is to ensure the proper management of ACM and compliance with Federal regulations pertaining to ACM found in 40 CFR Part 61, "National Emission Standards for Hazardous Air Pollutants." Finding: Alaska Power Administration (APA) has not developed a formal asbestos management plan which establishes procedures for the identification, inspection, collection, and disposal of ACM throughout the APA facilities. Discussion: Given the vintage of many of the APA structures, the possibility exists that ACM was utilized in construction. During the Audit, floor tiles which may contain friable asbestos were observed in some facilities. While these tiles were generally in good repair, some damaged tiles were noted. Particular concern is expressed for the floor tiles from the former laboratory building at the Eklutna Project. This building was removed in 1975 and the foundation slab, covered with floor tiles, still remains and is exposed to the weather. As a result, many of the tiles, which have not been tested for their asbestos content, are heavily deteriorated. There is no documentation that a careful survey of the laboratory building was performed and that other ACM was removed and properly disposed before the building was removed from the site. Likewise, there are no APA procedures for the identification, removal, and disposal of ACM from other structures scheduled for demolition or disposal. APA personnel have indicated that ACM is contained in many pieces of electrical equipment and that maintenance or replacement of this equipment may result in the generation of ACM wastes (I-A-4 and I-A-5). However, in the absence of a formal asbestos management program, it is the practice of APA personnel to review each individual maintenance activity to identify the involvement of ACM and provide for its proper management (I-A-1 and I-A-5). APA maintenance personnel have not been given formal training on the proper identification of ACM. The probable causal factors for this finding are a lack of policy addressing the identification, inspection, and management of ACM; a lack of training for individuals responsible for equipment maintenance with respect to ACM identification; and a lack of written procedures for ACM Management which provide sufficiently for compliance with 40 CFR Part 61. 3-4 A/BMPF-2: Written Procedures for the Snettisham Solid Waste Incinerator Performance Objective: Alaska Administrative Code (AAC) regulations contained in Title 18 (18 AAC Chapter 50.040) establish opacity standards for visible emissions from incinerators. Finding: Alaska Power Administration (APA) has not provided the operator of its Snettisham solid waste incinerator with written directives to ensure that incinerator operation remains in compliance with 18 AAC Chapter 50.040. Discussion: The solid waste incinerator at the Snettisham Project site is operated by Alaska Department of Fish and Game (ADF&G) personnel. The incinerator, a Consumat Waste Disposal system, Model C-32P is rated at 85 pounds per hour. This production rate is below regulatory controls for particulate emissions and the incinerator is not required to have an operating permit (18 AAC Chapter 50.040(b)). However, all incinerators, regardless of size, are subject to the opacity standard contained in 18 AAC Chapter 50.040. The incinerator is approved by the Alaska Department of Environmental Conservation as a model being capable of meeting the opacity standard. However, opacity is highly dependent upon the proper actions of the operator. APA has not provided the ADF&G with written directives to ensure that the incinerator operation remains in compliance with the opacity standards (I-A-5). The probable causal factors for this finding include a lack of adequate policy regarding the operation of APA facilities by others, and a failure to develop procedures that ensure APA’s compliance with relevant regulations. 3-5 3.2 SURFACE WATER/DRINKING WATER 3.2.1 Overview The purpose of the surface water/drinking water portion of the Environmental Audit was to evaluate compliance with Federal, state, and local water pollution control requirements established in conformance with the Clean Water Act (CWA), and with drinking water requirements codified under the Safe Drinking Water Act (SDWA). The Audit also evaluated compliance with DOE Orders for effluent monitoring and environmental media surveillance, and water pollution control practices with respect to industry-accepted best management practices (see Table 3-2). The general approach to the surface water/drinking water assessment included the inspection of surface water discharges including tailrace water, storm drains, overland runoff, building drains and sumps, and oil/water separator discharges; inspection of a potable water surface intake and chlorination system; groundwater well, pumphouse, and water tank; review of site maps describing potable and nonpotable water systems and wastewater discharge; review of site procedures for potable water treatment; review of drinking water sample test results; interviews with site personnel regarding water discharges and potable water system operations; and contact with an official from the Alaska Department of Environmental Conservation (ADEC) Drinking Water Division. This part of the Audit was coordinated with the quality assurance, environmental management, and inactive waste site specialists. Alaska Power Administration (APA) does not have any point source effluent discharges which would be subject to permitting requirements under the National Pollutant Discharge Elimination System (NPDES) program. APA has documented that it is not subject to stormwater permitting requirements under NPDES (D-SW-13). APA has one nondomestic seepage well which may require permitting under Alaska Wastewater Discharge Regulations. APA has a Spill Prevention Control and Countermeasures (SPCC) Plan, prepared under 40 CFR Part 112 (D-SW-3), "Oil Pollution Prevention," for the Snettisham Fuel Farm, but does not have SPCC Plans for the Eklutna Powerplant or Thane and Snettisham Substations. Domestic (sanitary) wastes from APA facilities are treated via onsite septic systems and subsurface infiltration drains. There are no surface water outfalls from septic systems at APA. At Snettisham, the infrequent nondomestic wastewater from floor drains in the Heavy Equipment Maintenance Building is routed via an oil/water separator directly to a local septic system (D-SW-24). Basement sumps collect wastewater, including dripped oils and floor washings, from the powerplant buildings at Eklutna and Snettisham. APA personnel collect surface oil from the sumps using oi1 absorbent pillows. Automatic, water-level pumps discharge the sump contents to the powerplant tailrace water. The tailrace discharge consists of the turbine-contact water withdrawn from mountain lakes at Eklutna and Snettisham, along with the sump discharges. There are no process-derived wastewaters generated at the powerplants. 3-7 TABLE 3-2 LIST OF SURFACE WATER/DRINKING WATER REGULATIONS, REQUIREMENTS, AND GUIDELINES DOE Order 5400.1 General Environmental Protection Chapter IV Program Environmental Monitoring Requirements DOE Order 6430.1A General Design Criteria | DOE 40 CFR Part 112 0i1 Pollution Prevention | EPA 40 CFR Parts 122-125 | NPDES Permits and NPDES Stormwater Clean Water Act Requirements 40 CFR Parts 141-133 |National Primary and Secondary Drinking Safe Drinking Water |Water Regulations Act 18 AAC Chapter 72 Alaska Wastewater Disposal Regulations 18 AAC Chapter 75 Alaska Oi] and Hazardous Substances ADEC | Pollution Control Regulations } 18 AAC Chapter 80 Alaska Drinking Water Regulations 3-8 APA withdraws penstock water to supply nonpotable water for facility operations at Eklutna. Bottled drinking water is supplied by an outside contractor. Bottled water also supplies consumptive needs at Anchorage Substation; no water is provided at Reed or Palmer Substations. Potable water for domestic use at Thane Substation is obtained from Sheep Creek and is disinfected by an automatic liquid chlorine feed system operated by APA. Nonpotable water for the Snettisham Powerplant is withdrawn from the water penstock. There is no drinking water provided in the powerhouse; employees must provide their own water. At the Snettisham Camp, APA supplies potable water via a groundwater well and a 47,000-gallon water storage tank. The Snettisham Camp and Thane water systems are Alaska Class C Public Water Supplies. Overall, normal APA operations would result in a low potential for surface water contamination. Catastrophic releases of oi] from electrical equipment or storage tanks could contribute oi] discharge to surface waters. APA programs for spill containment have not fully addressed this contingency for all sites. Additionally, APA has not addressed the collection of the necessary data, nor provided data to the ADEC to formally certify operation of either Class C Public Water System. The surface water/drinking water portion of the Environmental Audit identified six compliance and two best management practice findings. The compliance findings relate to: labeling of nonpotable water supply; SPCC Plans; public water supply requirements; water disinfection procedures; environmental surveillance program; and industrial wastewater discharge. The best management practice findings relate to update of septic system Maps and oi] water separator inspection. 3-9 3.2.2 Compliance Findings SW/CF-1: Labeling of Nonpotable Water Supply Performance Objective: DOE Order 6430.1A, "General Design Criteria," requires that where there are both potable and nonpotable water systems in a facility, the systems should be clearly identified. Finding: The raw (industrial) water supplied to washsinks throughout the Eklutna Powerplant and office area is not consistently labeled as nonpotable. Discussion: DOE Order 6430.1A, Section 0266, "Water Distribution Systems," requires that where both domestic (potable) and industrial (nonpotable) water systems are used in a facility, the systems should be clearly identified as to the status of the water for human consumption. At Eklutna, drinking water is provided by bottled water dispensers located at various locations at the facilities. Throughout the Eklutna site, washsinks in washrooms and in work areas provide raw, untreated, water tapped from the penstock which carries water directly from Eklutna Lake. Except for an Alaska Power Administration (APA) memorandum taped on cabinets above the sink in the kitchen of the office area, there is no identification that tap water is considered nonpotable. According to APA (I-SW-1), in the past, Eklutna did have a small system to filter and chlorinate the lake water, rendering all water potable. However, this treatment system was removed 7 to 8 years ago and bottled water purchased from a water dealer in Anchorage was brought in to satisfy consumptive requirements. The water piping system which previously carried treated potable water is now the conveyance for the untreated lake water. The probable causal factors for this finding include a lack of understanding of the risk of not labeling water sinks, and policy implementation of the DOE Order 6430.1A requirements on water system identification. 3-10 SW/CF-2: Spill Prevention Control and Countermeasures Plans Performance Objective: Facilities which could discharge oil or petroleum products into navigable waters of the United States must prepare and implement a Spill Prevention Control and Countermeasures (SPCC) Plan, as required under 40 CFR Part 112, "Oil Pollution Prevention." A facility which has 1,320 gallons of oi] or greater, and could discharge oil in harmful quantities to navigable waters of the United States must prepare an SPCC Plan which addresses the requirements in 40 CFR Part 112.7, "Guidelines for the Preparation and Implementation of an SPCC." These guidelines require that the plan: ° Be prepared in accordance with good engineering practices with the full approval of management to implement the plan; e Contain a description of the site, type and quantity of oi] present, the flow direction, and amount of oi] which could be discharged; e Provide for appropriate containment and/or diversionary structures to prevent discharged oil from reaching a navigable waterway; and e Outline administrative procedures to ensure that oi] will not be discharged to the waterway. The SPCC Plan must be certified by a Professional Engineer (PE) and must be evaluated at least once every 3 years. Finding: Alaska Power Administration (APA) has not prepared SPCC Plans for the Eklutna Powerplant, Thane, and Snettisham Substation facilities and has not adequately implemented the terms of the SPCC Plan for the fuel farm at Snettisham. Discussion: APA has not prepared SPCC Plans for either the Eklutna Powerplant nor Thane Substation. At Eklutna there is one 3,300-gallon reservoir tank containing transformer oi] and 1,500 gallons of turbine oil in the generator lubricating system, which drain via floor drains to a sump in the sub-basement (D-SW-17). The sump base is at 9.75 feet with the normal static liquid level maintained at 11.0 feet. Pumps automatically drain the sump to the 11-foot level when the liquid reaches a trigger height of 12.75 feet. Given the surface area of the sump (259 square feet), it can contain, at a maximum, approximately 3,400 gallons between the static and trigger levels. If there were some water in the sump between the 11 and 12.75 feet elevation, a release of oil large enough to trigger sump-pump operation, could result in the discharge of water and oi] to the tailrace which drains directly to the Knik River. The sump has the capability to contain over 7,000 gallons, however, the current automatic trigger level for the pumps do not allow this much liquid to fill the sump. At Thane Substation there are two large power transformers each containing approximately 7,200 gallons of oil. There is no containment, other than gravel, beneath the transformers. Traversing from east to west under the substation gravel is an open culvert drain which collects runoff, and possibly 3-11 some infiltration from beneath the substation, and channels discharge toward a ravine which ultimately drains to the Gastineau Channel via Sheep Creek. There are no constructed barriers to prevent an oi] discharge from either transformer from migrating to the culvert and ultimately to the Channel. The fuel farm at Snettisham contains two aboveground gasoline tanks (4,600 and 5,100 gallons) and two aboveground diesel tanks (6,000 and 8,000 gallons) located approximately 75 feet east of Speel Arm at Port Snettisham. The tank farm is surrounded by an earthen berm with a containment capacity of greater than 40,000 gallons (D-SW-2). At the time of the Audit, it appeared that the liner may no longer be providing adequate secondary containment, i.e., plants were seen growing from the surface of the bermed area and it is possible that the roots have penetrated the liner. Fuel is pumped to the facility from barges brought to the dock at Speel Arm. Pumping operations are documented in the Operations Manual for Marine Oi] Transfer (I-SW-2) prepared by APA according to Coast Guard requirements. At Snettisham Substation, there are three power transformers containing dielectric fluid; two transformers contain approximately 4,100 gallons, and the third, 5,600 gallons. There is no secondary containment located beneath the transformers. Spilled oi] would likely travel overland toward the tailrace discharge. The original SPCC Plan for the facility, prepared and registered by a PE in December 1985 (D-SW-14), covers only the fuel farm. A similar June 1992 update to the Plan (D-SW-3) has been prepared and is undergoing review. A review of operations by the Audit Team revealed that containment controls required under the 1992 SPCC Plan are not being implemented. According to the "Spill Prevention" section of the Snettisham SPCC Plan, the containment basin is drained by a 2-inch water drain which is controlled by two valves, one on either side of the berm. The valves normally remain closed and are to be opened only "under responsible supervision and a log kept of the operation" (D-SW-3). This meets the requirements under 40 CFR Parts 112.7(e)(2)(A), (B), (C), and (D) for operations of containment facilities. However, at the time of the Audit, both drain valves were open. APA personnel indicated that the drains remain open to allow the discharge of rainwater and to allow an electrically heated tube to pass through the pipe (I-SW-15). According to APA, the fuel farm is inspected daily; however, no inspection log was being kept. The probable causal factors for this finding include inadequate policy implementation to prepare SPCC Plans for Eklutna and Thane; lack of training of site personnel in the requirements of the SPCC Plan; inadequate supervision of spill control operations; and inadequate barriers and controls in the use of a valve heater which requires the valves remain open at all times. 3-12 SW/CF-3: Public Water Supply Requirements Performance Objective: The operation of public water systems must be certified under the requirements of Title 18 of the Alaska Administrative Code (AAC), Chapter 80, "Drinking Water," and are subject to requirements regarding disinfection, bacteriological and inorganic/organic sampling and analysis, and well log reporting (for groundwater sources). Finding: Alaska Power Administration (APA) has not certified the operation of the public water systems at Thane or Snettisham with the Alaska Department of Environmental Conservation (ADEC). APA does not have complete water quality sample results, disinfection records, or well log data required for certification by ADEC. Discussion: According to the guidelines in 18 AAC Chapter 80.900, "Definitions," the APA water systems at Thane and Snettisham are Class C Public Water Systems. Under 18 AAC Chapter 80.300, "Plan Review," no person may "construct, install, alter, renovate, or improve a public water system without written approval of engineering plans submitted to the department." According to the ADEC (I-SW-18), the state requires background data on the bacteriological quality (coliform count) and chemical analyses for inorganic and organic contaminants, well logs (for groundwater sources), and the separation distance between the water source and potential sources of contamination prior to public water system certification. For Class C Systems, the Department has discretionary authority as to additional future routine water monitoring requirements. Usually, only periodic bacteriological tests would be required for Class C Systems. APA has not submitted any required test data, well logs, and design plans to the ADEC, nor received operating certification for the two public water systems at Thane and Snettisham. APA does not have well log data for the well which provides water to the Snettisham Camp. There are no system disinfection records for Thane (see Finding SW/CF-4), and the test results for Thane and Snettisham are incomplete. Water test analyses for Thane (12/88) and Snettisham (4/87), omit selenium analysis, a required inorganic test (D-SW-6), and organic/pesticide analyses as required by 18 AAC Chapter 80.50. Bacteriological analyses from Thane (12/88 and 4/90) and Snettisham (4/90) were satisfactory for coliform count (D-SW-8, D-SW-9, and D-SW-10). APA classification of the water systems and sample submittals are inconsistent. On the Bacteriological Water Analysis forms, APA describes Thane as a Class C Public System; while APA lists Snettisham as an individual system. On the 12/88 test for Thane, the water is "chlorinated," while on the 4/90 test form, the water is "untreated" (D-SW-8). For Snettisham, there is no indication as to the treatment status of the water. The probable causal factors for this finding include inadequate policy implementation in following the requirements for public water systems, and a lack of supervision in the completion of test forms. 3-13 SW/CF-4: Water Disinfection Procedures Performance Objective: The Operations Manual for the Snettisham Project identifies procedures to be followed for the chemical disinfection of potable water at Thane Substation and testing of finished water for residual chlorine. Finding: There are no records to demonstrate that the water treatment system at Thane Substation is operated according to the procedures outlined in the Operations Manual. Discussion: Potable water at Thane Substation is withdrawn from behind a weir on Sheep Creek, approximately 700 feet south of the Thane Control Building. The water is treated using an automatic liquid chlorine feed and is then pumped to a pneumatic storage tank which provides 30 minute contact time for disinfection. According to the instructions for system operation outlined in the Operations Manual for the Snettisham Project, pages 429-430 (D-SW-16), the chlorinator should be filled weekly with a freshly mixed 2 percent chlorine solution, and the chlorine residual in the finished water should be tested daily to ensure that the potable water has at least 0.5 parts per million (ppm) chlorine. At Thane, there were no operator records documenting the weekly mixing of fresh chlorine feed solution, nor any residual chlorine test logs. The probable causal factors for this finding include lack of supervision in operation of the water treatment system according to specifications, and inadequate quality assurance/control in documenting residual chlorine values. 3-14 SW/CF-5: Environmental Surveillance Program Performance Objective: DOE Order 5400.1, Chapter IV, Section 5.b, "Environmental Surveillance," requires that DOE sites undertake environmental surveillance to monitor the effects of DOE activities on onsite and offsite environmental and natural resources. Environmental surveillance shall be designed to satisfy one or more of the following objectives: (1) verify compliance with applicable laws and regulations; (2) verify compliance with environmental commitments; (3) establish baselines of environmental quality; (4) characterize the physical, chemical, and biological condition of environmental media; (5) provide a continuing assessment of pollution abatement programs; and (6) identify and quantify new or existing environmental quality problems. Finding: Alaska Power Administration (APA) does not have an environmental program to assess discharges of surface water from substations and powerplant facilities, and to assess the impact of APA operations on surface water and sediment. Discussion: DOE Order 5400.1, Chapter IV, Section 5.b, requires sites to conduct environmental surveillance activities as part of a program to monitor the effects of site operations on the environment. The Order proposes that environmental surveillance screening be undertaken at DOE sites to determine the need for a permanent environmental surveillance program at a site. The components of such a program are site-specific and should reflect the individual site characteristics, hazard potential, quantities and concentrations of materials released, and the potential extent of affected land and water. Surveillance programs may include procedures describing monitoring stations, a sampling and analysis protocol, and data recordkeeping. Three of the APA facilities, the Eklutna Powerplant, Thane Substation, and the Snettisham Powerplant/Camp, are located proximate to significant surface water resources including tidal rivers and fish hatcheries. Eklutna and Snettisham discharge significant amounts of water through powerplant tailraces. At Eklutna the tailrace discharge actually becomes the headwaters of a channel which is tributary to the Knik River. At powerplants, tailrace discharges may carry small amounts of contaminants including turbine oil, transmission oil, solvents, cleaning chemicals, and battery acid which can be washed into the powerplant basement sump. The sumps at both Eklutna and Snettisham discharge directly to the tailrace outflow. At Snettisham, there is additional surface water runoff from inside the Crater Lake Powerplant Tunnel through an oil/water separator to a surface creek (see Finding SW/BMPF-2), from the landfill, and from the boneyard area on the road up to Long Lake. Snettisham also operates a fuel farm near the dock on Speel Arm. Fuel could migrate to the water as runoff during refueling operations or from groundwater outflow of spilled fuel. At Thane, the storm drain which traverses the substation (see Finding SW/CF-2) could carry oil-contaminated runoff from electrical equipment. This runoff has the potential to reach Sheep Creek, a salmon hatchery, and Gastineau Channel. APA lacks documentation that it has collected any baseline environmental monitoring data of the water at any of these surface water discharges. 3-15 The probable causal factors for this finding include lack of policy implementation to fulfill the requirements of DOE Order 5400.1, and inadequate assessment of the potential risk associated with the lack of environmental surveillance screening of discharges. 3-16 SW/CF-6: Industrial Wastewater Discharge Performance Objective: Title 18 of the Alaska Administrative Code (AAC) , Chapter 72.500, Article 5, "Nondomestic Wastewater," of the Alaska Wastewater Disposal Regulations, requires that nondomestic wastewater be discharged onto land, surface water, or groundwater only through a permit issued by the Alaska Department of Environmental Conservation (ADEC). Finding: The nondomestic wastewater from the Heavy Equipment Building at Snettisham is discharged via an oi1/water separator to a local septic system without a permit or exemption waiver from the ADEC. Discussion: The Heavy Equipment Building at Snettisham is used for maintenance of motor vehicles and other heavy equipment. The floor drain system is connected to an oil/water separator which is designed to divert waste oi] to an underground temporary collection tank and drain wastewater to a local septic system located east of the building (D-SW-24; I-SW-15). Given the maintenance operations conducted in the building and the presence of industrial chemicals such as solvents, acid, oils, and fuel proximate to the floor drains, wastewater discharged from the building would appear to meet the qualifications for "nondomestic wastewater" as defined by the Alaska Administrative Code Wastewater regulations under 18 AAC Chapter 72.900, "Definitions." As such, a permit or written waiver from the State is required to discharge the wastewater (18 AAC Chapter 72.500, "Restrictions"). APA does not have a permit or waiver from the state which authorizes or acknowledges the discharge to the septic system. Even though the discharge from the building is infrequent, the regulations do not set a minimal discharge limit. Upon review of the system, the ADEC has the ability to grant a waiver for the discharge permit. The probable causal factor for this finding is inadequate policy implementation in following the state guidelines for wastewater discharge. 3-17 3.2.3 Best Management Practice Findings SW/BMPF-1: Update of Septic System Maps Performance Objective: Best management practice suggests that engineering drawings for the wastewater disposal system be up-to-date, detailing recent changes and current piping layout. Finding: The map detailing the wastewater/septic system at the Snettisham Project does not show the 1984-85 retrofit design changes which divert septic discharge to a seepage well. Discussion: The original (1969) site plan for the Snettisham Project (D-SW-22) describes wastewater treatment via a large septic tank with final discharge into a drain field at the southeast corner of the site. The drawing indicates that when the project construction is complete, and the number of persons working at the site greatly decreases, wastewater flow should be diverted to a smaller septic tank adjacent to the initial, large-capacity tank. The second phase of the project, the Crater Lake addition, was initiated around 1984 and the revised site drawing (D-SW-23) further indicates that the drain field was to be abandoned. The revised drawing provides no additional data about how final septic discharge would occur. According to Alaska Power Administration (APA) (I-SW-15 and I-SW-17), actual septic discharge is now routed via a lift station to a seepage pit north of the septic tank, and east of the Heavy Equipment Maintenance Building. The Audit Team observed the lift station in operation as described by APA. However, the most recent engineering map is the 1984 drawing (D-SW-23) which does not clearly show the final changes to the system. If not for personal recollection by APA employees it would be difficult to trace wastewater discharge. The probable causal factors for this finding are inadequate quality assurance/ control in maintaining current site records and a lack of procedures that would instruct personnel to change engineering drawings when physical system modifications occur. 3-18 SW/BMPF-2: Oil Water Separator Inspection Performance Objective: Best management practice suggests that inspection of oil/water separators be done on a regular schedule as a part of routine facility maintenance. Finding: The oil/water separator at the Snettisham Heavy Equipment Building and the oil/water separator outside the Crater Lake Power Tunnel have never been inspected. Discussion: Oil/water separators are designed to physically separate immiscible liquids, using an overflow weir or baffle chamber so that lighter liquids, like petroleum oils and fuels, decant to one holding basin, while heavy fluids (i.e., water) and sludge drain to a second basin or are diverted toward sewage discharge. The dividing weir or baffles must remain free of accumulated debris so that the separator can operate as designed. Nonfunctional separators can allow waste to pass directly to the water discharge. Normally, oil/water separators are equipped with a lid which can be opened to allow for periodic inspection and cleanout of the separation chamber. At Snettisham there are similar oil/water separators located in the floor drain system of the Heavy Equipment Building and the outflow from the Crater Lake Power Tunnel. There are no schematic drawings for either separator and they are constructed without easy-access top lids. According to APA, neither separator has ever been opened or inspected (I-SW-15). The oil/water separator at the Heavy Equipment Building is connected to an underground temporary collection tank. This tank was inspected for the first time in at least 7 years (I-SW-15) in response to inquiries from the Audit Team. It contained no oil. There is no oi] collection tank for the Crater Lake Tunnel separator. According to APA (I-SW-13), the Crater Lake Tunnel separator was probably constructed to collect runoff from construction equipment during development of the tunnel. Although this separator has reportedly been disconnected from service (I-SW-13), this is not documented. Additionally, a small amount of water was running out of the discharge pipe at the time of the Audit, indicating that liquid is still being routed to the tank. Outflow from the separator drains to a surface ditch, which flows into the tidal waters at the Snettisham site. The probable causal factor for this finding is lack of procedures to regularly inspect oil/water separators. As a secondary factor, the lack of appraisals, audits, and reviews allows these conditions to persist. 3-19 3.3 GROUNDWATER 3.3.1 Overview The purpose of the groundwater portion of the Alaska Power Administration (APA) Environmental Audit was to evaluate the programmatic and technical status of the APA groundwater protection and monitoring program in terms of compliance with Federal and state laws and regulations, DOE Orders, and Secretary of Energy Notices (see Table 3-3). Also considered were internal APA directives, industry guidance, and best management practices. The general approach to the groundwater assessment at APA involved interviews with APA staff regarding local subsurface geology. The assessment also included reviews of documents such as regional geological reports and facility construction diagrams. This review was coordinated with those of the inactive waste sites and surface water specialists. The hydrologic settings underlying all of the APA facilities have not been characterized sufficiently to determine local conditions such as aquifer quality, groundwater depth, direction of local groundwater flow, permeability of overlying units, and proximity to private or public water wells. General regional descriptions of the Eklutna and Snettisham areas have been published. However, because both areas have been subjected to repeated glacial advances and recesses resulting in complex stratigraphies, it is difficult to predict local hydrologic settings based on regional studies. Because the facilities associated with both the Eklutna and Snettisham projects are geographically dispersed, the hydrologic setting for each APA facility may be distinct. At the time of the Environmental Audit, informative documentation such as local geologic descriptions, facility construction diagrams, and regional hydrologic reports were not available for all of the APA facilities. For those facilities where some amount of information was available, discussions of the hydrologic settings are presented below. Eklutna Powerplant The Eklutna Powerplant appears to be situated on, or adjacent to, the flood plains of the Knik River. According to available construction diagrams, sediments underlying the plant consist of thick sequences of silty clays with some bituminous layers, suggesting that the site was once occupied by a pond or bog. Clay units are characterized by low permeability and, where surface gradient is sufficient, high surface runoff; they make poor groundwater aquifers. The bedrock underlying the clay sequence consists of granitic intrusives and metamorphosed siltstones, graywackes, arkoses, and conglomeratic sandstones (D-GW-3 and D-GW-6). Depth to bedrock ranges from 30 feet near the base of the mountain immediately south of the plant to over 90 feet near the tailrace. Regionally, the bedrock does not constitute a significant groundwater aquifer. It usually is characterized by low porosity and low water content; although, where extensively weathered or fractured, it may yield up to 10 gallons per minute (gal/min) or more (D-GW-5). Local depth to groundwater is unknown. 