DOE/NE-ID-11230

Revision 0

Remedial Action Report for Operable Unit 3-13, Group 6, Buried Gas Cylinders

June 2005

DOE/NE-ID-11230Revision 0

Project No. 23510

Remedial Action Report for Operable Unit 3-13, Group 6, Buried Gas Cylinders

June 2005

Prepared for theU.S. Department of Energy

DOE Idaho Operations Office

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ABSTRACT

In accordance with the Federal Facility Agreement and Consent Order between the U.S. Department of Energy Idaho Operations Office, the Environmental Protection Agency, and the Idaho Department of Environmental Quality, this Remedial Action Report was produced to document the completion of remedial actions for the Waste Area Group 3, Operable Unit 3-13, Group 6, Buried Gas Cylinders. This report provides summary descriptions of the actions taken to meet the requirements of the Record of Decision for the Idaho Nuclear Technology and Engineering Center, as identified in the Remedial Design/Remedial Action Work Plan for Operable Unit 3-13, Group 6, Buried Gas Cylinders, and in accordance with requirements identified in the Federal Facility Agreement and Consent Order.

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CONTENTS

ABSTRACT........................................................................................................................................... iii

ACRONYMS......................................................................................................................................... ix

1. INTRODUCTION...................................................................................................................... 1-1

1.1 Site Description and History .......................................................................................... 1-2

1.1.1 CPP-94......................................................................................................... 1-31.1.2 CPP-84......................................................................................................... 1-3

1.2 Purpose.......................................................................................................................... 1-3

1.2.1 Documentation Necessary to Support Deletion of the Site from the NPL ...... 1-5

2. GROUP 6 BACKGROUND....................................................................................................... 2-1

2.1.1 Remedial Design/Remedial Action Work Plan.............................................. 2-1

3. REMEDIATION ACTIVITIES .................................................................................................. 3-1

3.1 CPP-94 Remediation...................................................................................................... 3-1

3.1.1 CPP-94 Mobilization and Site Controls ........................................................ 3-13.1.2 CPP-94 Cylinder Excavation ........................................................................ 3-13.1.3 CPP-94 Cylinder Inspection ......................................................................... 3-13.1.4 CPP-94 Cylinder Staging and Treatment....................................................... 3-13.1.5 CPP-94 Cylinder Decommissioning and Disposal......................................... 3-23.1.6 CPP-94 Post Removal Sampling................................................................... 3-23.1.7 CPP-94 Site Reclamation.............................................................................. 3-23.1.8 CPP-94 Modifications to the RD/RA WP ..................................................... 3-2

3.2 CPP-84 Remediation...................................................................................................... 3-2

3.2.1 CPP-84 Mobilization and Site Controls ........................................................ 3-23.2.2 CPP-84 Cylinder Excavation ........................................................................ 3-33.2.3 CPP-84 Cylinder Inspection and Removal .................................................... 3-33.2.4 CPP-84 Cylinder Staging and Sampling........................................................ 3-33.2.5 CPP-84 Cylinder Treatment.......................................................................... 3-43.2.6 CPP-84 Cylinder Decommissioning.............................................................. 3-43.2.7 CPP-84 Waste Disposal................................................................................ 3-53.2.8 CPP-84 Post-Removal Sampling .................................................................. 3-53.2.9 CPP-84 Site Reclamation.............................................................................. 3-53.2.10 CPP-84 Modifications to the RD/RA WP ..................................................... 3-5

4. CHRONOLOGY OF EVENTS .................................................................................................. 4-1

5. PERFORMANCE STANDARDS AND QUALITY CONTROL ................................................ 5-1

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6. FINAL INSPECTION AND CERTIFICATIONS....................................................................... 6-1

6.1 Inspections..................................................................................................................... 6-1

6.2 Health and Safety........................................................................................................... 6-1

7. OPERATION AND MAINTENANCE ACTIVITIES................................................................. 7-1

8. SUMMARY OF PROJECT COSTS........................................................................................... 8-1

9. OBSERVATIONS AND LESSONS LEARNED........................................................................ 9-1

10. OPERABLE UNIT CONTACT INFORMATION.................................................................... 10-1

11. REFERENCES......................................................................................................................... 11-1

Appendix A—Original Magnetometer Survey Report .......................................................................... A-1

Appendix B—Photographs of Remediation Activities for CPP-94 and CPP-84 .................................... B-1

Appendix B-1—Photographs of Remediation Activities for CPP-94 .......................................... B-3

Appendix B-2—Photographs of Remediation Activities for CPP-84 ........................................ B-13

Appendix C—CPP-94 HF Cylinder Treatment Facility Information..................................................... C-1

Appendix C-1—Suitability Determination for SET.................................................................... C-3

Appendix C-2—Notification of Treatment of Hydrogen Fluoride from CPP-94 ........................ C-7

Appendix D—CPP-94 Post-Removal Sample Locations ...................................................................... D-1

Appendix D-1—CPP-94 Post-Removal Sample Locations ......................................................... D-3

Appendix D-2—CPP-84 Post-Removal Sample Locations ......................................................... D-7

Appendix E—Final Magnetometer Survey Reports for CPP-94 and CPP-84 .........................................E-1

Appendix E-1—WAG 3, Geophysical Field Screening for CPP-94.............................................E-3

Appendix E-2—WAG 3, Geophysical Field Screening for CPP-84...........................................E-11

Appendix F—Recycling Facility Information .......................................................................................F-1

Appendix F-1—E-mail Approving SET as a Recycling Facility ..................................................F-3

Appendix F-2—E-mail Approving CFC as a Recycling Facility..................................................F-9

Appendix F-3—Notification of Acceptance of Chlorine Cylinder for Recycling.......................F-15

Appendix F-4—Notification of Acceptance of Freon for Recycling and Decommissioning of Cylinders .................................................................................................................F-19

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Appendix G—Soil Compaction Certification Report............................................................................ G-1

Appendix H—Completed CPP-94 Pre-Final Inspection Checklist ........................................................ H-1

Appendix I—Escalation Indices.............................................................................................................I-1

Appendix J—Actual Costs and Cost Reporting Adjustments................................................................. J-1

FIGURES

1-1. Location of the Idaho National Laboratory ............................................................................... 1-2

1-2. Locations of CPP-84 and CPP-94 near INTEC......................................................................... 1-4

TABLES

2-1. Data quality objective (DQO) COPC list and action levels for CPP-94 and CPP-84 (DOE-ID 2004a, Table 3-2) ..................................................................................................... 2-2

3-1. Summarization of cylinders recovered from CPP-84 ................................................................ 3-3

4-1. Chronology of events relating to WAG 3, OU 3-13, Group 6, Buried Gas Cylinders................. 4-1

