3.4.6 Load-Out and Transport to Rail Facility
The load-out area is located adjacent to the contaminated soil/debris stockpiles. Although the stockpiles are located within the Exclusion Zone, the flat bed truck used for the transport of the intermodals will be located outside the Exclusion Zone.
The transportation subcontractor will deliver empty intermodal containers that will be filled within the Exclusion Zone at the loading area or directly adjacent to the excavation. The containers are double lined with a 10-mil plastic inner liner and a 64-mil neoprene rubber outside liner that provides for the strength and durability of the container. Each container has a capacity of 10 cubic yards in volume or 12 tons by weight.
After the loading of the containers to capacity, the containers will be sealed, inspected and cleaned of loose material, and surveyed in accordance with the Sampling and Analysis Plan. A crane or a forklift will be used to lift and store the packages until ready for shipment. A Dynamometer mounted to the crane or forklift will be used to determine the actual container weight.
After the completion of the appropriate DOT and Envirocare documentation by the Broker, the containers will be loaded onto flat bed trucks for delivery to the rail facility at Lakehurst, New Jersey, approximately 10 miles from the site. See Drawing 799147-B3, Transportation Route (Appendix F). The maximum number of days that the intermodal containers will be stored at the rail facility within the rail cars is 30 days.
Flat bed trucks will arrive on-site and will be directed to the loading station, which is located adjacent to the Exclusion Zone. A general survey of the truck will be conducted prior to loading to confirm the absence of off-site contamination. Wipe samples will also be collected, as necessary.
The crane or a forklift will load the containers onto the trucks and then be transported to Lakehurst, New Jersey. At the rail facility, a second crane or forklift will load the containers on rail cars for delivery to Envirocare in Clive, Utah.
Daily surveying of the truck loading area during load-out days will be conducted to confirm the absence of contamination within the clean zone used by the transport trucks.
3.4.7 Manifesting, Transportation, and Disposal
Shipping manifests, instructions to the carrier, and advance shipment notification forms will be prepared, approved, and one copy each given to McGuire AFB and IOC representatives.
A separate set of forms will be prepared for each container. Waste characterization (profiling) as required by Envirocare has been conducted. However, radiological sampling of the soils will be ongoing during the remediation effort, which will be used to determine the activity of the soils and confirm the previous profile.
All waste materials will be properly packaged and labeled in accordance with the United States Department of Transportation (DOT) Hazardous Materials Regulations contained in 49 CFR Parts 171 through 180. In addition, a unique identification number will be assigned to each container and/or rail car to permit tracking of the waste from shipment through off-site disposal and receipt of the certificate of acceptance and disposal.
All exterior surfaces of the trucks/cars/containers will be surveyed prior to shipment to ensure that all are in compliance with DOT 49 CFR 173.441 and 173.443. Any radioactive material found on the exterior of the trucks/cars will be decontaminated and resurveyed prior to release for transportation. This process will be documented prior to release on appropriate forms.
All rail shipments will be completed under contract with a single transporter. The transporter will provide a daily report to include tracking information for all rail cars. All coordination and tracking of shipments will be through a single point-of-contact, irrespective of the "secondary" rail companies involved in car movements.
All radioactive waste materials will be disposed of at the Envirocare Facility located in Utah under their Nuclear Regulatory Commission (NRC) Special Nuclear Material License. Details on waste manifestation, transportation, and disposal are provided in the Waste Management, Transportation and Disposal Plan (Appendix D).
3.4.8 Quality Control and Oversight
As excavation proceeds it will be necessary to document conditions prior to excavation, during excavation, after excavation, after backfilling and after final cover construction. Documentation activities may include, but not be limited to:
· Quantity of contaminated soils removed from excavation areas,
· Quantity of clean soils removed from excavation areas,
· Location of soils removed from excavation areas (using elevation and planar coordinates),
· Quantity of contaminated debris removed from Shelter 204,
· Quantity of clean debris removed from Shelter 202, 204, 206, and the bunkers,
· Soil sample locations, survey locations and associated results,
· Air monitoring results,
· Quantity and quality of backfill materials delivered and placed, and
· Transportation documentation and tracking
These activities will be documented by appropriate field personnel assigned to each task, and tracked by the on-site QA Officer.
