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12.0 PROJECT ORGANIZATION, PERSONNEL, KEY SUBCONTRACTORS
The Colonie FUSRAP project is managed using, an organizational approach that designates a project manager supported by a nucleus of engineering personnel and key subcontractors. In order to ensure that the project meets the quality assurance requirements established by the TERC, the Colonie project is under the overall direction of the New York Distdct USACE project manager and the IT TERC program manager.
The IT project organization is a subset of the TERC organization and identifies key personnel and responsibilities. The TERC program identifies five contractor organizational components that mirror USACE staff development. These components include management, administration, remedial action, technical support, and compliance. A reporting structure from the USACE field representative to the project manager has been established to ensure proper communication. The USACE organizational chart is presented as Figure 5. The iT organization chart is presented in F!gure 6. . The goals of the project team are to provide responsible and responsive~ technical management, effective cost a.nd schedule-control, highly qualified technical personnel, effective communication with USACE, and assurance that quality and safety standards are met for this remediation effort. To meet these goals, the project organization contains the following features: o Direct reporting and technical supervision among the various components, with clearly defined project control responsibilities and authorities; Experienced and qualified key technical personnel ; Direct interaction of project technical personnel with USACE; ¯ Weekly project progress meetings; Independent quality control functions interacting directly with USACE and monitoring the activities and outputs of project organizational elements; Independent health and safety function ir~teracting directly with USACE; Establishment of an effective community relations process; and ¯ Website data access for rapid reporting and wide dissemination of work products.
Members of the project team are accustomed to working within a multi-disciplinary, framework utilizing the resources of IT. As a result, potential interfacing problems and conflicts (if any) are minimized and are readily and quickly resolved. Other plans for ensuring the successful interface of various organizational elements are: close coordination in planning stages; firm definition of work and assignment of responsibilitieslauthorities through discrete work packages; and regular communications among program personnel. Interactions among the technical work elements will take place continuously.
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Section 2.0 Project Organizaf~on, Personnel, Key Subcontractors
responsible for overall quality, Schedule and costcompliance, project staffing and employee relations, subcontractor approval, management and direction, and bottom-line health, safety, and .regulatory compliance. Proiect Engineer-Kevin S. Dufek, E.I.T. The Project Engineer performs engineering support services and is responsible for the field design, day-to-day direction of on-site technical resources, day to day operations of the water treatment plant, day to day operations of the soil stabilization system, and the general oversight of the work. In addition, the Project Engineer oversees most professional services subcontractors, transportation and disposal activities, and other duties as assigned by the Project Manager. Quality Control ('QC) Manaqer- Scott Brock The ~ite QC Manager is responsible for day-to-day compliance monitoring of the approved quality control plans specified in the CQCP and SAP including records filing, archiving and reporting project activities. Mr. Brock also serves as the-site Data Manager, responsible for ensuring that all required data is obtained and entered into the project master database. Site Safety Officer / Health and ...s. afety Manaqer -David Root, CtH The Colonie Site Safety Officer / Health and Safety Manager is responsible for day-to-day compliance with the approved Colonie Site HASP. This plan specifies site-specific personnel training, maintenance of the medical monitoring program, as low as reasonable achievable (ALARA). program implementation, management of personal protective equipment (PPE), respiratory protection, decontamination operations, and operations support to the on-site construction work force. The Site Safety Officer (SSO) will ensure that all Colonie Site workers maintain Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Response ¯ (HAZWOPER) and radiological worker certifications and are current under medical monitoring programs meeting 29 Code of Federal Regulations (CFR) 1910.120. General employee radiation training and associated radiological monitoring will be handled as site-specific activities. Site Radiation Control Officer- David Sendra The site Radiation Safety Officer (RSO) will be responsible for day-to-day compliance with the approved Colonie Site Radiation Safety Manual (IT Corp., September 2000). The Radiation Safety Manual specifies the operations involving radiation hazards or use of radioactive material or radiation generating devices. The site RSO will conduct surveys, evaluate and secure any specialized assistance to assure compliance with radiation protection standards. The RSO is responsible for day to day management of the radiation controls and monitoring subcontractor, Environmental Dimensions, Inc. (EDi). EDi maintains a fulltime staff of radiological and industrial hygiene technicians who complete all aspects of radiological controls, monitoring and on-site testing required to complete the project. EDi's staffing levels have ranged from five to eight people depending on the project activities underway at any given point in time. Proiect Chemist- Eric Malarek