5-1. Post-removal confirmation sample results for CPP-94 compared to DQO action levels............. 5-1

5-2. Post-removal confirmation sample results for CPP-84 compared to DQO action levels............. 5-2

8-1. Cost summary of remedial actions for CERCLA Group 6 sites CPP-94 and CPP-84................. 8-1

10-1. Points of contact for the WAG 3, OU 3-13, Buried Gas Cylinders project .............................. 10-1

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ACRONYMS

BBWI Bechtel BWXT Idaho, LLC

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFA Central Facilities Area

CGA Compressed Gas Association

COPC contaminant of potential concern

DEQ Department of Environmental Quality (Idaho)

DOE U.S. Department of Energy

DOT Department of Transportation

DQO data quality objective

EPA Environmental Protection Agency

FFA/CO Federal Facility Agreement and Consent Order

HF hydrogen fluoride (hydrofluoric acid)

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Center

NPL National Priorities List

OU operable unit

PINS portable isotopic neutron spectrometer

RA remedial action

RD remedial design

ROD Record of Decision

WAG waste area group

WP work plan

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Remedial Action Report for Operable Unit 3-13, Group 6, Buried Gas Cylinders

1. INTRODUCTION

The Idaho National Laboratory (INL)a is a government facility managed by the U.S. Department of Energy (DOE), located 51.2 km (32 mi) west of Idaho Falls, Idaho, that occupies 2,305 km2 (890 mi2) of the northeastern portion of the Eastern Snake River Plain (Figure 1-1). INL is currently listed on the National Priorities List (NPL). The NPL is the list of national priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States and its territories. To better manage environmental investigations and remedial actions (RAs), INL is divided into 10 waste area groups (WAGs). Identified contaminant release sites in each WAG aregrouped into operable units (OUs) to expedite the investigations and RAs.

The Idaho Nuclear Technology and Engineering Center (INTEC) is located in the south-central area of INL (see Figure 1-1) and is designated as WAG 3, which is currently subdivided into 14 OUs. In 1999, a Final Record of Decision (ROD) was completed for WAG 3, OU 3-13. Fifty-five release sites were identified in the ROD requiring RA to mitigate risks or threats posed to human health and/or the environment. These 55 sites were divided into seven groups based on similar media, contaminants of concern, accessibility, or geographic proximity. The seven groups are

• Group 1: Tank Farm Soils

• Group 2: Soils Under Buildings and Structures

• Group 3: Other Surface Soils

• Group 4: Perched Water

• Group 5: Snake River Plain Aquifer

• Group 6: Buried Gas Cylinders

• Group 7: SFE-20 Hot Waste Tank System.

In accordance with the Federal Facility Agreement and Consent Order (FFA/CO) (DOE-ID 1991) between the DOE Idaho Operations Office (DOE Idaho), the Environmental Protection Agency (EPA), and the Idaho Department of Environmental Quality (DEQ), hereafter referred to as the Agencies, DOE submits this Remedial Action Report for the WAG 3, OU 3-13, Group 6, Buried Gas Cylinders.

This report documents completion of remediation activities for Group 6, Buried Gas Cylinders, as identified in the ROD for INTEC (DOE-ID 1999), as identified in the Remedial Design/Remedial Action (RD/RA) Work Plan (WP) for OU 3-13, Group 6, Buried Gas Cylinders (DOE-ID 2004a), and in accordance with requirements identified in the FFA/CO (DOE-ID 1991).

a. Beginning February 1, 2005, the name of the Idaho National Engineering and Environmental Laboratory was changed to Idaho National Laboratory (INL). The Idaho Completion Project is the name of the project that is performing remediation work at the Idaho National Laboratory.

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Figure 1-1. Location of the Idaho National Laboratory.

1.1 Site Description and History

Group 6, Buried Gas Cylinders, consists of two buried gas cylinder sites designated Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) sites CPP-94 and CPP-84. Gas cylinders believed to have been derived from INTEC were buried in trenches outside the INTEC fence during the 1950s and 1960s. Anecdotal information indicates CPP-84 consisted of cylinders derived from INTEC; while the derivation of cylinders at CPP-94 was not known, but was speculated to be from INTEC as well.

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1.1.1 CPP-94

Site CPP-94 is located in an area approximately 2.4 km (1.5 mi) northeast of the INTEC security fence, along the south side of a dirt security road (see Figure 1-2). Four exposed cylinders discovered atthe site provided evidence to suggest the cylinders contained hydrogen fluoride (HF). Neither anecdotal evidence nor near-surface radiological surveys indicated the presence of radiological contamination at CPP-94. Three exposed cylinders were identified at one location, and another cylinder was identified

approximately 60 ft to the northeast. The approximate dimensions of CPP-94 are 6 × 6 m (20 × 20 ft)

for the three exposed cylinders and approximately 3 × 3 m (10 × 10 ft) for the additional cylinder to the northeast (cylinders were buried approximately 0 to 2 ft deep in both areas). Appendix A contains the geomagnetic survey results confirming the cylinder locations. Portable isotopic neutron spectrometer (PINS) instrumentation was used to analyze a fully exposed cylinder present at the site. The PINS analysis results provided a high confidence that HF was present in the cylinder in greater than trace quantities.

1.1.2 CPP-84

Site CPP-84 is located outside the current INTEC security fence, east of Lincoln Boulevard

and south of the Big Lost River (see Figure 1-2). The approximate dimensions of CPP-84 are 8 × 26 m

(25 × 85 ft) and approximately 2 m (5 ft) deep. The site consisted of a buried trench where compressed gas cylinders were previously disposed. The cylinders were believed to contain gases used for construction purposes. The exact number and contents of the cylinders were not known, but anecdotal evidence suggested that 40 to 100 cylinders were disposed at the site. The gases in the cylinders were suspected to include acetylene, compressed air, argon, carbon dioxide, helium, nitrogen, or oxygen. Neither anecdotal evidence nor near-surface radiological surveys indicated the presence of radiological contamination at CPP-84. An investigative geomagnetic survey of the area confirmed the location of the buried cylinders (see Appendix A).

1.2 Purpose

The purpose of this Remedial Action Report is to document completion of RAs for OU 3-13, Group 6, Buried Gas Cylinders. This report includes information outlined in the RD/RA WP (DOE-ID 2004a) and required by the FFA/CO. Acceptance of this report by the Agencies fulfills and completes the requirements detailed in Section 2.1.1.2, Remedial Action Process, of the FFA/CO and renders CERCLA sites CPP-84 and CPP-94 clean and closed. Specific requirements to include in this report from the FFA/CO and RD/RA WP are listed below with the document sections addressing the requirement:

1. A brief description of outstanding items from the Pre-Final Inspection Report (Section 6)

2. Synopsis of work defined in the RA WP (Section 4)

3. Certification that this work was performed (Section 6)

4. Explanation of any modifications to the RA WP (Section 5)

5. Certification that the remedy is operational and functional (Section 6)

6. Documentation necessary to support deletion of the site from the NPL (Section 1.2.1).

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Figure 1-2. Locations of CPP-84 and CPP-94 near INTEC.

