BOMARC Missile Site Plutonium Remediation

BOMARC Missile Site Plutonium Remediation
WASTE MANAGEMENT, TRANSPORTATION, AND DISPOSAL PLAN

4.0 MATERIAL AND WASTE SOURCES AND CLASSIFICATION

This section describes the sources and classifications of the materials and wastes that may be generated during the remedial activities to be performed at the BOMARC facility.

4.1 Sources of Materials and Wastes

Implementation of the remedial action activities at the Site will result in the generation of materials and wastes that will require appropriate on-site and off-site management. These materials and wastes will be generated during the excavation of radiologically contaminated soil, decontamination and demolition of Shelter 204, as well as during the execution of associated support operations (i.e., equipment decontamination, sampling, etc.) The anticipated materials and wastes to be generated from the implementation of the remedial action activities include, but are not limited to:

Source	Potential Materials and Wastes
Contaminated Soil Excavation Activities	Radiologically contaminated soils and concrete (>8 pCi/g Pu 239/240)Radiologically contaminated soils and concrete (<8 pCi/g Pu 239/240)Water from excavation areas and surface run-offSpent PPE, debris, disposable equipment
Shelter 204 Activities	Radiologically contaminated soil (>8 pCi/g Pu 239/240) containing leadClean debris (
Decontamination activities	Decontamination watersSpent PPE, debris, disposable equipment
Other	Common trash and garbage (non-contaminated)Sanitary wastewaterWaste oil (from filters, equipment maintenance)

4.2 Material and Waste Classifications

The primary material to be handled during the remedial action activities will be Low Specific Activity (LSA) material, Surface Contaminated Objects (SCO) and non-regulated material. The potential for encountering hazardous waste also exists. Analysis results for material and waste management characterization should be recorded on the Material and Waste Characterization Tracking Log, Appendix G. Each of these material and waste classifications are discussed in detail below.

4.2.1 Radiological Materials and Wastes

The primary contaminates are Pu-239, Pu-240, and their associated decay products. There is also a potential for encountering mixed wastes during the remediation. Soils that contain radiological contamination above 2,000 pCi/g will be designated as LSA soils (LSA-1 or LSA-2 depending on the activity). Soils with radiological contamination below 2,000 pCi/g is not regulated by the U.S. Department of Transportation and will be transported based on the requirements of the disposal facility.

4.2.2 RCRA Hazardous Materials and Waste

Implementation of the remedial action activities may involve handling waste materials that are subject to the RCRA Hazardous Waste Regulations. A solid waste may be a RCRA hazardous waste if it is specifically listed as a RCRA Hazardous Waste, or if it exhibits any of the following characteristics of hazardous waste: ignitability, corrosively, reactivity, and/or toxicity. The regulatory definitions for each of these characteristics are contained in 40 Code of Federal Regulations (CFR) Part 261.21 through 261.24. Any wastes identified as being either RCRA Listed or Characteristic Hazardous Wastes must be managed in accordance with all applicable RCRA hazardous waste management regulations.

It is not anticipated that any listed wastes are present at the Site. Therefore, for the purposes of this plan, discussion will be limited to RCRA Characteristic Hazardous Wastes.

RCRA characteristic hazardous wastes are materials that exhibit ignitability (Hazardous Waste Code Drum 001), corrosively (Hazardous Waste Code Drum 002), reactivity (Hazardous Waste Code Drum 003), and/or one or more of the toxicity characteristics (Hazardous Waste Codes Drum 004 through Drum 043). The hazardous waste characteristics are identified through laboratory analysis of waste materials or based on the waste generator's knowledge of the process generating the waste. As part of the Site Characterization Report, soil samples were collected for hazardous waste characterization. None of the soil samples collected from the surface and subsurface contained levels above the regulatory limit for hazardous waste. Therefore, hazardous waste will not be encountered during the excavation of the soil.

The sediments in the launch pit at the shelter will be removed and stockpiled separately. Based on historical investigation, the potential for lead contamination above the regulatory limit of 5 mg/l (TCLP) vice 5 mg/l exists which would cause the sediments to be hazardous. These sediments will be analyzed for lead to determine if concentrations are above 5 mg/l prior to packaging and off-site shipping.

Spent PPE, equipment, and materials that are contaminated with RCRA Hazardous Waste may themselves be classified as RCRA Hazardous Wastes based on the "Derived From" Rule. It is anticipated that personal protective equipment (PPE) generally will be classified as radiological waste, rather than RCRA Hazardous Waste, since most spent PPE will be generated during the removal and handling of radiological materials.