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The Project Chemist is responsible for the design, implementation and oversight of the sampling and analysis efforts at the site, encompassing a wide vadety of media, including soil, water, air and debris. The Project Chemist is also responsible for statistical analysis and presentation of the data required for several, different end uses, including coordination with personnel at Argonne National Laboratory in support of the project website, in addition, the Project Chemist is responsible for oversight of the analytical laboratories and performs other duties as assigned by the Project Manager. While Mr. Malarek resides at our Edgewood Maryland office, the day to day on-site duties of the project chemist are completed by Ms. Jeri Kiburz and other fulltime on-site staff. ¯ ' Site Superintendent_ - Joseph Fort The site Superintendent is responsible for the day-to-day remediation construction consisting of mobilization,, site preparation activities (Le., installation of roads, fences, etc.) and operations (Leo, excavation, material conditioning,¯ remediation, etc.). The.site Superintendent works closely with the project engineer and project manager to maximize the effective and¯ efficient delivery of field services. He directly oversees construction, operations and maintenance activities with support from construction technicians (Le., the union craft labor). Labor Foreman and Field Crew Field Crews will consist of a foreman, stewards, !aborers and operators from local union craft under a direct hire arrangement. IT has signed National Environmental Agreements with the Laborers International Union (Local !90) and the Operating Engineers International Union (Local 106). IT's Director of Labor Relations and the TERC Program Remedial Manager routinely meet with representatives of the union trades to ensure a strong working relationship and discuss staffing requirements and schedules. Union craft staffing levels have ranged from eleven to twenty-two people depending on the project activities underway at any given point in time. Subcontractors Current subcontractor services for utility connections are in place with NiMo (electric), Vedzon. (telephone), Time Warner (internet access), ADT and Alarm & Suppressio.n, Inc. (security for the trailers and monitoring of the groundwater treatment plant), and the Latham Water District. Professional service subcontractors currently include the following: Licensed land/civil surveying: Geotechnical laboratory analyses: Licensed Electrical services: ° ¯ ¯ Waste Transportation: Disposal Services: CT Male, Latham, NY; SJB Services, Inc. Ballston Spa, NY; Brunswick Electric, Troy, NY; and SSP Electric, Saratoga, NY; Environmental Rail Solutions, Tinton Hill, NJ US Ecology (Formerly EnviroSafe Services of Idaho); and Envirocare of Utah
Well/geoprobe/MIP/DSSC: Maxim Technologies, Ballston Spa, NY; and
2-4 OperationsWork Plan Colonie FUSRAP Project Rnal
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2.1
UNITED STATES ARMY CORPS OF ENGINEERS
USACE provides direct oversight of the remediation of the Colonie Site. The USACE project organizational chart is presented as Figure 5. Team members from both New York District and Baltimore District form the majority of USACE's Colonie Project team. These Districts are assisted by components of the Kansas City District for contracted disposal services and the Omaha District's Center of Expertise. The USACE oversight includes contractual compliance, technical review and interface with other governmental and private organizations. The IT projec~ manager will report to both the USACE project manager (Mr. James T. Moore, CPG.) arid the USACE contracting officer (Mr..Jeff May) through the on-site USACE field representative (Mr. Sterrett Daniels). Working closely with the USACE field representative, the IT project manager (Mr. Anthony Sheeran, P.E.) will obtain prior USACE concurrence for major technical decisions and changes in scope (if. any). 2.2 IT CORP. TOTAL ENVIRONMENTAL RESTORATION CONTRACT ('rERC) TEAM
The IT project management team for the Colonie Site R~medial Action consists of two cohesive and interacting management units. The first management unit consists of the Colonie Project Team field staff. The second management unit consists of the IT TERC Program Management Team. Both teams interact on a routine basis with their respective USACE project team members. The IT Corp project organization and key personnel employed in performing the Colonie Remedial Action are depicted on Figure 6. As of December 2001, this project team has completed over 185,000 work-hours in Support of the project. The following p.rovides a brief description of overall duties and responsibilities of the TERC Program team supporting the Colonie Project: The TERC program manager (Mr. John Franz, P.E.) has complete management authority and responsibility for all work performed under TERC. The TERC program manager directs the program management organization as a central resource for management, continuity and control of all TERC program activities. The centralized program management is organized to facilitate communication with and reporting to USACE and to expedite and support project execution. The TERC Program Quality Control Manager (Mr. Pete Hunter), Health and Safety Officer (Mr. Robert Brooks, CSP), Radiation Safety Officer (Mr. John McGowin, CHP), Costs & Scheduling Manager (Mr. Rene Mendoza) and Procurement Manager (Mr. Arnold Shaver) will assist in implementing the remedial plans at Colonie. These personnel report directly to the Program Manager, and have a direct line of communication with the Colonie Project Manager and their counterparts on the field project team. 2.3 IT CORPORATION ON-SITE COLONIE PROJECT TEAM
The IT Corp on-site project organization and key personnel employed in performing the Colonie Remedial Action are depicted on Figure 6...The following provides a brief description of overall duties and responsibilities by major functional work area: Project-Manaaer-Anthony R. Sheeran, P.E. The Project Manager is responsible for overall coordination and direction of the remediation effort. He serves as the principal point of contact with the USACE project organization and is
DACW41-01-D-0031 Task Order No. DA02 August 2002 2-2 Operations Work Plan . Colonie FUSP~P Project Final