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1.2.1 Documentation Necessary to Support Deletion of the Site from the NPL

OU 3-13, Group 6, Buried Gas Cylinders, is a segment of the remediation work being conducted at INL. INL as a whole is currently listed on the NPL. In accordance with Section XXV of the FFA/CO, to remove INL from the NPL, all RAs require completion as determined by EPA in consultation with DEQ.

This RA Report was prepared using guidance listed in Section 2.2.2, Final RA Report, and Section 2.5.3, Contents of the RA Report, of Close Out Procedures for National Priorities List Sites

(EPA 2000). This guidance was used to provide necessary documentation to support the future deletion of INL from the NPL.

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2. GROUP 6 BACKGROUND

Both CPP-84 and CPP-94 were included in the INTEC ROD (DOE-ID 1999) as Group 6, Buried Gas Cylinders. The principal threat posed by the buried gas cylinders, as identified in the ROD, was a safety hazard, including chemical exposure, fire, explosion, and projectile hazards. The remediation goal for Group 6 was identified to remedy the safety hazard posed by the buried cylinders. The selected remedy to complete the remediation goal was removal, treatment, and disposal of the buried gas cylinders. The remedy was chosen based on the following criteria: overall protection; compliance with applicable or relevant and appropriate requirements; long-term effectiveness; reduction of toxicity, mobility, or volume; short-term effectiveness; implementability; and net present value cost. To restrict access to the burial sites pending remediation, rope barriers and signs were posted around each site. These controls were monitored and maintained until RAs commenced at each location.

2.1.1 Remedial Design/Remedial Action Work Plan

To implement the selected remedy, a RD/RA WP was developed for the completion of RAs (DOE-ID 2004a). The methods for removal, treatment, and disposal of gas cylinder carcasses and site reclamation at sites CPP-94 and CPP-84 were included in the RD/RA WP. Sections 2.1.1.1 and 2.1.1.2summarize the RD for each of the Group 6 sites.

2.1.1.1 CPP-94 Accelerated Remedial Action Implementation Design Summary. Hazards to inadvertent intruders, the negative effect wildland fire could have on the exposed HF cylinders at CPP-94, and potential risk to wildland firefighters prompted the planning of accelerated removal prior to completion of the RD/RA WP. The accelerated RA implementation statement of work was included in the RD/RA WP as Appendix B. Post-removal sampling and site reclamation activities for CPP-94 were detailed in the RD/RA WP. The accelerated work design used for the remediation of CPP-94 is summarized below:

Accelerated Work Remediation Design

• Excavate compressed gas cylinders at CPP-94 (as applicable) to allow for physical evaluation of the cylinders

• Visually inspect each cylinder and document all applicable characteristics (e.g., valve configuration, container construction, integrity, labeling, corrosion effects)

• Place cylinders into safe storage condition

• Recycle or dispose of cylinder carcasses.

RD/RA WP Soil Sampling and Site Reclamation

• Collect soil samples and compare contaminants of potential concern (COPCs) results to remediation action levels (see Table 2-1)

- If data exceed action levels, collect contaminated soil and dispose of appropriately, resample, and again compare results with action levels. Repeat as necessary until sample results are below action levels.

• Backfill site and perform site reclamation.

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Table 2-1. Data quality objective (DQO) COPC list and action levels for CPP-94 and CPP-84 (DOE-ID 2004a, Table 3-2).

COPC Action Level (mg/kg)

Arsenic 3.1 E+01

Acetonea 1.6 E+03

Barium 5.5 E+03

Beryllium 1.6 E+02

Cadmium 3.7 E+01

Chromium 2.3 E+02

Cobalt 4.7 E+03

Copper 3.1 E+03

Iron 2.3 E+04

Lead 4.0 E+02

Mercury 2.3 E+01

Nickel 1.6 E+03

Total fluorideb 3.7 E+03

Asbestosa, c >1%

a. COPC is specific to CPP-84.

b. Total fluoride is listed in the DQO table of the RD/RA WP as a CPP-94 COPC only. Fluoride was later included in soil analyses for CPP-84 due to the discovery of cylinders containing HF.

c. Asbestos samples will only be collected if visual evidence indicates asbestos-containing material may be present.

2.1.1.2 CPP-84 Remedial Design Summary. The RD/RA WP describes the design for remediation of CPP-84. The general design is summarized below:

• Excavate cylinders using mechanical and/or hand excavation techniques.

• Inspect each cylinder and determine if it is safe to handle.

- If safe to handle, remove cylinder from excavation using a remote grappling device and segregate according to the suspected contents.

- If not safe to handle, overpack the cylinder for sampling and treatment using a mobile cylinder management vessel.

• Sample cylinder contents and treat appropriately (e.g., vent inert gases per Compressed Gas Association [CGA] guidelines).

• Decommission cylinders per CGA guidelines.

• Recycle/dispose of decommissioned cylinder carcasses appropriately.

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• Collect soil samples and compare COPC results to remediation action levels (see Table 2-1).

- If data exceed action levels, collect contaminated soil and dispose of appropriately, resample, and again compare results with action levels. Repeat as necessary until sample results are below action levels.

• Backfill site and perform site reclamation.

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3. REMEDIATION ACTIVITIES

This section provides a summary of the activities undertaken to implement RAs associated with CERCLA sites CPP-94 and CPP-84. The following subsections describe the methods used to implement the RAs. Significant events, including unanticipated occurrences are also included in these summary descriptions. The chronology of events is outlined in Section 4. A photographic record of remediation activities is included in Appendix B.

3.1 CPP-94 Remediation

3.1.1 CPP-94 Mobilization and Site Controls

The subcontractor mobilized equipment to the site necessary for excavating, inspecting, moving, staging, monitoring, and decommissioning the cylinders.

Site control included posting signs, limiting access to the general area where the work was being conducted, alerting security to the work, and making proper notifications.

3.1.2 CPP-94 Cylinder Excavation

Excavation activities for cylinders at CPP-94 included hand excavating around the cylinders using nonsparking equipment. The cylinders were loosened from the soil for inspection and removal. HF monitors were frequently used during excavation to ensure no gases were leaking from the cylinders. The depths at which cylinders were found ranged from ground surface to about 1 ft below ground surface.