3-21 TABLE 3-3 LIST OF GROUNDWATER REGULATIONS, REQUIREMENTS, AND GUIDELINES See 2 ee DOE Order 5400.1 General Environmental Protection Program Recommended Practices for Monitoring Well Design, Installation, and Decommissioning; April 1992 3-22 Given the low permeability of overlying clay units, it is unlikely that there is significant vertical communication between activities at the Eklutna Powerplant and the underlying bedrock. Instead, it is likely that downward migrating fluids would accumulate on the upper surface of the clay unit and migrate along its surface toward structurally low areas. Most likely, fluid migration would be toward the Knik River, although migration toward localized low areas cannot be ruled out. Reed Substation Reed Substation is located to the southwest of the Eklutna Powerplant along the strike of the Chugach Mountains. Because of its similar physiographic position, the hydrologic setting at Reed Substation may be expected to be similar to the setting at Eklutna Powerplant. However, available geologic maps indicate that Reed Substation is located in an area where the bedrock is overlain by alluvial fan deposits associated with the Eklutna River (D-GW-5). The alluvial deposits are composed of moderately well-sorted sand and gravel with some localized silt and clay beds. Unlike the clay sequence documented at the powerplant, the alluvial deposits are quite permeable and are characterized by good to excellent water yield capabilities ranging from 5 to 50 gal/min or more (D-GW-5). The thickness of the aquifer section at Reed Substation and depth to groundwater are unknown. Palmer Substation Palmer Substation is located in the Matanuska River valley. It appears to be located on glacial outwash deposits consisting of well-sorted, permeable sands and gravels; however, the presence of overlying, impermeable till deposits cannot be ruled out without more detailed investigation. In the Matanuska Valley, outwash deposits range in thickness from only a few feet to over 100 feet and are generally saturated at depths below 10 to 20 feet. Water yields’ as high as 100 to 200 gal/min have been documented from wells completed in the outwash deposits (D-GW-3). Where overlying till deposits are absent, the outwash deposits are recharged primarily by precipitation. Where present, till deposits generally are not water bearing, but serve as a confining layer creating artesian aquifer conditions. The bedrock underlying the Matanuska River valley consists of sandstones, shales, and greenstones and does not constitute an important regional aquifer. Snettisham Powerplant Snettisham Powerplant is located in the Speel River valley. The floor of this broad valley is composed of deposits of unconsolidated sand, gravel, and boulder derived from glacial and alluvial erosion of the surrounding mountains (D-GW-2). According to local soil logs from the Snettisham Project, the shallow subsurface (0 to 12 feet) consists of layers of sand, sandy gravel, and gravelly sand (D-GW-8 and D-GW-9). These deposits are likely to be quite permeable allowing for rapid infiltration of precipitation and migration of shallow groundwater into the Speel River. The thickness of these deposits at Snettisham is unknown, although they are likely to be thickest near where the Long River joins the flatter Speel River valley. The bedrock underlying the unconsolidated deposits consists of igneous intrusive rocks characterized as a quartz diorite with some associated metamorphic gneisses and schists (D-GW-2). The bedrock is not likely to serve as a significant groundwater aquifer, although it may yield some water from fractured zones. 3-23 Drinking water at Snettisham is provided by a well that is approximately 72.3 feet deep (D-TCM-20). Well logs and construction diagrams for this well were not available at the time of the Audit. However, it seems likely that the well is drawing water from unconsolidated sediments rather than the bedrock. The well is pumped on a schedule designed to supply enough water to meet the demands of the resident population. Pump test information indicating = yield capabilities is not available (I-GW-4) and depth to groundwater is not known. Thane Substation According to an as-built diagram for Thane Substation (D-GW-7), shallow subsurface sediments at this location consist of interbedded layers of sandy silt, sandy gravel, and silts. Test pit diagrams indicate a "probable top of rock" at depths ranging from 6.7 to 14.3 feet. This may represent bedrock. Information describing the bedrock or groundwater depth was not available during the Audit. Several activities and operations at APA facilities have the potential to impact local groundwater: onsite septic systems at Eklutna Powerplant, Anchorage Substation, Snettisham Powerplant, and Thane Substation; the mud drain and leach pit at Snettisham Powerplant; underground storage tanks at Snettisham Powerplant and the Taku Terminals; former landfill operations at Eklutna and Snettisham; current landfill operations at Snettisham; and potential oil leaks and spills at all of the facilities. However, since APA has not conducted a formal characterization of any of its facilities, it is not possible to determine whether these activities have had an effect on the groundwater. Additionally, because local geologic and hydrologic conditions are not well understood by APA staff, contaminant migration pathways also are not known. Available data suggest that infiltration of precipitation is quite likely at most of APA’s facilities due to the relatively high permeability of the surface and shallow subsurface deposits. In addition, lateral migration through these permeable units toward surface waters is likely. One possible exception would be the Eklutna Powerplant where thick, impermeable sections of clay are present. The groundwater portion of the Environmental Audit identified one compliance finding pertaining to the lack of a Groundwater Protection Management Plan. 3-24 3.3.2 Compliance Finding GW/CF-1: Groundwater Protection Management Program Performance Objective: DOE Order 5400.1, "General Environmental Protection Program," Chapter III, Section 4(a), states that for each site, the Head of Field Operations shall prepare a Groundwater Protection Management Program that includes: (1) documentation of the groundwater regime with respect to quantity and quality; (2) design and implementation of a groundwater monitoring program to support resource management and comply with relevant environmental laws and regulations; (3) a management program for groundwater protection and remediation, including specific Safe Drinking Water Act (SDWA), Resource Conservation and Recovery Act (RCRA), and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) actions; (4) a summary and identification of areas that may be contaminated with hazardous substances; (5) strategies for controlling sources of these contaminants; (6) a remedial action program that is part of the site CERCLA program required by DOE Order 5400.4; and (7) decontamination and decommissioning, and other remedial Programs contained in DOE directives. Plans, permits, and other technical documents such as those associated with compliance with the SDWA, RCRA, and CERCLA may be used in whole or in part to satisfy these requirements. This plan shall be completed no later that November 9, 1988 (18 months after the effective date of the DOE Order). The plan shall be reviewed annually and updated every 3 years. Finding: Alaska Power Administration (APA) has not developed a plan for a Groundwater Protection Management Program as required by DOE Order 5400.1, Chapter III, Section 4(a). Discussion: The issue of groundwater protection was addressed in APA’s Annual Site Environmental Reports for 1988, 1989, 1990, and 1991 (D-GW-10, 12, 11, and 13). In the 1988 and 1989 reports (D-GW-10 and D-GW-12, respectively), APA stated that its operations at the Eklutna and Snettisham Projects did not discharge any significant pollutants to the air or water and that requirements for a Groundwater Protection Program were not applicable. In the 1990 annual report (D-GW-11), APA documented that two locations of historic releases of transformer insulating oi] had been identified. (Tests revealed that the oil was not contaminated by polychlorinated biphenyls (PCBs).) As a followup activity to any remediation efforts at these two locations, APA stated it would initiate monitoring for groundwater contamination during fiscal year (FY) 1993. APA also stated that a formal Groundwater Protection Subprogram would be developed in FY 1992. In the 1991 annual report (D-GW-13), APA recognized that activities relating to the management of hazardous materials, solid waste, oil-filled electrical equipment, underground storage tanks (USTs), and aboveground storage tanks may have an impact on environmental media unless managed to prevent environmental releases. APA stated that it intends to evaluate the need for groundwater monitoring programs for: (1) Snettisham’s solid waste landfill; (2) Snettisham’s aboveground fuel storage area; (3) oil-filled electrical equipment removed from service at Anchorage Substation; (4) a smal] number of historic spills of non-PCB insulating oi] at both projects; and (5) all future A-106 Pollution Abatement Projects. To date, no action in this area has been taken. These proposed evaluations omit other potential sources of groundwater 3-25 impact, such as the old landfills at Eklutna and Snettisham; the septic systems at Eklutna, Snettisham, Thane, and Anchorage Substations; the mud drain and leach pit at Snettisham; and the USTs at Snettisham. To date, APA has not characterized the hydrologic settings at any of its facilities. A hydrologic characterization is essential to evaluating the need for a groundwater monitoring program. Additionally, APA has not adequately characterized the impact to groundwater associated with its current operations or its inactive waste sites. Even if APA were to complete the evaluations proposed in the 1991 annual report, not all of its potential sources of groundwater impact would be characterized. The probable causal factors for this finding are failure to develop an APA policy to meet the requirements of DOE Order 5400.1; failure to adequately assess the risk of groundwater contamination associated with APA activities; and lack of personnel with appropriate technical experience and background with regard to hydrologic characterization. 3-26 3.4 WASTE MANAGEMENT 3.4.1 Overview The purpose of the waste management portion of the Environmental Audit of the Alaska Power Administration (APA) was to evaluate APA’s activities related to solid and hazardous waste management. Activities evaluated included the generation, accumulation, storage, and disposal of these wastes. Additionally, an evaluation of underground storage tank (UST) Management was conducted. The general approach to the waste management portion of the Environmental Audit included: (1) inspections of facilities and operations associated with waste generation, accumulation, storage, and disposal; (2) interviews with APA staff responsible for environmental compliance, waste generation, and waste management; (3) a review of documentation including policies and procedures, waste characterization records, manifests and other shipping documents, waste accumulation logs, inspection records, training records, environmental Management reports, and self-assessments; and (4) coordination with all of the other Audit Team specialists. Information collected from these Audit activities was evaluated against Federal and state regulations, DOE and APA Orders, industry guidance, and best management practices (BMPs) (see Table 3-4). APA generates a variety of solid and hazardous wastes at its facilities associated with the Eklutna and Snettisham Projects. APA relies primarily on process knowledge to determine its hazardous waste streams and APA has applied for, and received, two separate hazardous waste generator numbers for the two projects. Both projects currently are considered to be "conditionally exempt smal] quantity generators" (CESQGs), generating less than 100 kilograms (kg) of hazardous wastes per month and less than 1 kg of acutely hazardous wastes. However, from April through October 1991, the Snettisham Project exceeded the generation limits and was a "small quantity generator" (SQG) due to the removal of a backlog of wastes and discarded chemical products that had accumulated onsite over a period of many years. Because the entire backlog of wastes appears to have been removed, it is not anticipated that either the Eklutna or Snettisham Project will exceed the CESQG limits in the future through the normal course of operations. Solid wastes generated at APA facilities include waste paper, garbage, scrap wood and metal, aluminum cans, and used oi]. In Alaska, used oi] is not considered a hazardous waste unless it is contaminated with hazardous constituents or exhibits any of four hazardous characteristics. APA collects its used oi] in segregated containers and disposes of it via recycling facilities. Before the recycling facilities will accept the used oil, it is tested by the recycler to verify that it is not contaminated with chlorinated substances. At Eklutna, used oils are transported to a collection facility located at the Anchorage landfill and operated by Northwest Environmental Services (Northwest). Used oils generated at Snettisham are transported by barge and flatbed truck to Thane Substation where they are collected in bulk by a local oil recycler. 3-27 TABLE 3-4 LIST OF WASTE MANAGEMENT REGULATIONS, REQUIREMENTS, AND GUIDELINES DOE Order 5400.1 General Environmental Protection Program DOE Order 5400.3 Hazardous and Radioactive Mixed Waste Program 40 CFR Parts 260-271 | Hazardous Waste Management Regulations 40 CFR Part 280 Underground Storage Tank Regulations 18 AAC Chapter 60 Alaska Solid Waste Management ADEC Regulations 18 AAC Chapter 62 Alaska Hazardous Waste Management ADEC Regulations 18 AAC Chapter 63 Alaska Hazardous Waste Management ADEC Facilities Siting Regulations Alaska Statutes, Alaska Underground Storage Tank Act ADEC Title 46, Chapter 3, Article 6A APA Supplement 1 APA Hazardous Waste Program 3-28 APA recycles its office paper, newspaper, aluminum cans, and scrap metal. Other solid wastes from the Eklutna Project and Thane Substation are disposed of at municipal solid waste landfills in Palmer and Juneau, respectively. At Snettisham, most combustible solid wastes are incinerated onsite and the resultant ash is deposited in an onsite permitted landfill located near Crater Cove. Other solid wastes, such as wooden pallets and empty petroleum product containers, also are disposed of in the landfill. Periodically, open burning is conducted at the landfill. Hazardous wastes generated at APA facilities generally are limited to waste stoddard solvent, oily rags contaminated with solvents, waste paints, batteries, and battery electrolytes. In the past, small quantities of chlorinated solvent, a Resource Conservation and Recovery Act (RCRA)-listed hazardous waste, was used. Both the Eklutna and Snettisham Projects still maintain minor amounts of chlorinated solvent in stock, although it is no longer used in the course of normal operations (I-WM-8, I-WM-12, and I-WM-18). As part of APA’s waste minimization program, staff have tried to replace hazardous materials with less hazardous materials. Currently, many of the facilities are using a water soluble citrus-based solvent in place of stoddard solvents for parts cleaning. However, the practice of individual employees purchasing chemicals through private vendors is ongoing at Eklutna. APA has established a Satellite Accumulation Area (SAA) at the Eklutna Maintenance Shop. When waste containers are full, the Environmental Coordinator transfers them to a central storage area located in a hazardous materials storage unit behind the garage. Hazardous wastes generated in the garage are taken directly to the central storage area. At Snettisham, SAAs have been established at the Heavy Equipment Shop and the Machine Shop Tunnel. A central storage area has been established in a separate hazardous materials/ hazardous waste storage unit located near the incinerator. Almost all hazardous wastes currently are disposed of via transfer to Northwest. Hazardous wastes from Eklutna are transported to Northwest’s collection center at the Anchorage landfill. This center was established specifically for the collection of hazardous wastes generated by Anchorage households and other CESQGs. Once the wastes are accepted by Northwest, pending the results of screening tests, they are transported under the City of Anchorage’s generator number to a disposal facility located in Washington State. Hazardous wastes generated at Snettisham are transported to Thane Substation along with used oi]. Used batteries are transported by APA personnel to a recycling facility in Juneau and all other hazardous wastes are collected by Northwest directly from Thane Substation. APA has recently developed a Hazardous Waste Program (D-WM-19) and a set of implementing procedures (D-WM-12 through D-WM-16 and D-WM-18). For the last 2 months, hazardous waste accumulation logs have been maintained by each project. These logs will be used to demonstrate APA’s compliance with CESQG generation limits. The procedures call for hazardous waste accumulation areas to be inspected at least weekly and, monthly in greater detail, by the Project Environmental Coordinators. Other records being maintained include copies of hazardous waste manifests and other shipping documents, and copies of some of the waste analysis results. APA has not developed a solid waste management 3-29 program or a formalized training program for workers who generate and handle solid or hazardous waste. APA owns and operates four USTs as part of the Snettisham Project. Three of these tanks are used solely for storage of diesel fuel used by emergency power generators and, therefore, are not subject to Federal release detection requirements. One of these tanks is located at the Snettisham Powerplant and has a capacity of 2,000 gallons (D-WM-23). The other two tanks are located at the Taku Terminals and each has a capacity of 500 gallons (D-WM-23). None have secondary containment, but two of the three have painted coatings and the third is equipped with cathodic protection. All three USTs are dipped periodically for inventory monitoring. They have been registered with the State of Alaska (D-WM-23). The fourth UST is located at the Snettisham Heavy Equipment Shop. It is plumbed to the facility’s oil/water separator. Although a design plan for the separator was not available during the Audit, the tank is intended to function as a temporary collection tank for overflow waste oil from the separator. According to an as-built diagram (D-WM-50), the UST has a capacity of 500 gallons and is constructed of steel. Before this Audit, the tank was last dipped approximately 7 years ago (I-WM-15). No other information is available describing this UST. It has not been registered with the State of Alaska as an exempt UST. : APA once owned and operated a 1,500-gallon UST at the Eklutna Project for the storage of gasoline. The tank was removed on June 25, 1992 (during the pre-Audit site visit), by New Horizons Telecom, Inc. According to the closure report (D-WM-21), a visual inspection of the tank revealed no defects, rust spots, or damaged fittings. No fuel contamination was detected during the removal using an organic vapor analyzer. Analyses of three samples revealed no contamination of the surrounding soils. This tank was registered with the State of Alaska (D-WM-22). The waste management portion of the Environmental Audit identified five compliance findings and two BMP findings. The compliance findings address hazardous waste determination, UST Management requirements, the Hazardous Waste Program, the solid waste disposal permit, and hazardous waste training. The BMP findings address solid waste Management program requirements and waste spill containment. 3-30 3.4.2 Compliance Findings WM/CF-1: Hazardous Waste Determination Performance Objective: 40 CFR Part 262.11, "Hazardous Waste Determination," requires all solid waste generators to determine if a waste is hazardous by virtue of being listed as a hazardous waste in 40 CFR Part 261, "Identification and Listing of Hazardous Wastes," Subpart D, "Lists of Hazardous Wastes." If a waste is not listed, the generator must then determine if it exhibits hazardous characteristics as defined in 40 CFR Part 261, Subpart C, "Characteristics of Hazardous Waste." This determination may be made by either: (1) testing the waste according to methods set forth in 40 CFR Part 261, Subpart C; or (2) applying knowledge of the hazardous characteristic of the waste in light of the materials or processes used. 40 CFR Part 262.40(c), "Recordkeeping," requires that generators must keep records of any test results, waste analyses, or other determinations made in accordance with 40 CFR Part 262.11 for at least 3 years from the date that the waste was last sent to onsite or offsite treatment, storage, or disposal. Finding: Proper characterization of all potentially hazardous wastes generated at Alaska Power Administration (APA) facilities has not been performed in accordance with the requirements of 40 CFR Part 262.11. In addition, records of all test results, waste analyses, or other determinations have not been maintained in accordance with the requirements of 40 CFR Part 262.40(c). Discussion: APA relies primarily on process knowledge for the determination of its hazardous waste streams. Currently, no listed hazardous wastes are routinely generated at APA facilities. Given the limited number of hazardous waste streams (e.g., waste stoddard solvent, expended batteries, rags with stoddard solvent, and occasionally rags with chlorinated solvents), reliance on process knowledge probably is an adequate determination method for most wastes generated by APA. The adequacy of this method can be reinforced through diligent use of waste accumulation logs to delineate separate sources of specific wastes. Additionally, reliance on process knowledge requires that hazardous waste managers are aware of all potentially hazardous substances in use by waste generators (see Finding TCM/BMPF-6). However, one potentially hazardous waste stream was identified at Snettisham that had not been identified previously by process knowledge: crushed fluorescent light bulbs are disposed of in the Crater Cove solid waste landfill. The potential hazardous properties of fluorescent light bulbs (namely the presence of mercury and antimony) have not been characterized by APA. Disposal of hazardous wastes in the landfill is not allowed by APA’s solid waste disposal permit (D-WM-10). As a "conditionally exempt small quantity generator" (CESQG), APA must include all hazardous wastes in monthly generation totals and must handle them in accordance with all established permits or procedures related to hazardous waste management. Testing of potentially hazardous wastes is conducted before these wastes are accepted for disposal by offsite waste disposal companies. At Eklutna, project wastes, including used oi] and waste solvents, are tested by Northwest Environmental Services (Northwest) when the wastes are delivered to their 3-31 facility located at the Anchorage landfill. The results of these tests determine how the wastes will be managed by Northwest. Copies of these test results are not provided to APA and, as a result, APA is not maintaining records of all tests conducted on their wastes. The probable causal factors for this finding include a lack of knowledge on the part of personnel to recognize the potential hazardous characteristics associated with fluorescent light bulbs; failure to establish a policy to obtain copies of all test results, waste analyses, and other determinations performed on APA wastes; and failure to recognize the risk. of environmental liability associated with insufficient documentation of waste characteristics. 3-32 WM/CF-2: Underground Storage Tank Requirements Performance Objective: 40 CFR Part 280.22, "Notification Requirements," requires that owners and operators of underground storage tank (UST) systems notify designated state or local agencies of the existence of all UST systems. 40 CFR Part 280, "Underground Storage Tanks," Subpart C, "General Operating Requirements," requires that all UST owners and operators must ensure that environmental releases due to spills, overfills, or tank corrosion do not occur. In accordance with 40 CFR Part 280, Subpart D, "Release Detection," all UST owners and operators must provide methods to detect tank releases such as monthly inventory control] or annual tank tightness testing. Compliance with the release-detection requirements of Subpart D is required for all tanks by 1993, according to an age-based, phased-in schedule. Best management practice suggests that all USTs, including those that are excluded from Federal UST regulations according to 40 CFR Part 280.10, "Applicability," should be managed in accordance with the requirements of Subparts C and D to minimize the potential for environmental releases. Finding: Alaska Power Administration (APA) has not registered or developed an UST management program for all regulated and unregulated USTs. Discussion: The oil/water separator located at the Heavy Equipment Shop at Snettisham is equipped with a 500-gallon, steel UST intended for the temporary collection of overflows from the oi]/water separator. Limited information is available describing the installation of this tank and APA staff did not appear to be knowledgeable of the design of either the UST or the associated oil/water separator. Based on the estimated age of as-built diagrams for this facility (D-WM-50), it appears that the UST was installed during or before 1976. The tank does not appear to have any secondary containment features and it is unknown whether it is equipped with any corrosion protection features. Given the nature of operations at this facility, the waste oil that would accumulate in this tank potentially could be contaminated with hazardous substances such as solvents. APA has not notified the Alaska Department of Environmental Conservation (ADEC) of this tank. If APA manages this tank as an emergency overflow containment system (i.e., develops adequate procedures for identifying overflow conditions and expeditiously emptying the tank), the tank will be exempt from the requirements of 40 CFR Part 280. Even so, APA still is required to register the tank with ADEC as an exempt tank. If APA fails to manage this tank as an emergency overflow containment system, it will no longer be exempt and will be subject to the full requirements of 40 CFR Part 280. During the Audit, the UST was dipped and determined to be empty; however, it could not be ascertained whether the tank was empty because it had not received any oil from the separator, or because the system has a leak. Without better records describing the design, use, and past maintenance of both the separator and the UST system, one can only speculate about the condition of the UST. APA also owns and operates three additional USTs associated with the Snettisham Project. One tank, with a 2,000 gallon capacity, is located at the 3-33 Snettisham Powerplant. The other two tanks, each with a 500 gallon capacity, are located at the Taku Terminals. All of these USTs are used to store diesel fuel solely for use by emergency power generators and are excluded from release detection requirements of 40 CFR Part 280. Despite this exclusion, APA has notified ADEC of their existence (D-WM-23). According to the draft Multimedia Environmental Management Audit (Fiscal Year (FY) 1992) for Snettisham (D-WM-37), these tanks are scheduled for removal in FY 1995, or at the latest by FY 1998. According to APA staff (I-WM-15), the UST located at the powerplant is dipped monthly. The USTs located at the Taku Terminals are dipped only after the emergency generators have been run, or during the months preceding winter when access to the facilities is not possible. Records of these inventory monitoring activities are not maintained. As a result, it may be difficult to detect product losses from these UST systems that are not. attributable to use of the emergency generators. Even though these tanks are scheduled for removal, in the interim, best management practice suggests that they be addressed by a formalized UST management program. The probable causal factors for this finding are lack of knowledge on the part of personnel to identify all USTs requiring notification, and failure to develop policy to ensure proper UST management. 3-34 WM/CF-3: Hazardous Waste Program Performance Objective: DOE Order 5400.3, "Hazardous and Radioactive Mixed Waste Program," requires DOE facilities to implement a hazardous waste program complying with all applicable laws and regulations. Best management practices suggest that Hazardous Waste Programs be sufficiently comprehensive to ensure effective program management. DOE Order 5400.3, Alaska Power Administration (APA) Supplement 1, "APA Hazardous Waste Program" (D-WM-19), implements the DOE Order to ensure that APA’s operations are environmentally sound and in compliance with relevant regulations. The "APA Hazardous Waste Program" specifies the requirements for maintaining the "conditionally exempt smal] quantity generator" (CESQG) status and establishes requirements related to waste storage, transportation, and disposal; waste minimization; spill response; training; personnel protection; program reviews; and recordkeeping. Finding: APA’s Hazardous Waste Program has not been fully developed as suggested by best management practice and has not been fully implemented as required by APA hazardous waste procedures. Discussion: APA’s Hazardous Waste Program was approved on May 1, 1992, for implementation by August 1, 1992. Implementing procedures including container labeling instructions (D-WM-18), weekly and monthly inspections logs (D-WM-13 through D-WM-16), and a corrective action form (D-WM-7) were issued on June 5, 1992 (D-WM-17). As a CESQG, APA is not required to comply with most of the requirements governing hazardous waste management contained in the Federal and state regulations implementing the Resource Conservation and Recovery Act (RCRA). However, APA has chosen to develop its Hazardous Waste Program to address many of the Federal and state requirements. The program and related implementation procedures have a number of deficiencies, examples of which include: . The program does not adequately assign programmatic responsibilities below the Project Manager level. "APA Hazardous Waste Program," Section 4, "Responsibilities and Authorities," does not identify individuals or positions responsible for specific tasks required by the program such as compilation of monthly generation records, management of waste storage areas and waste containers, waste determination, transportation, and disposal. ° The program does not identify the location of each waste storage area and satellite accumulation area (SAA) at the projects. e Implementation procedures do not specify requirements for segregating containers of hazardous wastes from containers of potentially incompatible hazardous materials. Some of the hazardous materials used at APA facilities may be chemically incompatible with the hazardous wastes generated. If incompatible products are stored together, spill response activities could be unnecessarily complicated. 3-35 ° The program does not address all potentially hazardous waste streams that are likely to be encountered at APA facilities (e.g., there are no management procedures for battery electrolytes). Because the Hazardous Waste Program is newly-developed, the related implementation procedures are still undergoing a review and revision process. As a result, some of the procedures have not been fully implemented. Examples of this are provided: ° Some waste containers are not labeled correctly. Containers of waste solvents at the Eklutna Maintenance Shop and at the Snettisham Heavy Vehicle Shop were not labeled as "FLAMMABLE." The accumulation start dates were missing from most waste containers and, in one instance, the date was clearly incorrect. ° Waste accumulation logs (D-WM-29) were not completed correctly with all required information. ° Hazardous waste manifests (D-WM-27 and D-WM-28) used to transport a number of wastes from Snettisham to Thane Substation were not completed correctly. e Housekeeping practices at the Snettisham Heavy Vehicle Equipment Shop SAA were marginal. Containers were stored haphazardly and several open plastic tubs and buckets contained small quantities of waste oi]. Not all solid waste streams were properly segregated. ° Offsite facilities and companies providing waste analysis or disposal have not been audited for regulatory compliance. The probable causal factors for this finding include lack of training of APA personnel in all of the essential elements in the Hazardous Waste Program, and inadequate training of APA personnel on implementation procedures. A lack of effective appraisals, audits, and reviews is a secondary contributing factor which allows these situations to persist. 