BOMARC Missile Site Plutonium Remediation

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

6.0 MATERIAL AND WASTE MANAGEMENT PROCEDURES

This section presents the specific guidelines and procedures that will be followed for the management of material and wastes handled during the remedial action activities at the Site. These procedures are generally applicable to the management of wastes after they have been excavated/removed. Specific procedures for material and waste excavation and removal are presented in the Site Operations Work Plan. The procedures presented in this section are based on the project goals of minimizing threats to Site workers, human health, and the environment during all material and waste handling activities. Specific procedures and guidelines for visually characterizing, segregating, handling, staging, storing, sampling, packaging, labeling, and transporting material and waste are presented in the following sections.

6.1 General

Material and waste handling activities will be performed in a manner that minimizes the threat of a release of potentially contaminated material to the environment and surrounding community, and protects worker health and safety. Care will be taken during operations and activities that will generate materials and wastes, such as excavation, demolition, and dewatering, to prevent releases of material, waste, and dust to the surrounding environment.

6.2 Material and Waste Handling Precautionary Measures

The following steps may be implemented prior to or during remedial activities to ensure that there are no releases of material and/or waste to the environment and surrounding community, and to protect Site workers.

6.2.1 Engineering controls such as water sprays may be used during activities that could potentially generate dust (i.e., excavation and loading) to prevent the spread of contaminants via wind dispersion.

6.2.2 Plastic sheeting may be placed under and around containers while they are being loaded. Any material that falls onto the plastic sheeting during loading will be collected and placed in the container.

6.2.3 Site workers will wear PPE appropriate for the specific task being performed, in accordance with the Site Health and Safety Plan. Spent PPE and contaminated disposable equipment and materials will be containerized and disposed of appropriately.

6.2.4 Equipment used during construction activities in potentially contaminated areas will be properly decontaminated before moving through clean areas of the Site or leaving the Site.

6.2.5 Haul roads and the loading area will be surveyed for radiation and contamination periodically during excavation and at the end of the project to verify that these areas have not been contaminated during material and waste handling operations. More frequent surveying of the roads may be performed as deemed necessary based on the schedule of activities, site conditions, and results of initial survey activities.

6.3 Pre-Excavation Screening

All materials and wastes to be excavated will be screened using appropriate radiation detection equipment. In addition, perimeter soil samples will be collected for on-site analysis to define the perimeter of the excavation based on a 5-meter grid. Materials containing >8 pCi/g Pu 239/240 will be segregated for off-site transportation. Materials containing <8 pCi/g Pu 239/240 will be segregated for use as Site backfill.

6.4 Material and Waste Handling, Staging, and Storage

The guidelines that will be used for handling, staging, and storage of waste materials generated during the remedial activities at the Site are presented below. 6.4.1 As radioactive contaminated soils are excavated, they will be transferred to the appropriate designated staging area or material preparation area for further management. The Site Operations Work Plan identifies the locations of the designated staging areas within the Exclusion Zone. Excavated soils will be segregated based on in-situ scanning results and on-site soil analytical results as they are being excavated. Contaminated soils can also be loaded directly in intermodal containers at the excavation area. Filled containers can be transferred to the staging area using a forklift.

6.4.2 Materials transported for disposal must not contain any free liquids and must pass the paint filter test. Therefore, any materials that are saturated upon excavation will be staged within the Exclusion Zone. Materials to be shipped will be analyzed using the paint filter test to satisfy applicable disposal requirements. The staging area will be equipped with a sump to allow for collection of waters. These waters will be transferred to the on-site holding tank for treatment and reuse. The sump will be cleaned out, as necessary, to remove accumulated sediments. Cleaning of the sediment traps will be performed using hand tools and heavy equipment, as appropriate. Sediments removed from the sump will be stabilized, as necessary, and disposed of along with soils. Water that is used will be collected and tested for radioactivity in accordance with the Sampling and Analysis Plan, Appendix C.

6.4.3 The staging areas for non-radioactive (<8 pCi/g Pu 239/240) soils will be constructed within the exclusion zone as close as possible to the areas where remedial activities will occur.

6.4.4 Radioactive soils with an activity of >8 pCi/g Pu 239/240 shall be packaged in intermodal containers at the stockpile area, loaded on to flat-bed trucks for transportation following the completion of the radiological screening and sampling/analysis procedures specified in the Sample and Analysis Plan (SAP).