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Parratt-Wolff, Syracuse NY, and Zebra Environmental, Albany NY Analytical lab services: Southwest Oklahoma Labs; and Eberline, Oak Ridge, TN Radiation controls: Technical Support Staff For remediation support operations, a .technical staff (not necessarily full-time field or office staff but rather assigned tasks as needed) consisting of sampling technicians, geologists and engineers in the following major functional areas: Enq_ineerin.q consisting of: establishment and maintenance of the site coordinate system; operation and. maintenance of water treatment system, operation and maintenance of soil stabilization system, land surveying (Le., property boundaries, preand post-excavation limit.s, and post-restoration); field design; inspection and testing support; regulatory compliance monitoring; and records maintenance and transfer to the site QC Manager. Laboratory Operations consisting of: maintenance of the air and water monitoring programs; real time soil scanning using the X-Ray Fluorescence Spectroscopy (XRF) and Field Instrument for Detecting Low Energy Radioactivity (FIDLER) in support of the excavation and material stockpile operations; free release program oversight; radiological monitoring; on-site laboratory analysis for rail car shipments and radiation control.both inside and outside designated exclusion zones; verification sampling; offsite laboratory analysis coordination; facilities and equipment radiological monitoring; and records maintenance and transfer to the site QC Manager. Transportation and Disposal Coordination consisting of: waste manifesting; scheduling and tracking; disposal coordination a~d record transfer; record maintenance and transfer to the site QC Manager. Proiect Administration: Project administration consists of cost controls, scheduling, procurement, payroll, finance, procurement and administration assistance personnel. Major responsibilities of the on-site project administration staff will consist of: ¯ Cost controls and project scheduling: Subcontracts, purchasing, and property management: ¯ Timekeeping, document controls and support services: Mr. James Berry, E.I.T.; Mr. Steve Huffmon; and Ms. Gina Carley Environmental Dimensions, Inc. Albuquerque, NM
Database Mana.qement and Proiect Files Project data management efforts are robust and diverse. Systems are in place for the maintenance of field sampling logs and records; maintenance and storage of on-site and offDACW41-01-D-0031 Task Order No. DA02 August 2002
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site laboratory data; and validation and tabulation of data for practical use. A Microsoft word based database holds a listing of all project related documents, reports and correspondence received or generated by IT Corporation. This system generates control logs/inventory and is the basis for the on-site project filing system. An oracle .based laboratory database management system captures all the electronic data deliverables from the laboratories. The database application utilized is ORACLE® 8.0. The software application used to interface with the database is ITEMS 6.5 and was developed using ORACLE® Forms 4.5. ITEMS is Used to enter the data, generate queries, and produce reports. Data entry and database maintenance is performed by a combined effort of the CQC Manager and offsite ITEMS and ORACLE® experts. A separate software program selec.ted by USACE is utilized by Community Relations staff for development and maintenance 0f-the Administrative Record indexes and p.ublic library repository.
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13.0 PRE-REMEDIATION ACTIVITIES Pre-remediation activitiesincluded the preparation of temporary facilities that are now in place and preparatory activities that were completed prior to commencing full scale remedial activities. The majority of pre-remedial activities were completed over the pedod of mobilization through December 1999. 3.1 TEMPORARY FACILITIES
Existing temporary facilities are being utilized to support remedial activities. These facilities include the six modular multiple unit, inherited site trailers: administration trailer (six units), technical/conference trailer (six units), on-site laboratory trailer, decon trailer, supply trailer (nine units), and showedbathroom trailer (4 units). The former decontamination pad was removed in the course of routine excavation work in CY2001. The perimeter security fence has received pdvacy screening along the Occupied areas and both the screens and.the fence remain in place. A new trailer to house on-site USACE staff and the necessary site improvements to support this trailer were completed in 1998. Maintenance and improvements to these facilities are periodically required. Two new access gates have been installed .since mobilization to facilitate the relocation of the NiMo high voltage power lines. These gates are shown on the updated ~ite map. An on-site groundwater treatment facility has been designed, permitted, and constructed. The treatment plant is being operated in accordance with the Groundwater Treatment Plant ProveOut Report (IT: November, 1999), the final Engineering Design Plan (IT: October, 1999), and the Treatment System Operations and Maintenance Manual, Revision 2 (IT: February, 2001). These documents have previously been submitted and are on file at the site. Waters collected from the dewatering excavations, decontamination operations, and storm water management have been treated in the system since September 1999. A totalof 13,050,000 gallons have been processed through the system as of December 31, 2001. The ground below the treatment plant will require remediat~on as the plant was constructed prior to receipt of final clean-up criteria. This activity is expected to occur late in the project schedule in the hope that plant reconstruction/start-up can be avoided. Ideally the plant will be demobilized at the time the excavation below it is undertaken. See the referenced documents 'for a complete description of the groundwater treatment system and its components. All inherited temporary storm water control measures were inspected and rehabilitated during the first phases of work. These measures typically consist of silt fence and haybales. These items are routinely inspected and cleaned of accumulated sediments on an as necessary basis. Any sediments which are removed from sediment control elements are subjected to the same screening and Categorizing as excavated materials. Please see the Sediment and Soil Erosion Control Plan in Appendix B for a complete description of sedimentation and erosion control measures implemented at the site. All temporary facilities are inspected on a periodic basis by the Quality Control Manager to determine if maintenance or upgrading is required. Maintenance of temporary facilities is performed as needed to ensure the facilities remain in good working order.