3-36 WM/CF-4: Solid Waste Disposal Permit Performance Objective: Solid Waste Disposal Permit No. 9211-BA003 (D-WM-10), issued by the Alaska Department of Environmental Conservation (ADEC), establishes specific requirements for the operation of a solid waste landfill owned by Alaska Power Administration (APA). This permit restricts waste streams that may be disposed of in the landfill and establishes location, operating, monitoring, and recordkeeping requirements. Best management practice suggests that all operators of a permitted solid waste disposal facility be provided with a copy of the permit requirements and any relevant operating procedures to ensure permit compliance. Finding: Operations at APA’s permitted solid waste landfill are not conducted in accordance with permit requirements. A copy of the permit has not been provided to all solid waste disposal facility operators. Discussion: In January 1992, APA submitted a solid waste permit application to ADEC for three solid waste management facilities located at the Snettisham Project (D-WM-39). These facilities included a landfill (located near Crater Cove) that is permitted to accept only incinerator ash, an incinerator that accepts only nonhazardous domestic and commercial waste, and a scrap material staging area. On March 10, 1992, ADEC issued a "camp waste" disposal permit (D-WM-10) for the disposal of 1,400 pounds of incinerated camp wastes per year, and an unspecified quantity of noncombustible, nonputrescible wastes. Based on a literal interpretation of Section I of the permit, "Ashfill," current operations at the Snettisham landfill do not meet the location and operations requirements of the permit. Examples of how these requirements are not met include the following: e Landfilling is to be restricted to residues from the combustion of domestic refuse. Alaska Department of Fish and Game (ADF&@) , which operates the incinerator, currently incinerates industrial wastes such as oily rags and drained oil filters, in addition to domestic wastes. e The permit is only for camp domestic wastes and does not authorize the disposal of, among other things, oi] drums and hazardous or potentially hazardous materials. APA currently disposes of empty petroleum product containers and potentially hazardous fluorescent light bulbs (see Finding WM/CF-1) at the landfill. e The landfill should not be sited within 50 feet from any surface waters and any leachate from the site should be diverted from surface waters. The landfill is situated on the edge of a structurally elevated area where borrow material resulting from tunnel excavations has been deposited. However, this area is located in the course of Crater Creek upgradient of a wetlands area. Because the wastes are deposited along the downgradient edge of this elevated area, any leachate would drain into the wetlands. Along this side of the area, alder growth is excessively thick, making it difficult to monitor for leachate. 3-37 e Runon water should be diverted away from the disposal site. Currently, there are no runon controls at the landfill. Despite APA’s request in its application, neither the permit nor the permit transmittal letter state that the permit is intended to cover operations of the onsite incinerator or the scrap metal staging area. According to an ADEC staff member (I-WM-20), Section II of the permit is intended to regulate operations at the scrap metal staging area; however, this is not obvious from the language contained in the permit. The ADEC representative also indicated that the permit does not extend to operation of the incinerator (see Finding IWS/BMPF-1) . APA staff have made rather liberal interpretations of the conditions of the permit (I-WM-14). APA staff feel that the permit allows the incineration of industrial wastes and the landfilling of empty petroleum product containers. In addition, although not specifically mentioned in the permit, APA conducts open burning of combustible items such as wooden pallets and cardboard at the landfill. On occasion, noncombustible items such as polyvinyl chloride (PVC) piping are included in the open burning events. Also not mentioned in the permit is the use of the landfill by parties other than APA (e.g., ADF&G). According to the ADEC representative, the state intends to allow operators like APA great flexibility in the interpretation of camp waste disposal permits. ADEC inspected the Crater Cove landfill before issuing the permit and found no problems with its location with respect to surface waters. When asked, the ADEC representative indicated that he thought it was acceptable to dispose of empty petroleum product containers in the landfill, provided the product contained no hazardous constituents. In addition, the ADEC representative stated that the permit is intended to include waste disposal activities conducted by ADF&G. Contrary to the interpretations of APA staff, the ADEC representative said the permit does not prohibit the incineration of fish processing wastes, only the landfilling of noncombusted fish processing wastes. Despite the apparent concurrence of ADEC’s and APA’s interpretation of the permit requirements, written agreement of the actual intent of the permit has not been documented. A change of philosophy on the part of ADEC management could result in a much more literal and stringent interpretation of the permit. As a related issue, APA relies on staff from ADF&G to operate its incinerator and transport the resultant ash to the landfill. In addition, ADF&G staff are allowed to dispose of other solid wastes directly into the landfill. Waste disposal activities conducted by ADF&G must meet the requirements for waste management stated in APA’s permit; however, APA has not provided ADF&G with a copy of the permit or with a set of solid waste Management procedures interpreting permit requirements (see Finding WM/BMPF-1). The probable causal factors for this finding include inadequate design and operation of the landfill; failure to recognize the risk associated with making assumptions about permit requirements; and failure to recognize the risk associated with allowing ADF&G@ to conduct operations without a copy of the permit or a set of written operating procedures. 3-38 WM/CF-5: Hazardous Waste Training Performance Objective: DOE Order 5480.19, "Conduct of Operations Requirements for DOE Facilities," requires on-the-job training (OJT) programs that identify specific knowledge requirements for each employee, specific training elements each employee must receive, schedules for completion of OJT, and procedures for documenting completion of required training. Finding: Alaska Power Administration (APA) has not developed a formalized OJT program for employees who generate or manage hazardous wastes. Discussion: Formal, classroom training in hazardous waste Management has been provided to APA’s Chief of Environmental Safety and Health, Environmental Protection Specialist, and Environmental Coordinators at both the Eklutna and Snettisham Projects (I-WM-2). Other APA personnel who generate or handle hazardous wastes during the course of their normal job assignments have not received any formalized, classroom instruction. APA relies on an informal OJT program to convey information regarding hazardous waste management to these personnel (I-WM-2, I-WM-12, and I-WM-13). For the most part, APA’s OJT program for hazardous waste management consists of training sessions that are conducted periodically during weekly safety meetings held at each project. In addition, verbal communication is relied on to convey relevant information such as the requirements of APA’s Hazardous Waste Program (D-WM-19). APA’s OJT for hazardous waste workers has not been documented or formalized in any manner, and specific knowledge requirements for individual employees based on job task analyses have not been identified. APA has not developed a schedule for OJT completion and does not document the occurrence or adequacy of OUT. The probable causal factors for this finding include failure to develop a policy requiring a formalized OJT program for hazardous waste workers, and failure to develop written procedures specifying training requirements. 3-39 3.4.3 Best Management Practice Findings WM/BMPF-1: Solid Waste Management Program Performance Objective: Best management practices suggest that a formal solid waste management program be developed to identify all solid waste streams, establish management procedures for each waste stream, and specify procedures for the operation and management of all onsite solid waste disposal facilities. Finding: Alaska Power Administration (APA) has not developed a solid waste Management program. Discussion: APA has not developed a set of written procedures identifying and specifying how each solid waste stream generated at its facilities is to be managed. The only procedure developed for solid waste Management is contained in the waste minimization section of APA’s Hazardous Waste Program (D-WM-19), requiring recycling of office paper, newsprint, and metals. Elements of an effective solid waste Management program include the following: e Assignment of individual responsibilities; ° Identification of individual solid waste streams and their proper disposition, including special wastes such as asbestos; ° Identification of potentially hazardous wastes and the need to manage them separately from solid wastes; e Waste reduction opportunities and recycling procedures; e Procedures for the collection, packaging, and transportation of solid wastes; ° Procedures for operation of the incinerator at Snettisham, including restrictions on its use, maintenance requirements, and monitoring/inspection requirements; and e Procedures for operation of the Crater Cove landfill] at Snettisham, including restrictions on its use, maintenance requirements, and monitoring/inspection requirements. The probable causal factor for this finding is failure to assess the ris associated with not having a formalized solid waste Management program. 3-40 WM/BMPF-2: Waste Spill Containment Performance Objective: Best management practices suggest that areas used for the storage and handling of hazardous wastes or used oi] be designed to minimize the potential for environmental releases due to spills. Finding: Alaska Power Administration (APA) has not provided for adequate spill containment for hazardous waste and waste oils stored at the Snettisham Heavy Equipment Shop. Discussion: Hazardous wastes and used oil generated at the Heavy Equipment Shop at Snettisham are stored in a Satellite Accumulation Area (SAA) located near the garage doors on the southeast side of the building. This section of the facility is designed so that any surface runoff in this area, including spilled waste or oil, would not be captured by the facility’s drain system. Instead, surface runoff in this area would be directed outside the building toward a mud drain located outside the garage doors. This mud drain is not plumbed to any collection device and acts as a leach pit. Any hazardous wastes or used oi] entering this drain would percolate into the subsurface with the potential to migrate vertically to the groundwater or laterally to surface waters. This SAA is equipped with a grated structure that potentially serves as its secondary containment. However, it is likely, due to the small size of the structure, that some spills would not be contained. The grate is not recessed and there are no features present to stabilize tipped drums. If a waste container were inadvertently knocked over, or developed a large leak, wastes likely would not be captured by the containment structure. Additionally, during the Audit, containers holding minor quantities of used oi] were stored in this area outside of the containment structure. The probable causal factor for this finding is a failure to identify the risk of environmental release associated with the location and design of the SAA. 3-41 3.5 TOXIC AND CHEMICAL MATERIALS 3.5.1 Overview The purpose of the toxic and chemical materials (TCM) portion of the Environmental Audit was to evaluate the status of the Alaska Power Administration (APA) operations with regard to regulations promulgated under the Toxic Substances Control Act (TSCA); Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); DOE Orders; and best management practices (BMPs). These regulations and Orders establish the basic requirements for the use, storage, and disposal of toxic and hazardous materials (see Table 3-5). The general approach to the TCM Audit section consisted of an inspection of facilities; a review of documents including Material Safety Data Sheets (MSDSs), polychlorinated biphenyl (PCB) test logs, and APA correspondence; and interviews with APA personnel responsible for safety labeling, material storage, and chemical use. This part of the Audit was coordinated with the quality assurance, inactive waste sites, and environmental management specialists. APA no longer applies herbicide to control tree or weed growth at substations, powerplants, or along power line right-of-ways. Herbicide application was discontinued several years ago and the last known disposal of herbicide was in 1989 (D-TCM-2). Since at least 1986, APA has been active in the identification and removal of PCB-contaminated electrical equipment at the powerplants and substations (D-TCM-9). In addition to testing the oi] and/or reviewing the manufacturer’s specifications for oil in APA-owned equipment, APA has also tested or requested oi] analyses from tenant-owned equipment at the Eklutna, Reed, and Anchorage Substations. APA has complete results for tenant-owned equipment at Anchorage (D-TCM-21), and has requested, though not yet received, PCB test data on the equipment at Reed, where all equipment is tenant-owned. At Eklutna, APA has not received data on the single tenant transformer located on the south side of the powerplant building. There are three transformers at Thane Substation that have not been tested. Sampling cannot be performed while the transformers are in service and APA is planning to sample when they are temporarily removed from service for maintenance. APA owns three transformers known to contain PCBs above the regulatory limit of 50 parts per million (ppm): a PCB Transformer at Eklutna, and two PCB-contaminated transformers at Anchorage. Of these, only the PCB Transformer at Eklutna remains in service. The transformers at Anchorage are de-energized and will be removed from the superstructure pending availability of suitable transport containers. APA has budgeted removal of its remaining PCB equipment for fiscal year (FY) 1993 and FY 1994 (D-TCM-3) . Additionally, there are three known tenant-owned, PCB-contaminated transformers at Anchorage Substation. APA has requested that the tenant remove the PCB-contaminated transformers from Anchorage Substation (I-TCM-5). Bushings have not been sampled for PCBs because they are factory-sealed and intrusive sampling would render the devices inoperable. At APA, oil-filled 3-43 TABLE 3-5 LIST OF TOXIC AND CHEMICAL MATERIALS REGULATIONS, REQUIREMENTS, AND GUIDELINES z pe z ss sa DOE Order 5400.1 General Environmental Protection Program 40 CFR Part 112 Oi] Pollution Prevention 40 CFR Part 165 (FIFRA) Pesticide Storage/Disposal Regulations (TSCA) Polychlorinated Biphenyls (PCBs) - Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions Hazard Communication 40 CFR Part 761 40 CFR Part 1910.1200(g) 3-44 bushings which are associated with PCB-free transformers are assumed to be PCB-free. There are no oil-filled bushings attached to the identified PCB-contaminated equipment. Maintenance operations at APA include painting and cleaning of electrical equipment; upkeep of power generators; maintenance of facility vehicles and groundskeeping at substations, the powerplants, and along electric distribution lines. Toxic and/or hazardous chemicals used at APA include gasoline and diesel fuel for vehicle propulsion and heating/emergency generator use; solvents, such as stoddard or aqueous-based detergent, for parts wash devices; spray cans of freon or trichloroethylene (TCE) for fine parts cleaning and metal cleaning; and weld/solder preparatory compounds, enamels, lacquer paints, and thinners. Other chemicals include minor amounts (several gallons or less) of chlorine liquid (for disinfection), a surface fungicide, and typical workshop chemicals such as WD-40, Liquid Wrench, propane, and alcohols. Chemical bottles or cans are stored in ventilated safety-type yellow flammable storage cabinets at APA facilities. The only significant amounts of corrosive acid present at APA are contained in the standby power battery banks at the Eklutna, Thane, Anchorage, and Snettisham electrical facilities. These are filled with sulfuric acid electrolyte, however, the only maintenance performed by APA is the addition of distilled water. APA does not store sulfuric acid for battery maintenance. Bulk fuel storage at Eklutna consists of one aboveground gasoline tank (1,100-gallon), one aboveground diesel tank (500-gallon), and one diesel-containing tank wagon (400-gallon). Additionally, two aboveground gasoline tanks (approximately 5,000 gallons each) and two aboveground diesel tanks (6,400 and 8,200 gallons) are located at the Snettisham fuel farm. Gasoline at Eklutna is dispensed via a standard pump dispenser. Diesel fuel at Eklutna is dispensed to vehicles by gravity flow, while at Snettisham there are standard service station-type fuel dispensers which pump the fuel via an underground line from the fuel farm. Bulk oils and solvents at Eklutna and Thane are stored in drums and 5-gallon cans in standard commercial hazardous material storage units. At Snettisham, oils and solvents are stored in a commercial hazardous material storage unit and in a corner of the Heavy Equipment Building. At Eklutna, there is a 3,300-gallon transformer oi] tank in the sub-basement, which is the oil reserve for the two large power transformers outside the powerplant. Oi] from the transformers can be piped directly through an onsite oi] filtration system to the reserve or back to the transformer. The generators in the Eklutna Powerplant sub-basement are lubricated by turbine oi] contained in a two reservoir closed loop system. This oil is also purified through the onsite oil filter unit. Separate filters are used for transformer and turbine oil cleansing. A similar turbine oi] reservoir, pump, and filter loop operates in the Snettisham Powerplant. APA maintains a file of MSDSs at each individual facility with a central file for MSDSs at APA headquarters. MSDS coverage is not yet complete for all chemicals present at APA facilities and MSDS file organization is confusing. APA is working on a program to identify and label all hazardous materials and chemical storage areas using the National Fire Prevention Association (NFPA) four-part label. Chemical safety data are derived from the NFPA and the Hazmat Information Guide (HMIG). Charts explaining the color-coded NFPA system are visible throughout APA storage and work areas. The system is not 3-45 yet fully implemented and there are some program inconsistencies. Overall, the program appears to be a good start toward effective chemical hazard communication in the workplace. APA has initiated a program to obtain PCB test results for oil-filled equipment, both APA and tenant-owned. However, APA has not fully implemented a program which effectively provides secondary containment for bulk product storage. The TCM portion of the Audit identified one compliance and.six best management practice findings. The compliance finding addresses PCB labeling, identification, and containment. The best management practice findings relate to storage of chemicals; chemical hazard labeling; an MSDS inventory; secondary containment around tanks; acid spill response equipment; and procurement of hazardous materials. 3-46 3.5.2 Compliance Finding TCM/CF-1: Identification, Labeling, and Leak Containment for Polychlorinated Biphenyl Transformer Performance Objective: The Toxic Substances Control Act (TSCA), as codified under 40 CFR Part 761, "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions," requires that a transformer which contains 500 parts per million (ppm) PCB, or greater, be termed a PCB Transformer (40 CFR Part 761.3). Certain requirements are placed upon such transformers. These include: e PCB Transformers must be registered with local fire department personnel with information about transformer location, constituents of the fluid in the transformer, and the name and telephone number of the facility contact (40 CFR Part 761.30(a)(1)(vi)); ° If a PCB Transformer is found to have a leak, leaking material must be cleaned up and proper containment must be installed around the transformer (40 CFR Part 761.30(a)(1)(x)); and ° PCB Transformers must be labeled (40 CFR Part 761.40(c)(1)). Best management practice suggests that all equipment containing dielectric fluids be tested, where possible, for PCB content to determine appropriate levels of control under 40 CFR Part 761. Finding: The PCB Transformer east of the warehouse building at Eklutna that has leaked is not labeled, has not been properly identified to the local fire department, and has no secondary containment. Three transformers at Thane Substation have not been categorized or labeled in accordance with 40 CFR Part 761 requirements. Discussion: According to Alaska Power Administration (APA) records, there is only one transformer owned by APA which is known to contain oi] with a PCB concentration greater than 500 ppm (D-TCM-8). The transformer (serial number B330717) contains 1,470 ppm PCBs and is currently in service as part of a bank of active transformers located outside the east end of the warehouse at Eklutna. The transformer displays no PCB labeling. Also, a stain on the transformer and its concrete pad indicates that the transformer has leaked at some time in the past. The transformer is not labeled, as required by 40 CFR Part 761.40(c)(1), and has no form of secondary containment to prevent further leaks from dispersing PCBs into the environment, as required by 40 CFR Part 761.30(a)(1)(x). In addition, APA has not provided adequate notification to the local fire department about the PCB Transformer, as required by 40 CFR 761.30(a)(1)(vi). In April 1990, APA notified the Butte Fire Department in Palmer, Alaska, that PCB-contaminated transformers previously identified at the Eklutna facility had been removed from the site, and that there were no known PCB hazards remaining at the site (D-TCM-9). In the June 1992, Emergency Planning Notification submitted to the Butte Fire Department (see Finding IWS/BMPF-3), APA did indicate that there was one transformer containing PCBs at Eklutna. 3-47 However, this submission did not list all criteria as required under 40 CFR Part 761.30(a)(1)(vi), including the constituents of the fluid in the transformer and telephone number of the facility contact. There are also three transformers at Thane Substation that have not been tested. APA is aware of the need to sample them, however, sampling cannot be performed while these transformers are in service. APA is planning to sample the transformers when they are temporarily removed from service for maintenance. The probable causal factors for this finding are inadequate policy implementation for determining PCB notification, labeling, and containment requirements; a lack of supervision in the labeling and containment of an identified PCB Transformer; and, as a secondary contributing factor, a lack of appraisals, audits, and reviews which has allowed these conditions to go unidentified/uncorrected. 3-48 3.5.3 Best Management Practice Findings TCM/BMPF-1: Material Safety Data Sheet Inventory Performance Objective: Best management practice suggests that Material Safety Data Sheets (MSDSs) should be available for all chemicals used at a facility, and that the sheets be organized in a consistent and understandable manner. Finding: The file of MSDSs for chemicals used at the Alaska Power Administration (APA) is not complete and is not organized in an accessible format. Discussion: The Occupational Safety and Health Administration (OSHA), under 40 CFR Part 1910.1200(g), "Hazard Communication," requires manufacturers to develop an MSDS for each hazardous chemical, mixture, or product they produce, and requires employers to have an MSDS for each hazardous chemical which they use or store. MSDSs are obtainable from the manufacturer and are often supplied with the shipment of each chemical. MSDSs provide valuable information about the physical and chemical properties, incompatibilities, and hazards associated with the material, as well as giving information about safety precautions and emergency response actions. A spot check by the Audit Team of chemicals stored at the Eklutna Project, compared to the site’s available MSDSs, found several instances where an MSDS was not available. For example, in the Eklutna Machine Shop, a 1-gallon bottle of Alodine 1201, an aluminum finish product, and a bottle of Knapp #4 Cabinet Flux were not represented in the MSDS file. In addition, locating MSDSs for other products proved to be difficult, even with the assistance of the APA person familiar with the file (I-TCM-3). Some compounds were listed alphabetically under product name (e.g., WD-40) or chemical name (e.g., acetone), while others were listed under product type, such as solvent (e.g., Chevron 325, a stoddard solvent). An analogous situation was observed at the Snettisham site with a similar spot check of chemicals. At Eklutna, the APA person indicated unfamiliarity with much of the information contained in an MSDS, and indicated that the employee had not received any formal training in using the information contained on an MSDS (I-TCM-3). In other cases, MSDSs were posted on large oil-filled tanks and equipment, and sulfuric acid batteries at the various powerplants. However, in the battery storage room at Eklutna, there was no MSDS information. The probable causal factors for this finding include inadequate procedures in obtaining MSDSs for all site chemicals, and lack of training of personnel in the proper organization of MSDS files and information contained in MSDSs. 3-49 TCM/BMPF-2: Chemical Storage Performance Objective: Best management practice suggests that hazardous chemicals be stored with compatible materials in containers designed to safely contain the specific chemical, and that gas cylinders be detached from fittings when in storage. Finding: Two examples of incompatible chemical storage were observed at Alaska Power Administration (APA) operations. An organic-reactive chemical was stored in a cabinet at Eklutna along with various organic solvents, and a corrosive acid was stored in a metal can at Thane. Discussion: Many types of chemicals are incompatible and can react if inadvertently brought together either via direct mixing or by indirect contact. For example, oxidizers can initiate combustion when combined with flammable materials. An adverse chemical reaction can result in personal injury or a release of hazardous chemicals to the environment. It is important that incompatible chemicals be segregated and stored in separate locations and in vessels which will safely contain the material. An invaluable source of information regarding chemical storage and handling requirements can be found on the Material Safety Data Sheet (MSDS) for that material (see Finding TCM/BMPF-1). In an elevated flammable storage cabinet at the Eklutna Machine Shop, two inorganic compounds, Alodine 1201 and Knapp #4 Flux were stored proximate to organic compounds such as WD-40, alcohols, solvents, and various lubricant oils. APA did not have an MSDS for either compound (see Finding TCM/BMPF-1), but the bottle label of the Alodine 1201 stated that "contact with organic materials may cause fire after evaporation of water." In addition, the cabinet also contained propane gas cylinders with attached torch valve inserts and spark devices. The label on the propane cans contained instructions recommending to "detach the cylinder when not in use." At Thane Substation, a chemical labeled as "a caustic acid" had been poured into a 5-gallon metal gasoline container. APA persons could recall no more about the material except that it was an acid used in the past to clean concrete (I-TCM-7) and that it was originally contained in a metal can. It is not known whether that can was lined. Certain acids, such as hydrochloric or nitric, can corrode unlined metal, potentially releasing acid to the outside environment. The probable causal factors for this finding include inadequate procedures to obtain and utilize the information available on MSDSs; a lack of training in the proper segregation of materials; and a lack of supervision in the recognition of potentially hazardous conditions. 3-50 TCM/BMPF-3: Chemical Hazard Labels Performance Objective: Best management practice suggests that labels at hazardous chemical storage areas be accurate and consistent as to the chemical and health hazards of materials, and that there be a central index that can be used as a reference to consistently coordinate all the labels applied to storage areas at the site. Finding: There are four examples where the labeling of storage cabinets and/or chemical containers is not consistent, and there is no central index or defined labeling procedure for hazard identification. Discussion: Alaska Power Administration (APA) has initiated a program to label hazardous material storage areas and chemical containers. The labels adopted were the four-part color coded National Fire Protection Association (NFPA) scheme with some additional use of the Department of Transportation (DOT) labels. Information garnered from Material Safety Data Sheets (MSDSs) or product labels was used to determine the proper label identification for each material/chemical (I-TCM-2 and I-TCM-15). At the time of the Audit, flammable storage cabinets, chemical storage buildings, several oi] and fuel tanks, and numerous individual chemical containers were labeled with NFPA and/or DOT labels. Overall, the APA chemical hazard labeling program represents a positive approach to hazard communication. However, a spot check of storage areas by the Audit Team revealed four cases where label application was not consistent: ° A flammable storage cabinet in the garage at Thane Substation contained two spray cans of WD-40, a multi-purpose lubricant. The first contained an NFPA label marked 1-health, 1-flammability; while the second was labeled 2-health, 2-flammability. ° In the same cabinet at Thane, a 1-gallon bottle of 20/10 Pre-Mixed Instant Windshield Cleaner was labeled as 0-health, 1-flammability; while the bottle label read "contains methyl] alcohol, Poison" (a "O-health" indicates no health risk). ° The NFPA labels were applied to the inside door of flammable storage cabinets at most APA facilities; however, at the Snettisham Powerplant, two cabinets had the label on the outside cabinet door. An outside label on the cabinet door can provide information more quickly and safely to someone responding to an area emergency. ° A DOT flammable label was affixed to the parts washer in the Eklutna Machine Shop, even though the chemical presently used is aqueous and nonflammable. Conversely, the parts washer in the Eklutna vehicle shop, which does contain a flammable solvent, had no label. APA has not developed effective procedures to ensure the consistent application of chemical hazard labeling. However, APA has provided initial training for the person responsible for labeling chemicals, through attendance of an Occupational Safety and Health Administration (OSHA) course in hazard 3-51 communication (I-TCM-15). Some labels applied to small containers partially obscured more detailed manufacturer’s data affixed to the container. APA has issued guidance on the labeling of individual containers intended to address this issue (D-TCM-22). The probable causal factors for this finding include inadequate procedures to formalize and coordinate chemical labeling and storage areas; insufficient training in the interpretation of chemical hazards; and lack of supervision in the assurance of consistent label application. 3-52 TCM/BMPF-4: Secondary Containment Performance Objective: Best management practice suggests that there be effective secondary containment around oi] and fuel storage tanks and drums, and oil-filled electrical equipment to prevent leaks from reaching the environment. Finding: Transformers, stored electrical equipment, diesel and oil tanks and drums do not have adequate secondary containment to prevent a release to the environment. Discussion: Various environmental regulations cover the requirements for containment around certain types of chemical storage vessels. For example, storage of petroleum products proximate to waterways is regulated under 40 CFR Part 112, "Oil Pollution Prevention," (see Finding SW/CF-2), and the storage of polychlorinated biphenyls (PCBs) is covered under the Toxic Substances Control Act (TSCA). However, vessels which do not require special containment under the aforementioned requirements, and which still may contain significant quantities of fuels or oils, can leak and cause damage to the environment. The Audit Team identified several instances where such storage lacked secondary containment including: e The two large in-service transformers west of the Eklutna Powerplant (KWIA and KW2A), each of which contain approximately 2,400 gallons of Wimco mineral transformer oi1, have no spill containment other than a bed of uncontained gravel. ° The 500-gallon free standing diesel tank and 400-gallon mobile diesel tank west of the Vehicle Maintenance Building at Eklutna do not have any containment beneath the tanks. e The electrical equipment storage yard outside the Eklutna Warehouse has numerous items filled with non-PCB dielectric oil which rest on the bare ground near the property fence. e The approximately 250-gallon diesel tank located near the car parking area outside the main Snettisham dormitory has no secondary containment. e One drum of gasoline and a 300-gallon tank of diesel rest on the ground behind the old Snettisham used 01] building without secondary containment. ° In each of the two terminal buildings, there is a 100-gallon day tank, plumbed to an underground 500-gallon diesel storage tank. The day tank is in a bermed area, however, there is a floor drain within the area that is plumbed to a dry well. Also within each building is a 1,500-gallon tank of dielectric fluid connected to a pressure regulator system. Any release from this system would also migrate to a floor drain that is plumbed to the dry well (see Finding IWS/CF-3). The probable causal factors for this finding include failure to understand the risk to the environment resulting from the leak of oi] or fuel, and lack of a formal policy on secondary containment. 