6.4.5 All trucks, excluding those dedicated to the excavation site(s), will remain on the "contaminant-free" haul road. All vehicles leaving the Exclusion Zone will be scanned, and, if leaving the Site property, tested for removable contamination prior to release. In the unlikely event that contamination is discovered, the vehicles will be decontaminated at the equipment decontamination facility prior to release.

6.4.6 All hazardous materials and wastes generated at the BOMARC Missile Site Remediation Project will be stored in compliance with applicable state and federal law based on suspected or known contaminants. The following are general guidelines for the management of the soils:

6.4.6.1 The stockpiles of soil and debris will be sampled as required to meet the characterization data quality objectives specified in the Field Sampling and Analysis Plan and to meet the waste acceptance criteria of the disposal facility.

6.4.6.2 Chemically incompatible materials shall not be stored together.

6.4.6.3 Radioactive material stockpiles awaiting packaging or transport will be stored in a "Radioactive Materials Area" with yellow and magenta rope barriers or other physical boundaries and postings as specified in Reference 2.3. Stockpiled materials may not exceed 1000 cubic yards.

6.4.6.4 Hazardous or mixed wastes, if identified, will be properly labeled at the beginning of their accumulation within a storage or disposal container. Labeling and storage requirements will be as specified in Reference 2.2 for interim storage of hazardous wasters. No hazardous waste will remain in storage for greater than 90 days after accumulation begins.

6.4.6.5 Materials awaiting transport, once properly marked, labeled, and otherwise prepared for transport in accordance with Reference 2.1, may be stored without regard to Section 6.2 of this document.

6.5 Material and Waste Sampling and Analysis

6.5.1 Historical analytical results will be used to prepare a profile for the materials to be shipped to the appropriate disposal facility. Additional samples of excavated materials will be collected as needed during the remedial activities for disposal classification. The detailed procedures for sampling excavated materials are presented in the SAP. The SAP also identifies the anticipated analytical parameters for each waste stream to be sampled. A representative sample of each different waste stream will be collected and analyzed, with the results used to prepare a new waste profile, if necessary, or modify an existing waste profile.

6.5.2 Testing equipment specifications and sampling and analysis procedures to be utilized by personnel are included in the SAP.

NOTE: SAMPLE ANALYSIS IN SUPPORT OF ENVIOCARE WASTE PROFILING MUST BE PERFORMED BY A UTAH APPROVED LABORATORY.

6.6 Material and Waste Packaging

All material and waste scheduled for off-site transportation and disposal will be properly packaged in accordance with all applicable local, State and Federal regulations, including DOT Hazardous Materials Regulations contained in 49 CFR Parts 171 through 180. Materials scheduled for shipment out of state will be packaged in intermodal containers for shipment by rail. All other material and wastes to be shipped off-site will be packaged in appropriate containers such as lined roll-off boxes or 55-gallon drums. However, the packaging selected must be authorized for the specific material being shipped.

The following minimum packaging requirements apply for materials to be shipped.

6.6.1 Bulk Packaging

6.6.1.1 Bulk packaging must, at a minimum, meet the applicable requirements contained in 49 CFR 173.24, General Requirements for Packaging and Packages.

6.6.1.2 Bulk packaging must be covered. The top must be completely enclosed with no opening along the sides or openings in the top.

6.6.1.3 Bulk packaging (e.g. railcars, etc.) must be tightly sealed to prevent material from leaking out or water from leaking in. Shipments containing free water will not be accepted by the disposal facility. Bulk containers must be equipped with an appropriate liner to prevent contamination of the container itself.

6.6.1.4 Bulk packaging must be clean. It must not have any waste materials, or other material that could be mistaken for waste material, on the outer surface.

6.6.1.5 Bottom dump rail cars are not permitted.

6.6.1.6 Each bulk container that requires marking will be properly marked in accordance with 49 CFR 172 Subpart D.

6.6.2 Non-Bulk Packaging (Containers)

6.6.2.1 Non-Bulk packaging must, at a minimum, meet the applicable requirements contained in 49 CFR 173.24, General Requirements for Packaging and Packages.

6.6.2.2 Containers must be properly sealed to prevent load movement from "pumping" dust-laden air out of the container.

6.6.2.3 Containers must be clean. They must not have any waste materials, or other material that could be mistaken for waste material, on the outer surface.

6.6.2.4 Containers in a shipment must be properly loaded and blocked and braced securely to prevent shifting and damage during transport. Shippers should examine the specific transport loading requirements contained in 49 CFR 174 for rail and 49 CFR 177 for highway.