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3.2 SITE CONTROLS The entire site is surrounded with a chain link fence of a minimum height of six (6) feet. Access to the site is controlled through a main gate, located at a stop light off Central Avenue. Entrance is restricted to authorized personnel, contractors and visitors. A logbook is maintained at the Administration Trailer to record information regarding visitors and contractors on the site for the duration of the project. Signs are .posted to direct all visitors to the administration trailer. Perimeter signs clearly identify the site as government property, and the. site is posted "No Trespassing Allowed." All exclusion zones are posted as hazardous areas with restricted access. All visitors are assigned a numbered "Visitors" badge and assigned a responsible escort from the permanent staff. Visitors are issued a "Red" hard hat that clearly identifies that the wearer is a visitor and should not be out and about the site without one of the Corps/It Corp Team . members in their immediate presence. All visitors, regardless of whether or not they enter the work. ±ones are provided a Health and Safety Briefing and required to sign acknowledgement forms as to the site safety briefing/site conditions. Any visitors or subcontractors who actually enter the exclusion zones are required to complete site specific Health and Safety training. Copies of all visitor acknowledgement forms and site safety training for subcontractors is maintained in the project files. Copies of the daily sign-in log are distributed with the Daily Contractor's Quality Control Report. Two work actions have altered the perimeter fence since mobilization. Minor fence work was completed to remove the fence separating the Town of Colonie VP from the main site in 1998. A new fence, approximately 395 linear feet of 10-foot high chain link fence covered with visual screening fabric, was installed along the east/northeast property boundary. This fence was installed at the request of the owner of the adjacent property, with concurrence from USACE personnel, to shield site operations and reduce noise. 3.2.1 Control Zones An exclusion zone has been established around all known contaminated areas and potentially contaminated areas of the site. Entrance into exclusion zones is restricted to trained personnel only. Visitors may enter only under escort of a fully qualified team member. All persons entering the exclusion zone must wear appropriate safety attire and abide by the Colonie Site HASP and related hazardous work permits. Personnel and equipment will exit exclusion zones through designated decontamination reduction zones in accordance with the HASP. The RSO maintains vadous daily access registers that document the time each individual spends within a given exclusion area, by individual work tasks. For a more detailed description of the site control measures associated with the exclusion zones, please see the Site HASP/Radiation Safety Manuals. 3.3 NOTIFICATIONS AND ACCESS FOR VICINITY PROPERTIES
An access agreement executed by the DOE is in,place for the Town of Colonie VP. Currently, this property is enclosed by the site. perimeter fence and is being remediated as an integral part of the Colonie Site. Access to the CSXT VP is presently in-place. USACE secured this access agreement in the summer of 2000 in support of the ongoing groundwater remedial investigation activities. Advance notice of any specific actions will be provided to CSXT prior to additional investigation
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Section Pre-Remediation Activities
and remedial activities in accordance with the access agreement. In 1999, IT Corp secured a lease for 2,000 linear feet of track in support of rail transportation to off-site disposal facilities. This lease provides daily access to the VP. Any and all such investigation work on the CSXT VP will be the subject of a separate work plan. Historically, a portion of the CSXT VP is located inside the perimeter fencing. This portion of the VP is being remediated as an integral part of the main site remedial efforts. Access to the Niagara Mohawk Power Substation located northeast of the Colonie Site. was received and screening/sampling was completed in 1999. The electdc substation survey results indicate that the U-238 concentration is less than 35 pCi/g and the Th-232 concentration is less than 15 pCi/g. Please see USACE's June 2000, Focused Site Investigation Report for the Niagara Mohawk Power Station for details and conclusions from these activities. No further work.is contemplated for the NiMo substation under this work plan. 3.4 SITE IMPROVEMENTS
Due to the large volume of matedal to be managed during remedial activities, it was necessary to prepare additional site infrastructure, staging and temporary storage areas prior to subsurface remedial activities. Infrastructure activities completed since mobilization include construction of site utilities, staging areas, phosphoric acid storage tank, soil stabilization system, dewatedng well field, groundwater treatment system, and their associated supporting utilities. These areas/items will be maintain6d throughout the project and the portions of the site they occupy will be remediated in the final phases of the project. Other miscellaneous site improvements will. be periodically required to support ongoing remedial activities. These improvements include constructing additional haul roads, relocating utilities, rerouting drainage features and periodic movement of exclusion zones and entry control points. 3.4.1 Roads Temporary haul roads have and will be const~'ucted on an as required basis to safely ,and efficiently implement the work plan and reined!ate the Colonie Site. These roads will consist of a minimal amount of imported dense road base or other clean material. 3.4.2 Utilities Relocation
The high voltage power lines owned by NiMo were relocated in CY 2000. The relocation of the power lines was completed by a combination of subcontractors and NiMo work crews. The abandoned electrical distribution system within the site boundaries was demolished and disposed of once the new system was functional. Historical information indicates that under the guidance of the DOE, radiologically contaminated soil was removed from the new power pole .locations in the proposed Niagara Mohawk Power Line Relocation Corridors. Definitive information indicating the radius of power pole areas that were excavated, the depth of excavation, or sample collection at the bottom of the excavation is not available, In order to confirm that contamination in a 15' radius from the power poles have been removed to a depth of eight feet (as required by Niagara Mohawk), an intrusive geoprobe investigation was performed in 1999. During this investigation soil samples were collected from the power pole locations as well as from other select locations. The results of this investigation were reported in the June 1999 Power Pole Geoprobe Report. Based on this data, USACE conducted additional excavation at several new pole locations. The excavation work was