3-53 TCM/BMPF-5: Acid Spill Response Equipment Performance Objective: Best management practice suggests that there be sufficient acid neutralization material and spill cleanup equipment available in the vicinity of major acid storage areas to neutralize and contain potential acid spills. Finding: At standby power battery storage rooms at Eklutna, Anchorage, and Thane, the spill response equipment is inadequate to neutralize and contain an acid spill. Discussion: Each of the large substations and powerplants in the Alaska Power Administration (APA) system is equipped with a bank of batteries wired to provide reserve electricity to the facility in the event of a power interruption. All batteries are Exide-type lead-acid cells, which contain approximately 1 to 2 gallons of sulfuric acid solution. There are 60 batteries at both Eklutna and Anchorage and 84 batteries at both the Thane and Snettisham sites. At Eklutna there is one floor drain connected to a building sump. There is a minimal supply (less than 1 gallon) of solid neutralizer, and no device to apply the material if there were an acid spill. At Anchorage, the battery area does not have a floor drain, but there is no spill mitigation equipment available. At Thane, the battery room has a floor drain and there is a ripped, partially spilled bag of solid neutralizer on the floor with no means to apply the material to an actual spill. At each location, there is no secondary containment to prevent spilled acid from reaching either the local sewer or the outside environment (see Finding SW/BMPF-4) . The probable causal factors for this finding include an inadequate understanding of the risk that spilled unneutralized acid could have on the environment, and lack of an APA policy to maintain an adequate amount of spill absorption and neutralizing chemicals at APA battery storage rooms. 3-54 TCM/BMPF-6: Chemical Procurement Procedures Performance Objective: Best management practice suggests that procurement officials be provided necessary guidance addressing the purchase of hazardous materials. Additionally, written procurement procedures should be established that include necessary environmental reviews in order to ensure the safe storage, handling, use, and ultimate disposal of hazardous materials. Finding: APA has not provided its procurement officials with sufficient guidance on the procurement of hazardous materials, or developed formalized procedures which provide for appropriate professional environmental reviews of proposed purchases of hazardous materials. Discussion: Hazardous materials used by APA are purchased under a variety of mechanisms. All purchases greater than $1,000 per transaction must be made by the APA Contract Specialist. Items under $1,000 are typically purchased directly by individual staff through the Eklutna and Snettisham Project Offices. Currently, the APA Contract Specialist and Eklutna and Snettisham staff have not been provided any formalized training, guidance or procedures for the purchase of hazardous materials. APA professional environmental staff do not routinely review proposed hazardous material purchases to ensure that they can be adequately stored, handled, used, and disposed within APA. Formalized procedures and ES&H Branch involvement will ensure that waste minimization efforts are not compromised; Material Safety Data Sheets (MSDSs) are routinely obtained; and that use, handling, and ultimate disposal of hazardous materials are considered at the time of purchase. The hazardous materials used at the two APA projects are limited in both types and quantities. However, formalized guidance and procedures for the purchase of hazardous materials are lacking. The probable causal factor for this finding is risk, in that APA did not fully assess the risk associated with a lack of formal controls on the purchase of hazardous materials. 3-55 3.6 QUALITY ASSURANCE 3.6.1 Overview The purpose of the quality assurance portion of the Environmental Audit was to evaluate the quality assurance for Alaska Power Administration’s (APA’s) environmental protection programs for compliance with DOE Orders, regulatory agency requirements, and against accepted best management practices. The relevant DOE Orders, regulations, and guidelines used in the evaluation are listed in Table 3-6. The general approach to the quality assurance assessment for APA’s environmental protection programs involved interviews with APA staff regarding how quality is assured in environmental protection programs. The assessment also included reviews of documents, such as APA procurement requests and laboratory reports. The assessment of quality assurance for the APA environmental protection programs was coordinated with all Audit Team specialists to ensure that all potential quality assurance issues were identified, reviewed, and addressed. Several of the APA environmental protection programs include sampling and analysis. These activities include the collection of transformer oils for the determination of polychlorinated biphenyl] compounds and the collection of drinking water for determination of drinking water parameters. APA does not have an analytical laboratory onsite; therefore, all analyses are performed at contractor laboratories. Sampling of the transformer oils and the drinking water supply is conducted by APA personnel. To date, APA has not formally developed the- quality assurance component for its environmental protection programs. The quality assurance portion of the Environmental Audit identified three compliance findings addressing the following areas: quality assurance program for environmental monitoring and surveillance programs; environmental samp] ing procedures; and procurement of environmental technical support services. 3-57 TABLE 3-6 LIST OF QUALITY ASSURANCE REGULATIONS, REQUIREMENTS, AND GUIDELINES Public Law 95-92 DOE Organization Act DOE Order 5400.1 General Environmental Protection Program DOE Order 5700.6C | Quality Assurance QAMS-005 Interim Guidelines and Specification for Preparing a Quality Assurance Project Plan SW-846 3-58 3.6.2 Compliance Findings QA/CF-1: Quality Assurance Program for Environmental Monitoring and Surveillance Programs Performance Objective: DOE Order 5400.1, "General Environmental Protection Programs," requires that a quality assurance program consistent with DOE Order 5700.6B, "Quality Assurance" (replaced by 5700.6C, "Quality Assurance," August 21, 1991), be established covering each element of environmental monitoring and surveillance programs commensurate with its nature and complexity. DOE Order 5700.6C requires organizations to establish quality assurance requirements to ensure that risks and environmental impacts are minimized and that safety, reliability, and performance are maximized through the application of effective management systems commensurate with the risks posed by the facility and its work. In addition, Section 302 of the DOE Organization Act (PL 95-92) directs the Secretary to operate and maintain the Power Marketing Administrations by and through their Administrators. The Administrators have statutory and public utility responsibilities for the safety, security, and reliability of the systems operated by their organizations. The Administrators shall review and approve the quality assurance standards, policies, and activities appropriate for their facilities and operations. Such determination shall include appropriate consideration of the criteria set forth in the Order. Finding: Alaska Power Administration (APA) lacks a formal quality assurance program for its environmental monitoring and surveillance programs which meets the requirements in DOE Orders 5400.1 and 5700.6C. Discussion: A formal quality assurance program has not been developed for APA’s environmental monitoring and surveillance activities (I-QA-2). Asa result, quality assurance/quality control for sampling and analysis have not been instituted. This is important for providing a basis for ascertaining sample integrity, analytical method acceptability, and data validation. The following aspects of a quality assurance program plan are required by DOE Order 5400.1, and have not been documented in a quality assurance program: ° Organizational responsibility; ° Program design; ° Procedures; e Field quality control; e Laboratory quality control; ° Human factors; e Recordkeeping; ° Chain-of-custody procedures; e Audits; 3-59 ° Performance reporting; and ° Independent data verification. Operating without a formal environmental quality assurance program can result in the use and reporting of analytical data of questionable validity and compromise the defensibility of data. The use of such data to support management decisions can result in ineffective expenditures of funds and resources, and improper handling and disposal of wastes. The probable causal factors for this finding are a lack of policy implementation, in that the requirements of DOE Orders 5400.1 and 5700.6C have not been implemented; and a lack of training of APA personnel in quality assurance requirements. 3-60 QA/CF-2: Environmental Sampling Procedures Performance Objective: DOE Order 5400.1, "General Environmental Protection Programs," requires a quality assurance program consistent with DOE Order 5700.6B, "Quality Assurance" (replaced by 5700.6C, "Quality Assurance," August 16, 1991), be established covering each element of environmental monitoring and surveillance programs commensurate with its nature and complexity. DOE Order 5700.6C, Subparagraph 9.b(2)(a), "Work Processes," requires work be performed to established technical standards and administrative controls; and under controlled conditions using approved instructions, procedures, or other appropriate means. Finding: Alaska Power Administration (APA) has not developed written procedures for environmental sampling. Discussion: APA does not have documented standard operating procedures, including chain-of-custody guidelines, for the collection of environmental samples (I-EM-6, I-EM-18, and I-QA-2). Current environmental sampling conducted by APA staff includes the collection of oil, soil, and/or wipes for polychlorinated bipheny] (PCB) compound and drinking water for drinking water parameter determinations. Written procedures would provide quality assurance that all samples are collected in the appropriate manner and ensure that all necessary samples, including any required quality control samples, are collected. Formal procedures would also provide guidelines to instruct new personnel. The probable causal factors for this finding are inadequate policy implementation, in that the requirements of DOE Orders 5400.1 and 5700.6C have not been implemented; risk, in that site personnel were not aware of the potential problems associated with unreliable/undefensible data; and training, in that staff responsible for environmental sampling have not been fully trained against formal procedures. 3-61 QA/CF-3: Procurement of Environmental Technical Support Services Performance Objective: DOE Order 5400.1, "General Environmental Protection Programs," requires a quality assurance program consistent with DOE Order 5700.6B, "Quality Assurance" (replaced by 5700.6C, August 16, 1991) be established covering each element of environmental monitoring and surveillance programs commensurate with its nature and complexity. DOE Order 5700.6C, "Quality Assurance," Subparagraph 9.b(2)(c), "Procurement," requires the organization ensure that procured items and services meet established requirements and perform as specified, that prospective suppliers be evaluated and selected on the basis of specified criteria, and that approved suppliers can continue to provide acceptable items and services. Finding: Alaska Power Administration (APA) requirements, evaluations, and oversight of procured environmental technical support services are insufficient to meet the requirements in DOE Orders. Discussion: APA does not have an analytical laboratory as part of its operation; therefore, all environmental monitoring sample analyses, including those for drinking water, waste materials, and dielectric oils are contracted to offsite environmental analytical laboratories. These laboratories were not audited prior to, and have not been audited since their services were contracted (I-QA-2). Quality assurance plans for these analytical laboratories were not available for the Audit (I-QA-2). Currently, it is APA’s environment, safety, and health (ES&H) policy that all samples are sent to laboratories that are acceptable to, and certified by, either the Bonneville or the Western Power Marketing Administrations. The laboratory that is currently used by APA sends out 15 percent of all samples to a second laboratory for independent verification. No inaccuracies have been noted (D-QA-5). However, APA has not performed a formal review of the Bonneville and Western programs, or conducted an audit of specific laboratory activities or results to confirm quality attainment and quality assurance program effectiveness for these procured services (I-QA-2). Analytical data received from the contracted laboratories do not include laboratory quality control data (D-SW-6 and D-SW-7) and APA has not requested such data (D-SW-8, D-SW-9, and D-SW-10). Without quality specification, data evaluation, and technical oversight of environmental technical support services, it is difficult to ensure that the analytical data or services received are consistent in quality, as well as technically valid and defensible. The probable causal factors for this finding are lack of policy implementation in that the requirements of DOE Orders 5400.1 and 5700.6C have not been implemented; and lack of APA personnel training in quality assurance requirements. 3-62 3.7 INACTIVE WASTE SITES 3.7.1 Overview The purpose of the inactive waste sites portion of the Environmental Audit was to evaluate the Alaska Power Administration’s (APA’s) actions required under DOE Order 5400.4, "Comprehensive Environmental Response, Compensation, and Liability Act Requirements," with respect to the discovery, identification, and characterization of inactive waste disposal sites and APA’s response to spills, leaks, and releases of oi] and other regulated substances from its equipment and facilities. The specific regulations, requirements, and guidelines used to evaluate APA during this assessment are shown in Table 3-7. In addition, the Audit evaluated facility reporting of hazardous materials according to the requirements under the Superfund Amendments and Reauthorization Act (SARA) Title III, "Emergency Planning and Community Right-to-Know Act." The general approach to the inactive waste sites portion of the Audit included the following activities: (1) inspections of the APA facilities; (2) inspections of chemical storage areas; (3) inspections of inactive waste sites and areas and equipment where spills, leaks, or releases have occurred or are now occurring; (4) interviews with APA personnel; (5) interviews with officials of the Southeast Regional Office of the Alaska Department of Environmental Conservation (ADEC); and (6) review of documents related to past spills and disposal activities and chemical inventory notification. This portion of the Audit was coordinated with the environmental management, waste Management, and toxic and chemical materials specialists. There are three known inactive waste sites located at APA: a landfill (known as Bear Pit) located at the Snettisham Project, which operated under the auspices of an ADEC-issued permit; a construction contractor’s boneyard/disposal area at the Snettisham Project, which was operated without a permit; and a landfill at the Eklutna Project, which also was operated without a permit. APA has not begun characterization and assessment of the Snettisham Bear Pit or Eklutna landfills in accordance with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requirements and Environmental Protection Agency (EPA) guidances. APA is presently engaged in removal/remediation activities at the boneyard/disposal area located at Snettisham. The majority of materials being recovered from the boneyard/disposal area has been scrap metal, which is currently being stockpiled elsewhere on the Snettisham Project site awaiting disposal through recycling. However, some chemical wastes have also been recovered from the boneyard/disposal area. Subsequent analyses have shown these wastes to be mostly water with trace amounts of petroleum products. Spills and leaks were observed at various locations and from both APA-owned and tenant-owned equipment at APA facilities. The most significant documented release has been the spillage of an estimated 300 gallons of dielectric fluid into a dry well at the West Terminal Building. APA has no facilities currently listed on the National Priorities List (NPL) or the Federal Facilities Hazardous Waste Compliance Docket (the Docket). No APA facilities have been identified as candidates for future listing on the NPL or the Docket. 3-63 TABLE 3-7 LIST OF INACTIVE WASTE SITES REGULATIONS, REQUIREMENTS, AND GUIDELINES Public Law 96-510 |Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) Superfund Amendments and Reauthorization Act of 1986 (SARA) (including Title III: Emergency Planning and Community Right-to-Know Act (EPCRA)) Public Law 94-469 | Toxic Substances Control Act (TSCA) | EPA Public Law 99-499 DOE Order 4300.1C | Real Property Management DOE DOE Order 5400.1 General Environmental Protection Program DOE DOE DOE Order 5400.4 Comprehensive Environmental Response, Compensation, and Liability Act Requirements DOE Order 5484.1 Environmental Protection, Safety and Health Protection Information Reporting Requirements 29 CFR Part Occupational Safety and Health Standards OSHA 1910.120 for Hazardous Waste Site Workers 40 CFR Part 112 Oil Pollution Prevention 40 CFR Part 300 National Oi] and Hazardous Substance Contingency Plan (NCP) i EPA i EPA Designation, Reportable Quantities and EPA EPA EPA 40 CFR Part 302 Notification Emergency Planning and Notification Hazardous Chemical Reporting: Community Right-to-Know Toxic Chemical Release Reporting EPA Reporting Hazardous Substance Activity EPA When Selling or Transferring Federal Real Property Subpart G - PCB Spill Cleanup Policy EPA 40 CFR Part 355 40 CFR Part 370 40 CFR Part 372 40 CFR Part 373 40 CFR Part 761 3-64 41 CFR Part 101-47.304-14 Sale or Transfer of Federal Property Provisions Relating to Hazardous Substance Activity OSWER Directive Guidance for Performing Preliminary 9345.1-01A Assessments Under CERCLA (September 1991) 18 AAC Chapter 75 |Alaska Oi] and Hazardous Substances ADEC Pollution Control Regulations 3-65 In 1992, APA has submitted SARA Emergency Planning Notification for the Eklutna and Snettisham Projects to appropriate state and local emergency Planning agencies. APA has not submitted the Tier I or Tier II reports specified in SARA Title III. APA does not have a formal, implemented program to effectively deal with characterization, evaluation, remediation, and reporting requirements related to inactive waste sites and releases. The inactive waste sites portion of the Audit identified three compliance findings and three best management practice findings. The compliance findings pertain to characterization of two inactive waste sites, removal/remedial activities at the third inactive waste site, and responses to spills and leaks (including notification and reporting). The best Management practice findings involves tenant equipment and activities at APA facilities, hazardous substance activity inventories relating to the sale or transfer of Federal real properties, and incomplete submission of Tier I and/or Tier II hazardous material notification. 3-66 3.7.2 Compliance Findings IWS/CF-1: Assessment and Characterization of Former Landfills at the Eklutna and Snettisham Projects Performance Objective: DOE Order 5400.4, "Comprehensive Environmental Response, Compensation, and Liability Act Requirements," states that DOE installations will respond to releases or potential releases of hazardous substances from their facilities in accordance with the provisions of the Comprehensive Environmental Response, Compensation, and Liability Act Requirements (CERCLA) (as amended), the National Contingency Plan (NCP) (as amended by 54 FR 8666), and Executive Order 12580. 40 CFR Part 300, Section 420, "Remedial Site Evaluation," and 40 CFR Part 300, Section 410, "Removal Site Evaluation," specify the scope of removal and remedial site evaluations that are required. U.S. Environmental Protection Agency (EPA) guidelines provide the detailed framework for conducting Preliminary Assessments (PAs) and Site Investigations (SIs) (where necessary), including inventory of sites and contaminants, identification of sources, and evaluation of site conditions (including identification of target populations and resources potentially impacted). DOE Order 5400.4 further requires that DOE installations comply with notification, documentation, and other procedural requirements of CERCLA, NCP, and the National Environmental Policy Act (NEPA) where applicable, and that such compliance occur in a timely manner. CERCLA Section 103 requires that a notice be filed with the EPA of any occasion of known or suspected release of hazardous contaminants to the environment throughout the history of the facility. Section 120(d) of the Superfund Amendments and Reauthorization Act (SARA) clarifies that the above requirements are applicable to Federal facilities and properties unless otherwise specifically exempted. Finding: Alaska Power Administration (APA) has not performed assessments of the former landfill at the Eklutna Project and the alternative landfill site at the Snettisham Project, as required by DOE Order 5400.4, CERCLA 103, and SARA 120(d). Discussion: Eklutna Landfill The original operator of the Eklutna Project, the U.S. Bureau of Reclamation, is reported to have used the landfill for disposal of Eklutna construction camp wastes, household garbage, and office wastes (I-IWS-2). The exact date on which landfilling began has not been firmly established, but the landfill continued to operate at least until 1965 (1-IWS-2). In the mid-1960s, upon recommendation of the U.S. Army Corps of Engineers (COE), junk vehicle bodies were placed along a line generally paralleling the tailrace discharge of the powerplant to provide erosion protection to the dike. Inundation is especially possible in the spring months as a result of substantial water releases from Lake George, an upland ice-dammed mountain lake not associated with the Eklutna Project (I-IWS-1 and I-IWS-2). Additionally, such stabilization efforts continue to provide protection to the privately-owned 3-67 fish hatchery which draws water from the tailrace at a point roughly opposite the landfill. Because the landfill was operational over the period of powerplant construction, it is conceivable that construction-related wastes were deposited there. APA officials have also indicated that broken asphalt from refurbishment of the powerplant parking area was deposited in the landfill in the mid-1970s (I-IWS-2). Finally, APA personnel have indicated that they have had a continuing problem with keeping the public from driving into the area (primarily to fish from the tailrace), and that household trash and debris not connected with the Eklutna Project may also have been deposited in the area during that period of inadequate access control. A more substantial, locked gate now prevents unauthorized vehicle access to this area (I-IWS-2). The landfill was never operated under the auspices of a Federal or state permit and no formal closure plan has been developed or implemented. The specific characteristics and quantities of wastes deposited in the landfill from the various noted sources have not been established. Although it is reasonable to conclude that the majority of materials deposited in the landfill were nonhazardous, APA has not investigated disposal activities sufficiently to conclude that no hazardous substances were introduced. Circumstantial factors, specifically the proximity of the Knik River wetland, the tailrace (which ultimately discharges to the Knik River), and the fish hatchery, suggest that any hazardous substances released from the landfill would have a high probability of impacting any or all of these resources. However, there is no current evidence of such adverse impacts. APA has acknowledged that the landfill is deserving of additional investigation (including limited environmental sampling in the event that a comprehensive characterization of deposited wastes is not possible based on hearsay information alone) (I-IWS-1). However, the lack of evidence of adverse environmental impacts from the landfill has resulted in this investigation being assigned a low priority. Currently, there are no established plans or schedules for landfill investigations (I-IWS-1). Snettisham Landfill Details regarding this landfill are limited, however, based on documentation (D-IWS-58, 59, 60, 61, 62, and 73) and interviews with APA and Alaska Department of Environmental Conservation (ADEC) personnel (I-IWS-13, I-IWS-14, and I-IWS-15), the following synopsis of landfill operation has been developed. The landfill, known as Bear Pit, is a former borrow pit area located behind (northwest of) the incinerator building, and was established as an alternative site for solid waste disposal during those periods when the Crater Cove landfill access road was unpassable due to weather. Records appear to indicate that Crater Cove was always used as the principal landfill area at Snettisham since original occupancy sometime in 1969. Sometime after 1973, Bear Pit was utilized as an alternative site. Records also indicate that open burning of combustible solid wastes may also have occurred at Bear Pit site. This site was first formally acknowledged as an alternative landfill site in APA’s 1983 application to ADEC for an extension of the Crater Cove landfill permit. It is likely to have operated until incinerator installation in 1984. A permit extension for the Crater Cove landfill, granted in 1983, extended the operational period to 1987 and was based on an APA application which proposed a wastestream consisting of 2 cubic yards per week of "household and light industrial" solid wastes (D-IWS-59). Such light 3-68 industrial wastes may also have been delivered to Bear Pit. Finally, APA personnel have indicated that some previously buried solid wastes were removed from Bear Pit and relocated to the Crater Cove landfill (currently operational on the Snettisham Project site) (I-IWS-15). This could not be substantiated with documentation, however. There has been no formal closure of the Bear Pit landfill. As with the Eklutna landfill, available information suggests that the majority of wastes received at Bear Pit were nonhazardous in nature. However, APA has not conducted a sufficiently detailed investigation of past operations to affirm that no hazardous substances were introduced into the Bear Pit landfill, or that hazardous substances have not been released from the site. Finally, additional performance objectives for landfill characterization studies result from the proposed divestiture of APA facilities. These additional requirements, contained in DOE Order 4300.1C, "Real Property Management," and 40 CFR Part 373, "Reporting Hazardous Substance Activity When Selling or Transferring Federal Real Property," are discussed more fully under Finding -IWS/BMPF-2. The probable causal factors for this finding are a lack of policy implementation for the characterization of inactive waste sites, and a failure to properly evaluate risks associated with past disposal activities. 3-69 IWS/CF-2: Remediation of the Snettisham Construction Contractor’s Disposal/Boneyard Area Performance Objective: DOE Order 5400.4, "Comprehensive Environmental Response, Compensation, and Liability Act Requirements," states that DOE facilities will respond to releases or potential releases of hazardous substances in accordance with the provisions of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), its implementing regulations contained in the National Contingency Plan (NCP) (40 CFR Part 300 et seq.), and Executive Order 12580. DOE responses shall include both removal and/or remedial actions, as appropriate, regardless of whether the facility is listed on the National Priorities List (NPL). The NCP requires that a formal health and safety plan be developed and that the plan specifies, at a minimum, employee training and protective equipment and medical surveillance requirements, standard operating procedures, and contingency plans in conformance with 29 CFR Part 1910.120, "Occupational Safety and Health Standards for Hazardous Waste Site Workers." Finding: Removal and remedial actions currently underway at the former construction contractor’s disposal/boneyard area at the Snettisham Project are not being performed in conformance with DOE Order 5400.4, CERCLA, and NCP requirements. Discussion: Historical information indicates that the Snettisham Project construction contractor (a consortium doing business as Pacific Ventures) established a disposal area and boneyard on the Snettisham Project property in the early 1970s, ostensibly for receipt of construction-related wastes and debris (I-IWS-6). Utilizing both Alaska Power Administration (APA) personnel and contractor employees, APA began cleanup of this area approximately 2 years ago (I-IWS-13 and I-IWS-14). Preliminary reconnaissance of the disposal area revealed that scrap metals comprised the majority of the wastes deposited in the area. However, approximately 30 drums and chemical containers were also identified. Many were empty or nearly so (I-IWS-13). Cleanup activities included retrieval and relocation of scrap metal materials to a central area on the project site where they are currently stored awaiting recycling. All chemical containers were accumulated and temporarily stored in a gravel area within the disposal site until the results of samples retrieved by APA personnel could be obtained and proper disposal completed (I-IWS-14). Disposals of all chemical containers retrieved to date have been completed (I-IWS-14). Disposal records indicated that most of the wastes were nonhazardous, but others were Resource Conservation and Recovery Act (RCRA)-regulated (D-IWS-74). However, because these records also represent other wastes generated at, or transported from, the site over the same timeframe as drum removals from the boneyard, it is not clear whether the RCRA-regulated waste was recovered from the boneyard or otherwise generated by routine facility operation. Explorations of the disposal area are continuing and additional containers may still be discovered. Cleanup activities are ongoing, but APA believes that the majority of deposited wastes have already been retrieved (I-IWS-13). No subsurface investigations are planned for the area (I-IWS-14). 3-70 The cleanup activities conducted to date do not conform to the procedures established in the NCP and guidance developed by the U.S. Environmental Protection Agency (EPA) for preliminary assessment, site inspection, or removal/remedial activities. In retrospect, there is no evidence that workers have been inadvertently exposed to hazardous chemicals during cleanup activities to date. Nevertheless, circumstantial factors establish the possibility that hazardous chemicals may have been deposited in the disposal area and adherence to established hazardous waste site investigation and cleanup protocols (including health and safety provisions) is warranted. Finally, during inspection of the site, oil-like sheens were observed in standing water throughout the site, but especially in the gravel area where the chemical containers had been previously staged. However, it is impossible to determine without analysis whether the observed sheens are the result of release of oil or petroleum derivatives at the site, or instead are caused by organic compounds resulting from decomposition of vegetation in the area. APA has not developed formal plans for sampling of the soils in the disposal area to determine residual chemical contamination (1-IWS-14). The probable causal factors for this finding include a failure to develop policy for site remediation which is consistent with DOE Orders and relevant Federal regulations; a failure to develop specific procedures for site remediation activities (including site-specific health and safety procedures) ; a failure to properly evaluate the risks to personnel performing remedial or removal activities; and a lack of training for personnel engaged in potentially hazardous activities. 