During the excavation and removal of the launch pit sediments, PPE will be kept separate from other PPE used at the site. If RCRA Hazardous Wastes are identified at the Site, spent PPE generated during the removal and handling of the sediments will be disposed along with the RCRA hazardous waste itself.

4.2.3 Mixed Materials and Waste

Mixed wastes are defined by the Low Level Radioactive Waste Policy Act, Public Law 96-573; this includes radioactive material not classified as high-level radioactive waste, transuranic waste, spent nuclear fuel, or by-product material as defined by Section 11.e(2) of the Atomic Energy Act, and contains hazardous waste that is either listed as a hazardous waste in Subpart D of 40 CFR 261 and/or exhibits any of the hazardous waste characteristics identified in Subpart C of 40 CFR 261, or hazardous waste which also contains naturally occurring radioactive materials. Encountering mixed waste is not anticipated at the site.

4.2.4 Unregulated Materials and Wastes

In addition to the waste classifications identified above, remedial action activities may also result in the generation of waste materials that are not classified as radiological material or RCRA hazardous wastes but may contain hazardous substances requiring special management procedures (Regulated Wastes). Such Regulated Wastes may include the following:

4.2.4.1 Non-hazardous Contaminated Soils and Debris - Contaminated soils and debris that are not classified as radioactive material or RCRA hazardous wastes may be subject to restrictions for transportation, treatment, recycling, and/or disposal, depending upon the concentration of the contaminants present and the intended disposition of such materials.

4.2.5 Other Materials and Wastes

A variety of non-hazardous materials will likely be generated during remedial action activities that will also require proper management. These materials may include the following:

4.2.5.1 Construction Debris - This category includes material that has not been contaminated by radiological materials or otherwise impacted by hazardous substances or wastes. Clean debris may be used as on-site fill material or may be disposed of at a licensed off-site construction debris landfill.

4.2.5.2 Trash and Rubbish - This material includes spent packaging materials, equipment, and general garbage and trash that has not been impacted by radioactive or hazardous substances. Trash and rubbish will be stored on-site in appropriate containers and will be disposed of at a licensed off-site municipal waste facility. A licensed local municipal waste hauler will transport this material to a municipal landfill.

5.0 REGULATORY REQUIREMENTS

5.1 Prerequisites

The following prerequisites must be met prior to any individual shipping or assisting in the shipment of waste by any conveyance on the public highway, by vessel or rail, or by air.

5.1.1 The person performing activities associated with the shipment of hazardous, radioactive, or mixed waste shall be properly trained in accordance with the requirements of Reference 2.1, Part 172, Subpart H and will meet all qualification requirements of Reference 2.6.

5.1.2 The Broker performing shipments from the BOMARC Missile Site Remediation Project shall ensure that the following administrative requirements are addressed prior to any shipment of materials or wastes off-site:

5.1.2.1 All materials being shipped from the project site must be identified by the most appropriate Proper Shipping Name in accordance with the Hazardous Materials Tables of Reference 2.1, Part 172. Radioactive and mixed wastes being shipped for disposal or shipped to a collector or processor for eventual disposal must also be classified in accordance with Reference 2.3, Part 61 or a valid disposal site license, as appropriate.

5.1.2.2 If hazardous or mixed waste materials are generated on-site, these wastes must be identified by the most appropriate USEPA Waste Code in accordance with Reference 2.2.

5.1.2.3 For any hazardous or mixed wastes generated on-site, all notifications and certifications for waste material subject to the land disposal restrictions must be completed in accordance with Reference 2.2, Part 268.

5.1.3 The Broker shall ensure that all shipments of waste for treatment or disposal are prepared and shipped in compliance with the receiving facility's waste acceptance criteria.

5.1.4 Hazardous Materials not shipped as waste shall be shipped in such a manner as to conform to all federal, state and local ordinances. Material Safety Data Sheets for hazardous materials to be shipped shall be reviewed, if available, prior to any shipping related activities. Non-waste radioactive materials shall only be shipped to a facility upon provision of evidence, such as a valid USNRC license, that the material is acceptable at the receiving facility.

5.2 Tools, Materials, and Equipment

The Broker will ensure that all tools, administrative forms, survey instruments, labels, markings, and placards are available for each shipment of materials. Special care must be taken by the Broker to ensure that an adequate supply of such materials is maintained.

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