Cylinders were identified in two locations at CPP-94, as mentioned in Section 1.1.1. During the process of excavating around partially buried cylinders at the southwest location, two additional cylinders were discovered. These cylinders were also low-pressure cylinders and were assumed to contain HF. It was also discovered that the cylinders appeared to have been placed on a lime bed prior to burial. A total of five cylinders were found at the southwest location (one on land surface, four requiring excavation), and one was excavated from the northeast location, for a total of six HF cylinders.

3.1.3 CPP-94 Cylinder Inspection

After excavation, each cylinder was visually inspected and monitored for leaks using monitoring equipment. Cylinder integrity was then checked using an instrument that checked the thickness of the cylinder wall. Using a tripod lifting device, each cylinder was then partially lifted for additional visual, monitoring, and thickness inspections. All six cylinders were found to be in stable condition. Each cylinder was then moved for staging. Based on comparison of weights and physically handling the cylinders, only one of the six cylinders was suspected to contain substantial product.

3.1.4 CPP-94 Cylinder Staging and Treatment

Each cylinder was secured to a cylinder rack in an upright position. Cylinders with operable valves were pressure-tested. Cylinders with inoperable valves were inspected and valves removed while monitoring closely. Each cylinder was inspected to determine if there were any free liquids inside. This was done by initially listening for liquids within the cylinder during movement. The presence of liquid was then confirmed by removing the valve and placing a glass tube into the cylinder. HF etches glass, so if the glass was etched upon removal from the cylinder, liquid HF was confirmed present. Only one cylinder was found to have free liquid HF remaining inside. The valve on this cylinder was replaced, and the cylinder was determined to be Department of Transportation (DOT) -shippable.

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3.1.4.1 CPP-94 Cylinder Recovery Summary. A total of six cylinders were recovered from CPP-94. Five of these cylinders were determined to be empty. One cylinder contained free liquid HF and was modified to be DOT-shippable.

3.1.5 CPP-94 Cylinder Decommissioning and Disposal

To decommission the five empty cylinders, the valves were removed, and holes were drilled in the cylinder walls. These cylinders were then sent for disposal in the Central Facilities Area (CFA) Landfill. The cylinder containing HF was determined to be DOT-shippable and was shipped to the Onyx Environmental Services Treatment Storage and Disposal Facility in Henderson, Colorado, for storage pending approval of an appropriate treatment facility. The cylinder was then sent to the Treatment One facility, a division of SET Environmental, Inc., in Houston, Texas for treatment and disposal (see Appendix C).

3.1.6 CPP-94 Post Removal Sampling

Soil samples were collected as outlined in the Preliminary Characterization Plan for the OU 3-13 Group 6 RD/RA Buried Gas Cylinder Sites: CPP-84 and CPP-94 (DOE-ID 2001), and a biased sample was also collected from grayish-white cement-type material in the excavation. Sample results from the excavation were acceptable to meet remediation goals, while the results from the grayish-white material returned a fluoride level above action levels (Hain 2001). The action taken to resolve the fluoride issue involved collecting the grayish-white clumps from within the excavation and managing them as CERCLA waste. Confirmation samples were then collected from the excavations (Hain 2004). Results of the confirmation sampling indicated the fluoride levels were below action levels. Maximum sample results are reported in Section 5. Appendix D includes information concerning sample locations. Remediation was considered complete at this point, awaiting site grading and revegetation.

3.1.7 CPP-94 Site Reclamation

A geophysical survey of the site was performed and confirmed the removal of all cylinders (see Appendix E). The excavation sites were filled and graded. As recommended by the site plant ecologist, a native species seed mix was planted, and bark was spread over the site.

3.1.8 CPP-94 Modifications to the RD/RA WP

As explained in Section 2.1.1.1, remediation of site CPP-94 occurred prior to finalizing the RD/RA WP. The final remedy is consistent with the method listed in Section 2.1.1.1 and the method stated in the ROD for removal of cylinders, treatment of contents, and disposal of cylinder carcasses.

3.2 CPP-84 Remediation

3.2.1 CPP-84 Mobilization and Site Controls

The general area of CPP-84 was mowed and roped and signs were posted. A magnetic survey was conducted to establish the corners of the trench where the cylinders were buried. Site control included roping off access points and posting signs.

The subcontractor mobilized an office trailer, equipment necessary for excavation, inspection, cylinder handling, treatment, and cylinder decommissioning.

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3.2.2 CPP-84 Cylinder Excavation

Excavation activities at CPP-84 included mechanical excavation down to within 1 ft of the cylinders. The remaining overburden was then removed using a vacuum excavator and air lance to reduce the chance of damaging cylinders. During excavation activities, cylinders labeled as containing “Hydrofluoric Acid” were discovered. Based on cylinder and valve type, a cylinder suspected to contain chlorine was also discovered. After mitigating hazards associated with handling these unexpected cylinders, excavation continued.

3.2.3 CPP-84 Cylinder Inspection and Removal

After cylinders were uncovered, they were visually inspected to assess their integrity. Monitoring was also conducted over and around the cylinders to ensure they were not leaking. All cylinders were determined to be safe to handle based on the preliminary assessments and were removed remotely from the excavation using a specialized cylinder-grappling device attached to a track hoe.

3.2.4 CPP-84 Cylinder Staging and Sampling

Cylinders were segregated into groups including oxidizers, flammables, and inerts based on cylinder type, valve type, and/or cylinder body markings. Cylinders containing HF were segregated from other cylinders into their own group.

Cylinder content sampling was conducted to confirm or determine cylinder contents. Many of the cylinders were determined “empty.”

3.2.4.1 CPP-84 Cylinder Recovery Summary. A total of 148 cylinders were removed from CPP-84. A summary of the cylinders recovered from CPP-84 is provided in Table 3-1.

3.2.4.2 HF Release. During the process of staging an HF cylinder, a release occurred. The cylinder was being moved remotely using the grappler-device when a small hole developed in the sidewall of the cylinder. Subcontractor personnel responded by allowing pressure to dissipate from the cylinder (a low-pressure cylinder) and then placed the cylinder into an overpack (approximately 8 minutes from release to placement into overpack). It was determined that the estimated amount of HF released to the atmosphere was below the reportable quantity.

Table 3-1. Summarization of cylinders recovered from CPP-84.

Cylinder Contents

Number of Cylinders Recovered

Comments

Inerts/other 97 This category includes cylinders that contained inert gases such as argon and carbon dioxide, other gases and mixed gases appropriate for venting, and empty cylinders.

Acetylene 18 Acetylene cylinders were vented and/or decommissioned according to CGA guidelines.

Hydrogen fluoride

28 Contents of HF cylinders were treated on-Site using a potassium hydroxide reagent. Approximately 450 lb of HF were treated.

Chlorine 1 This cylinder was found to be nearly full of high-purity chlorine suitable for recycling.

Freons 4 Contents of these cylinders were suitable for recycling.