3-71 IWS/CF-3: Notices and Reports of Spills and Responses to Spills and Leaks Performance Objective: DOE Order 5400.4, "Comprehensive Environmental Response, Compensation, and Liability Act Requirements," requires that DOE installations respond in a timely fashion to releases or potential releases of hazardous substances originating from their facilities and that these responses be in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the National Contingency Plan (NCP) (as amended by 54 FR 8666), and Executive Order 12580. Federal regulations in 40 CFR Part 761 (Subpart G), "PCB Spill Cleanup Policy," implementing some provisions of the Toxic Substances Control Act (TSCA), establish specific requirements for cleanup of historic spills of fluids containing regulated concentrations of polychlorinated biphenyls (PCBs) . Alaska Administrative Code (AAC) regulations, administered by the Alaska Department of Environmental Conservation (ADEC) establish notification, cleanup, and reporting requirements for releases of hazardous substances (including oi1) (AAC Chapter 75, "Oil and Hazardous Substances Pollution Control Regulations"; 18 AAC Chapter 75.080, "Notification"; 18 AAC Chapter 75.090, "Interim Reporting"; and 18 AAC Chapter 75.100, "Reporting"). Finding: Alaska Power Administration (APA) has failed to notify and submit a report to ADEC for release of an estimated 300 gallons of dielectric oil from the west cable Terminal Building. Additionally, APA has not responded in a timely manner to this and other spills, leaks, or continuous releases of oils from equipment located at its facilities. Discussion: During inspections of APA facilities conducted during both the pre-Audit site visit and the Audit, a number of current and historic leaks were observed at various electrical equipment and support facilities. Examples include: ° Oil-stained gravel at each of two main transformers at the Eklutna Powerplant. (Eklutna personnel indicated that stained gravel had been present since 1965 (I-IWS-2).) ° Visible stains were observed on the PCB Transformer and underlying concrete pad at the east side of Eklutna warehouse building (see Finding TCM/CF-1). ° A leaking tenant-owned transformer had recently been replaced at the Eklutna powerplant, but oil-contaminated soils had not been remediated. e 0i1 was observed leaking from a reel of marine cable stored at Thane Substation. e Oil staining was observed on the tank surfaces of aboveground diesel and gasoline tanks at the Snettisham Project Fuel Farm and 0il-soaked ground was present near valves and plumbing in the bermed area. (Although the Fuel Farm, consisting of four aboveground tanks, is surrounded by an earthen berm for spill 3-72 containment, only the side slopes of the berm appear to be covered with a liner designed to be oil impervious. However, the liner has been extensively weathered and breached by vegetation. Vegetation growing in the base of the impoundment suggests that the liner either does not extend beneath the entirety of the impoundment, or that it has been compromised. Engineering plans for the impoundment were not available for review.) e An estimated 300 gallons of dielectric oil was released to a dry well at the west cable Terminal Building sometime before 1983. In 1989, APA discussed this release with ADEC officials and concluded that remedial actions were not likely to recover any oil] and no remedial actions have been undertaken to date. However, this release has not been formally reported to ADEC as required in 18 AAC Chapter 75.080. Oi] staining was observed on the ground around the Terminal Building by the Audit Team. ° Heavy oi] staining was observed on the foundation pads and gravel beneath each of three transformers at Anchorage Substation. These transformers are being removed from service and have recently been drained. APA began investigations of the west cable Terminal Building spill in 1989 (D-IWS-11; I-IWS-15). There is apparently no documentation of the original discovery of the spill, which may have been anytime between 1979 and 1983. As part of the after-the-fact investigation, APA consulted with ADEC Southeast Regional Office personnel in an attempt to identify appropriate options for a belated response to the spill (D-IWS-11; I-IWS-15). The recommended (and apparently adopted) option was to do nothing, given the long period of time that had passed since the spill, and the presumed likelihood that all oi] had already migrated from the area. However, while based on relevant circumstantial factors and observations made at the spill site in 1989, this recommendation did not incorporate potentially critical information on the characteristics of the subsurface and groundwater regimes at the Terminal Building. Additionally, the fate of the oil is based on speculation, rather than actual measurement of contamination levels through sampling of subsurface materials, including the gravel in the dry well from which oi] was ultimately released. There is no documentation that ADEC specifically asked for site investigations or characterization studies after having learned of the spill in 1989. Regardless, the spill site still represents an undefined potential liability for APA and the conclusion that remedial actions would be fruitless or unnecessary is not sufficiently justified. APA has recently developed a formal (draft) Spill Prevention Control and Countermeasures (SPCC) Plan for the tank farm at Snettisham, but has not developed a system-wide spill contingency plan (D-IWS-19) (see Finding SW/CF-2). Furthermore, APA has not characterized the subsurface and groundwater characteristics extant at each of its facilities as a means of predicting the fate and transport of spilled materials at each of those locations (see Finding GW/CF-1) (I-IWS-3). The probable causal factors for this finding are a lack of fully developed and implemented policy with respect to minor or continuous releases of oil or other hazardous substances; a failure to have a consistent procedure for responding to releases of oil or other hazardous substances including 3-73 notification and reporting; and insufficient training of personnel responsible for appropriate first response upon discovery of spills or releases, or for making decisions regarding appropriate spill response actions. 3-74 3.7.3 Best Management Practice Findings IWS/BMPF-1: Tenant Activities Performance Objective: DOE Order 5400.1, "General Environmental Protection Program," requires that all DOE facilities be operated in full compliance with applicable Federal and state regulations. Compliance with a number of Federal and state regulations requires comprehensive knowledge of all activities and events at the Federal facilities subject to control by those regulations. Best management practice suggests that sufficiently detailed agreements be established with all entities maintaining equipment at Federal facilities or conducting activities at those facilities which May come under control of those Federal or state regulations. Finding: Currently, Alaska Power Administration (APA) does not have sufficiently formalized agreements with tenants that provide for the timely exchange of information necessary for APA’s demonstration of compliance with relevant regulations. APA does not maintain formal oversight of tenant activities on APA-controlled property. Discussion: Memoranda of agreement do not exist to specifically require certain tenant actions to ensure compliance and prohibit those tenant activities that might result in noncompliance with relevant requirements. A number of tenant activities are ongoing at APA facilities that have the potential to compromise APA’s compliance with Federal and state regulations. Among them is the Alaska Department of Fish and Game (ADF&G) operation of the incinerator and Crater Cove landfill at the Snettisham Project site. Activities at the landfill are subject to the stipulations contained in the current operating permit issued to APA by the Alaska Department of Environmental Conservation (ADEC) (see Finding WM/CF-4). However, the current agreement between APA and ADF&G does not contain specific prohibitions and directives designed to maintain APA’s compliance with the ADEC permit. Likewise, ADF&G’s operation of the incinerator can compromise APA’s compliance with relevant air quality regulations contained in the Alaska Administrative Code (AAC) (e.g., the visible opacity standard contained in 18 AAC Chapter 50.040). APA has not formally directed ADF&G on the correct operation of the incinerator or identified relevant Alaska air quality regulations. Private utility-owned equipment is, or has been, located at the Eklutna Powerplant and Reed, Palmer, and Anchorage Substations. Releases of hazardous substances (as defined in 18 AAC Chapter 75.900) from privately-owned electrical equipment can create notice and reporting requirements as defined in 18 AAC Chapters 75.080, 75.090, and 75.100. Yet, tenants are not currently formally involved in development of spill contingency planning for those APA facilities, or required to add spill prevention and containment features to their equipment as may be appropriate to maintain conformance with site-specific spill contingency plans (D-IWS-19). (Formal spill contingency plans currently exist only for the Fuel Farm at the Snettisham Project. However, APA intends to develop formal plans for other facilities under its control.) Tenants are not currently required to notify APA when accidental releases through spills or leaks have occurred (1-IWS-13 and I-IWS-14). The presence of polychlorinated biphenyl (PCB)-containing dielectric fluids in tenant equipment introduces additional inventory and labeling requirements contained in 40 CFR Chapter 761 et seq., the implementing regulations of the 3-75 Toxic Substances Control Act (TSCA). APA has recently requested its tenants to provide relevant information regarding the PCB content of dielectric fluids contained in equipment currently at APA facilities. However, not all of the requested information has been received. Maintenance activities conducted by tenants on their equipment present at APA facilities on Federal property can result in the creation of regulated wastes and increases the possibility of accidental releases. Although APA recognizes that such maintenance activities are being performed, tenants are not presently required to give specific notice to APA of such maintenance events (I-IWS-3). Tenants are also not required to provide certification to APA that regulated wastes generated as a result of those activities have been properly managed and disposed of, or that inadvertent releases of regulated substances or wastes to the environment have not occurred or have been properly remediated, as necessary. The above discussion is not intended to identify all instances or situations where formalized tenant agreements may be warranted, but rather to provide examples of the general concerns embodied in the finding. The probable causal factor for this finding is the failure to assess the risk associated with tenant activities. 3-76 IWS/BMPF-2: Information Disclosures Relating To The Sale of Federal Property Performance Objective: Best management practice suggests that a comprehensive cataloguing of hazardous substance activities (including actual or potential impacts to the environment resulting from spills or releases of those substances) be completed for all DOE facilities. Best management practice also suggests that during the process of Divestiture, timely disclosure of this type of information to prospective purchasers of DOE facilities not only demonstrates a good faith effort to properly represent the. condition of said properties, but also serves to limit DOE’s future environmental liabilities regarding those properties. Finding: Alaska Power Administration (APA) has not developed an inventory of the occurrences of storage, use, release to the environment, or disposal of hazardous substances at all APA facilities and properties and has not made such information known to prospective purchasers. Discussion: DOE Order 5400.1, “General Environmental Protection Program" requires that DOE installations be operated in full compliance with all applicable Federal and state regulations. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120, "Federal Facilities," Paragraph h, "Property Transferred by Federal Agencies," requires information regarding all hazardous materials that were stored, used, or disposed of on Federal properties to be provided at the time contracts for the sale of those properties are entered into. Federal regulations implementing CERCLA Section 120(h) requirements are found in 40 CFR Part 373, "Reporting Hazardous Substance Activity When Selling or Transferring Federal Real Property." Article 40 CFR Part 373.1 of those regulations, effective October 17, 1990, states: "Whenever any department, agency, or instrumentality of the United States enters into any contract for the sale or other transfer of real property which is owned by the United States and at which, during the time the property was owned by the United States, any hazardous substance was stored for one year or more, known to have been released, or disposed of, the head of such department, agency, or instrumentality must include in such contract notice of the type and quantity of such hazardous substance, and notice of the time at which such storage, release, or disposal took place, to the extent such information is available on the basis of a complete search of agency files." DOE Order 4300.1C, "Real Property Management," establishes Department-wide policies and procedures for the disposal of real property or interests therein. Chapter II, "Disposal of Real and Related Personal Property, " Section 1(g)(18) requires a "Certification that property, including abandoned landfills, is sufficiently free of radioactivity and hazardous or toxic waste to permit unrestricted public use. This applies whether Government-owned land, improvements, or both, are being disposed." Determining both the strict applicabilities of CERCLA 120(h), 40 CFR Part 373, and DOE Order 4300.1C, and the date (or dates) on which those authorities became or may become applicable to APA Divestiture is not straightforward, is subject to legal interpretation, and is beyond the scope and authority of this Audit. An agreement for sale of the Eklutna Hydroelectric Project was entered into between APA and Chugach Electric Association, Inc., Matanuska Electric 3-77 Association, Inc., and the Municipality of Anchorage d/b/a Municipal Light and Power on August 2, 1989 (D-IWS-16). A purchase agreement for the Snettisham Hydroelectric Project between APA and the Alaska Energy Authority was entered into on February 10, 1989 (D-IWS-16). Both agreements were entered into after the effective date of the Superfund Amendments and Reauthorization Act (SARA) of 1986 which amended CERCLA to include Section 120, but before codification of CERCLA 120 requirements in 40 CFR Part 373. No inventory of hazardous material storage, release, or disposal activities were contained in those agreements. APA officials have indicated that these purchase agreements are not formal sale contracts, but rather represent proposed sale terms for Congressional consideration during its deliberations on authorizing legislation. These terms would not become effective unless or until they are ratified by legislation specifically authorizing APA divestiture (I-IWS-18). Contingencies to this effect are specified in both Purchase Agreements under "Article 2. Purpose." APA has not considered the potential applicability of CERCLA 120(h) or 40 CFR Part 373 requirements for inventories of hazardous substance storage, use, release, or disposal, or the analogous certification requirements contained in DOE Order 4300.1C, Chapter II, Section (1) (18). The probable causal factors for this finding include a lack of policy development with respect to Divestiture activities; inadequate procedures for identification of regulations with potential applicability to Divestiture of APA facilities; and the lack of training of APA personnel in DOE property transfer requirements. 3-78 IWS/BMPF-3: Submission of SARA Title III Reports Performance Objective: Title III, "The Emergency Planning and Community Right-to-Know Act," of the Superfund Amendments and Reauthorization Act (SARA), 40 CFR Part 370, requires that a facility submit annual Tier I and/or Tier II forms by March 1 for the preceding calendar year to comply with the requirements for hazardous material inventory reporting. Although the requirements under SARA Title III may not be legally applicable to APA, at a minimum, they constitute a best Management practice. Finding: Alaska Power Administration (APA) did not submit completed Tier I/Tier II forms for the Snettisham Fuel Farm by March 1, 1992. Discussion: Title III, Sections 311 and 312 of SARA, as codified in 40 CFR Part 370 requires that facilities which have present: (1) any hazardous chemicals in quantities greater than 10,000 pounds; or (2) any listed extremely hazardous substance in excess of 500 pounds or the threshold Planning quantity (TPQ), must submit annual Tier I and/or Tier II reports on the chemical inventory to the appropriate state and local emergency planning or response agency. Requirements for reporting under Title III began in 1988 for calendar year 1987. The Fuel Farm at Snettisham is the only APA facility which meets the reporting criteria under SARA Sections 311 and 312. APA did not submit a SARA Title III response prior to 1992. In 1991, APA was contacted by a contractor to the Matanuska-Susitna Borough Local Emergency Planning Committee (LEPC) regarding submission of a Tier II Form based on a gasoline storage tank at the Eklutna site (D-TCM-10). An undated APA file memorandum indicates that, after telecommunication between APA and the contractor, submission of the Tier II Form for the Eklutna site was deemed no longer required (D-TCM-11). In June 1992, APA submitted an Emergency Planning Notification, as required by SARA Section 302, to the local and state emergency response/planning agencies near the Eklutna site indicating that the facility contains no "extremely hazardous substances or hazardous chemicals above reportable quantities or threshold planning quantities" (D-TCM-12). On August 21, 1992, APA submitted a similar Emergency Planning Notification under SARA Section 302 to the Juneau LEPC for the gasoline and diesel fuel stored in excess of 10,000 pounds at the Snettisham Fuel Farm (D-TCM-16). The notification also acknowledged the presence of large battery racks at both Snettisham and Thane Substation (D-TCM-20), but indicated that there was no extremely hazardous chemical present above the reporting threshold. However, submission of the SARA Section 302 notification (40 CFR Part 355) does not obviate the need for the submission of the Tier I/Tier II forms required for Snettisham under SARA Sections 311 and 312 (40 CFR Part 370). In addition, the notification was not submitted within the timeframe specified by SARA. The probable causal factors for this finding include a lack of training of personnel in the requirements of SARA Title III, Sections 311 and 312; and inadequate policy implementation, in that the reporting requirements of SARA Title III have not been fully implemented. 3-79 3.8 ENVIRONMENTAL MANAGEMENT 3.8.1 Overview The environmental management portion of the Environmental Audit evaluated the status and effectiveness of the Alaska Power Administration (APA) and the Office of the Assistant Secretary for Conservation and Renewable Energy (CE) managements, as they relate to implementing DOE’s environmental protection policies and directives and ensuring environmental compliance at APA. The Audit included an assessment of APA’s Management of its environmental protection program, its line organization interfaces to its environmental protection programs, and its interface with CE. The specific performance objectives and criteria against which the APA and CE Managements were assessed include, in part, the Performance Objectives and Criteria for Environmental Management Section from the Performance Objectives and Criteria for Conducting DOE Environmental Audits. Table 3-8 lists the DOE Orders, Secretary of Energy Notices (SENs), and guidelines used in this Audit to define what environment, safety, and health (ES&H) functional relationships should exist within and between organizations, and what environmental programs should exist at an organization. The general approach to the environmental Management and organizational assessment included interviews and discussions with representatives of CE and APA. In addition, coordination with all of the other Audit Team specialists was conducted and various documents including policies, procedures, position descriptions, performance standards, internal and external reports, and correspondence were reviewed. APA has responsibility for operation, maintenance, transmission, and power marketing for the two Alaskan Federal hydroelectric projects. These are the 30 megawatt (MW) Eklutna Project, which has served the Anchorage and Matanuska Valley area since 1955; and the 78 MW Snettisham Project, which has been Juneau’s main power source since 1975. Snettisham has three generating units with a total capacity of 78 MW. Relatively minor construction activity is underway by the U.S. Army Corps of Engineers (COE) to complete all elements of its design and construction responsibilities for the Crater Lake unit at the Snettisham Project. It should be noted that DOE is seeking "divestiture" legislation to authorize sale of Eklutna and Snettisham Power Projects and subsequent closeout of APA. APA maintains its headquarters in Juneau and field offices at each project. The headquarters components include the Power Division, Administrative Division, and Administrator’s Office. The Power Division supervises the two operating projects; handles the marketing functions; provides staff assistance in engineering; and provides environmental Management, safety, and health support. The Administrative Division provides a full range of administrative management functions including finance accounting, contracting, program planning and budgeting, and other Procurement and personnel management support. Each project office is headed by a Project Manager and staffed with technical and craft specialists to cover facilities maintenance and provide backup operating capability. Portions of the operating and maintenance activities 3-81 TABLE 3-8 LIST OF ENVIRONMENTAL MANAGEMENT REGULATIONS, REQUIREMENTS, AND GUIDELINES Departmental Organization and Management Arrangements SEN-11-89 Setting the New Course | DOE DOE Order 5400.1 General Environmental Protection Program | DOE DOE Order 5400.3 Hazardous and Radioactive Mixed Waste Program DOE Order 5480.1B | Environment, Safety, and Health Program for Department of Energy Operations DOE Order 5480.19 {Conduct of Operation Requirements for DOE Facilities DOE Order 5482.1B |Environment, Safety, and Health Appraisal Program DOE Order 5700.6C | Quality Assurance DOE Memorandum Preliminary Review of Trends in Tiger Team Assessments DOE Memorandum Guidance on ES&H Self-Assessment Draft, March 1992 | Self-Assessment Guidance Document 3-82 are contracted with customer utilities. The contracted work includes normal operations and monitoring by supervisory control for each project, and transmission line maintenance at Eklutna. The environmental protection Program at APA began evolving in the mid-1980s, in that the environmental responsibilities were assigned as a collateral duty to a staff member. In 1990, an Environmental Manager was hired. In early 1992, an Environmental Protection Specialist was added to the staff. These initial assignments were in the Administrative Division. Just recently, APA instituted an organizational change and established an ES&H Branch. In the reorganization, the ES&H Branch was assigned to the Power Division. From an environmental management perspective, the APA environmental program has a number of strengths. The ES&H Branch staff is committed to developing and implementing a quality environmental Program. Although discussions with some APA staff members indicated that there has been some resistance to the implementation of the organization’s environmental program, there has been Progress over the last several years. APA’s environmental program is still significantly behind the level of increased emphasis expected at DOE facilities. Additionally, there is a clear need for the development of effective management systems to institutionalize APA’s increased environmental commitment. The Audit Team identified a total of seven findings related to programmatic management deficiencies: five compliance findings (including one related to CE’s oversight of APA’s environmental programs) and two best management practice findings. The APA management findings centered on internal environmental self-assessment and oversight; environmental training; documentation, communication and tracking of environmental deficiencies; establishment of defined environmental responsibilities and performance Measures; establishment of formalized environmental protection programs; and the organizational structure of APA. 3-83 3.8.2 Compliance Findings EM/CF-1: Environmental Performance Responsibilities Performance Objective: DOE Order 5480.18, "Environment, Safety, and Health Program for Department of Energy Operations," requires line management to be responsible for effective environmental performance in its programs. Secretary of Energy Notice (SEN)-11-89, "Setting the New Course," indicates the importance of line management responsibility and requires clear, documented identification of responsibilities for environmental performance of individuals. This requirement extends to DOE contractors. Finding: Alaska Power Administration (APA) management and staff functions, authorities, and responsibilities regarding environmental protection have not been effectively defined in job descriptions and performance standards. Discussion: Although SEN-11-89 was effective in 1989, to date, very few of the job descriptions and performance standards for APA managers, supervisors, and staff have been updated to include environmental responsibilities. Although most job descriptions and performance standards for personnel with specific environmental protection and compliance responsibilities do contain specific environmental performance criteria (D-EM-51), those for managers, including division directors, branch chiefs, project managers, area power managers, and supervisors do not contain environmental protection criteria (D-EM-22, 23, 24, and 50). Even though a few of the job descriptions have been updated to reflect environmental protection and compliance responsibilities, performance criteria in job descriptions of individuals with environmental protection responsibilities are necessary to ensure employees are cognizant of these responsibilities. The probable causal factor for this finding is lack of policy implementation, in that the DOE policies on environment, safety, and health have not been implemented. A secondary contributing factor allowing this situation to persist, is the lack of appraisals, audits, and reviews in regard to implementation of this policy. 3-84 EM/CF-2: Environment, Safety, and Health Self-Assessment and Appraisal Programs Performance Objective: The DOE memorandum, "Preliminary Review of Trends in Tiger Team Assessments," issued by the Secretary of Energy on January 26, 1990, directs all line management organizations to institute a formalized Self-Assessment Program. A second DOE memorandum, issued by the Secretary on July 31, 1990, "Guidance on ES&8H Self-Assessment," provides guidance for the development of programs for self-assessment of environment, safety, and health (ES&H) implementation. The guidance states that a comprehensive Self-Assessment Program should cover all facilities, buildings, and activities under the control of the line management entity and includes all applicable areas of ES&H. All ES&H areas should be examined at all levels within the organization. Continual line management self-evaluation should be implemented at all levels of the line organization, however, this does not substitute for independent internal assessment. DOE Order 5482.1B, "Environment, Safety, and Health Appraisal Program," Paragraph 8(e), requires Heads of Field Organizations to conduct Management appraisals of ES&H programs of subordinate field activities, functional appraisals of DOE and contractor activities with sufficient scope and frequency to ensure effectiveness of ES&H activities, and internal appraisals at the operating levels of their ES&H activities. Finding: The Alaska Power Administration (APA) has not developed and implemented a formal comprehensive ES&H Self-Assessment Program as directed by DOE Memoranda, and a formal ES&H Appraisal Program as directed by DOE Order. Discussion: The DOE memorandum of January 26, 1990, directs all line organizations to implement a comprehensive Self-Assessment Program to identify and characterize ES&H concerns relating to their operations. The July 31, 1990, Self-Assessment Program guidance memorandum requires that each organization have a documented program for self-assessment that assigns responsibilities; defines assessment scope and schedule; provides for development of standard operating procedures for conducting assessments; specifies procedures for documenting, communicating, and tracking findings and identifying trends, causal factors, and root causes; and formalizes a system for carrying out corrective actions. APA has not initiated the development of a formalized Self-Assessment Program. To date, the Office of the Assistant Secretary for Conservation and Renewable Energy (CE), the responsible Program Senior Official (PSO) for APA, has not transmitted any formal guidance to APA to develop and implement an institutional ES&H Self-Assessment Program. In addition to the Self-Assessment Program requirements, DOE Order 5482.1B requires an ES&H Appraisal Program to determine that ES&H policies and requirements are appropriately interpreted and implemented by DOE and DOE contractor programs and organizations; evaluate the effectiveness of ES&H policies, requirements and standards and their implementation; provide management with objective, timely, and reliable information on ES&H performance; provide management with recommendations for improvement of ES&H program performance; and determine the adequacy of DOE requirements for achieving DOE policy and Federal statutory ES&H requirements. In implementing this program, the Heads of Field Organizations have the responsibility and 3-85 authority to conduct management appraisals, functional appraisals, and internal appraisals of the field organization’s ES&H activities. APA has not developed a formal appraisal system which is clearly defined in writing and is auditable, and has not reviewed the overall operation of each facility with sufficient frequency to ensure adequate environmental protection coverage. In addition, APA has not provided for objective and independent review of its ES&H functions to determine that the ES&H Branch is conducting reviews of modifications to the plants and equipment; procedures and their revisions for administrative, operational, maintenance, and emergency activities; training programs; certification procedures; accidents; incidents; and unusual occurrences. Although APA has not developed and implemented a formal ES&H Appraisal Program, it conducted Multimedia Environmental Management Audits for both the Eklutna and Snettisham Projects in July 1992 (D-EM-55 and D-EM-56), and Annual Hazardous Waste Management Audits for both the Eklutna and Snettisham Projects in April 1992 (D-EM-57, 58, 59, and 60). The probable causal factors for this finding are lack of policy implementation, in that APA has not implemented the Secretarial directives on self-assessment and the DOE Order on ES&H appraisals formally; lack of training in the requirements of DOE Orders and directives; and supervision, in that supervisory controls were not adequate to ensure that necessary Management systems were instituted within APA. 3-86 EM/CF-3: General Environmental Protection Program Performance Objective: DOE Order 5400.1, "General Environmental Protection Program," establishes the environmental protection program requirements, authorities, and responsibilities for DOE operations for ensuring compliance with applicable Federal, state, and local environmental protection laws and regulations, Executive Orders, and internal Department policies. It also establishes requirements and guidance for: (1) notification and followup of environmental occurrences, and (2) periodic routine reporting of significant environmental protection program information. DOE organizations are also required to develop and implement specific environmental protection program plans and environmental monitoring programs for each facility or group of facilities for which they are responsible. Paragraph 9(f) of the Order states "Heads of Field Organizations shall issue and update, as required, a general environmental statement that reflects the statement of policy in this Order and contains broad environmental protection goals for all facilities and activities for which he or she is responsible; ensure that all operations under their authority comply with applicable environmental protection laws and regulations, and directives; conduct environmental appraisals of programs, projects, and facilities in accordance with DOE Order 5482.1B and other ES&H requirements; and prepare long range environmental protection plans in accordance with guidance issued by EH-1." DOE Order 5480.19, "Conduct of Operations Requirements for DOE Facilities," Chapter I, Section A, states that effective implementation and control of operating activities is primarily achieved by establishing written standards in operations, periodically monitoring and assessing performance, and holding personnel accountable for their performance. Section B states that a high level of performance is accomplished by establishing operating standards, communicating these standards to the working level, and by providing sufficient resources to the Operations Department. Finding: Alaska Power Administration (APA) has not fully developed and implemented a formalized Environmental Protection Program that meets all the requirements of the DOE Orders. Discussion: APA has not developed, assessed the need to develop, and/or fully implemented the following environmental protection programs and plans required by DOE Order 5400.1: e Long-Range Environmental Protection Plan; ° Groundwater Protection Management Plan; ° Pollution Prevention Awareness Plan; ° Environmental Monitoring Program; and e Quality Assurance and Data Verification Program. Additionally, although there was a December 1990 Annual Update for the APA Environmental Protection Implementation Plan (D-EM-66), no documentation for subsequent annual reviews or updates was available. 