6.6.2.5 Although preferred, containerized rail shipments are not required to be enclosed or covered.

6.6.2.6 Overpack containers will be used only when necessary to meet DOT requirements for shipment. Drums may be shipped on pallets with prior approval from the Site Transportation and Disposal Coordinator. However, the pallets must be strong enough to withstand collapse during transit. The drums should be securely banded to the pallet. Drums may not be stacked.

6.6.2.7 Railcar beds used to transport containers must be free of all loose material, waste or otherwise.

6.6.2.8 Tarps must extend over the top and down the sides far enough to prevent access to the load, wind blowing through the load, or precipitation reaching the load.

6.6.2.9 Moving-Van trailers may not be used.

6.6.2.10 Each container that is requires labeling must be properly labeled in accordance with the requirements of 49 CFR 172 Subpart E.

6.6.2.11 Each container that requires marking must be properly marked in accordance with the requirements of 49 CFR 172 Subpart D and/or 49 CFR 173.421 and 425.

6.6.3 All packaging and preparation of materials for transport from the BOMARC Missile Site Remediation Project shall be in strict adherence to the requirements of Reference 2.1 and all other applicable federal, state, local and disposal site regulations.

6.6.4 Materials shall be packaged and the packaging inspected in accordance with the requirements of Reference 2.1, Part 173 for the Proper Shipping Name and USDOT Subtype of the material being offered for transport. Any required Type B and USNRC approved Type A Packages shall be prepared in accordance with the applicable Certificate of Compliance.

6.6.5 The major portion of wastes generated at the BOMARC Missile Site Remediation Project are expected to be less than 2000 pCi/g and, as such, not Class 7 hazardous material for shipment. If no other USDOT hazard is identified, the materials may be shipped without regard to the Hazardous Materials Regulations of Reference 2.1.

6.6.6 Wastes with specific radioactivity concentrations greater than 2000 pCi/g will be shipped as Class 7 hazardous material. Based on preliminary analysis of these materials, the appropriate proper shipping name will be "Radioactive Material, Low Specific Activity, n.o.s." or "Radioactive Material, Surface Contaminated Object, n.o.s." These materials will be packaged in collapsible, strong-tight intermodal containers.

6.6.7 Any unwanted materials or wastes found to be a hazardous or mixed waste based on characterization data, will be packaged either as Class 7 (Radioactive-LSA or SCO) materials or Class 9 (Hazardous Waste, Solid) materials depending upon its radiological constituents. The materials will also be packaged in intermodal containers.

6.6.8 All packages offered for transport shall be properly marked and labeled in accordance with the requirements of Reference 1, Part 172 prior to shipment.

6.6.9 Shipping Papers will be prepared for shipments as follows:

6.6.9.1 All hazardous materials (unless otherwise excepted) shall have USDOT hazardous materials shipping papers prepared in accordance with Reference 2.1, Parts 172.200 - 172.205.

6.6.9.2 All hazardous and mixed waste shall, in addition to USDOT hazardous materials shipping papers, shall have a Uniform Hazardous Waste Manifest selected and prepared in accordance with Reference 2.2, Part 262.20 and Reference 2.8.

6.6.9.3 All radioactive waste shall have a USNRC Uniform Radioactive Waste Manifest prepared in accordance with the requirements of Reference 2.3, Part 20.311.

6.6.9.4 Additional forms shall be prepared as may be required by Federal, State, and Local ordinances, and by receiving site license or acceptance criteria.

6.7 Procedure for Material Loading

With the exception of common carrier shipments of hazardous materials (non-waste shipments) the following procedure shall be followed when loading material for transportation.

6.7.1 Conduct and document a visual inspection of the conveyance and ensure any discrepancies are repaired prior to loading. This inspection shall include all vehicle safety devices, tires, brakes, and trailer as applicable.

6.7.2 For radioactive and mixed waste, defined as >8 pCi/g for this requirement, perform and document a radiation and contamination survey of the conveyance prior to loading. Compare the survey results to the requirements of Reference 2.1. Vehicles with contamination levels greater than 10% of the DOT limits shall not be loaded.

6.7.3 The Broker shall inspect all packages as they are loaded to ensure that the packages are in full compliance with all the requirements set forth in this procedure. Incompatible materials shall be segregated as required by Reference 2.1.