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Because of the HF cylinder failure, a decision was made to treat all HF cylinders on-Site (no shipments to an off-Site treatment facility, as was done for the HF cylinder at CPP-94). A specialized treatment system was ordered to the site to treat cylinders containing HF. During mobilization of the treatment system, subcontractor personnel detected a leak from the overpack pressure gauge while conducting routine monitoring and inspection of the overpack containing the HF cylinder that had previously failed. The gauge was removed and replaced with a plug. The amount of HF released to the atmosphere was determined to be below the reportable quantity. Residual vapor within the overpack was then treated using a high-vacuum scrubber containing potassium hydroxide that arrived with the specialized treatment unit. The scrubber was used until the overpack held a vacuum, confirming no remaining gaseous product. This event prompted a partial shutdown of the project to reanalyze the situation and ensure proper hazard mitigations were in place prior to proceeding with treatment.

After reanalyzing the situation, a decision was made to stage the HF cylinders in a containment structure that was manifolded to a scrubber system. This provided added protection to personnel and the environment in the event of another cylinder failure.

3.2.5 CPP-84 Cylinder Treatment

The treatment methods used for the cylinder contents from CPP-84 included venting, neutralization, and recycling.

3.2.5.1 Venting. Inert gases and acetylene were vented to the atmosphere in accordance with appropriate environmental and clean air guidelines. Acetylene cylinders were then allowed to vent residual acetone from within the cylinders to the atmosphere per CGA guidelines. Once cylinders were empty and determined treated, they were staged for decommissioning.

3.2.5.2 Neutralization. Treatment of HF cylinders included use of a high-vacuum wet scrubber to neutralize the contents in a reagent of potassium hydroxide. HF cylinders were transferred into a mobile treatment unit where cylinders with operable valves were manifolded to the scrubber system. Cylinders with inoperable valves were loaded into a vessel that enabled the contents to be transferred to the scrubber system (see Appendix F of the RD/RA WP). Once the HF cylinders were empty, they were transferred out of the treatment unit and staged for decommissioning.

3.2.5.3 Recycling.

3.2.5.3.1 Chlorine—The cylinder containing chlorine was full, and sample resultsindicated it was of high purity. A vendor was identified and approved (see Appendix F), appropriate documentation was completed, and the cylinder was shipped off-Site for recycling.

3.2.5.3.2 Freon—Among the cylinders unearthed from CPP-84, four cylinders were found to contain Freon. Rather than treat and destroy the material, the cylinders were sent off-Site for Freon recycling. A vendor was identified and approved (see Appendix F), appropriate documentation was completed, and the cylinder was shipped off-Site.

3.2.6 CPP-84 Cylinder Decommissioning

Cylinders were decommissioned according to CGA guidelines. Generally, cylinders, other than acetylene cylinders, were de-valved, threads of the cylinder were damaged, and a hole was drilled in the sidewall. Acetylene cylinders were de-valved, and a plug was forced into the threads to prevent any future release of asbestos from the cylinder.

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3.2.7 CPP-84 Waste Disposal

Nonacetylene decommissioned cylinders were radiologically surveyed for release and were recycled as scrap metal. One cylinder was found to have fixed contamination on the bottom. The contaminated portion (lower 6 in.) was cut off and managed as CERCLA radiologically contaminated waste in accordance with the project Waste Management Plan (DOE-ID 2004b) while the upper portion was included for recycling.

After appropriate venting and decommissioning, acetylene cylinder carcasses were found suitable for disposal on-Site. The cylinders were placed into waste boxes and shipped to the CFA asbestos landfill for final disposition.

Liquid waste derived from the neutralization of HF was determined to meet the acceptance criteria for the evaporation pond at the Idaho CERCLA Disposal Facility. Approximately 350 gal of this liquid waste were transferred.

Other waste, including personal protective equipment, was managed in accordance with the Waste Management Plan.

3.2.8 CPP-84 Post-Removal Sampling

Soil samples were collected as outlined in the Preliminary Characterization Plan for the OU 3-13 Group 6 RD/RA Buried Gas Cylinder Sites: CPP-84 and CPP-94 (DOE-ID 2001). Due to the unexpected discovery of HF cylinders, fluoride was added for sample analysis. Appendix D includes information concerning sample locations. Maximum sample results are reported in Section 5. Complete sample results are reported in the Limitations and Validation Reports (Verwolf 2005). Sample results from the excavation fell below contaminant action levels. Remediation was considered complete at this point.

3.2.9 CPP-84 Site Reclamation

A geophysical survey of the site was performed and confirmed the removal of all cylinders (see Appendix E). The excavation was filled, compacted to a minimum of 90% (see Appendix G), and graded. As recommended by the site plant ecologist, a native species seed mix was planted, and bark was spread over the site.

3.2.10 CPP-84 Modifications to the RD/RA WP

During the RA for CPP-84, it was noted that the RD/RA WP was intimately descriptive concerning remediation methods, means, and management practices for the RA. While the general intent and methods listed in the RD/RA WP were applicable, many of the details listed were onerous to completing the work. Because of this, an agreement with the Agencies was reached stating that not all details specified in the RD/RA WP would be implemented as long as RA objectives were met (Verwolf 2004). The final remedy for remediation of CPP-84 is consistent with the method stated in the ROD for removal of cylinders, treatment of contents, and disposal of cylinder carcasses.

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Notable differences between the implemented remedy compared to what was planned in the RD/RA WP are listed below:

• The RD/RA WP states that acetylene carcasses will be sent off-Site for disposal due to acetone and asbestos concerns.

- Guidelines from CGA pamphlet P-22, Addendum 1998, “Disposition of Unserviceable Acetylene Cylinders,” were implemented to properly treat and decommission the acetylene cylinders and address acetone. The treated acetylene cylinder carcasses were determined to meet the CFA asbestos landfill disposal criteria and were disposed of on-Site.

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4. CHRONOLOGY OF EVENTS

This section includes a chronology of events, starting with the signing of the ROD and ending with transmittal of post-removal sample results for CPP-84. Table 4-1 lists dates and significant events relating to WAG 3, OU 3-13, Group 6, Buried Gas Cylinders.

Table 4-1. Chronology of events relating to WAG 3, OU 3-13, Group 6, Buried Gas Cylinders.

Date Event

October 1999 Record of Decision for Operable Unit 3-13 finalized (DOE-ID 1999).

July 12, 2000 Complete Characterization Plan (DOE-ID 2001) and Health and Safety Plan (INEEL 2004). (The Characterization Plan and the Health and Safety Plan were originally completed in July 2000.)

August 2, 2000 Complete preliminary characterization activities, including initial magnetic surveys at CPP-94 and CPP-84 and PINS analysis on cylinder at CPP-94 (INEEL 2000).