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Section 3.0 Pre-Remediation Activities
completed prior to installation of the new poles and was summarized in a report to USACE entitled Niagara Mohawk Power Pole Post-Remediation Report (IT Corp~ June 2000). The stormwater culvert that transits the site was removed and replaced with an "in-kind" class 5 reinforced concrete culvert in the fall of 2001. Work is underway to prepare a summary report of this effort. No further utilities relocation work is contemplated under this work plan. Upon demobilization, minimal utility services (only the connection points) are expected to remain in place. 3.4.3 Treatability Study and Soil Stabilization System Bench scale treatability studies conducted under subcontract with Kiber Environmental in 1999. to identify stabilization materials that might be utilized to minimize future leaching of lead from the soils. In order for matedal to be disposed off-site, waste material must meet LDR criteria. Additional objectives of the studies were to identify a matedal that maintained a soil like consistency as well as limiting the volumetric expansion of stabilized material. For details on the treatability study efforts, please see the final Kiber Treatability Study (May 1999) previously submitted to both the USACE and the New York State Department of Environmental Conservation (NYSDEC). Based upon the results of the treatability study, a phosphor!c acid based system was recommended and implemented. Subsequently, the soil treatment system equipment was mobilized and assembled in the east yard. A chemical bulk storage permit was required for the 6,800 gallon capacity, double contained polyethylene onsite phosphoric acid storage. USACE applied for and was issued this permit (NYSDEC Chemical Bulk Storage Permit Number 4-000243) in September 1999. This permit was renewed in June of 2001 and is current through September 2003. The soil treatment system was tested and successfully completed an operational prove-out period in October 1999. The results of the system prove-out are documented in a separate report entitled Stabilization System Prove-out Report (IT, December 1999). After each soil pile is treated, they are sampled for post treatment TCLP lead levels in accordance with the procedures presented in the SAP. Stabilized soils will not be shipped offsite until analysis indicating the material passes all applicable criteda is received. Over the period of initial testing in October 1999 through December 2001, the soil treatment system has successfully stabilized 46,277 tons of formerly characteristic hazardous waste soils using some 75,000 gallons of phosphoric acid as the stabilizing agent. Weekly work in progress reports provide information on system operations .and are discussed at each weekly. progress meeting. 3.4.4 Groundwater Treatment System The groundwater treatment facility an.d dewatering well field was constructed and completed their operational prove-out in November 1999. The primary flow to the system is from the dewatering well field constructed in the general vicinity of the former Patroon Lake portion of the site. Secondary flow consists of waters collected dudng excavations outside the influence of the dewatering well field, decontamination water .and storm water runoff. Current configuration and locations of the dewatering wells and treatment system equipment are shown on Figure 3..
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Information on system performance is provided in the monthly Discharge Monitoring Reports (DMR) required under the State Pollution Discharge Elimination System (SPDES) permit (#0261084 issued 01 July 1999). System operational data is reported in the weekly work in progress reports and discussed at the weekly progress meetings. Details for the groundwater treatment facility and well field design, construction, prove-out and operationslmaintenance can be found in the following previously, submitted documents: SPDES Engineering Design Report (October 1999) Groundwater Treatment Plant Prove-Out Report (November 1999) Treatment Plant Operations and Maintenance Manual (Rev 2, Feb 2001)
~3.4.5 . Compost Pad Contaminated wood chip piles were generated in 1998 as a result of the reduction of inherited wood materials associated with the former NL building and the reduction of numerous trees, shrubs and other foliage on-site at the time of mobilization. All existing vegetation was cleared, chipped and subjected to a "box count study" to accurately determine radioactivity levels of the wood chips. Those materials deemed to be within site release criteria (approximately 120 cyds) were shipped for incineration at the For~ Edward incinerator in 1998. in a volume reduction approach, USACE authorized the execution of IT Corp's Compost Pad Work Plan (IT, Jan 1999). The remaining votUme (approximately 1200 cyds) was composted to reduce the mass of material. Composting was performed in a prepared area of the north lawn in accordance with the work plan. As of March 2000, all compost pad materials have been shipped for off-site disposal to US Ecology's (formerly EnviroSafe) Idaho landfill. The former compost pad area was taken out of service by removal of the upper soil surface and replacement with topsoil and seeding in the summer of 2000.
3.4.6 Rail Facilities A rail tease was successfully negotiated with Conrail (now CSXT) in April 1999. At the conclusion of lease negotiations, the railroad load-out pad was constructed for the transportation of waste materials destined for off-site disposal. The pad is located as shown in the site base map and is off the east parking lot, adjacent to the CSXT siding. Details for the construction of this pad were defined in the January 1999 Railroad Loading Facility Plan and in accordance with the lease. The rail load-out facility began operations in August 1999 in support of the first off-site waste shipments to Envirocare of Utah for inherited materials. This facility will be removed and the area restored to original or better conditions pdor to demobilization. As ¯ of the date of this revised work plan a total of 58,550 tons of contaminated material in 2,624 intermodal units have been successfully loaded out using this rail load-out facility. Please see Appendix D for a complete description of the Waste Transportation Plan, waste disposal facilities, and waste profiles in place in support of the work. Transportation and disposal activities are reported in the weekly work in progress totals report and discussed at each weekly progress meeting. Shipping logs and rail car location reports are posted on the website weekly.