3.4.9 Final Status Survey Sampling and Analysis
Final status survey sampling and analyses will be performed following excavation of soils >8 pCi/g Pu 239/240 materials and prior to backfilling, in accordance with the guidelines specified in NUREG 1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). The Final Status Survey (FSS) design is presented in Sampling and Analysis Plan (Appendix C).
The review process will determine whether the data demonstrates compliance with the cleanup goal (8 pCi/g). If not, the site will be evaluated for additional remediation at areas that fail to meet the criteria.
If the results demonstrate compliance, the results of the analysis along with FSS data will be presented to the Air Force for review and approval. After approval from the Air Force, the excavations will be backfilled.
3.5 Back Filling and Site Restoration
Backfilling of the excavations will commence after the Final Status Survey sampling program has confirmed that soils containing >8 pCi/g Pu have been removed from individual survey units and has been approved by the Air Force. Following this sampling, the surveyor will perform a topographic survey to establish the final limits of excavation and volume of soil removed from the individual survey units.
The front-end loader used for loading of contaminated soils will be decontaminated. The front-end loader will then be used to transfer the clean soils back into the excavation. After all the clean soils have been returned into the excavation, clean backfill will be brought on-site. The area of this backfill material will be surveyed for the endangered plants noted in Section 3.3.3.5. Erosion control measures will also be installed at the Borrow Area.
Initially, backfilling will also be performed using the clean soils located at the clean soil stockpiles on-site. On-site sampling and analysis will confirm that all soils located at the clean soil stockpiles are less the 8 pCi/g Pu.
Backfilling of soils will be performed using native soils from the Pinelands area. To insure acceptance of imported fill materials before back filling commences, the imported fill will be analyzed for BTEX, TPH, and TCLP during the initial stages of the project. Imported soils will be sampled every 500 cubic yards.
The excavations will be backfilled by placing the materials in 12-inch lifts. For excavation less than 4 feet, the soils will be spread using a dozer. The material will be tracked in place with no further compaction. For excavation greater than 4 feet, backfill material will be placed, then spread and tamped using an excavator. The top 4 feet will be spread and compacted using a dozer as discussed above. All areas will be backfilled to within 4 inches of existing grade. The top 4 inches will then be backfilled by loosely placing one lift of topsoil. The area will then be hydroseeded.
3.6 On-Site Laboratory and Radiation Control Operations
An extensive monitoring, sampling, and on-site analytical program will be implemented in order to:
· Ensure that all contaminated soil materials exceeding the cleanup criteria are removed from the site,
· Minimize the volume of soil inadvertently removed from the site that is below the cleanup standards,
· Verify that all items leaving the radiologically controlled area are surveyed and meet the NRC Regulatory Guide 1.86,
· Ensure that quantities of airborne dust containing radionuclides leaving the site are at or below acceptable levels,
· Verify that all shipping containers meet the DOT (49 CFR 173.421) criteria before leaving the site,
· Monitor and verify that exposure of workers to external gamma radiation and airborne alpha emitters is within an acceptable limit and is ALARA, and
· Confirm that the Site meets the cleanup requirements stated in the Project Scope-of-Work and the Record of Decision through a Final Status Survey.
The quantitative analytical data generated as a result of these activities will be sufficient in type, quantity, and quality such that the cleanup of the site is verified, minimization of exposure to on-site workers can be quantified, and migration of radioactive materials to adjacent properties and roads is proven to be negligible. Each aspect of on-site monitoring, sample collection, and field laboratory operations including laboratory Data Quality Objectives are presented in the Sampling and Analysis Plan (Appendix C).