September 27, 2000 Scope for “CPP-94 Accelerated Remedial Action Implementation” defined (Appendix B of RD/RA WP).

November 30, 2000 Subcontractor mobilizes for CPP-94 remediation.

December 7, 2000 Subcontractor completes remedial action at CPP-94.

April 10, 2001 Pre-Final Inspection for CPP-94 completed.

May 1, 2001 RD/RA WP for OU 3-13, Group 6, Buried Gas Cylinders, completed (DOE-ID 2004a).

May 23 and 29, 2001 Post-removal samples collected at CPP-94.

September 18, 2001 Post-removal sample results for CPP-94 transmitted to Agencies(Hain 2001).a

October 3, 2001 Decision made to complete CPP-94 reclamation concurrent with CPP-84 reclamation (Smith 2001).

December 3-5, 2003 Gray soil clumps at CPP-94 collected and managed as waste, confirmation sampling conducted.

March 24, 2004 CPP-94 confirmation soil sample results transmitted to Agencies(Hain 2004).b

May 19, 2004 Subcontractor mobilizes to CPP-84.

June 7, 2004 Exhumation of buried gas cylinders at CPP-84 begins.

June 10, 2004 Cylinders suspected to contain HF and chlorine discovered at CPP-84; stop work initiated to mitigate hazards and revise contract to address new hazards.

June 21, 2004 Resume work at CPP-84 to exhume high-pressure cylinders and place HF cylinders in a safe configuration pending arrival of a specialized treatment system.

Table 4-1. (continued).

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Date Event

June 24, 2004 HF released to atmosphere when a small hole forms in sidewall of an HF cylinder at CPP-84. Cylinder is safely overpacked.c Sampling, treatment, and decommissioning of cylinders not containing HF, chlorine, or Freon continues.

July 26, 2004 Hazardous gas treatment system arrives onsite at CPP-84. Overpack develops leak through pressure gauge; HF gas releases to atmosphere. Gauge safely replaced with a plug.c

July 27, 2004 Final magnetometer survey completed at CPP-94 confirming removal of all cylinders.

July 30, 2004 Temporarily shut down work (partial demobilization) at CPP-84 to ensureappropriate planning and controls have been implemented prior to handling and treating cylinders containing hazardous substances.

October 4, 2004 Subcontractor re-mobilizes to CPP-84.

October 15, 2004 Exhumation of cylinders at CPP-84 resumes.

October 20, 2004 Treatment of HF cylinders at CPP-84 commences.

October 22, 2004 Hand-held magnetometer survey indicates all cylinders have been exhumed from CPP-84.

November 2, 2004 Collect post-removal soil samples at CPP-84.

November 6, 2004 Treatment of HF cylinder contents complete at CPP-84.

November 8, 2004 Subcontractor completes work at CPP-84, demobilizes.

December 2-6, 2004 CPP-84 and CPP-94 are backfilled and graded.d

December 13, 2004 Final magnetometer survey completed confirming removal of all cylinders from CPP-84.

December 13−15, 2004

Per recommendations of plant ecologist, CPP-84 and CPP-94 are reseeded and reclaimed.e

January 18, 2005 Transmit validated post-removal sample results from CPP-84 to Agencies.f

a. One sample result from a biased “clump” of gray soil returned a fluoride level above the defined action level.

b. Sample results were less than defined action levels; CPP-94 site remediation complete.

c. Estimated quantity of HF gas released was nonreportable.

d. CPP-84 post-removal sample raw data were received December 2, 2004, and indicated no action levels were exceeded.

e. Fair weather conditions allowed reseeding and reclamation activities to be completed.

f. Agencies opt not to conduct a Pre-Final Inspection and indicate that transmittal of the post-removal sample results from CPP-84 signifies completion of the Final Inspection.

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5. PERFORMANCE STANDARDS AND QUALITY CONTROL

Removal, treatment, and disposal of cylinders from CPP-84 and CPP-94 proved to be an effective manner for remediation. By removing the cylinders, RA objectives were met by eliminating the threat of release and hazards associated with the aged cylinders. Post-removal soil samples were collected in accordance with the project-specific characterization plan (DOE-ID 2001), the RD/RA WP, and the Quality Assurance Project Plan for Waste Area Groups 1, 2, 3, 4, 6, 7, and 10 and Deactivation,

Decontamination, and Decommissioning (DOE-ID 2004c).

Tables 5-1 and 5-2 list maximum concentration levels of COPCs from each site as compared to action levels defined in the DQOs. The only result reported above action levels is iron for site CPP-94. The ROD did not evaluate risk for essential nutrients below 10 times background levels. Iron is considered an essential nutrient. The maximum value for iron reported from CPP-94 is within background levels for the area as reported in Executive Summary for Background Dose Equivalent Rates

and Surficial Soil Metal and Radionuclide Concentrations for the Idaho National Engineering

Laboratory (INEL 1996). The iron result was evaluated and action was deemed unnecessary. In light of this, results of this remediation effort meet cleanup DQOs defined in the RD/RA WP.

Table 5-1. Post-removal confirmation sample results for CPP-94 compared to DQO action levels.

COPCMaximum Sample Result

(mg/kg)Action Level

(mg/kg)

Arsenic 1.1 E+01 3.1 E+01

Barium 8.0 E+02 5.5 E+03

Beryllium 6.7 E-01 1.6 E+02

Cadmium 1.4 E+00 3.7 E+01

Chromium 4.7 E+01a 2.3 E+02

Cobalt 9.7 E+00 4.7 E+03

Copper 2.7 E+01a 3.1 E+03

Fluoride 2.3 E+03b 3.7 E+03

Iron 2.6 E+04a,c 2.3 E+04

Lead 1.9 E+01 4.0 E+02

Mercury 5.0 E-02 2.3 E+01

Nickel 3.4 E+01d 1.6 E+03

a. Received a “J” validation flag. The material was analyzed for and detected at or above the applicable detection limit, but the reported value is an estimate and may be inaccurate or imprecise. These estimated values are well below action levels.

b. An initial biased sample result from a discolored soil clump reported fluoride above the action level. Action was taken to remove and manage contaminated soil clumps, after which confirmation sampling was conducted. The reported result is the maximum concentration from the confirmation sampling effort.

c. The ROD did not evaluate risk for essential nutrients below 10 times background levels. Iron is considered an essential nutrient. The maximum result reported is within background levels for the area (INEL 1996). The result was evaluated and action was deemed unnecessary.

d. Received an “E” flag, indicating the reported value was estimated due to interference during analysis.

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Table 5-2. Post-removal confirmation sample results for CPP-84 compared to DQO action levels.