3.4.7 Chemical Management Building Removal During the summer of 1999, under the technical direction of the USACE, the inherited former chemical management building (CMB) was cleaned out and formally decontaminated by IT
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S~ction 3.0 Pre-RemediatJon Activities
Corp staff. The tent structure was free released and was relocated intact to cover the water treatment facility along the south property line in October 1999. All chemicals and contaminated metals associated with the former CMB were characterized for off-site disposal in accordance with the SAP and shipp4d off-site for disposal/destruction as appropriate (based on the individual materials by either IT to GTS Duratek's Oak Ridge, TN facility or by .our subcontractor for laboratory chemical waste management, AETS Inc. of Albany, NY). '
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14.0 REMOVAL OF IMPACTED MATERIAL As remediation progresses at the Colonie Site, soils are excavated and segregated into soil piles of approximately 250 loose cubic yards in size based on both radiological and chemical content. The following sections provide information on the process being utilized in the removal of impacted soil and functions as the excavation plan for the remedial work. 4.1 SEQUENCE OF REMEDIAL ACTIVITIES
Remedial activities are normally conducted in a sequence that utilizes the limited space of the site as efficiently as possible. The ideal sequence of work involves a balance among the excavation amounts, the capacity of the soil stabilization system and the rail load-out rate. When this sequence of work is balanced, stockpiles are not created or added too, the soil input (excavation amounts) is matched by the soil output (off-site transportation and disposal). At this time and. for the previous work, the primary factor governing .this equation has been shipping rate (which is dependant on fiscal year funding allocations). Weekly work in progress reports provide information on the amounts of soils excavated, processed through the stabilization system and shipped off-site. The running soil inventory is reported weekly and has varied over time since excavation work was initiated in April 1999, with a high volume of approximately 18,000 cyds to the current 11,500 cyds level on 31 Dec 2001. The following sections discuss specific areas and general reas.oning for the sequence of remediation: Western Landfilled Areas The western landfilled areas of the site will be the first areas to be remediated. This area containsthe bulk of the anticipated waste materials. The anticipated depth and spatial orientation of the expected excavation is shown in Figure 4. The extent of current excavation is shown in Figure 3 and the pre-excavation conditions are present in Figure 2. Figure 4 is the one-foot contour mosaic created from the DOE's site characterization data modeled in EarthVision software. These contours are modified due to the Final Action Memorandum criteria as shown in Appendix G (which presents the Technical Memorandum's co-location of primary contaminants assessment). Actual excavation depths will be determined based on field survey instruments and confirmed in accordance with the Final Status Survey Plan requirements. Once the excavation is complete (as determined by radiological and inorganics field scanning instruments), the former landfill areas will be surveyed in accordance with the FSSP and sampled in accordance with the SAP to confirm compliance with site remedial goals prior to backfilling. As of December 2001, it is estimated that 80% of the landfilled area has been excavated and were awaiting Final Status Survey efforts. The backfilling of these areas (former Patroon Lake, Town of Colonie Vicinity Property and the "Keyhole") will be expedited, to the extent possible, to minimize the amount of water collected and treated. Upon FSS Unit Report approvals; these areas will be backfilled prior to beginning excavation in other areas. This area also includes the Town of Colonie VP, the "keyhole" area, and the former Patroon Lake area. Buildin.q Slab Area/East Loading Dock Area Remediation Following the remediation of the landfilled areas, excavation will begin in the building slab and ¯ east loading dock areas. The soil inventory must be sufficiently reduced in order to clear the
DACW41-01-D-0031 Task Order No. DA02 August 20~)2 4-1 Operations Work Plan Colonie FUSRAP Project Final
G001481
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areas of the slab currently covered by stockpiles awaiting off-site disposal. These areas have been identified as containing chemical contaminants to a depth of up to 30 feet below ground surface. The anticipated depth and spatial orientation of the expected excavation is shown in Figure 4 .and as adjusted per the Technical Memorandum's co-location of primary contaminants assessment provided in Appendix G. These areas will be remediated next in sequence due to the significant amount of material that may require removal. Per USACE's direction, all building ¯ slabs and footers will be removed to a depth of at least four feet, processed for. disposal and stockpiled as part of remedial activities. This work will continue throughout the project. All pipe chases and/or former piping systems buried below the slab will be completely removed to ensure that any piping that carried radioactive or inorganic contamination is fully removed from the former building slab areas. North Lawn/Trailer Complex and Parking Lot Remediation Following remediation of the building slab and east loading dock areas, the north lawn, trailer complex and parking lot areas will be remediated. The anticipated depth and spatial orientation of the expected excavation is shown in Figure 4 and as adjusted per the Technical Memorandum's co-location of primary contaminants assessment provided in Appendi× G. The extent of excavation and amount of matedal to be removed is expected to be minor in these areas. .Bay 1lEast Parkinq ...Lot The bay 1 and east parking lot, utilized throughout the project for stockpile storage, material treatment, and rail load-out, will be the final areas to be remediated. The anticipated depth and spatial orientation of the expected excavation is shown in Figure 4 and as adjusted per the Technical Memorandum's co-location of. pdmary contaminants assessment provided in Appendix Go Some of the material removed from these areas may be required to be loaded directly int0.temporary storage containers (e.g., roll-off boxes) and shipped for offsite treatment and disposal to prevent cross contamination of areas previously remediated and to facilitate demobilization work for the rail load-out pad. 4.2 GENERAL EXCAVATION PROCEDURE