3-87 APA has specifically identified in its "General Environmental Policy Statement Practice" that a program to create a pollution prevention ethic in the work place through specific training, specific campaigns, and incentive programs is being prepared (D-EM-16). However, no Pollution Prevention Awareness Plan has been developed. APA has prepared Annual Site Environmental Reports for calendar years 1988, 1989, 1990, and 1991 (D-EM-4, 5, 6, and 37) and these reports generally followed the content and format suggested for annual site environmental reports. However, APA has not included information on its drinking water monitoring or references. Failure to develop a comprehensive Environmental Protection Program has resulted in a lack of operational guidelines for APA staff who have line management responsibility. This is reflected in the lack of adequate environmental guidance, environmental training, and environmental oversight identified during the Audit. In light of these observations and concerns identified in other sections of this report, it may be difficult for APA to demonstrate its commitment to environmental protection and compliance with Federal, state, and local environmental laws and regulations because the requirements of the General Environmental Protection Program Directive have not been implemented in a timely manner. The probable causal factors for this finding are the lack of policy implementation that is clearly delineated in DOF Orders; the lack of commitment of resources toward implementing a General Environmental Protection Program in a timely manner; and risk, in that APA has not assessed the relative degree of risk involved in not developing and implementing its Environmental Protection Program. 3-88 EM/CF-4: Organizational Structure Performance Objective: DOE Order 5482.1B, "Environment, Safety, and Health Appraisal Program," recognizes the organization structure provide for the effective achievement of its mission, including ensuring comprehensive, continuous, preventive, and protective environment, safety, and health (ES&H) programs in all activities. ES&H line and staff responsibilities should be assigned to the various organizational components. Secretary of Energy Notice (SEN)-11-89, "Setting the New DOE Course," indicates the importance of strengthening the independent internal oversight to monitor the effectiveness of DOE management in execution of policies set by DOE, particularly in areas of environment, safety, health, and security. DOE Order 5700.6C, "Quality Assurance," requires planned and periodic independent assessments be conducted to measure item quality and process effectiveness and to promote improvement. The organization performing independent assessments shall have sufficient authority and freedom from line organizations to carry out its responsibilities. Finding: The corporate organizational structure of Alaska Power Administration (APA) does not provide for the independent internal oversight to monitor the effectiveness of the environmental program in all areas. Discussion: Historically, starting in the mid-1980s, the APA assigned the organizational environmental responsibilities as a collateral duty to an individual within the organization, but discussions indicated that there was minimal overall management support for the function. In the late 1980s, the assignment of this collateral duty slightly higher in the organization resulted in more responsiveness on the part of the organization to environmental protection and compliance issues. However, it was not until the hiring of an Environmental Manager in 1990 that APA began to focus on environmental compliance and protection as a commitment in its overall mission. In early 1992, an Environmental Protection Specialist was added to the staff. Until the recent reorganization, the environmental staff reported to the Director of the Administrative Division. The current organizational structure (D-EM-48) of APA has two divisions, Power and Administrative, reporting to the Administrator. The ES&H Branch is located within the Power Division. The Chiefs of the ES&H Branch and the Engineering and Technical Support Branch, along with the Eklutna and Snettisham Project Managers, report to the Director of the Power Division. The line organization within the Power Division at the Project level has designated environmental responsibilities to Environmental Coordinators as collateral duties. Within the Administrative Division there is no formal designee. All of the APA managers interviewed support, to varying degrees, the changing emphasis on environmental protection and compliance. However, fostering the commitment to environmental excellence, and the resetting of priorities to place ES&H issues ahead of production goals, has not been totally embraced at all levels within the organization. The organizational placement of the ES&H Branch within the Power Division results in the lack of ability to interact with the Administrative Division on 3-89 an equal basis. In addition, the ES&H Branch is not positioned to establish Administration-wide environmental policy and performance expectations, and lacks independent oversight authority to ensure the environmental regulations and issues are being addressed in all of the line organizations. It is APA’s position that the ES&H Branch Chief has direct access to the Administrator, although this is not formally documented. It is recognized that APA is an organization in transition. This is evidenced by recent organizational changes, as well as increased undertaking and initiatives in the areas of environmental protection and compliance. The situation is further complicated by the fact that APA and DOE are seeking "divestiture" legislation to authorize sale of Eklutna and Snettisham Power Projects and subsequent closeout of APA (D-EM-15). However commendable these recent efforts have been, and however tenuous the current organizational status is, the lack of a formalized independent environmental oversight function at APA is not consistent with current DOE expectations regarding ES&H responsibilities. The probable causal factors for this finding are the lack of policy implementation, in that DOE Orders and Secretarial Directives were not implemented; and risk, in that the organization has not assessed the risk associated with its organizational structure lacking an independent oversight function. . 3-90 EM/CF-5: Environmental Oversight of Alaska Power Administration Performance Objective: Secretary of Energy Notice (SEN)-6E-92, "Departmental Organization and Management Arrangements," states "PSO’s are accountable to me for their respective programs, including safety of the workers and the public, security, and environmental protection and compliance. They are to establish policies, program goals, and objectives for the administration/management of their program and its associated funding." DOE Order 5400.1, "General Environmental Protection Program," established the following areas of responsibilities for Program Senior Officials (PSOs): ° Provide clear and explicit delegations of authority and responsibilities for implementing DOE environmental protection programs; e Ensure that appropriate environmental requirements are included in program plans; e In consultation with the Office of the Assistant Secretary for Environment, Safety and Health (EH-1), provide environmental protection direction to field organizations consistent with Departmental Orders and policies; and ° Provide oversight and, as appropriate, verify field organization’s compliance with any environmental guidance provided by the PSOs. DOE Order 5482.1B, "Environment, Safety, and Health Appraisal Programs," establishes that it is the responsibilities of PSOs to "Perform reviews to confirm effective implementation of DOE ES&H requirements by program and field organizations. In the execution of this responsibility, maximum use should be made of the appraisals and other reviews performed by EH, including assuring recommendations made by EH are addressed in a responsive and timely manner." Finding: The Office of the Assistant Secretary for Conservation and Renewable Energy (CE) has provided limited guidance and direction to Alaska Power Administration (APA) on environmental protection and compliance programs, and has not provided effective oversight of APA environmental activities as required by SEN-6E-92 and DOE Orders 5400.1 and 5482.1B. Discussion: Within CE, the Facilities and Systems Coordination Division (CE-64) has line management responsibility for APA environment, safety, and health (ES&H) performance. CE-64 has not provided the guidance, direction, and oversight as required by established DOE directives. Specific concerns with respect to CE oversight of APA include: ° At the time of the Audit, CE-64 was unaware of the status of APA environmental protection programs (I-EM-2 and I-EM-21). DOE Orders 5400.1 and 5482.1B require PSO oversight of their subordinate office’s environmental performance. As discussed extensively throughout this report, formalized APA environmental protection programs, as required by DOE Orders, have not been established. 3-91 ° CE-64 has not conducted reviews of the performance of APA environmental programs as required by DOE Order 5482.1B or made the maximum use of reviews of other Power Marketing Administrations (PMAs) performed by the Office of the Assistant Secretary for Environment, Safety and Health (EH) (I-EM-2). CE-64 has not had any onsite field presence at APA Headquarters and field facilities (I-EM-2). Transfer of lessons learned by other PMAs from environmental audits conducted by EH could have significantly aided APA environmental programs. e CE-64 has provided only limited formal environmental guidance and direction to APA. However, CE-64 has been active in processing and transmitting environmental initiatives from EH. e CE has not facilitated the transfer of environmental protection programs developed by other PMAs to APA (I-EM-2). A continuing challenge for all PMAs is the translation of the environmental requirements of DOE Orders into specific PMA environmental program requirements. e APA reporting of environmental information to CE is not specifically required, thus hampering CE’s ability to effectively monitor APA’s environmental performance (I-EM-2 and I-EM-9). CE-64 has concentrated its oversight activities where it believes its greatest potential for environmental risk exists: the National Renewable Energy Laboratory (NREL) and the Southwest Power Administration (Southwestern) (I-EM-2). The proposed divestiture of APA has lowered its priority within CE-64. However, without knowledge of APA facilities and activities (obtained through onsite presence and/or review of APA environmental reports) , Headquarters has made this prioritization without having a complete data base. CE-64 is in the process of supplementing its staff and has initiated onsite field reviews at Southwestern. Additionally, CE-64 is initiating the development of more formal systems for issuing and transmitting environmental guidance, and plans the development of a CE ES&H Manual (I-EM-21). The probable causal factors for this finding are lack of policy implementation, and allocation of resources within CE to conduct oversight of APA. 3-92 3.8.3 Best Management Practice Findings EM/BMPF-1: Environmental Protection Training Performance Objective: Best management practice suggests that there should be a program in place to ensure that all personnel, including temporary and contractor employees, have received appropriate environmental protection training. Finding: Alaska Power Administration (APA) has not developed formal standards for environmental protection training, or implemented-an environmental protection training program for all personnel including temporary and contractor employees. Discussion: A formal environmental protection training program should be in place to ensure that all personnel have received environmental protection training appropriate for their job responsibilities. An effective training program will provide a systematic management system to ensure necessary capabilities of the staff and organization are realized. Additionally, it will serve as an effective planning tool to effect the orderly acquisition of environmental skills, and provide for tracking of ongoing commitments for individual’s training versus accomplishments on an organization-wide basis. Toward this effort, discussions with APA Managers (I-EM-8) indicated that the development of comprehensive environmental protection program training requirements based on job classification is being considered. Interviews with APA management personnel (I-EM-4, 5, 7, 8, 9, 10, and 11), support staff (I-EM-14), and project staff with collateral environmental responsibilities (I-WM-11 and I-EM-6) revealed that additional general and job specific environmental protection training is needed. A programmatic training deficiency in the APA hazardous waste program has also been identified (see Finding WM/CF-5). i In addition to environmental protection training being part of a good management program, DOE Order 5482.1B, "Environment, Safety, and Health Appraisal Program," Paragraph 10.e, includes training as one of the generic factors to be considered and applied to all levels of an environmental appraisal program. The Order requires that the adequacy and extent of training, promotion, and education in environmental areas for both environmental staff and operating personnel be formally evaluated as part of the appraisal. The probable causal factors for this finding are a lack of policy, in that APA has no policy for an environmental protection training program; risk, in that APA personnel have not totally assessed the risks associated with the lack of environmental protection training; and supervision, in that there are inadequate APA supervisory controls to ensure necessary management systems are in place. 3-93 EM/BMPF-2: Environmental Compliance Management System Performance Objective: Best management practice suggests that a formal reporting system for environmental protection program assessments designed to document, communicate, and track findings and corrective actions be in place. Such a system would provide management with objective, timely, and reliable information on environmental performance, including significant achievements and deficiencies. Finding: Alaska Power Administration (APA) has not fully implemented a formal reporting system for its environmental protection program assessments to document, communicate, and track findings and corrective actions. Discussion: APA issued DOE Order 5400.3, APA Supplement 1, "APA Hazardous Waste Program" (D-EM-32), on May 1, 1992. This was implemented effective August 1, 1992. The APA Order implements DOE Order 5400.3, "Hazardous and Radioactive Mixed Waste Program," to ensure that APA operations are environmentally sound and in compliance with relevant Federal, state, and DOE regulations. To complement the APA Order, "Concurrence and Implementation of Hazardous Waste Program Procedures" (D-EM-30), were issued on June 5, 1992. In implementing these procedures, the Project Environmental Coordinators conduct weekly hazardous waste storage area inspections and monthly hazardous material storage area inspections. These reports are to be reviewed by management and maintained in the project file. Although these reports are being submitted to the ES&H Branch, discussions indicated that the initial weekly hazardous waste storage area inspection reports were not being submitted to the project managers for review (I-EM-6 and I-EM-18). Corrective actions associated with significant concerns (i.e., those that cannot be closed-out within 1 to 3 weeks, or require more than the Project Manager’s authorization) are required to be tracked on an ES&H Corrective Action Form. Concerns noted on the weekly and monthly inspection forms are to be closed-out on the form. Corrective actions for concerns noted on the weekly and monthly inspections are recorded to be tracked by ES&H on the inspection form. Because of the recent implementation of this program, ES&H has no historical records. To date, requirements and guidelines for the reporting of findings and corrective actions, for areas other than hazardous materials and wastes, in the APA’s environmental program have not been addressed. The probable causal factors for this finding are inadequate design of the current system, in that the current system would exclude Many environmental concerns; and the lack of formal procedures to facilitate Management review of inspection reports. 3-94 APPENDIX A NAME: APPENDIX A: BIOGRAPHICAL SKETCHES OF THE ENVIRONMENTAL AUDIT TEAM Barry R. Clark AREA OF RESP: Team Leader ASSOCIATION: EXPERIENCE: U.S. Department of Energy 16 Years ° U.S. Department of Energy, Office of Environmental Audit (EH-24) Environmental Protection Specialist/Environmental Team Leader. Principal responsibilities include leading multi-disciplinary teams of professionals in performing environmental assessments and audits. Tiger Team Training at Savannah River Operations Office was followed by assignment to the Environmental Subteam of the Sandia National Laboratories, Albuquerque Tiger Team Assessment. Served as Team Leader for the Comprehensive Baseline Environmental Audit of the Uranium Mill Tailings Remedial Action (UMTRA) Program at Rifle, Gunnison, ‘and Grand Junction Colorado, and the Line Program Environmental Management Audit of Bonneville Power Administration in Portland, Oregon. Also served as Environmental Subteam Leader of the Tiger Team Assessment of the Naval Petroleum Reserves in California, the Y-12 Progress Assessment in Oak Ridge, Tennessee, and the Baseline Audit of selected Fossil Energy Sites in Wyoming. Current assignments include Team Leader responsibilities for the Environmental Audit of the Alaska Power Administration. ° U.S. Department of the Interior, U.S. Geological Survey and Minerals Management Service Marine Biologist/Fisheries Biologist/Environmental Protection Specialist. Focus of responsibilities was completion of environmental monitoring and compliance inspection of offshore oil and gas operations. Areas of expertise included water quality, marine biology, endangered species, drilling effluents, oi] spills, and compliance with the National Environmental Policy Act. e Environmental Consultant EDUCATION: Research Associate. Investigated the environmental effects of nuclear and fossil fuel power plants on the aquatic environment of the Great Lakes. Major fields of research included commercial and recreational fisheries, benthos, and water quality. Specialized in monitoring, research, and compliance with licensing requirements of the Nuclear Regulatory Commission. M.A., Biology/Aquatic Ecology, State University of New York (SUNY) at Buffalo B.A., Biology (Geology Minor), SUNY at Buffalo A-1 NAME: William A. Eckroade AREA OF RESP: Deputy Team Leader ASSOCIATION: EXPERIENCE: U.S. Department of Energy 5 Years e U.S. Department of Energy, Office of Environmental Audit Environmental Engineer under the direction of the Environmental Subteam Leader, provides guidance, direction and assistance to a multidisciplined group of professionals performing Environmental Audits, Tiger Team Assessments, and ES&H Progress Assessments at DOE facilities. Served as the Deputy Team Leader for the Maywood, New Jersey, FUSRAP Site Environmental Audit, the Energy Technology Engineering Center Tiger Team Assessment, the Grand Junction Environmental Audit, the Bonneville Power Administration Line Program Environmental Management Audit, and the Ames Laboratory Tiger Team Assessment. Served as Team Leader for the Western Area Power Administration Line Program Environmental Management Audit. Technical specialist for the ES&H Progress Assessment of the Hanford Site responsible for the conduct of a programmatic assessment of Hanford’s Environmental Restoration Program. e U.S. Department of Energy, Office of Environmental Comp] iance e U.S. E Enforce EDUCATION: Environmental Engineer responsible for conducting independent oversight of Environmental Compliance activities at the Savannah River Site. nvironmental Protection Agency, Office of Waste Programs ement Environmental Engineer responsible for providing assistance in technical case development to assigned EPA regional offices. Additionally, responsible for conducting oversight of regional activities involving activities at enforcement lead Superfund sites. > Civil Engineering, University of Maryland M.S. B.S., Geophysics, Virginia Polytechnic Institute NAME: Susan Barisas AREA OF RESP: Technical Coordinator ASSOCIATION: Argonne National Laboratory EXPERIENCE: 15 Years ° Argonne National Laboratory - Participant in the Tiger Team Assessments of Savannah River Site and Lawrence Berkeley Laboratory and Environmental Audits at the Environmental Measurements Laboratory, Southwestern Area Power Administration, Uranium Tailings Remedial Action Project, and the Component Development and Integration Facility sites. Provided technical assistance to the DOE in the development and execution of environmental survey and audit programs. Principal responsibilities include conducting environmental surveys at eight major DOE operating facilities, evaluating audit and appraisal procedures used by the DOE and private industry, and developing guidance manuals to be used by DOE facilities and field organizations. _ Worked on various projects related to hazardous waste materials management. Responsibilities included developing hazardous waste and materials management plans, evaluating applicability of treatment and disposal options for synthetic fuels facilities, evaluating technologies for the treatment and disposal of PCB waste, and assessing the environmental impacts of alternative energy scenarios. ° Iowa Natural Resources Council _ Developed task force reports on Water for Energy Production, Water for Commercial and Recreational Navigation, and Water quality for a State Comprehensive Water Plan. Aided in the development of a public participation program. EDUCATION: M.S., Water Resources/Agricultural Engineering, Iowa State University B.A., Biology, Grinnell College NAME: Lynne Day AREA OF RESP: Administrator ASSOCIATION: EXPERIENCE: ° META, META, Inc. 16 Years Inc. Information Management Specialist. Provides administrative support for Environmental Audits; Environment, Safety and Health (ES&H) Progress Assessments; and the Environmental Subteam on DOE Tiger Team Assessments. Participant in Environmental Audits of the Component Development and Integration Facility, Environmental Measurements Laboratory, and Alaska Power Administration. Participant in the ES&H Progress Assessments of the Fernald Environmental Management Project and Hanford Site. Participant in Tiger Team Assessments of the Solar Energy and Research Institute, Los Alamos National Laboratories, Strategic Petroleum Reserves, and Naval Petroleum Oi] Shale Reserves. Provided support for production of the Progress Assessment Guidance Manual and attended Progress Assessment Training Program. ° INNOVA Communications, Inc. Office Administrator. Provided system and documentation support for a local and wide area network integration firm. Worked on office automation systems configuration analysis project providing technical writing and project management support. Responsible for development of instruction materials, graphics support, manuals, and vendor documentation. Prepared proposals, presentations, graphics, and technical drawings. Compiled and prepared statistical data for price quotations, cost proposals, and for use in analysis and reporting. e Sandler & Greenblum EDUCATION: Word Processing Departmental Manager. Developed and coordinated activities related to the word processing department for law firm specializing in patent/trademark law. Responsible for supervision and staffing of word processing department and hardware and software procurement and installations. Identified and resolved problems, and repaired and replaced malfunctioning hardware components. Performed database management functions. A.A., Computer Science, Strayer College, Arlington, VA A-4 NAME: David A. Dolak AREA OF RESP: Surface Water/Drinking Water and Toxic and Chemical Materials ASSOCIATION: Argonne National Laboratory EXPERIENCE: 11 Years e Argonne National Laboratory Environmental Consultant. Participated in the Tiger Team Assessment of Lawrence Berkeley Laboratory and environmental audits at the Southwestern Area Power Administration, Uranium Mill Tailings Remedial Action Project, the Component Development and Integration Facility, and the Environmental Measurements Laboratory sites. Participated in numerous environmental audits of Air Force Bases under the USAF, Environmental Assessment and Compliance Management Protocol program. ° Versar, Inc. Prepared remedial investigation/feasibility studies for Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Resource Conservation and Recovery Act (RCRA) sites, and prepared environmental permits to comply with the Clean Water Act, Clean Air Act, and RCRA regulations. Performed environmental insurance audits at industrial facilities to assess the sites’ potential for financial liability due to chemical contamination, CERCLA responsibility, noncompliance with RCRA, or violation of Superfund Amendments and Reauthorization Act (SARA) Title III reporting requirements. Assisted various clients in preparing documents for hazardous materials reporting under SARA Section 311, 312, and 313, including data base development for Form R submissions. Lead investigator in the allocation of liability costs to 30 individual parties responsible for toxic contamination at a Superfund site. Project Manager for the assessment and removal of hazardous materials at a large abandoned industrial site near Cleveland, Ohio. e United States Steel Corporation; Seaway Laboratories EDUCATION: Analytical Chemist. Diverse background in wet chemical methods and instrument analysis of environmental media. M.S., Environmental Science, Water Chemistry, Indiana University B.S., Environmental Science, St. Joseph’s College A-5 Ron Kolpa AREA OF RESP: Air and Inactive Waste Sites ASSOCIATION: Argonne National Laboratory EXPERIENCE: 19 Years e Argonne National Laboratory Staff Scientist, Environmental Research Division. Principal responsibilities include CERCLA preliminary assessments and site investigations for the DOE, Department of Defense, Department of Commerce, and Army National Guard. Mr. Kolpa has also served as the project manager for property assessments required on Army Properties as a result of the Base Closure and Realignment Act, and as Team Leader for site characterizations of Army National Guard properties throughout the United States. Participated in the Tiger Team Assessment of Lawrence Berkeley Laboratory, environmental audits of the Southwestern Area Power Administration, Uranium Mil] Tailings Remedial Action Project, the Component Development and Integration Facility, and the Environmental Measurements Laboratory, and participation in Environmental Compliance and Management Plan (Audits) at Department of the Air Force bases under the control of Air Force Space Command. Participated in DOE’s development and evaluation of mixed waste management protocols for DOE installations. In addition, Mr. Kolpa serves on the Environmental Research Division’s Environment, Safety, and Health Committee and serves as the Environmental Compliance Representative for the Environmental Research Division and is responsible for regulatory assessments for the Division’s field investigation efforts. ° Towa Department of Natural Resources EDUCATION: Prior environmental experience includes over 14 years as technical program specialist and Environmental Program Supervisor for regulatory programs in air, solid waste, and hazardous waste for the State of Iowa. Included during this period was a 2-year detail to the U. S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, DC, where his responsibilities included the development of Federal and state implementation strategies for hazardous waste programs developed under CERCLA and RCRA authorities. M.S., Inorganic Chemistry, Iowa State University B.S., Chemistry, St. Procopius College A-6 NAME: Peter C. Lindah] AREA OF RESP: Environmental Management and Quality Assurance ASSOCIATION: EXPERIENCE: Argonne National Laboratory 20 Years Argonne National Laboratory Exxon Group Leader. Principal responsibilities include supervision of environmental analysis group. Currently is a detailee to DOE’s Office of Environmental Restoration and Waste Management in the Technology Development’s Laboratory Management Division. Served as analytical laboratory project manager for the DOE Environmental Survey Program and as task manager for the development of gas analysis methods and associated quality assurance requirements for the DOE Waste Isolation Pilot Plant Pretest Waste Characterization Program. Also, participated in the DOE Tiger Team Assessments of Savannah River Site and Lawrence Berkeley Laboratory, and environmental audits of the Southwestern Area Power Administration, Uranium Mill Tailings Remedial Action Project, the Component Development and Integration Facility, Environmental Measurements Laboratory, and Alaska Power Administration. Production Research Company Senior Research Specialist. Responsible for supervision of inorganic analytical chemistry laboratory in support of coal, oi] shale, and hydrothermal research projects and work in a research analytical chemistry laboratory to develop analysis methods for determining trace elements in coal. Perkin-Elmer Corporation EDUCATION: Senior Product Specialist. Responsible for atomic absorption spectrophotometry and analytical technical support. Ph.D., Analytical Chemistry, Southern I]linois University M.A., Inorganic Chemistry, Southern I]linois University B.A., Chemistry, Lake Forest College A-7 NAME: Karen P. Smith AREA OF RESP: Waste Management and Groundwater ASSOCIATION: Argonne National Laboratory EXPERIENCE: 8 Years ° Argonne National Laboratory Assistant Environmental Systems Engineer responsible for conducting environmental compliance audits at Department of Defense (DOD) and Department of Energy (DOE) facilities with respect to management of solid waste, hazardous waste, hazardous materials, petroleum products, and asbestos. Provides technical assistance to hazardous waste site investigations at DOE, DOD, and Department of Commerce facilities. Specific responsibilities include conducting background studies of the geologic and hydrologic conditions at a site, selecting and participating in sampling procedures, determining potential contaminant migration pathways and receptors, and preparing final reports. : Provides technical analyses of environmental regulations and policies addressing waste management in the energy industry to support policy development activities at DOE. e Sun Exploration and Production Company EDUCATION: Geologist responsible for the generation of economically viable oil and gas prospects and for the development and extension of productive oi] and gas properties. Work entailed analyses of subsurface fluid flow and hydrocarbon generation based on data derived from electric well logs, seismic surveys, and subsurface formation samples. M.S., Geology, Southern Methodist University B.S., Anthropology, Southern Methodist University B.A., Geology, Southern Methodist University APPENDIX B APPENDIX B: PLAN FOR THE DOE ENVIRONMENTAL AUDIT OF THE ALASKA POWER ADMINISTRATION JUNEAU, ALASKA August - September, 1992 1.0 INTRODUCTION On June 27, 1989, Secretary of Energy Watkins announced a 10-point Initiative to strengthen environmental protection and waste Management activities in the Department of Energy (DOE). One of the initiatives involves conducting Environmental Assessments at DOE’s operating facilities. The purpose of the Environmental Audit of the Alaska Power Administration (APA) is to provide the Secretary with information on the current environmental regulatory compliance status and associated vulnerabilities, root causes for noncompliance, adequacy of environmental Management programs, and response actions to address the identified problem areas. The scope of the APA Environmental Audit is comprehensive, covering all environmental media and relevant Federal, state, and local regulations, requirements, and best management practices. The environmental disciplines to be addressed in this Audit include air, soil, surface water, drinking water, groundwater, waste management, toxic and chemical materials, quality assurance, and inactive waste sites. The Audit also addresses the performance of environmental management functions. 2.0 ENVIRONMENTAL AUDIT IMPLEMENTATION The Environmental Audit of APA will be conducted by a team managed by a Team Leader and a Deputy Team Leader from the DOE’s Office of Environmental Audit (EH-24) and technical specialists from Argonne National Laboratory (ANL). The names and responsibilities are listed below: Barry Clark DOE Team Leader Bill Eckroade DOE Deputy Team Leader Susan Barisas ANL Technical Coordinator Ron Kolpa ANL Inactive Waste Sites and Releases/Air Dave Dolak ANL Surface Water/Drinking Water/Toxic and Chemical Materials Karen Smith ANL Waste Management/Groundwater Peter Lindah] ANL Environmental Management/Quality Assurance Lynne Day META Administrative Support B-1 2.1 PRE-AUDIT ACTIVITIES Pre-Audit activities for the APA Environmental Audit included the issuance of an introduction and information request memorandum, a pre-Audit Site visit, and initial review of documentation which was sent to the Audit Team by APA as a result of the information request memorandum. A pre-Audit Site visit was conducted on June 23 to 25, 1991 by the DOE Team Leader, Deputy Team Leader, and the ANL Technical Coordinator. The purpose of the pre-Audit visit was to become familiar with the site, to review information being supplied and request additional information, and to coordinate plans for the upcoming Audit with APA personnel. This Environmental Audit Plan is based upon the information received by the Environmental Team as of July 31, 1992. 