3.7 Supporting Operations
3.7.1 Health and Safety, and Radiation Protection
The HASP will be implemented to ensure both worker and public protection throughout the remediation effort. This plan establishes requirements in regard to medical surveillance and bioassays, PPE and air monitoring, stop work authority, restricted work areas, hazardous and radiation work permits, training requirements, emergency response and notifications, and waste minimization and pollution prevention. The provisions of this plan are mandatory for all on-site employees, including subcontractor employees.
The ALARA Program is a commitment on the part of the management of this project to closely monitor all exposures and seek methods or techniques to further reduce the radiation exposure personnel may receive. All reasonable efforts will be made to keep radiation exposures, as well as releases of radioactive material to unrestricted areas, to levels that are ALARA. Toward this end, several ALARA principles will be used:
· The CHP will have sufficient delegated authority to enforce regulations and administrative practices concerning any aspect of the health, safety, and Radiation Protection Plan,
· Personnel will be trained in safety procedures and ALARA philosophies to a level commensurate with their work scope,
· Safety inspections will be conducted,
· Hazardous and Radiation Work Permits will be required, and
· Radiation exposures will be minimized where practical, by the use of time, distance, shielding, administrative controls and engineering controls as specified in 10 CFR 20.1101(b).
The CHP, as the site safety representative, in consultation with the PM and applicable Home Office Safety Professionals will establish environmental health and safety policies and conduct independent inspections of the implementation of those policies.
Access to the Site will be controlled to protect workers from unnecessary radiation exposure and to minimize the potential for the spread of radiation. Each area will be divided into three zones:
· Exclusion Zone - Actual areas of contamination. Represents area that has highest inhalation exposure potential and/or presents a high probability of skin contact,
· Contamination Reduction Zone - Areas immediately surrounding the Exclusion Zone, including the personnel and equipment decontamination facilities, and
· Clean Zone - Areas outside the Contamination Reduction Zone where adverse exposure is unlikely.
Access to these areas will be controlled for people, vehicles, and equipment by fencing and posting the area, or by using other methods to prevent inadvertent entrance. Smoking, drinking, eating, or other activities that would enhance the transfer of radionuclides into the human body will be prohibited within the Exclusion and Contamination Reduction Zones.
Air samples will be collected and analyzed in accordance with the Sampling and Analysis Plan. High volume samplers will typically be used for area monitoring. Data from the high volume monitors will be used to assess releases due to excavation operations. Air filters will be analyzed for radioisotope identification and quantification to ascertain the airborne concentration.
Generally, work at the site will be performed under Level D protection. Level C protection might be required for activities where the potential for air-borne particulates (in excess of the action level as specified in the HASP) exists. This includes decontamination of shelter 204, storage piles, and material loading areas. If required, full-face, cartridge-type air purifying respirators will be utilized, as directed by the CHP.
3.7.2 Quality Control
The Sampling and Analysis Plan will be implemented and monitored to ensure that all sampling, surveying, and construction quality objectives are met.
The Site Quality Assurance Officer will work directly with the Project Manager and the Construction Manager and will be delegated authority to enforce the requirements and administrative practices concerning any aspect of the quality control requirements depicted in this Plan and its Appendices. A three-phase control process will be implemented which includes:
· Preparatory Phase Inspection - Review and document applicable requirements and verify that the necessary resources, conditions, and controls are in place,
· Initial Phase Inspection - Check and document preliminary work for compliance with procedures and plans, and
· Follow-Up Phase Inspection - On-Site monitoring and documentation of the practices and operations taking place and verifying continued compliance with the project requirements and applicable regulations. Outstanding and nonconforming items or practices will be identified, along with corrective measures.
Upon conclusion of a definable feature of work, a review will be completed to verify that all documentation is in order prior to close out and transfer of files to IOC.