NOTE: SPECIAL CARE SHALL BE TAKEN TO ENSURE THAT ALL STRONG TIGHT CONTAINERS USED FOR RADIOACTIVE MATERIAL TRANSPORT ARE COMPLETELY SEALED TO THE MAXIMUM EXTENT PRACTICAL. THIS INCLUDES THE USE OF SEALANT ON SEAMS OF METAL BOXES. SPECIAL CARE SHALL ALSO BE TAKEN TO ENSURE THAT ALL SPECIFICATION PACKAGES ARE PROPERLY PREPARED FOR TRANSPORT AND IN GOOD CONDITION PRIOR TO TRANSPORT.

6.7.4 Upon completion of loading, visually verify that all packages are loaded.

6.7.5 Verify the proper use of blocking, bracing, dunnage, and tie-down, as appropriate.

6.7.6 Verify the conveyance is properly placarded, as applicable.

6.7.7 For radioactive material shipments, perform and document a final contamination and radiation survey of the conveyance and ensure that the results are in compliance with the requirements of Reference 2.1.

6.8 Post Loading Requirements

6.8.1 Have the driver (or transporter's representative) and shipper (or shipper's agent) sign all required forms including the exclusive use instructions.

6.8.2 Review all paperwork to ensure legibility.

6.8.3 Copy and distribute paperwork in accordance with the Paperwork Distribution Checklist specified in Reference 2.6, Appendix H. Uniform Hazardous Waste Manifests shall be distributed in accordance with Reference 2.2, Part 262 and as required by the laws of the generating state.

6.8.4 Verify that the driver (transporter's representative) understands all special instructions such as the maintenance of exclusive use and prior notification requirements. The shipment may now be released for transport.

6.8.5 Make any required prior notification of correction telephone calls. Mail copies of the Radioactive Shipment Manifest (RSM) cover sheets to the disposal site for radioactive waste shipments, if applicable.

6.9 Material and Waste Labeling and Dating

Material and waste containers and packages will be marked in accordance with applicable local, State and Federal requirements (49 CFR 172 Subpart D). In addition, a unique identification number will be assigned to each container used for material storage to allow for proper tracking of the material from the time of shipment through off-site disposal and receipt of a certificate of disposal (if applicable). Containers will also be labeled to indicate the type of material they contain, the date of shipment, and the area from which the material originated. The information will be recorded on a Material and Waste Container Management Data Sheet (See Appendix G). The material and waste management database will be periodically reviewed to ensure that no materials are stored on-site while awaiting shipment for a period of time longer than allowed by applicable waste accumulation regulations (90 days for hazardous wastes).

6.10 Material and Waste Transportation and Disposal

6.10.1 This section describes the steps for transportation and disposal of material and waste during remedial activities. Details regarding the on-site loading operations, including material weighing and loading and are provided in the Site Operations Work Plan. Material and waste disposal summary will be contained in the Material and Waste Disposal Tracking Log, Appendix G.

6.10.2 The enroute rail tracking system and format will be available following contract execution with the transportation subcontractor. The transportation subcontractor will provide a daily summary of railcar locations. Based upon the present shipping schedule and material volume estimates, three or four railcars of radioactive material will be shipped weekly.

6.10.3 The transportation route for the flat-bed trucks from the BOMARC facility to the Lakehurst rail facility where the transportation containers will be loaded onto rail cars is depicted on Drawing 799147-B3 in Appendix F.

6.10.4 All radioactive materials >8 pCi/g excavated during the remedial activities will be transported to an appropriate, licensed and permitted facility. The radioactive wastes will be disposed of at the Envirocare facility at Clive, Utah.

If RCRA Hazardous Wastes are identified during the remedial activities, a licensed hazardous waste hauler will transport them to a permitted hazardous waste disposal facility. Each shipment of waste must be accompanied by a uniform hazardous waste manifest and must be labeled, marked, and placarded in accordance with DOT regulations.

Regulated wastes which are not classified as radioactive, RCRA hazardous, or mixed wastes will be transported to an appropriate permitted/licensed disposal facility by a hauler that is licensed to carry the specific type of regulated waste. Materials must be packaged, marked, labeled, and placarded in accordance with DOT regulations. Approval by the Industrial Operations Command (IOC) is required prior to disposal of these regulated materials and wastes.

6.10.7 Non-contaminated wastes will be transported by a licensed hauler to a permitted municipal waste or construction and demolition debris landfill.

7.0 RECORDS

7.1 The broker shall retain copies of records, forms, and shipping papers generated as a result of this procedure until written acknowledgment is received from the consignee for all waste shipments or telephone acknowledgment is received for all non-waste shipments. Notifications and reports shall be in accordance with Reference 2.6.

7.2 Copies of shipping papers shall be maintained in the on-site project file for the duration of the project.

BACK || CONTENTS || NEXT