2.2 ONSITE ACTIVITIES AND REPORTS The onsite activities for the Environmental Audit will take place from August 24 to September 11, 1992. Onsite activities will include field inspections, file/record reviews, and interviews with site personnel and regulatory personnel. The preliminary schedule for the Audit is shown in the attached agenda. The agenda will be modified as needed during the early part of the onsite Environmental Audit. Any and all modifications to the agenda will be coordinated with the principle contacts from APA. A daily debriefing with APA personnel will be held each afternoon at which time team specialists will describe their activities and identify issues that may develop into findings. A closeout briefing will be conducted at the conclusion of the onsite activities. Findings from the Environmental Audit will be presented during that briefing. The date provided in the schedule for the closeout briefing is tentative and will be finalized during the Audit. A draft report containing the results of the Audit will be provided to APA, the Office of the Assistant Secretary for Conservation and Renewable Energy (CE), and the Washington, D.C. Liaison Office - Alaska, Southeastern & Southwestern Power Administrations (WDC) for their review and comment. 3.0 AIR 3.1 ISSUE IDENTIFICATION The Environmental Audit activities related to air issues involve an assessment of facility-wide air emissions, emission control and emission monitoring procedures and equipment, and acquisition and processing of ambient air quality data, where appropriate. Areas of particular interest are the process emissions of particulates, organic vapors, inorganic compounds, and air toxics. Operational and procedural practices associated with emission control equipment will be evaluated. Compliance with the local air authority’s regulations, State of Alaska regulations, National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements, and DOE Order requirements will also be assessed. B-2 The general approach to the compliance assessment will involve a review of existing air permits, operating procedures, operating records and other relevant documents which identify sources of air emissions and demonstrate APA’s compliance status with respect to requirements. Following document review, a physical inspection of processes or operations, and emissions control and monitoring equipment will be accomplished along with interviews of site staff and managers. 3.2 RECORDS REQUIRED Documents and files to be reviewed during the Audit include, but will not be limited to, the following: e° Air permits; ° Source and source emission inventories; e Environmental monitoring reports; e Reports on accidental releases of airborne substances; ° Operating and testing/maintenance procedures for control equipment; e Air related correspondence with regulatory agencies including waivers or interpretations of air regulation applicability; and e Monitoring/sampling program documentation. 4.0 SURFACE WATER/DRINKING WATER 4.1 ISSUE IDENTIFICATION The focus of the surface water/drinking water portion of the Environmental Audit will be on the release of contaminated or polluted wastewaters to the sanitary, storm sewers, and septic systems, surface waters, or groundwater aquifers underlying the site. The Audit will review the potential for contamination of wastewaters by metals and organics (especially solvents, oils, fuels, and polychlorinated biphenyls (PCBs), and review the present conditions of wastewater collection, treatment, and discharge. Liquid waste treatment, collection and discharge equipment will be examined and records of operation will be reviewed. The Audit will review current discharge permits or agreements. It will also include a review of any dredge and fill permits granted under Section 401 of the Clean Water Act and onsite inspection of any fill material placed in potential wetland areas. A review of State of Alaska agreements regarding surface water runoff or discharge control measures will be undertaken. The Audit will also review drinking water distribution systems at APA to determine compliance with regulations under the Safe Drinking Water Act (SDWA) for delivery of safe drinking water to employees and/or the public. The Audit will include identification of discharges (e.g., overland stormwater runoff) to surface waters, or to the sanitary sewer system, which may not be addressed in operating permits or other documents. A walk-through of APA B-3 facilities will be made to observe normal runoff containment practices. Spill prevention provisions for fuels and hazardous material storage areas will be reviewed, along with APA’s procedures for reporting spills. 4.2 RECORDS REQUIRED Specific documents and files to be reviewed as part of the assessment include, but will not be limited to, the following: ° Sampling and analytical plans and/or data; e Correspondence with state or local regulatory agencies regarding wastewater, drinking water or stormwater runoff controls and requirements; ° Standard operating procedures (SOPs) for wastewater or stormwater collection, holding, and discharge; e Drawings of sanitary, storm sewer, and septic systems; ° Plans or diagrams showing where building floor drains discharge; ° Records of drinking water quality; e Procedures for collecting samples of drinking water and wastewater; ° Maintenance and inspection records for the drinking water system, including water tanks and cross connection/backflow prevention procedures; ° Spill Prevention, Control and Countermeasure (SPCC) plan and records inspection; e Internal memos or correspondence relating to surface water/drinking water problems; and e Other records as determined onsite. 5.0 GROUNDWATER 5.1 ISSUE IDENTIFICATION The groundwater portion of the Environmental Audit will involve the evaluation of both the programmatic and technical status of groundwater protection and monitoring as they relate to regulations, best Management practices, and DOE Orders. Included will be Alaska regulations pertaining to water resources and regulations developed by the U.S. Environmental Protection Agency as part of the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) programs. An evaluation of previous studies of the site hydrogeology, determination of the status of ongoing studies and site investigation will be included in the Audit. The adequacy of existing monitoring and characterization efforts will be determined by comparison to existing regulations, DOE Orders, and best B-4 management practices. In addition to a document review, visits will be made to areas of interest to observe field conditions. Interviews will be held with site personnel who have responsibilities for groundwater protection and remedial action. 5.2 RECORDS REQUIRED Documents and records to be reviewed as part of the Audit include, but are not limited to, the following: ° Data/maps concerning subsurface geology and hydrology; e Groundwater Protection Management Plan documents or guidance; e Recent chemical analytical data for soil and groundwater samples; ° Well construction as-built diagrams and well/boring locations; ° Well abandonment procedures and permits; and ° Any additional hydrogeologic or geologic investigation reports. 6.0 WASTE MANAGEMENT 6.1 ISSUE IDENTIFICATION The waste management portion of the Environmental Audit will address the generation and management of solid and hazardous wastes, including accumulation, labeling, characterization, transportation and disposal, with regards to DOE Orders, state and Federal regulations and best management practices. In addition, this portion of the Audit will evaluate APA’s compliance with Underground Storage Tank Regulations. Management of all waste streams will be reviewed. Specific issues that will be investigated include, but are not limited to: ° Status of waste generated and characterization of wastes disposed with respect to the Land Disposal Restriction (LDR), and Toxicity Characteristic Leaching Procedure (TCLP) Requirements; ° Status of onsite hazardous waste generation points (e.g., location, waste type, quantities) ; ° Manifesting and tracking of wastes; ° Satellite accumulation and storage areas; ° Solid waste accumulation, collection, treatment, and disposal; e Waste minimization plans for solid and hazardous wastes; ° Resource recovery activities; B-5 ° Training of hazardous waste generators; and ° Underground storage tanks (USTs). 6.2 RECORDS REQUIRED Specific documents and files to be reviewed as part of the Audit include, but will not be limited to, the following: ° Written policies and procedures relating to waste management activities including waste management plans, waste minimization plans, internal procedures, and other guidance documents; ° Waste generation and characterization documentation; e Waste storage, treatment, and disposal records; e Regulatory permits, permit applications, exclusions, or waivers related to waste management activities; e Emergency spill response and cleanup procedures; ° Underground storage tank notification and associated records; ° Any inspection reports or notices of violation from the State or Environmental Protection Agency (EPA) with regard to hazardous waste management activities; e Any internal audits or assessments of APA’s solid and hazardous waste management program; and ° Environmental training records. 7.0 TOXIC AND CHEMICAL MATERIALS 7.1 ISSUE IDENTIFICATION The toxic and chemical substances portion of the Environmental Audit will address the management and use of raw materials and chemical materials with reference to their handling, storage, and disposal. Primary emphasis will be given to the substances such as PCB’s, asbestos, and chlorofluorocarbons regulated by the Toxic Substances Control] Act (TSCA), and pesticides regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Storage vessels used for chemicals and fuels, especially tanks and drum storage and dispensing facilities, will also be included in the assessment. Information obtained will be evaluated to assess whether the Management and control of toxic and chemical substances complies with Federal, state, and local regulations and pertinent DOE Orders. The management of electrical and hydraulic equipment which contains or has contained PCBs or PCB-contaminated fluids will be reviewed during the Audit. Records concerning PCBs will be reviewed including PCB annual reports, records of offsite shipments and disposal, spill reports, and procedures for the analysis, identification, handling and removal of PCB-containing materials. B-6 The purchasing procedures and usage records for toxic and hazardous materials (including oi1) will be viewed. Areas where these materials are stored and used will be inspected and handling procedures evaluated. Uses of pesticides (i.e., herbicides, insecticides, and rodenticides) to control weeds, for wood preservation, and rodent control will be reviewed. If activities are conducted by subcontractors, contractor records and facility oversight will be evaluated. Chemical, oi] and/or fuel storage tanks, drums and cabinets will be inspected during this Audit. The management and handling of these materials to prevent or minimize releases to the environment will be evaluated. 7.2 RECORDS REQUIRED Specific documents and files to be reviewed as part of the Audit include, but will not be limited to, the following: e Toxic substances labeling and tracking system; e Procedures for procurement, handling, control, use, and Management of toxic substances; ° PCB handling, storage, and disposal procedures and documentation; e Pesticide purchasing, training, handling, storage, and disposal records; ° Special procedures involving handling, storage, use, and disposal of chlorofluoroalkanes (freons) and chloro-organic solvents; ° Spill control and emergency preparedness plans (e.g. SPCC plan) for aboveground storage tanks; and e Audits or inspection reports pertaining to the toxic substances program. 8.0 QUALITY ASSURANCE 8.1 ISSUE IDENTIFICATION The quality assurance (QA) portion of the Environmental Audit will evaluate current sampling and analysis procedures performed at APA. Data from laboratories conducting analyses on APA environmental samples will be audited to ensure that they are generating scientifically valid and defensible data. In addition to QA for environmental monitoring, the QA programs for al] environmental functions will be reviewed. Specific issues that will be addressed include sampling and analysis procedures for environmental samples; laboratory procedures; oversight of contractor laboratories; personnel training; and chain of custody procedures. In addition, the QA programs for environmental programs will be evaluated including documentation of past audits or assessments performed by APA; followup activities; a determination of the effectiveness of the QA program; and a review of the extent of interaction between APA and other DOE elements. B-7 8.2 RECORDS REQUIRED Part of the Audit will consist of a review of pertinent documents and files. This will include documents not previously reviewed or received, individual files, and documents which have not been identified at this time. Some specific documents and files to be reviewed include, but will not be limited to, the following: ° QA plans for any supporting analytical laboratories; ° Environmental sampling, analysis, and sample disposal procedures used by APA contractor(s); e QA audits by APA and subcontractor(s) conducting environmental sampling and analysis; ° QA plans, manuals, and implementing procedures for any environmental surveillance programs; e Summaries of results of QA sample analysis (conducted by supporting analytical laboratories) of external performance evaluation samples; ° Procedures and QA requirements for acceptance of offsite sampling and analysis subcontractor(s); ° Data validation procedures used for the APA environmental protection programs; and ° Other records as determined on site. 9.0 INACTIVE WASTE SITES 9.1 ISSUE IDENTIFICATION The inactive waste site portion of the Environmental Audit will assess the compliance status of the facilities relative to the identification of past disposal sites and the identification and location of spills/releases of hazardous materials or wastes. The compliance evaluation will be made based on requirements specified in CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA); the National Contingency Plan (NCP); the Natural Resource Trusteeship under CERCLA; the corrective action provisions of RCRA, as amended by the Hazardous and Solid Waste Amendments (HSWA) of 1984; the Emergency Planning and Community Right-to-Know Act (EPCRA) under Title III of SARA; and various DOE Orders, including DOE Order 5400.4 for CERCLA compliance requirements and Executive Order 12580 (Superfund Implementation) . The general approach to the inactive waste sites portion of the Environmental Audit will be to evaluate the procedures for identification of inactive waste sites or past spill/release sites, and how such sites were Managed once identified. Of particular concern will be past spills/releases/disposal of chemical materials, including solvents, PCB oils, and petroleum products, in excess of reportable quantities. In addition, there will be efforts to ascertain the quantities of hazardous materials in use and any corresponding B-8 requirements for public reporting (i.e., SARA Title III) based on the materials and quantities present. This portion of the Audit will also identify unique or particularly sensitive environmental factors present at any of the APA sites and identify best management practices for avoidance of adverse impacts to those sensitive environmental areas identified. 9.2 RECORDS REQUIRED Because the main focus of the inactive waste sites portion of the Environmental Audit is on past practices or events, the Audit effort will focus on record review and personnel interviews, supplemented by first-hand observations of known or potential spill/release/disposal sites. The types of records to be reviewed will include, but are not limited to: ° Any permits or compliance agreements addressing past practices; ° Previous environmental audit or inspection reports from outside agencies or internal efforts; e Preliminary Assessment (PA) and/or Site Inspection (SI) reports conducted under CERCLA authority; e Historical site maps and aerial photos (including transmission line rights of way); ° Work plans or sampling plans for current or planned investigative activities; e Environmental Protection Implementation Plans; ° Notifications or Emergency Planning submittal to local public authorities; e Real property and site development planning records associated with environmental assessment; and ° Agreements with utilities who have equipment on APA property or in APA controlled areas that relate to maintenance, spill response, clean up actions and removal. 10.0 ENVIRONMENTAL MANAGEMENT 10.1 ISSUE IDENTIFICATION The environmental management portion of the Environmental Audit will include an assessment of the overall policies and procedures implemented to ensure conformance with Federal, state, and local statutes and regulations, DOE Orders, and Secretary of Energy Notices (SENs). The principal focus will be to assess if there is a sufficient management understanding and oversight of environmental protection programs, and an effective communication of these programs to managers and staff. Management practices will also be reviewed against commonly accepted best industry practices. Quality assurance B-9 oversight of the environmental compliance process is a critical element of environmental management and will also be evaluated as part of this Audit. The general approach to the Audit will include reviews of APA’s environmental protection program, policies, and procedures documentation and interviews with personnel at APA who are responsible for implementation of environmental protection programs. The environmental management portion of the Audit will concentrate on the organizational and procedural arrangements by which all regulations, DOE Orders, SENs and best Management practices are implemented. Of particular interest will be determining if formal arrangements are in place to comply with the above and if these formal arrangements are part of routine operations. Also of interest will be any interagency relationships that determine/oversee or facilitate compliance. Specific areas of interest will be the effectiveness of Management: (1) in meeting the intent of DOE environmental policies; (2) in translating the DOE policies into a useable implementation program; (3) in communicating the environmental protection program to the staff; and (4) in establishing a reasonable oversight program (both at APA and in CE Headquarters) to ensure the staff, DOE consultants, and contractors are satisfying the program objectives. 10.2 RECORDS REQUIRED Records to be reviewed include, but are not limited to: ° Environmental Protection Implementation Programs ; ° APA Environmental Policies and internal documents; ° Environmental compliance audit reports; e Internal documents relative to audit findings; e Long Range Environmental Plan; e Self-Appraisal Reports, internal appraisals, and corrective action plans; e Standards for the preparation, review, approval, maintenance, and control of environmental compliance procedures and documents; ° Position descriptions/performance standards; e Environmental compliance program training; and ° Other records as determined on site. B-10 APPENDIX C T-3 APPENDIX C: ENVIRONMENTAL AUDIT TEAM SCHEDULE OF ONSITE ACTIVITIES Air/Inactive Waste | Orientation Site Visit Sites - Eklutna Power Site Visit - Snettisham Fly to Juneau Fly to Snettisham Document Review Site Visit Plant Site Visit Site Visit Preliminary - Eklutna Power ~ Reed Substation - Thane - Snettisham Fly to Juneau Findings Review Plant ~ Anchorage - Palmer Substation Substation Interviews Interviews Interviews - Project Manager, - Supv. Electronics | - Supv. Electronics Interviews Interviews Snettisham Technician Technician - Chief, ES&H - General ~ Student Trainee - Chief, ES&H - Chief, ES&H Branch Maintenance - Chief, ES&H Branch Branch - Area Power Worker/Env. Branch - Hydroelectric Manager, Eklutna Coordinator - Env. Protection Powerplant - Area Power Specialist Mechanic/Env. Manager, Eklutna Coordinator - Chief, ES&H Branch ~ General Maintenance Worker/Env. Coordinator Surface Water/ Orientation Site Visit Fly to Juneau Fly to Snettisham Site Visit Document Review Drinking Water/ - Eklutna Power - Snettisham Toxic Materials Site Visit Plant Site Visit Site Visit Preliminary - Eklutna Power ~ Reed Substation - Thane ~ Snettisham Fly to Juneau Findings Review Plant - Anchorage - Palmer Substation Substation Interviews Interviews Interviews - Project Manager, ~ Hydroelectric - Supervisory Interviews Interviews Snettisham Powerplant Electronics - Area Power - Area Power - Chief, ES&H Mechanic, Technician, Manager, Eklutna Manager, Eklutna Branch Snettisham/Env. Snettisham - Chief, ES&H - Chief, ES&H - Utility Worker, Coordinator - Project Manager Branch Branch Snettisham - Project Manager, Snettisham - Environmental ~ Power Plant Snetti sham Protection Operator - Supervisory Specialist - Supervisory Electronics - General Electronics Technician, Maintenance Technician Snetti sham Worker/Env. - Chief, ES&H Coordinator Branch Waste Management/ Groundwater Environmental Management / Quality Assurance ENVIRONMENTAL AUDIT TEAM SCHEDULE OF ONSITE ACTIVITIES (Continued) Orientation Site Visit - Eklutna Power Plant - Palmer Substation Interviews ~ General Maintenance Worker/Env. Coordinator Env. Protection Specialist Chief, ES&H Branch Area Power Manager, Eklutna Orientation Site Visit - Eklutna Power Plant - Palmer Substation Interviews - Environmental Protection Specialist Site Visit - Eklutna Power Plant - Reed Substation - Anchorage Substation Interviews - Area Power Manager, Eklutna Env. Protection Specialist Powerplant Operator, Eklutna General Maintenance Worker/Env. Coordinator Chief, ES&H Branch Supv. Electronics Technician Site Visit - Eklutna Power Plant - Reed Substation - Anchorage Substation Interviews - Area Power Manager, Eklutna - Supervisory Electronics Technician - General Maintenance Worker/Env. Coordinator Fly to Juneau Site Visit - Thane Interviews - Project Manager, Snettisham - Env. Protection Specialist Fly to Juneau Site Visit - Thane Fly to Snettisham Site Visit - Snettisham Interviews ~ Hydroelectric Powerplant Mechanic - Supv. Electronics Technician - Chief, ES&H Branch Write Findings Document Review Interviews - Director, Power Division - Director, Admin. Division - Administrator - Chief, Admin. Support Branch Site Visit - Snettisham Document Review Preliminary Fly to Juneau Findings Review Interviews - Supv. Electronics Technician - Chief, ES&H Branch - Env. Protection Specialist - Mechanic/Operator Write Findings Write Findings Document Review Document Review Interviews ~ Chief, Engr. and Technical Support Branch - Personnel Mgmt. Specialist - Director, Power Division - Contract Specialist Preliminary Findings Review €-9 Air/Inactive Waste Sites ENVIRONMENTAL AUDIT TEAM SCHEDULE OF ONSITE ACTIVITIES (Continued) Document Review Draft AIR and IWS AIR and IWS Factual Findings to Site Accuracy Reviews Write Findings for FAR (FAR) Interviews Document Review Report Preparation - ADEC, Solid Waste Mgmt. Program Write Findings Coordinator Write Overviews Incorporated FAR - ADEC, Env. Comments, as Specialist, Oi] Required Spill Prevention, Planning and Management - Chief, Engr. and Technical Support Branch Interview - Administrator Document Review Write Findings Surface Water/ Drinking Water/ Toxic Materials Interviews Followup Interviews | Document Review Write Findings Write Findings and Report - Student Trainee, Overview (SW) Preparation Power Division Document Review Write Findings Draft TCM Findings - Chief, Engr. & to Site for FAR TCM Factual Technical Support | Write Findings Write Overviews Accuracy Review Branch - Environmental Protection Specialist Draft SW Findings to Site for FAR Interview - ADEC Drinking Water Manager Document Review Write Findings SW Factual Accuracy Review Incorporated Comments into SW and TCM Sections, as Required Waste Management/ Groundwater Environmental Management / Quality Assurance ENVIRONMENTAL AUDIT TEAM SCHEDULE OF ONSITE ACTIVITIES (Continued) Followup Interviews - General Maintenance Worker/Env. Coordinator - Supv. Electronics Technician Interviews - ADEC Solid Waste Mgmt. Program Coordinator Document Review Write Findings Document Review Write Findings Interviews Assistant to the Administrator Division Assistant Environmental Protection Specialist Chief, Admin. Support Branch Followup Interviews Document Review Write Findings Document Review Write Findings Interviews - Project Manager, Snettisham - Director, Power Division - Environmental Protection Specialist Draft EM and QA Findings to Site for FAR Interviews - ADEC Regional Wastewater Program Manager ~ ADEC Leaking UST Program Manager Document Review Write Findings Write Overviews Write Overviews Draft EM and QA Overviews to Site for FAR Draft WM and GW Findings to Site for FAR WM and GW Factual Accuracy Reviews Incorporated Comments, as required EM and QA Factual Accuracy Reviews (FAR) Incorporated FAR Comments, as Required Report Preparation Interview - Staff, CE-64 Offsite Offsite APPENDIX D APPENDIX D: LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM ee 9/30/91 1/27/92 tice eer ee fae Gs mes mae = jf - D. Stokes R. Waldman, APA 3/10/92 All APA Offices/ 7/23/92 Projects eit _ 7 APA FY 1992 Annual Management Plan, Ist Quarter Update APA Annual Site Environmental Report for cy 1990 APA Site Environmental Report for CY 1989 Memorandum re: Approval of APA Order, DOE 5400.3 APA Supplement 1, APA Hazardous Waste Program Letter re: Solid Waste Disposal Permit #92110-BA003 (Port Snettisham Project) Project Descriptions (Snettisham and Eklutna Hydroelectric Projects) ES&H Corrective Action Form Policy, APA Environmental Statement re: General Environmental Policy Statement APA Annual Site Environmental Report for CY 1991 Memorandum re: Eklutna Environmental Inspection, 8/4/92 (and attached copy of Environmental Inspection) LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) 7/92 Multimedia Environmental Management Audit (FY R. Waldman Unknown 1992) for Snettisham Project Memorandum re: APA's Annual Waste Reduction R. Waldman R. Popino, CE-64 4/13/92 Report for CY 1991 (and attached report) J. Hancock, EM-352 Memorandum re: Water Test for Thane Substation |D. Low T. Spicher 2/21/89 and Water Analysis Report 7/28/92 Operations Manual for Snettisham Project Marine Unknown 0i1 Transfer Facility Draft Spill Prevention Control and : Unknown Unknown 7/28/92 Countermeasure Plan, Snettisham Powerplant, Fuel Storage Area Solid Waste Disposal Permit No. 9211-BA003 Jo. stokes = [aves 3/10/92 Project Descriptions (Snettisham and Eklutna Unknown Unknown Undated Hydroelectric Projects) 0-SW-6 Water Analyses, Inorganics, Thane Unknown Water Test 12/13/88 Corporation eer hives ictrilsinl we [inom | otomery abe Water Analyses, Bacteriological, Snettisham 4/10/90 Water Analyses, Inorganics, Snettisham Water Test 4/87 Corporation 2-d 4/10/90 Water Analyses, Bacteriological, Headquarters Montgomery Labs 6/91 APA DOE Stormwater Compliance N. Taimi SPCC Plan, Set Tohan Sowine | 6/18/92 D-SW-14 €-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) ome Water Treatment System, Snettisham Camp; Operations and Maintenance Manual for ih EA Contractor Snettisham Project D-SW-16 Water Treatment System, Thane Substation; Contractor Operations and Maintenance Manual for Snettisham Project O-SW-17 Unwatering and Drainage Map, Eklutna junknown | 0-SW-18 Plan and Water Hole Logs, Juneau Substation ——_— ne 2/7/55 6/71 = a SE Toilet Vent Line, Sewage Sump and CO,, | Powerhouse Map, Snettisham First Stage Development Map, Warehouse, 7/71 Snettisham Sewer Details Map, Juneau Substation Mechanical Sections and Details Map, Juneau Substation 0-SW-21 Water Details Map, Juneau Substation General Plan Map, Main Contract Camp Area, Snettisham Project, Drawing #1-SNE-96-04-01-03/1 Camp Facilities Site Plan, Legend 4, Soils Logs, Snettisham Project, Drawing #1-SNE-96-04-01-04 Submarine Cable Terminals, Mechanical Plan and Sections Map, Snettisham v-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Memorandum re: Hydrogeology of Projects U.S.G.S. Bulletin 1031-D, p. 71-102, "Geology of Waterpower Sites on Crater Lake, Long Lake and Spee] River near Juneau Alaska" J. Miller om Fuglestad T. H. Schmoll and R. Emanuel U.S.G.S. Water-Supply Paper 1494, “Geology and Groundwater Resources of the Matanuska Valley Agricultural Area Alaska” Division of Geologic and Geophysical Surveys Guidebook, Alaska Dept. of Natural Resources, Fairbanks, "The Alaska Railroad Between Anchorage and Fairbanks” U.S.G.S. Open File Report 83-479 (map), "Geologic Materials and Hydrogeologic Characteristics in the Fire Lakes - Eklutna Area, Anchorage, AK" Division of Geologic and Geophysical Surveys . Jokela et al. Report of Investigations 90-4, Alaska Dept. of Natural Resources, Fairbanks, "Ground-Water Resources of the Palmer - Big Lake Area, Alaska: A Conceptual Model” Plan and Water Hole Logs, Juneau Substation Unknown Camp Facilities Site Plan, Legend 4, Soils Logs, Snettisham Project, Drawing #1-SNE-96-04-01-04 First Stage Development Map, Warehouse, Snettisham | o-av-10 | APA Site Environmental Report for CY 1988 [unknown | APA Annual Site Environmental Report for cy 1990 APA Site Environmental Report for CY 1989 0-GW-13 APA Annual Site Environmental Report for CY 1991 s-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) re a PER st eos a S APA Site Environmental Report for CY 1988 Various Undated APA Annual Site Environmental Report for Unknown Various Undated cy 1990 T. Eade APA Various 5/1/92 [ TT i Ue aL 7/1/92 5/29/92 Herbicide Disposal Technical Spec (and Attached 7/19/89 Note to Hallum) Solid Waste Disposal Permit No. 9211-BA003 D. Stokes ADEC a 3/10/92 Plan for Disposal of Out-of-Service Unknown 6/11/92 Transformers Eklutna Underground Storage Tank Policy 7/1/92 7/1/92 (ES&H HW-06/0) OU ee Ea iad Liat Memorandum re: Approval of APA Order, DOE 5400.3 APA Supplement 1, APA Hazardous Waste Program Letter re: Solid Waste Disposal Permit 0. Stokes ADEC #92110-BA003 (Port Snettisham Project) List of Treatment, Storage, and Disposal Facilities Snettisham Hazardous Material Storage Area Monthly Inspections Form (ES&H HW-05/0) Snettisham Hazardous Waste Storage Area Weekly Unknown Inspection Form (ES&H HW-40/0) Eklutna Hazardous Material Storage Area Monthly Inspections Form (ES&H HW-03/0) Eklutna Hazardous Waste Storage Area Weekly Unknown Inspection Form (ES&H HW-02/0) 9-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) D-WM-17 Memorandum re: Concurrence and Implementation |T. Eade G. Hallum, M. Deihl, 6/5/92 of Hazardous Waste Program Procedures T. Wilde, R. Waldman Hazardous Waste Container Labeling and Marking 7/1/92 (ES&H HW-01/0) D-WM-19 DOE Order 5400.3, APA Supplement 1 re: APA All APA Offices/ 8/1/92 Hazardous Waste Program Projects D-WM-20 APA Annual Site Environmental Report for CY Undated 1991 APA Eklutna Project Underground Storage Tank J. Shepherd New Horizons Telecom, 6/25/92 Closure Site Assessment Inc. D-WM-22 Notification for Underground Storage Tanks for 4/29/86 Eklutna Project D-WM-23 Notification for Underground Storage Tanks for 4/29/86 Snettisham Project Memorandum re: Eklutna Environmental T. Eade T. Wilde 8/17/92 Inspection, 8/4/92 (and attached copy of Environmental Inspection) Used 011 Service Agreement (and Addendum), E. Polley Solid Waste 8/21/92 Effective 1/1/92 through 12/31/92 Solutions, Inc. Uniform Hazardous Waste Manifest Form, R. Senkovich/ Gumption Freight M. Pittman, APA 7/22/92 Snettisham Project, re: Used Battery, Waste J. Davenport 011, and Waste Petroleum D-WM-28 Uniform Hazardous Waste Manifest Form, Gumption Freight W. Dohrn, APA 7/28/92 Snettisham Project, re: Used Battery D-WM-29 Snettisham Hazardous Waste Monthly Generation M. Pittman 6/30/92 and Logs 7/28/92 Snettisham Hazardous Material Storage Area M. Pittman 7/28/92 Monthly Inspections L-d D-WM-32 Snettisham Hazardous Waste Storage Area Weekly Inspection LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Unknown 7/11/92 Snettisham Hazardous Waste Storage Area Weekly M. Pittman Inspection Snettisham Hazardous Material Storage Area M. Pittman Monthly Inspections M. Pittman Unknown Snettisham Hazardous Waste Storage Area Weekly 7/11/92 Inspection Eklutna Hazardous Waste Monthly Generation Logs Multimedia Environmental Management Audit (FY 7/92 1992) for Eklutna Project Multimedia Environmental Management Audit (FY R. Waldman 7/92 1992) for Snettisham Project Memorandum re: APA's Annual Waste Reduction R. Waldman R. Popino, CE-64 4/13/92 Report for CY 1991 (and attached report) J. Hancock, EM-352 Solid Waste Permit Application for Solid Waste ADEC 1/14/92 EPA 4/2/92 7/1/92 and 8/3/92 1991 Hazardous Waste Report for Eklutna Power System (and transmittal letter) 1990 Hazardous Waste Report for Eklutna Power System Management Facilities at Snettisham (and transmittal letter) ADEC , 4/5/91 ADEC 4/5/91 1991 Hazardous Waste Report for Snettisham Power System (and transmittal letter) 1990 Hazardous Waste Report for Snettisham Power System Memorandum re: Annual Hazardous Waste Audit of the Snettisham Project 8-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Annual Hazardous Waste Management Audit (FY R. Waldman SN-1 4/92 1992) for Snettisham Project Memorandum re: Annual Hazardous Waste Audit of | R. Waldman EK-1 and 6/8/92 the Eklutna Project B. Murphy 0-WM-47 Annual Hazardous Waste Management Audit (FY R. Waldman EK-1 and 4/92 1992) for Eklutna Project B. Murphy D-WM-48 Snettisham Hazardous Waste Manifest File, A0388 Lee ee a 12/12/91 ka Screening Test Results for Waste 01] Disposal eran ON LNT 8/25/92 First Stage Development Map, Warehouse, 7/71 Snettisham Sn D-TCM. letter re: Notice of Case Closure (EPA G. Haselberger R. Cross, APA 10/8/91 Inspection) D-TCM-2 Herbicide Disposal Technical Spec (and Attached 7/19/89 Note to Hallum) D-TCM-3 Plan for Disposal of Out-of-Service 6/11/92 Transformers D-TCM-4 Memorandum re: APA PCB Equipment Inventory ee NNT Te eA B. Eckroade 7/31/92 ES&H Hazardous Materials Procedure and Unknown 7/1/92 Instruction Log 7/1/92 7/13/92 Electrical Equipment to Determine PCB Levels D-TCM-8 PCB Sampling, Transformer Removal at Eklutna jUnknown