How these "discrepancies" were resolved between NYSDEC and KAPL should be extremely interesting and revealing. Currently, that matter is being pursued and will be reported herein.
Thomas C. Jorling Commissioner
Mr. A. R. Seepo Received Feb 06 1989
Radiological/Environmental Control & Safety Division
Bureau of Hazardous Waste Permitting
U.S. Department of Energy Facility
Division of Hazardous Substance Regulation
P.O. Box 1069
Schenectady, NY 12301-1069
Re: Knolls Atomic Power Lab
Knolls Site - River Road
Niskayuna, NY NY6890008992
Dear Mr. Seepo:
Thank you for meeting with myself and Department staff to discuss our environmental concerns at your facility. As we discussed, Knolls Atomic Power Laboratory (KAPL) will be subject to RCRA requirements since it has recently submitted an application for a Part B/373 hazardous waste storage permit. Section 3004(u) of the Resource Conservation and Recovery Act and Article 27, Title 9, 6NYCRR, Part 373-2.6 requires corrective action to address the release of hazardous waste or hazardous constituents from any solid waste management facility.
As a first step, the Department requests the information referenced in the attached list of references to be submitted as soon as possible. This material is needed by DEC staff to adequately review and evaluate the environmental situation at KAPL.
In addition, all discrepancies between the January 1986 report (status of KAPL Phase I Review of Disposal practices for DOE Order 5480.14) and the April, 1986 report (Knolls Atomic Power Laboratory Installation Assessment Report-Phase I) must be fully explained and documented in a submittal to the Department. Please pay particular attention to the main discrepancies outlined in the attached sheets.
These submittals and all future submittals should be made to the Region 4 office of the Department of Environmental Conservation. Copies should be submitted to:
Mr. Paul Counterman, Director
Bureau of Hazardous Waste Facility Permitting
Division of Hazardous Substance Regulation
New York State Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
Mr. Stanley Siegal
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New York 12078
If there are any questions on this matter, please contact myself or Mr. Thomas Cullen of my staff.
Sincerely,
Eldred Rich, P.E.
Regional Engineer
Region 4
TC/ER/vaa-6TC25
cc: Mr. Paul Counterman
Mr. Stanley Siegel
Knolls Atomic Power Laboratory
Knolls Site
NY6890008992
References required for Environmental Review
1. Information, methods and results from all past hydrogeological investigations. This should include all well logs, location maps, sampling results (groundwater, surface water and soil), Quality Assurance/Quality Control data and information, etc.
2. Information, methods and results of all past geophysical investigations.
3. All past and future work plans, anticipated actions and/or investigations at the KAPL site.
4. The following references from the status of the KAPL Phase I review of disposal practices for DOE Order 5480.14.
a. KAPL Memo to File #RFD-133 dated August 20, 1980, "Metal Detection Survey Data for the North Field" (Reference #8).
b. St. Jordan, KAPL Safety. "Summary of Waste Chemical Disposal Practices," 9/26/80 (Reference #9).
C. Angelo Bracco, KAPL Memo to File, "Field Investigation of KAPL Chemical Dump," July 2, 1979 (Reference #10).
d. KAPL letter to T.R. Young to R. Marchand/E. Callahan. "Disposal of Waste Oils, Collents, etc.", January 10, 1961 (Reference #11).
e. KAPL Letter #LSS-6161-129 dated December 16, 1982, "Report of the 1981 Knolls Site Soil Survey Program in the Former Slurry Drum Area of the Knolls site, and continuation of the program". (Refernece #12).
f. C.T. Male Report 1978, Geohydrologic Report KAPL Sanitary Landfill- Knolls Site, November 1978. (Reference #24).
g. C.T. Male Report 1979, Supplement to Geohydrologic Report Report KAPL Sanitary Landfill-Knolls Site, December, 1979 (Reference #25).
h. KAPL letter, A. Bracco to W. Lupa, "Evaluation of Cyanide in Knolls site Monitoring Wells Nm-i, NTH-2, NTH-3" dated 9/5/79 (Reference #33).
TC/vaa-6TC26
2) Gives details of a metal detection survey that showed 309 hits in 229 ten foot square sections.
3) Gives locations and methods of disposal for waste chemicals for a one year period (in the 50's) in the west field and 1956-1957, and 1969-1974 beneath and in an area of the current landfill. Describes throwing containers containing chemicals into a trench and states on one occasion, a chemical reaction caused an explosion and fire.
4) Documents disposal of scrap coolants and oils.
5) personnel interviews have indicated that North field depressions were filled with waste chemicals and covered. Visual inspections of these areas and others have shown protruding drums, empty reagent bottles, discolored runoff, areas without vegetation, etc.
6) Interviews with equipment operators have indicated waste oils possibly contaminated with low levels of Uranium may be beneath the Red Pine area (adjacent to the existing landfill). Greater than 100 drums are reportedly buried.
7) Two drums containing waste oil surfaced from a steep slope near the east boundary stream (one near the abandoned landfill and one near the current landfill).
2) Not mentioned.
3) States that chemical wastes were buried in the west field f or about one year in the 50's. Also states that waste chemicals may have been disposed beneath and in the current landfill and a possibility exists that chemical and industrial wastes may have been disposed in the old landfill.
4) Not mentioned.
5) States: "Interviews have indicated that pre-existing depressions were sometimes used for the disposal of waste chemicals and then covered with soil. Several visual inspections of each disposal location were conducted in 1985 & 1986". No details of the visual inspections are given.
6) Not mentioned.
7) Not mentioned