3.7.3 Decontamination and Release Operations
All equipment exiting a radiologically controlled area will be decontaminated and surveyed to demonstrate compliance with NRC Regulatory Guide 1.86, a summary of which is provided in Table 3-2. Aspects of rail transportation will be regulated by DOT 49 CFR 173.421.
All equipment will be dedicated for single use for the duration of the project as practical and will remain within the Exclusion Zone at the main site until decontaminated, surveyed, and verified in conformance with release limits.
All equipment will be dry brushed/scraped prior to transport to the site decon facility to retain contamination within the Exclusion Zone. At the decon facility, the following sequence will be followed until the equipment is verified clean:
· Low pressure (2,000 psi) wash until visibly clean,
· Low pressure detergent wash with brushing,
· High pressure wash (10,000 psi), and
· Sandblasting (if required as a lashnt resort).
Table 3-2
Decontamination and Release Operations
Surface Contamination Guidelines
Allowable Total Residual SurfaceContamination(dpm/100 cm2)a
|
Radionuclides(b) |
Average(b,c) |
Removable(d,f) |
Maximum(d,e) |
|
Plutonium 239/240, Americium-241 |
100 |
20 |
300 |
|
Beta-gamma emitters (radionuclides with decay modes other than alpha emission or spontaneous fission) |
5,000 (Beta-gama) |
1,000(Beta-gama) |
15,000(Beta-gama) |
a. As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute measured by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
b. Where surface contamination by both alpha-and beta-gamma-emitting radionuclides exists, the limits established for alpha-and beta-gamma-emitting radionuclides should apply independently.
c. Measurements of average contamination should not be averaged over an area of more than 1 m2. For objects of less surface area, the average should be derived for each such object.
d. The average and maximum dose rate associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad/h and 1.0 mrad/h, respectively, at 1 cm.
e. The maximum contamination level applies to an area of not more than 100 cm2.
f. The amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and measuring the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of surface area less then 100 cm2 is determined, the activity per unit area should be based on the actual area and the entire surface should be wiped. The numbers in this column are maximum amounts.
The use of solvents may be necessary to strip outer layers of porous rubber parts (e.g. tires). This procedure will only be used as a last resort. Other porous parts, (e.g. seats, wiper blades, etc.) which cannot be readily decontaminated, will be removed and treated in the same manner as contaminated soil material.
3.7.4 Personnel, Equipment, and Facilities Demobilization
At the conclusion of remedial activities, the Project will demobilize from the BOMARC site. All equipment will have been decontaminated and equipment tested and cleared through the Radiation Protection Plan (Appendix B). Decontamination and testing details are provided in the HASP (Appendix A) and Sampling and Analysis Plan (Appendix C).
Additionally, radiological surveys of roads, and decontamination facilities will be performed to meet the requirements of the Radiation Protection Plan. All records, including all post work submittals, will be submitted to the IOC.
3.8 Project Reporting
Throughout the execution of activities on-site, Daily and Monthly Reports will be prepared and distributed (as indicated on the report forms) electronically where possible.
3.8.1 Daily Reports as a minimum will provide the following:
· Personnel On-site by Contractor
· Major Equipment On-site
· Work Performed
· Problems Encountered
· Safety Issues
3.8.2 Monthly Reports as a minimum will provide the following:
· Narrative of Work Performed during report month
· Narrative for Work Expectations for the pursuant month
· Updated Project Schedule by Activity
· Scheduled Percentage Complete
· Actual Percentage Work Completed
· Safety Meeting Topic and Presenter
· Encountered Problems and Resolutions
Examples of the daily and monthly report forms are included in Appendix G.
3.9 Final Report
A final report of the site activities will be prepared once all required paper work and data for the project is received. The report will present the result of remediation sampling, volumes of soils excavated, volumes of soils transported for off-site disposal, and the results of the final status survey. All supporting documentation from the sampling (on-site/off-site), surveying, transportation, and disposal efforts will be included in the report. Once comments are received, a final draft will be prepared, followed by the final version of the report.
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