Undated 0-TCM-9 Memorandum re: PCB Transformer S. Sieczhowshi Butte Fire Dept., 4/6/90 Palmer, AK D-TCM-10 | SARA Reporting Request America North ra 7/17/91 Snettisham Hazardous Material Storage Area Monthly Inspections Form (ES&H HW-05/0) Memorandum re: Oi] Sampling of In-service 6-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) O-TCM-11 Ca T. Wilde Butte Fire Dept., 6/12/92 Palmer, AK Alaska State 6/12/92 Emergency Response Committee Matanuska, Susitina 6/12/92 Local Emergency Planning Committee APA Palmer Public Works 6/12/92 Dept. APA Juneau Local 8/21/92 Emergency Planning Committee fox ri <= i tL il PE if s SARA, Record to File O-TCM-12 SARA Report 1992, Eklutna D-TCM-13 SARA Report 1992, Eklutna O-TCM-14 SARA Report 1992, Eklutna D-TCM-15 SARA Report 1992, Eklutna D-TCM-16 Thane and Snettisham SARA Report 1992, O-TCM-17 Transformers for Disposal Log Unknown 0-TCM-18 Chemical Data Inventory Sheet, Turbine 0i 0-TCM-19 Transformer KW3A Twin Peakes Subdivision (Camp Line) Failure D-TCM-20 Memorandum re: Batteries at Terminals, Thane and Snettisham 0-TCM-21 Letter re: PCB Test Results for AMPL-owned Transformers and Circuit Breakers at Anchorage Substation D-TCM-22 Memorandum re: Guidance on Use of Product R. Waldman Labels APA 7/17/92 APA Annual Site Environmental Report for Unknown Various Undated cy 1990 OI-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) sana T. Spicher == i al 2 Various 4/24/92 | D-an-3 | APA Site Environmental Report for CY 1989 D-QA-4 Memorandum re: Water Test for Thane Substation |D. Low and Water Analysis Report APA Annual Site Environmental Report for CY 1991 D-QA-6 APA Eklutna Project Underground Storage Tank J. Shepherd New Horizons Telecom, Closure Site Assessment : D-QA-7 Underground Storage Tank Removal and Disposal J. White Contract | o-tws-1 | APA FY 1992 Annual Management Plan APA FY 1992 Annual Management Plan, 1st Quarter | Unknown Update Ss = a Es Es APA FY 1992 Annual Management Plan, 2nd Quarter | Unknown APA Update APA Site Environmental Report for CY 1988 Unknown APA Various Undated D-IWS-5 APA Annual Site Environmental Report for ee | Various Undated cy 1990 Memorandum re: Approval of APA Order, DOE T. Eade APA Various 5/1/92 5400.3 APA Supplement 1, APA Hazardous Waste Program Letter re: Solid Waste Disposal Permit D. Stokes ADEC R. Waldman, APA 3/10/92 #92110-BA003 (Port Snettisham Project) Project Descriptions (Snettisham and Eklutna Unknown Undated Hydroelectric Projects) D-IWS-10 ES&H Corrective Action Form Junknown | 7/1/92 II-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) S. Willis APA APA een [ DOE, AD-543 APA, Administrator 4/17/92 Al] APA Offices/ 7/23/92 Projects 7/28/92 7/28/92 7/13/92 Memorandum and Report re: Report on Oi] Spill at West Terminal Building, Snettisham Project D-IWS-12 Memorandum re: Federal Employee Occupational 6/9/92 Safety and Health Evaluation of the APA (and procedures) AD-543, Chief 0-IWS-13 Procedure, APA ES&H 01, Draft A, re: Standard Procedure for Finalizing, Approving and Revising APA ES&H Orders, Policies and Procedures All APA Offices/ Projects D-IWS-14 Procedure, APA ES&H 02, Draft A, re: APA Position Hazard Analysis -- Safety Training; Safety Equipment, Record Management, and Review All APA Offices/ Projects 6/3/92 O-IWS-15 Memorandum re: Federal Employee Occupational Safety and Health Program Evaluation O-IWS-16 Divestiture Summary Report, Sale of Eklutna and Snettisham Hydroelectric Projects D-IWS-17 Policy, APA Environmental Statement re: General Environmental Policy Statement D-IWS-18 Operations Manual for Snettisham Project Marine Oil Transfer Facility D-IWS-19 Draft Spill Prevention Control and Countermeasure Plan, Snettisham Powerplant, Fuel Storage Area O-IWS-21 Memorandum re: Oi] Sampling of In-service Electrical Equipment to Determine PCB Levels 0-IWS-22 Plan for Disposal of Out-of-Service 6/11/92 Transformers D-IWS-23 Memorandum of Understanding between the U.S. Forest Service, Department of Agriculture and the Corps of Engineers, Dept. of Army Various et-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Eklutna Underground Storage Tank Policy (ES&H HW-06/0) O-IWS-24 <= = 7/1/92 0-IWS-25 Snettisham Hazardous Material Storage Area Monthly Inspections Form (ES&H HW-05/0) Unknown D-IWS-26 Snettisham Hazardous Waste Storage Area Weekly Inspection Form (ES&H HW-40/0) Unknown D-IWS-27 Eklutna Hazardous Material Storage Area Monthly Inspections Form (€S&H HW-03/0) D-IWS-28 Eklutna Hazardous Waste Storage Area Weekly Inspection Form (ES&H HW-02/0) Unknown 0-IWS-29 Memorandum re: Concurrence and Implementation of Hazardous Waste Program Procedures G. Hallum, M. Deihl, T. Wilde, R. Waldman D-IWS-30 Hazardous Waste Container Labeling and Marking Unknown (ES&H HW-01/0) O-IWS-31 DOE Order 5400.3, APA Supplement 1 re: APA Hazardous Waste Program Unknown All APA Offices/ Projects = = Ee Sa 8/1/92 0-IWS-32 APA Annual Site Environmental Report for CY 1991 Unknown 0-IWS-33 Memorandum re: Eklutna Weekly Report June 29 Through July 3, 1992 D-IWS-34 D-IWS-35 D-IWS-36 Memorandum re: Eklutna Weekly Report July 6 Through July 10, 1992 Memorandum re: Eklutna Weekly Report July 13 EK-1 Through July 17, 1992 Memorandum re: Eklutna Weekly Report July 13 Through July 24, 1992 D-IWS-37 Memorandum re: Eklutna Weekly Report July 27 Through July 31, 1992 0-IWS-38 Memorandum re: Eklutna Weekly Report August 3 Through August 7, 1992 eI-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) No. WR-B-92-2) Inspector General = Memorandum re: Eklutna Weekly Report August 7 PD-1 8/14/92 Through August 14, 1992 0-IWS-40 Memorandum re: Eklutna Weekly Report August 17 M. Deihl 8/21/92 Through August 21, 1992 O-IWS-41 APA Eklutna Project Underground Storage Tank J. Shepherd New Horizons Telecom, | APA 6/25/92 Closure Site Assessment 0-IWS-42 Audit of the Proposed Sale of APA (Report DOE, Office of 3/16/92 ‘A Notification for Underground Storage Tanks for Eklutna Project 4/29/86 Unknown A P. P; [an (ae oe APA T. Wilde 8/17/92 Solid Waste APA 8/21/92 Solutions, Inc. " | ee iro] me M. Pittman APA 7/28/92 APA 7/21/92 D-IWS-44 Notification for Underground Storage Tanks for Snettisham Project 0-IWS-45 Memorandum re: €klutna Environmental Inspection, 8/4/92 (and attached copy of Environmental Inspection) D-IWS-46 Used 011 Service Agreement (and Addendum), Effective 1/1/92 through 12/31/92 Waste Paint Related Material 0-IWS-47 Snettisham Hazardous Waste Storage Area Weekly Inspection M. Pittman Snettisham Hazardous Waste Storage Area Weekly Inspection M. Pittman M. Pittman Unknown Snettisham Hazardous Material Storage Area 7/11/92 Monthly Inspections D-IWS-52 Snettisham Hazardous Waste Storage Area Weekly Unknown 7/11/92 Inspection 0-IWS-53 Transformer KW3A Twin Peakes Subdivision (Camp Unknown Unknown Undated Line) Failure vI-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) z os Memorandum re: APA's Annual Waste Reduction Unknown 7/92 R. Popino, CE-64 4/13/92 Report for CY 1991 (and attached report) J. Hancock, EM-352 | o-tws-58 | Solid Waste Disposal Permit No. 8711-BA002 }o. Henkins | ADEC COE 5/27/87 D-IWS-59 | Solid Waste Disposal Permit No. 8310-BA00S (and |D. Henkins poe 5/24/83 cover transmittal letter) E. Mueller ADEC APA 8/23/77 Solid Waste Management Permit for Snettisham APA ADEC 3/9/83 Project (Application, Appendix A and map) Solid Waste Disposal Permit No. SER 2-73 for M. Brewer 10/17/73 Snettisham Project Solid Waste Permit Application for Solid Waste |R. Waldman APA ADEC 1/14/92 Management Facilities at Snettisham (and transmittal letter) R. Waldman ye ADEC 4/5/91 1991 Hazardous Waste Report for Snettisham R. Waldman Power System (and transmittal letter) O-IWS-67 1990 Hazardous Waste Report for Snettisham R. Waldman ADEC 4/5/91 Power System se ate z D-IWS-54 Underground Storage Tank Removal and Disposal J. White Contract 0-IWS-55 Multimedia Environmental Management Audit (FY R. Waldman 1992) for Eklutna Project D-IWS-56 Multimedia Environmental Management Audit (FY R. Waldman 1992) for Snettisham Project O-IWS-57 R. Waldman D-IWS-60 Solid Waste Disposal Permit No. SE-3-77 (and transmittal letter) O-IWS-61 D-IWS-63 D-IWS-65 Letter re: Application for Waste Disposal - R. Waldman 1991 Hazardous Waste Report for Eklutna Power System (and transmittal letter) 1990 Hazardous Waste Report for Eklutna Power System D-IWS-66 > g SS ind o iy SI-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Camp Facilities Site Plan, Legend 4, Soils Logs, Snettisham Project, Drawing #1-SNE-96-04-01-04 D-IWS-70 O-IWS-71 D-IWS-72 Lift Station and Seepage Pit Details Map, Snettisham Project Unknown Submarine Cable Terminals, Mechanical Plan and | Unknown Sections Map, Snettisham 7/19/71 PCB Sampling, Transformer Removal at Eklutna Undated 0-IWS-73 Memorandum re: Snettisham Landfill Permit S. Willis D-IWS-74 D-EM-1 Snettisham Hazardous Waste Manifest File, A0388 is APA FY 1992 Annual Management Plan APA FY 1992 Annual Management Plan, ist Quarter Update 1/27/92 APA FY 1992 Annual Management Plan, 2nd Quarter D-EN-3 4/24/92 Update D-EM-4 | APA Site Environmental Report for CY 1988 Undated itll Sev MM MI mi He AL aA a innin cy 1990 | o-eH6 | APA Site Environmental Report for CY 1989 Undated O-EM-7 5/1/92 Memorandum re: Approval of APA Order, DOE 5400.3 APA Supplement 1, APA Hazardous Waste Program Various Project Descriptions (Snettisham and Eklutna Hydroelectric Projects) APA Organization Description and Organization Unknown Chart ata 7/1/92 ES&H Corrective Action Form Unknown 9I-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Memorandum re: Federal Employee Occupational Safety and Health Evaluation of the APA (and procedures) Pe oa All APA Offices/ 6/3/92 Projects os a 4/92 7/23/92 ae ae “ Unknown APA 5/20/92 APA leva] | ee Procedure, APA ES&H 01, Draft A, re: Standard Procedure for Finalizing, Approving and Revising APA ES&H Orders, Policies and Procedures Procedure, APA ES&H 02, Draft A, re: APA Position Hazard Analysis -- Safety Training, Safety Equipment, Record Management, and Review Memorandum re: Federal Employee Occupational Safety and Health Program Evaluation Policy, APA Environmental Statement re: General Environmental Policy Statement ES&H Hazardous Materials Procedure and Instruction Log All APA Offices/ Projects APA, Administrator Various All APA Offices/ Projects Unknown Memorandum re: Oi] Sampling of In-service Electrical Equipment to Determine PCB Levels SN-1, EK-1 Memorandum of Understanding between the U.S. Forest Service, Department of Agriculture and the Corps of Engineers, Dept. of Army Supplementary Labor Mgmt. Agreement No. 2 Unknown between Eklutna Project, APA, DOE and International Brotherhood of Electrical Workers, Local Union No. 1547 P. Collins Position Description, Administrator | o-en-22 | Position Description, Chief, Power Division O-EM-23 Position Description, Area Power Manager, Eklutna L1-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) Position Description, Project Manager, Snettisham 0-EM-25 Eklutna Underground Storage Tank Policy (ES&H HW-06/0) Snettisham Hazardous Material Storage Area Monthly Inspections Form (ES&H HW-05/0) Snettisham Hazardous Waste Storage Area Weekly Inspection Form (ES&H HW-40/0) a ee Lia!) LET || Pad LG | Unknown 7/1/92 G. Hallum, M. Deihl, 6/5/92 T. Wilde, R. Waldman APA Unknown 7/1/92 APA All APA Offices/ 8/1/92 Projects APA Unknown Undated Eklutna Hazardous Material Storage Area Monthly Inspections Form (ES&H HW-03/0) Memorandum re: Concurrence and Implementation of Hazardous Waste Program Procedures Hazardous Waste Container Labeling and Marking (ES&H HW-01/0) DOE Order 5400.3, APA Supplement 1 re: APA Hazardous Waste Program Functional Statement, Power Division, Engineering and Technical Support Branch Unknown Functional Statement, Power Division, Unknown APA Undated Environmental, Safety and Health Branch Functional Statement, Power Division, Unknown APA li iil! Lia 7/2/92 Snettisham Project Functional Statement, Power Division, Eklutna Project Unknown APA Annual Site Environmental Report for CY 1991 Memorandum re: Eklutna Weekly Report June 29 Through July 3, 1992 8I-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) se Memorandum re: Eklutna Weekly Report July 6 Through July 10, 1992 J. Toothaker Memorandum re: Eklutna Weekly Report July 13 Through July 17, 1992 EK-1 Memorandum re: Eklutna Weekly Report July 13 Through July 24, 1992 D-EM-43 Memorandum re: €klutna Weekly Report July 27 Through July 31, 1992 Memorandum re: Eklutna Weekly Report August 3 Through August 7, 1992 Memorandum re: Eklutna Weekly Report August 7 Through August 14, 1992 7/24/92 EK-3 APA 7/31/92 Memorandum re: Eklutna Weekly Report August 17 Through August 21, 1992 T. Wilde D-EM-48 D-EM-51 D-EM-47 APA Eklutna Project Underground Storage Tank Closure Site Assessment Audit of the Proposed Sale of APA (Report No. WR-B-92-2) DOE APA Organization Chart APA List of Employees, Names and Titles Performance Record for Performance Management and Recognition System Employees and Performance Management System Employees, Electronics Technician, Eklutna Project Performance Record for Performance Management and Recognition System Employees and Performance Management System Employees, Maintenance Mechanic, Eklutna Project Merit Staffing Vacancy Announcement, Mechanical Engineer, GS-830-12/13 (Announcement No.: APA-92-11) J. Shepherd New Horizons Telecom, Inc. Unknown DOE, Office of Inspector General S. Showshi G. Hallum S. Showshi M. Dillon aa aL owe 8/26/92 9/12/90 9/20/90 10/15/90 5/6/91 Various 8/20/92 6I-d LIST OF SITE DOCUMENTS REVIEWED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) a Small Purchase Clauses (DOE SET 319) Unknown Fixed-Price Supplies and Services Excerpts from the Draft Thane and Snettisham Operators and Maintenance Contract 0-EM-55 Multimedia Environmental Management Audit (FY R. Waldman 1992) for Eklutna Project 0-EM-56 Multimedia Environmental Management Audit (FY R. Waldman 1992) for Snettisham Project Memorandum re: Annual Hazardous Waste Audit of the Snettisham Project D-EM-59 Annual Hazardous Waste Management Audit (FY 1992) for Snettisham Project Memorandum re: Annual Hazardous Waste Audit of the Eklutna Project Annual Hazardous Waste Management Audit (FY 1992) for Eklutna Project APA Summary FY 1992 Financial Plan as of 7/8/92 APA Project Manager Hazardous Materials Management Training Procurement Request - Requisition, Supplies/ Services Under $25,000 (for oi] samples taken at Eklutna) Order for Supplies or Service (for misc. of] sampling for PCB content) Analytical Associates Memorandum re: Environmental Protection Implementation Plan P. Ziemer, EH-1 APPENDIX E APPENDIX E: LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM APA, Power Division Chief, ES&H Branch Air permits at Eklutna, gas tanks and pumps, asbestos management program ial 8/25/92 R. Kolpa Coordinator I-A-3 8/25/92 R. Kolpa APA, Eklutna Project Area Power Manager Gasoline storage at Eklutna and asbestos surveys R. Kolpa APA, Snettisham Project | Supv. Electronics Technician Gasoline storage and pumps at Snettisham, asbestos management and surveys R. Kolpa APA, Snettisham Project | Supv. Electronics Technician Incinerator operation, asbestos management plan Solid Waste Management Air quality regulations applicable to Program Coordinator Snettisham incinerator Area Power Manager APA, Eklutna Project General Maintenance Worker/Environmental Gasoline storage at Eklutna Water drainage, spill control, and Ee : 8/24/92 D. Dolak APA, Eklutna Project transformers at Eklutna Substation I-SW-2 8/24/92 0. Dolak APA, Power Division Chief, ES&H Branch Spill control, PCB tests and records at Eklutna and Palmer Substations 8/24/92 0. Dolak APA, Power Division Environmental Protection PCB records at Eklutna Substation Specialist 8/24/92 D. Dolak APA, Eklutna Project General Maintenance Chemical storage, MSDSs, fuel tanks, and 8/25/92 0. Dolak APA, Eklutna Project Worker/Environmental warehouse storage at Eklutna Coordinator Area Power Manager Transformers, surface drainage, and spill containment at Anchorage and Reed Substations Transformer and electrical equipment test logs at Anchorage and Reed Substations 8/25/92 APA, Power Division Chief, ES&H Branch é-4 LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) z : ee Supervisory Electronics Spilled oi] collection at Eklutna Technician Project Manager Transformer logs, hazardous chemical storage, and water treatment at Thane Substation Chief, ES&H Branch Transformer, electrical equipment test logs and chemical storage at Thane Substation Utility Worker Drinking water intake at Sheep Creek Hydroelectric Powerplant Water drainage and oi] containment at Mechanic/Environmental Snettisham site Coordinator APA, Eklutna Project APA, Snettisham Project 8/26/92 | 0. Dolak eee | D. Dolak APA, Power Division I-SW-10 8/26/92 D. Dolak APA, Snettisham Project Alita 8/27/92 D. Dolak APA, Snettisham Project 8/27/92 Dolak Water drainage, transformers, and chemical storage at Snettisham APA, Snettisham Project | Project Manager 8/27/92 Dolak APA, Snettisham Project | Supv. Electronics Technician | Chemical storage and use at Snettisham Substation 8/27/92 0. Dolak APA, Power Division Chief, ES&H Branch Electrical equipment test logs at Snettisham I-SW-15 8/28/92 D. Dolak APA, Snettisham Project | Supv. Electronics Technician Drinking water, wastewater disposal, MSDSs, and fuel containment at Snettisham | i-si-16 | 8/28/92 0. Dolak APA, Snettisham Project | Project Manager Fuel containment at Snettisham I-SW-17 8/31/92 D. Dolak APA, Power Division Chief, Engr. and Technical Drinking water disinfection, wastewater Support Branch disposal, and SPCC plans at Thane and Snettisham 9/4/92 D. Dolak Drinking Water Program Certification of Drinking Water Systems Manager ea eee 8/24/92 K. Smith APA, Eklutna Project Area Power Manager Facility construction, local hydrogeology 8/26/92 K. Smith APA, Snettisham Project | Project Manager Groundwater conditions at Thane Substation 8/27/92 K. Smith APA, Snettisham Project | Supv. Electronics Technician Groundwater conditions at Snettisham tid LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) = & = oe 8/31/92 Smith APA, Snettisham Project | Supv. Electronics Technician Documentation of groundwater conditions at Thane Substation and Snettisham 9/2/92 K. Smith ADEC Regional Wastewater Program Groundwater protection standards and well Manager design criteria 9/2/92 K. Smith ADEC Leaking UST Program Manager Groundwater monitoring well standards Se oes 3S 8/24/92 K. Smith APA, Eklutna Project General Maintenance Waste management at Eklutna Worker/Envi ronmental Coordinator 8/24/92 K. Smith APA, Power Division Environmental Protection Waste management d Specialist 8/24/92 K. Smith APA, Power Division Chief, ES&H Branch Waste management 8/25/92 K. Smith APA, Power Division Environmental Protection Waste management at Eklutna Specialist 8/25/92 K. Smith APA, Eklutna Project Powerplant Operator Sanitary waste management at Anchorage Substation 8/25/92 APA, Eklutna Project General Maintenance Waste management at Eklutna Worker/Environmental Coordinator 8/25/92 : APA, Eklutna Project Supervisory Electronics Hazardous waste generation Technician 8/25/92 APA, Power Division Chief, ES&H Branch Waste management at Eklutna 8/26/92 APA, Snettisham Project | Project Manager Waste management at Thane Substation and Snettisham Project 8/26/92 APA, Power Division Environmental Protection Waste management at Thane Substation and Specialist Snettisham Project 8/27/92 Snettisham Project | Hydroelectric Powerplant Waste management at Snettisham Mechanic/Environmental Coordinator f rwea | 8/25/92 K. Smith APA, Eklutna Project Waste management at Anchorage Substation | LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) I-WM-13 8/27/92 K. Smith APA, Snettisham Project | Supv. Electronics Technician Waste management at Snettisham 8/27/92 K. Smith APA, Power Division Chief, ES&H Branch Waste management at Snettisham 8/28/92 K. Smith APA, Snettisham Project | Supv. Electronics Technician Waste management and USTs at Snettisham 8/28/92 K. Smith APA, Power Division Chief, ES&H Branch USTs at Snettisham I-WM-17 8/28/92 K. Smith APA, Power Division Environmental Protection Waste management at Snettisham Specialist 8/28/92 K. Smith APA, Snettisham Project Mechanic/Operator Waste management at Snettisham 8/31/92 K. Smith APA, Eklutna Project General Maintenance Worker/Environmental Coordinator 8/31/92 K. Smith Solid Waste Management Snettisham Solid Waste Disposal Permits Program Coordinator 8/31/92 K. Smith APA, Power Division Environmental Protection Pollution Prevention Awareness Program Specialist i i Shes 8/24/92 APA, Eklutna Project 1-TeM-2 | 8/24/92 |. Dolak I-TCM-3 8/24/92 D. Dolak I-TCM-4 8/25/92 D. Dolak I-TCM-5 8/25/92 0. Dolak Waste management records at Eklutna Water drainage, spill control, and Area Power Manager transformers at Eklutna Substation APA, Power Division Chief, ES&H Branch Spill control, PCB tests and records at Eklutna and Palmer Substations APA, Eklutna Project General Maintenance Chemical storage, MSDSs, fuel tanks, and Worker/Environmental warehouse storage at Eklutna Coordinator APA, Eklutna Project Area Power Manager Transformers, surface drainage, and spill containment at Anchorage and Reed Substations Chief, ES&H Branch Transformer and electrical equipment test logs at Anchorage and Reed Substations Supervisory Electronics Spilled of] collection at Eklutna Technician APA, Power Division 8/25/92 D. Dolak APA, Eklutna Project s-4 LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) I-TCM-7 8/26/92 D. Dolak APA, Snettisham Project | Project Manager Transformer logs, hazardous chemical storage, and water treatment at Thane Substation I-TCM-8 8/26/92 D. Dolak Power Division Chief, ES&H Branch Transformer, electrical equipment test logs and chemical storage at Thane Substation I-TCM-9 8/27/92 D. Dolak APA, Snettisham Project | Hydroelectric Powerplant Water drainage and oi] containment at Mechanic/Environmental Snettisham site Coordinator APA, Snettisham Project Supv. Electronics Technician Chemical storage and use at Snettisham Substation I-TCM-12 8/27/92 0. Dolak Power Division Chief, ES&H Branch Electrical equipment test logs at Snettisham I-TCM-13 8/28/92 D. Dolak APA, Snettisham Project | Supv. Electronics Technician Drinking water, wastewater disposal, MSDSs, and fuel containment at Snettisham I-TCM-14 8/28/92 D. Dolak APA, Snettisham Project | Project Manager Fuel containment at Snettisham D. Dolak I-TCM-15 8/31/92 APA, Power Division Student Trainee Hazard communication of APA pesticide disposal at APA I-TCM-16 8/31/92 0. Dolak APA, Power Division Chief, Engr. and Technical Drinking water disinfection, wastewater Support Branch disposal, and SPCC plans at Thane and Snettisham I-TCM-17 8/31/92 D. Dolak APA, Power Division Environmental Protection SARA Title III records Specialist P. Lindah] AP. Division Contract Specialist Contracting, QA provisions 8/31/92 P. Lindah) APA, Power Division Environmental Protection Testing laboratory oversight Specialist I-TCM-10 8/27/92 D. Dolak APA, Snettisham Project | Project Manager Water drainage, transformers, and chemical storage at Snettisham D. Dolak I-TCM-11 8/27/92 : 9-4 LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) INA ee pet 8/24/92 APA, Power Division | Chief, ES&H Branch I-IWS-2 R. Kolpa APA, Eklutna Project Area Power Manager 8/25/92 R. Kolpa APA, Power Division 8/25/92 R. Kolpa APA, Eklutna Project 8/25/92 R. Kolpa material/waste storage 8/26/92 R. Kolpa APA, Snettisham Project | Project Manager Marine cable leak, PCB inventory at Thane, pesticide uses, hazardous material labels I-IWS-7 8/26/92 APA, Power Division Student Trainee Hazardous material labels, building placards 8/26/92 R. Kolpa APA, Power Division Chief, ES&H Branch Marine cable leaks, PCB inventory, waste oi] staging area pore 8/26/92 | R. Kolpa I-1Ws-10 | 8/27/92 I-IWS-11 8/27/92 R. Kolpa Eklutna landfill, leaks and transformers, tenant activities, boneyard Eklutna landfill, leaks at transformers, tenant equipment, boneyard, bank stabilizations Chief, ES&H Branch Anchorage equipment, spills, PCB sampling, tenant activities, of] disposals, waste drum at Reed Area Power Manager Septic tank, oi] spills and leaks, tenant equipment, tenant maintenance activities, substation rebuild, laboratory building at Eklutna APA, Eklutna Project General Maintenance Worker/Environmental Coordinator Hazardous material and hazardous waste storage, gas tanks and pumps, spills in shop area, sump design equipment leaks, hazardous APA, Power Division Environmental Protection Specialist Spills at Thane APA, Snettisham Project | Supv. Electronics Technician Snettisham operations, incinerator, waste management, warehouse wastes, hazardous material storage, junk pile, landfill, Crater Lake pump house, boneyard Power Division Chief, ES&H Branch Snettisham operations, incinerator, waste management, warehouse wastes, hazardous material storage, junk pile, landfill, Crater Lake pump house, boneyard I-IWS-12 8/27/92 APA, Snettisham Project | Hydroelectric Powerplant Mechanic/Environmental Coordinator Snettisham landfill, warehouse activities LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) I-IWS-13 8/28/92 Snettisham tank farm, old oi] storage building, oil/water separator Supv. Electronics Technician . Kolpa APA, Snettisham Project R. Kolpa APA, Power Division Snettisham tank farm, old oi] storage building, oil/water separator R. Kolpa APA, Power Division Chief, Engr. and Technical Oi] spill at West Terminal Building, Support Branch Snettisham landfill permit R. Kolpa ADEC, SE Reg. Office Solid Waste Management Alaska solid waste management regulations Program Coordinator I-IWS-17 8/31/92 R. Kolpa ADEC, SE Reg. Office Env. Specialist, Oi] Spill 041 spill notice and reporting requirements Prevention, Planning and Management I-IWS-14 8/28/92 Chief, ES&H Branch I-IWS-15 8/31/92 I-IWS-16 8/31/92 I-IWS-18 9/4/92 R. Kolpa APA, Admin. Division Administrator Divestiture I-EM-1 8/3/92 B. Clark/ CE-62 Staff CE Self-Assessment Program W. Eckroade L-4 8/4/92 B. Clark/ CE-64 Director CE oversight of APA W. Eckroade 8/24/92 P. Lindahl APA, Power Division Environmental Protection ES&H organization and environmental Specialist protection 8/25/92 W. Eckroade/ APA, Eklutna Project Area Power Manager Management and environmental protection P. Lindahl 8/25/92 W. Eckroade/ APA, Eklutna Project Supervisory Electronics Management and environmental protection P. Lindahl Technician 8/25/92 W. Eckroade/ APA, Eklutna Project General Maintenance Environmental protection P. Lindahl Worker/Environmental Coordinator I-EM-7 8/27/92 W. Eckroade/ APA, Admin. Division Director Management and environmental protection P. Lindahl I-EM-8 8/27/92 2= Eckroade/ APA, Power Division Director Management and environmental protection Lindahl LIST OF CONTACTS AND INTERVIEWS CONDUCTED BY THE ENVIRONMENTAL AUDIT TEAM (Continued) NT (Continue 8 8/27/92 W. Eckroade/ APA, Admin. Division Administrator Management and environmental protection P. Lindahl 8/27/92 P. Lindahl APA, Admin. Division Chief, Administrative Support | Purchasing and environmental protection Branch APA, Power Division P. Lindahl 8/28/92 W. Eckroade/ Chief, Engr. and Technical Engineering and environmental protection Support Branch 8/28/92 P. Lindahl APA, Admin. Division Personnel Management Training Specialist 8/28/92 W. Eckroade/ APA, Power Division Director Management planning and environmental P. Lindahl protection I-EM-14 8/28/92 P. Lindahl APA, Admin. Division Contract Specialist Contracting and environmental protection 8/31/92 P. Lindahl APA, Admin. Division Assistant to the Training records Administrator I-EM-16 8/31/92 P. Lindahl APA, Admin. Division Division Assistant DOE Orders and SENs I-EM-17 8/31/92 P. Lindahl APA, Admin. Division Chief, Administrative Support | ES&H budget Branch 8-4 | r-eH-18 | 9/1/92 P. Lindahl? APA, Snettisham Project | Project Manager Management and environmental protection | r-en-19 | 9/1/92 | P. Lindahl APA, Power Division ES&H conmunicat ions I-EM-20 9/1/92 P. Lindahl APA, Power Division Environmental Protection ES&H training Specialist | tenet | 9/4/92 B. Eckroade cess Staff CE environmental activities ee APPENDIX F APPENDIX F: DEFINITIONS OF CAUSAL FACTORS AND CONTRIBUTING FACTORS Evaluate if ineffective, outdated, or nonexistent policies contributed to the finding. Policy Implementation Ascertain if written policies reflecting Federal, state, and local laws and regulations, codes, and standards were appropriately disseminated, implemented, and updated. Evaluate if the site personnel responsible for a situation contributing to a finding have assessed and were aware of the relative degree of risk involved in the action. Procedures Identify if written procedures that have been prepared to effectively implement site policy, DOE Orders, and Federal, state, and local laws and regulations were a contributing factor to the finding. Determine if unfamiliarity with, or unavailability of those procedures contributed to the finding. Personnel Identify if the educational and work experience backgrounds for personnel holding responsible positions contributed to the finding. Determine if the level of personnel knowledge about the technical and safety aspects of their jobs contributed to the finding. Resources Ascertain if the number of personnel or extramural resources available to a job were a contributing factor in the finding. Evaluate if inadequacies in facilities and equipment were a contributing factor to the finding. [Training l Identify if adequate personnel training on implementing site policy, DOE Orders, and applicable Federal, state, and local Jaws and regulations was a contributing factor to | the finding. F-1 DEFINITIONS OF CAUSAL FACTORS AND CONTRIBUTING FACTORS (Continued) Change Appraisals, Audits, and Reviews Design Human Factors Barriers and Controls Supervision Quality Assurance/Control Evaluate if changes in site mission, function, operation and established requirements, which rendered existing policies or procedures inadequate or inappropriate, were contributing factors to the finding. Evaluate if the timeliness and effectiveness of changes to site and DOE policy, and the implementing procedures, were a contributing factor to the finding. Determine if ineffective or insufficient appraisals, audits, and reviews or oversight were contributing factors to the findings. The factor should only be used as secondary contributing factor to the finding. Evaluate if inadequate design of a system was a contributing factor to the finding. Ascertain if human factors, such as fatigue or deliberate circumvention of a safety system, were contributing factors to the finding. Determine if inadequacies in established barriers and controls, both administrative and physical, including operational readiness, routine inspections, and preventive maintenance, and/or a lack of these controls, contributed to the finding. Identify if ineffective supervisory controls for implementing policies, procedures, standards, laws, etc., were contributing factors to the finding. Identify if inadequacies in the quality assurance/control program were causal factors in the identified finding. This includes inadequate followup to previously identified findings. F-2 APPENDIX G APPENDIX G: LIST OF ACRONYMS AND ABBREVIATIONS AAC Alaska Administrative Code ACM Asbestos-Containing Material ADEC ADF&G AML&P ANL Argonne National Laboratory Alaska Department of Environmental Conservation Alaska Department of Fish and Game Anchorage Municipal Light and Power Alaska Power Administration Best Management Practice BMPF E Best Management Practice Finding Office of the Assistant Secretary for Conservation and Renewable Energy Facilities and Systems Coordination Division CERCLA Comprehensive Environmental Response, Compensation, and Liability Act Conditionally Exempt Smal] Quantity Generator oO OQ ™ a 9 F COE U.S. Army Corps of Engineers WA Clean Water Act OE U.S. Department of Energy QT oO m n OQ @ Compliance Finding Q oO U.S. Department of Energy Headquarters So OT Department of Transportation Office of Environment, Safety and Health Office of the Assistant Secretary for Environment, Safety and Health Office of Environmental Audit M EPA U.S. Environmental Protection Agency Environmental Management Emergency Planning and Community Right-to-Know Act Environment, Safety, and Health mim “nly ] G-1 LIST OF ACRONYMS AND ABBREVIATIONS (Continued) Federal Insecticide, Fungicide, and Rodenticide Act gal/min gallons per minute HMIG Hazmat Information Guide Hazardous and Solid Waste Amendments a LDR Land Disposal Restriction LEPC Local Emergency Planning Committee million gallons per day Material Safety Data Sheet Megawatt MSDS NCP National Contingency Plan National Environmental Policy Act National Emission Standards for Hazardous Air Pollutants National Fire Prevention Association Northwest Northwest Environmental Services = 7“ uo > National Pollution Discharge Elimination System =z vu Oo m n = PL National Priorities List NREL JT On-the-Job Training OSHA National Renewable Energy Laboratory Oo Occupational Safety and Health Administration Preliminary Assessment vu CB Polychlorinated Bipheny1 Professional Engineer Power Marketing Administration Parts Per Million uv SO Program Senior Official Polyvinyl Chloride G-2 LIST OF ACRONYMS AND ABBREVIATIONS (Continued) Quality Assurance Radiation RCRA SAA Satellite Accumulation Area SARA Superfund Amendments and Reauthorization Act Safe Drinking Water Act SEN Secretary of Energy Notice I Site Investigation SLF Sanitary Landfill Standard Operating Procedure Resource Conservation and Recovery Act Southwestern Southwest Power Administration SPCC SQG Small Quantity Generator Spill Prevention Control and Countermeasures Surface Water Trichloroethylene TCLP TCM Toxic and Chemical Materials Toxicity Characteristic Leaching Procedure il oa m Threshold Planning Quantity Toxic Substances Control Act ST DC Washington, D.C. Liaison Office - Alaska, Southeastern & Southwestern Power Administrations Underground Storage Tank c/a] 4/35 > = Waste Management UNITED STATES DEPARTMENT OF ENERGY EH-24 WASHINGTON, DC 20585 OFFICIAL BUSINESS PENALTY’FOR PRIVATE USE, $300