COPCMaximum Sample Result

(mg/kg)Action Level

(mg/kg)

Arsenic 1.3 E+01a 3.1 E+01

Acetone Not detected 1.6 E+03

Barium 2.2 E+02 5.5 E+03

Beryllium 9.6 E-01 1.6 E+02

Cadmium 5.2 E-01 3.7 E+01

Chromium 3.3 E+01 2.3 E+02

Cobalt 6.9 E+00b 4.7 E+03

Copper 1.8 E+01 3.1 E+03

Fluoridec 1.1 E+02b 3.7 E+03

Iron 2.0 E+04 2.3 E+04

Lead 1.4 E+01b 4.0 E+02

Mercury 2.0 E-02 2.3 E+01

Nickel 2.7 E+01 1.6 E+03

Asbestos Not analyzedd >1%

a. All arsenic results were reported with "R" validation flags, indicating that it is recommended the data not be used. These flags were applied by the validator because the laboratory failed to demonstrate adequate measurement precision for arsenic from the analysis of a representative sample and its duplicate. However, based on the results of other laboratory quality control parameters, i.e., spiked matrix samples and spiked control samples, the laboratory demonstrated good laboratory accuracy. Because it is not uncommon for laboratory precision to be poor for some analytes in solid samples due to matrix inhomogeneity and because the laboratory accuracy is believed to be sound for these analyses, the reported laboratory results are believed to be reliable enough to confirm that arsenic is below action levels.

b. Received a “J” validation flag. The material was analyzed for and detected at or above the applicable detection limit, but the reported value is an estimate and may be inaccurate or imprecise. These estimated values are well below action levels.

c. Fluoride was added as a COPC for CPP-84 upon the unexpected discovery of cylinders containing HF.

d. Asbestos sampling was omitted as prescribed in the Group 6 RD/RA WP DQOs because there was no visual evidence of asbestos, and none of the asbestos-containing cylinders (acetylene) were breached.

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6. FINAL INSPECTION AND CERTIFICATIONS

6.1 Inspections

A prefinal inspection of CPP-94 was conducted on April 10, 2001, in the presence of EPA, DEQ, and DOE Idaho representatives (see Appendix H). Personnel conducting the inspection noted that white residue at the bottom of the pit could have originated from leaking cylinders. A suggestion was made to collect a biased sample of the material when sampling takes place. The biased sample produced an elevated fluoride result, necessitating additional cleanup and confirmation sampling to complete remediation.

Confirmation sample results reported acceptable fluoride levels and were sent to Agency personnel on March 29, 2004. Reclamation activities occurred concurrent with CPP-84 reclamation activities.

After visiting CPP-84 during remediation activities, Agency personnel declined to conduct a pre-final or final inspection of the site. The Agencies indicated they would approve completion of the RA upon receipt of acceptable post-removal sample results from CPP-84. Post-removal sample results were transmitted to the Agencies on January 18, 2005, and served as completion of the final inspection.

Both CPP-94 and CPP-84 have been reclaimed to restore the sites to their original state. The final state serves the functionality of a natural habitat for native plants and wildlife. Operational activities do not apply to these sites.

6.2 Health and Safety

No health and safety problems were encountered during the RA. Upon the discovery of HF cylinders at CPP-84, personal protective equipment was upgraded for increased dermal protection. Also, additional access restrictions were placed on the support zone during RA activities.

Work was performed in accordance with Revision 5 of the Health and Safety Plan (INEEL 2004). During RAs, field modifications to the Health and Safety Plan were implemented to mitigate emerging safety hazards. These field modifications aided in the safe completion of remediation activities. The modifications included updating items related to the following:

• Safe handling, staging, and treatment of cylinders containing hazardous substances

• Emergency action levels, emergency response, and emergency contact information

• Additional site access restrictions

• Personnel roles and responsibilities.

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7. OPERATION AND MAINTENANCE ACTIVITIES

CPP-94 and CPP-84 have been remediated and reclaimed and are located in unused, remote, vegetated areas. Because of this, no operation or maintenance activities are planned for either site. Periodic checks of the sites by the facility owner will be conducted to monitor revegetation efforts. If efforts are determined unsuccessful, reseeding will again be attempted until the sites are adequately revegetated.

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8-1

8. SUMMARY OF PROJECT COSTS

Table 8-1 provides a summary of costs for the RAs at CPP-94 and CPP-84 and a comparison to the original ROD estimate. As reported in the ROD, all costs associated with this remediation are considered capital costs. Dollar amounts were adjusted using escalation indices included in Appendix I. Total actual costs for CPP-94 and CPP-84 were <1% more than the estimate in the ROD. Appendix J contains a more detailed breakdown of actual costs.

Table 8-1. Cost summary of remedial actions for CERCLA Group 6 sites CPP-94 and CPP-84.

Cost Elementsa ROD Estimate (2005 $ Value)b Actual Cost (2005 $ Value)c

FFA/CO Management and Oversight $1,059,000 $896,000

Remedial Design $55,000 $26,000

Remedial Action Construction $1,098,000 $1,292,000

Total $2,213,000 $2,214,000

Difference between total actual cost and the total ROD estimate

+$1,000 or <+1%

a. Cost elements are listed as identified under “Capital Costs” in Table 11-7 of the ROD. All costs are considered capital costs as estimated in the ROD.

b. Each estimate was adjusted to 1997 net present value prior to adjusting to 2005 values.

c. Reported costs are actual values through January 2005. Cost for FFA/CO Management and Oversight includes an additional forecast amount of $60K for 2005 to finalize this report.

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9. OBSERVATIONS AND LESSONS LEARNED

During the CERCLA investigation of cylinder disposal activities for Group 6, Buried Gas Cylinders, personnel associated with the initial cylinder disposal activities were interviewed. Based on information provided from these interviews, the cylinders disposed at CPP-84 were identified as associated with standard construction gases, while CPP-94 was believed to have been the disposal area for cylinders containing HF. The CERCLA RD/RA WP was prepared based on this information. During the review and comment process for the RD/RA WP, the document was revised based on Agency comments to identify the potential to discover cylinders containing unexpected gases at CPP-84. During project implementation, the subcontractor’s proposal acknowledged the possibility of finding cylinders containing unexpected gases such as HF. The field implementation planning included development of anemergency response plan that established steps to be performed if unexpected gases were discovered. Since cylinders containing unexpected gases were discovered during remediation, this preplanning helped the personnel to respond safely.

Below are specific examples of lessons learned from this project. The following examples illustrate some of the successes, problems, and ways the project could have been improved:

• The use of a vacuum excavator and air lance decreased the amount of time to excavate when compared to hand excavation, decreased the number of personnel needed for excavation, and decreased the risk involved with exhuming the cylinders.

• Contingency planning for unanticipated cylinders enabled the project to assess and mitigate hazards after the exhumation of cylinders containing unanticipated gases and continue work soon after their discovery. This provided an efficient method to continue with work without the added expense of planning for unsubstantiated gases.