Radiological, chemical and material impacted by both categories is removed using conventional excavation equipment, which includes excavators, backhoes, front-end loaders, and articulated dump trucks. In general, excavation proceeds from the removal of radiologically impacted soils to the removal of chemically impacted soils. The excavated material and work zones are monitored with a combination flame ionization detector (FID) and photoionization detector (PID) for the presence of VOCs in accordance with the HASP and SAP. All excavation work is based on the site grid shown on Figure 3. As individual grids are targeted for excavation they are first surveyed with field instruments (a FIDLER for radiological COCs and the XRF for inorganic COCs) to determine starting points within the assigned grid. This data is compared to the anticipated aerial and vertical extent of excavation available from Figure 4 and Appendix G. The radiological levels are marked directly on the soil using spray paints. XRF levels are not typically, marked unless the grid only contains inorganics above the clean-up criteria. Excavation generally proceeds in approximately one to 1.5 foot lifts, using standard and proven geotechnical engineering means. Material is preferentially excavated in order of radiological
DACW41-01-D-0031 Task Order No. DA02 August 2002 4-2 OperalJons Work Plan Colonie FUSRAP Project Final
G001482
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levels, i.e. all hot matedal (by correlation matedal inferred to have radiological levels of Th-232 > 55 pic/gm and/or U-238 > 167 pic/gm) in a grid is removed first, followed by warm material (by correlation material inferred to have radiological levels of 2.8
Prior to actual excavation in any given grid, a radiological surface scan of the area is performed using field instruments in accordance with procedures specified in the SAP. Areas are delineated in the field as radiologically "hot" (U-238 at greater than or equal to 167 pCi/g) or radiologically contaminated (U-238 at greater than or equal to 35 pCi/g but less than 167 pCi/g). These areas are cleady marked using marking paint, flagging, stakes or other appropriate means. USACE's hand held Niton 700 Series X-ray fluorescence unit (model 723Q) is used to guide excavation efforts with respect to inorganic COCs. This equipment allows the determination of lead concentrations on a real-time basis within the actual excavation area. Typically, the Niton unit is used to survey for inorganic COCs (principally using lead as the dominant indicator) on an approximate 25 by 25 foot grid. These XRF readings are used to assist with sequencing the excavations. A review of the historical inorganic contaminate maps is conducted to compare the field survey data to the expected aerial and vertical extent of contamination present within the given grid area. Taken together this information is reviewed by site management personnel and a specific excavation plan implemented for the grid. All areas that are marked as radiologically "hot" or "warm" during completion of the preexcavation survey work will be excavated using the procedures outlined in section 4.2.2. Non-radiologically contaminated soils will be excavated following procedures defined in section 4.2.4.
DACW41-01-D-0031 Task Order No. DA02 August 2002 4-3 Operations Work Plan Colonle FUSRAP Project Final
G001483
Case 1:05-cv-01075-TCW
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Section 4.0 Removal of Impacted Material
4.2.2
Initial Radiological Excavation
Marked out areas areexcavated in approximately one to 1.5 foot lifts. At the completion of each lift within a marked area, a radiological survey instrument (e.g., FIDLER) is used to determine if the newly exposed surface meets the target radiological criteria. This process of excavation in approximate one to 1.5 foot lifts followed by surveying the new surface will continue for a maximum of three lifts or an excavation depth within a marked area of no more than three feet. This maximum depth has been selected for health and safety purposes and to minimize extraneous efforts required for the OSHA confined space four feet limitation on excavations. 4.2.3 Continuing Excavation Once the soil in areas of radiological concerns have been removed from a given area or to a maximum three foot depth, excavation into adjacent grids is conducted following the same initial procedures, i.e. field surveyed, marked and then excavated in approximate one to 1.5 foot lifts. At the conclusion of removal of each lift of soils, the new surface is surveyed to determine both the lead and radiological levels present. If radiological or inorganics levels above clean-up criteria are found during the field survey of this new surface, these areas of concern .are marked and the area excavated as detailed above. If no radiological areas of concern or inorganic areas of concern are found during the field survey of this new surface, excavation is finished and the excavation moves to the next sequential grid. This process will continue until the targeted, elevations presented in Figure 4 and Appendix G are approached or field data indicates clean-up criteria have been achieved. Upon achievement of this goal, the area will then be subjected to the procedures outlined in the FSSP and the SAP to document/confirm clean-up criteria has been met. If the final status survey efforts .reveal unacceptable levels of radio~ogical or chemical constituents, the areas of concern will be delineated and re-excavated until acceptable levels are achieved as demonstrated by completing a second final status survey in these areas. 4.2.4 Lead Excavation Depth Limitation