• The performance of dry-run emergency action drills enabled project personnel to respond appropriately to the spontaneous breach of an HF cylinder with no personnel exposures.

• Information obtained from the interviews of personnel concerning past disposal activities at CPP-84 was not completely accurate. This may have been due to the number of years between the disposal of the cylinders and the interviews, resulting in only a partial recollection by the interviewees; or the interviewees may not have been fully cognizant of other activities being performed at the site such as the disposal of HF cylinders. In view of this, planning for the unexpected during remediation activities is important.

• During planning for project implementation, requesting a bid alternative for a more robusttreatment system that could have also treated unexpected gases, such as HF, in addition to the expected construction gases, would have been advantageous.

• To be protective of workers in the proximity of CPP-84, the emergency response to the HF releases was conservative in terms of the areas that were evacuated and controls established. However, had a better understanding of HF release properties been used during project planning and in establishing initial emergency action levels, neither of the two HF release incidents would have triggered emergency action levels. Thus, the project likely would have been completed earlier and at a lower cost.

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10. OPERABLE UNIT CONTACT INFORMATION

Points of contact for the WAG 3, OU 3-13, Buried Gas Cylinders project are listed in Table 10-1.

Table 10-1. Points of contact for the WAG 3, OU 3-13, Buried Gas Cylinders project.

Contact Title Affiliation Address Phone Number

Bob Waters WAG 3 project manager

Bechtel BWXT Idaho, LLC (BBWI)(primary contractor)

2525 Freemont AveIdaho Falls, ID 83415

208-526-6013

Marty Doornbos WAG 3 project engineer

BBWI (primary contractor)

2525 Freemont AveIdaho Falls, ID 83415

208-526-0676

Mary Verwolf DOE Idaho WAG 3 project manager

DOE Idaho 1955 Freemont AveIdaho Falls, ID 83415

208-526-7001

Dennis Faulk EPA WAG 3 project manager

EPA Region X 712 Swift Blvd., Suite 5Richland, WA 99352

509-376-8631

Ted Livieratos DEQ WAG 3 project manager

DEQ 1410 N. HiltonBoise, ID 83706

208-373-0217

Jody Lyday Operations manager

Onyx Environmental Services (subcontractor for CPP-94)

9131 East 96th

Ave.Henderson, CO 80640

303-289-4827

Jeff Gold President Integrated Environmental Services (subcontractor for CPP-84)

1445 Marietta Blvd.Atlanta, GA 30318

404-352-2001

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11-1

11. REFERENCES

DOE-ID, 1991, Federal Facility Agreement and Consent Order and Action Plan, 1088-06-29-120, U.S. Department of Energy Idaho Field Office, Environmental Protection Agency Region 10, State of Idaho Division of Environmental Quality, December 1991.

DOE-ID 1999, Final Record of Decision Idaho Nuclear Technology and Engineering Center Operable

Unit (OU) 3-13, DOE/ID-10660, Rev. 0, U.S. Department of Energy, Idaho Operations Office, October 1999.

DOE-ID, 2001, Preliminary Characterization Plan for the OU 3-13 Group 6 RD/RA Buried Gas Cylinder

Sites: CPP-84 and CPP-94, DOE/ID-10842, Rev. 2, U.S. Department of Energy Idaho Operations Office, March 2001. (formerly INEEL/EXT-2000-00398)

DOE-ID, 2004a, Remedial Design/Remedial Action Work Plan for Operable Unit 3-13, Group 6,

Buried Gas Cylinders, DOE/ID-10838, Rev. 2, U.S. Department of Energy Idaho Operations Office, July 2004.

DOE-ID, 2004b, Waste Management Plan for Operable Unit 3-13, Group 6, Buried Gas Cylinders, DOE/ID-10837, Rev. 2, U.S. Department of Energy Idaho Operations Office, July 2004.

DOE-ID, 2004c, Quality Assurance Project Plan for Waste Area Groups 1, 2, 3, 4, 5, 6, 7, and 10 and

Deactivation, Decontamination, and Decommissioning, DOE/ID-10587, Rev. 8, U.S. Department of Energy, Idaho Operations Office, March 2004.

EPA, 2000, Close Out Procedures for National Priorities List Sites, EPA 540-R-98-016, Environmental Protection Agency, January 2000.

Hain, Kathleen, DOE Idaho, to Wayne Pierre, EPA, and Dean Nygard, DEQ (Idaho), September 18, 2001, “Transmittal of the Soil Sampling Results from Site CPP-94, Group 6-Buried Gas Cylinders at Waste Area Group 3, Operable Unit 3-13,” EM-ER-01-152.

Hain, Kathleen, DOE Idaho, to Nicholas Ceto, EPA, and Daryl P. Koch, DEQ (Idaho), March 24, 2004, “Transmittal of the Limitations and Validations Report for Group 6, Buried Gas Cylinders, Post Removal Characterization of CERCLA Site CPP-94,” EM-ER-04-071.

INEEL, 2000, Summary of FY-2000 Characterization Activities at OU 3-13 CPP-84 and CPP-94 (Buried Gas Cylinders), INEEL/EXT-2000-01113, Rev. 0, U.S. Department of Energy Idaho Operations Office, November 2000.

INEEL, 2004, Health and Safety Plan for WAG 3, OU 3-13, Group 6, Buried Gas Cylinders, INEEL/EXT-2000-00270, Rev. 5, U.S. Department of Energy Idaho Operations Office, June 2004.

INEL, 1996, Executive Summary for Background Dose Equivalent Rates and Surficial Soil Metal and

Radionuclide Concentrations for the Idaho National Engineering Laboratory, INEL-94/0250 (Exec Sum), Rev. 1, U.S. Department of Energy Idaho Operations Office, September 1996.

Smith, F. Lee, BBWI, Inc., to Kathleen E. Hain, DOE Idaho, October 3, 2001, “Response to Environmental Protection Agency Region X Position Regarding the Cleanup of Site CPP-94,” CCN 26035.

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Verwolf, Mary C., DOE Idaho, to Joy Stuart, BBWI, Inc., October 21, 2004, “Summary of the Conference Call Regarding the Group 6 Buried Gas Cylinder Remediation Approach Related to the RD/RA Work Plan for Information Repository (FMDP-FFA/CO-04-045),” CCN 53326.

Verwolf, Mary C., DOE Idaho, to Nicholas Ceto, EPA, and Daryl P. Koch, DEQ (Idaho), January 18, 2005, “Transmittal of the Limitations and Validations (L&V) Reports for Operable Unit 3-13, Group 6, Buried Gas Cylinders, Post Removal Characterization of CERCLA Site CPP-84 (FMDP-FFA/CO-05-099),” CCN 54616.