once radiological contamination has been removed from any given grid, the area is checked using the XRF for compliance with the specified inorganic COCs (Lead above 450 ppm, Copper above 1,912 ppm and/or Arsenic above 7.4 ppm). The elevations within the subject grid are surveyed to determine the depth of the assumed radiologically clean surface. In accordance with the Action Memorandum, if this surface is determined to I~e equal to or greater than a depth of nine (9) feet below grid's original grade, no further excavation will occur. Under this condition, the surface is deemed ready .to be subjected to the confirmation .procedures presented below and detailed in the Final Status Survey Plan and the Sampling and Analysis Plan for post-excavation surfaces. For the purposes of this work plan, o~iginal grades are those defined in the pre-existing survey as shown in Figure 2. 4.3 POST EXCAVATION FINAL STATUS SURVEYS "The processes described above will continue until achievement of both of the following levels: Regardless of depths at which encountered, no U-238 or Th-232 areas of concern as defined by field radiological surveys for Action Memorandum specified clean-up levels; and
DACW41-01-D-0031 Task Order No. DA02 August 2002 Operations Work Plan Colonie FUSRAP Project Final
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Case 1:05-cv-01075-TCW
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Section 4.0 Removal of Impacted Material
For depths above nine feet below original grade, no lead, copper or arsenic areas of concern as defined by on-site XRF equipment for Action Memorandum specified clean-up levels. Levels of lead, copper and/or arsenic above c!ean-up criteria found at depths greater than nine feet below original grade Will be left in place per the Action Memorandum. Upon achievement of the above levels, the specific area will then be subjected to the procedures outlined in the FSSP and SAP to confirm post excavation quality levels. The sampling procedures outlined in the FSSP will also be followed for final status inorganic sampling where applicable, using the same sampling locations and sampling scheme. If the final status survey efforts reveal unacceptable levels (as determined by USACE) of radiological (regardless of depth encountered) or chemical constituents (at depths above the maximum nine feet depth below original ground surface elevations), these specific areas of concern will be delineated and re-excavated until acceptable levels are achieved as demonstrated by completing re-survey and re-sampling in these specific areas of concern." Upon completion of excavation (as defined by remedial scanning with field instruments) within a given area or final survey unit, a final status radiological surface survey and verification sampling for chemical and radiological analysis is conducted in accordance with the SAP and the FSSP. Details on final status surveying, verification sampling and analyses procedures are . provided in the FSSP and the SAP. When these final chemical and radiologidal analysis/surveys are completed and deemed acceptable, a civil survey of the final vertical and horizontal extent of the given 'excavation area will be performed under the direction of licensed land surveyors provided by CT Male & Associates. 'NYSDEC has indicated that they will conduct their own confirmatory radiological survey of each final status unit. Individual Final Status Survey Reports will be prepared to document the post-excavation compliance with clean-up criteda for each final status survey unit. A post remedial certification report will be submitted to USACE at the conclusion of the specified work. This report will document soil excavation and segregation activities at the site. The report .will present the total excavation volume and the disposition of all excavated materials. 4.4 DEBRIS It is anticipated that debris (including drums, concrete, masonry, wood, and miscellaneous metal) will continue to. be encountered during excavation activities, especially within the areas where direct landfilling occurred. These materials will be removed and segregated for charactedza~ion. Concrete, asphalt, and wood debris will be processed for disposal as necessary and handled as specified in section 5. Intact drums containing product (if any) will be placed in overpacks and sampled for disposition. If drums containing product(s) are damaged and/or leaking and contain product, they will be overpacked or the product will be removed and placed in an appropriate storage container. If deemed appropriate, metals with salvage value will be segregated for disposal as scrap.
DACW41-01-D-O031 Task Order No. DA02 August 2002
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Operations Work Plan Cotonie FUSRAP Project Final
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Section 4.0 Removal of Impacted Material
4.5
FREE PRODUCT REMEDIATION
A light non-aqueous phase liquid (LNAPL) has been previously documented in monitoring well B39W19S. This well is located on the building slab in the former bay 5 area of the site (coordinates N 1,294 E 1,396). According to historical information, an air compressor which leaked "light oil" was located in bay 5, and a 30-gallon drum used to collect the oil was reportedly .dumped at the back of the building once it was filled. Historic data indicates the LNAPL thickness has ranged from approximately.a thin layer (0.2 feet) to allegedly as high as five feet. Free product was reportedly located approximately 14 feet below the slab of the building and was first measured to be 5.6 feet thick on July 28, 1998. A sample of the LNAPL from the well was collected and analyzed in 1998. The results indicated that the LNAPL consists mainly of fuel oil. In January 1999, a test pit excavation was completed approximately 10 feet east of monitoring well B39W19S. PID readings taken at approximately one foot intervals were below 5 ppm up to the depth of 13 feet below the building slab surface. Excavation continued to approximately 15.6 feet below building slab surface with PID readings reaching 400 ppm. A strong fuel type odor was detected at a depth greater than 13 feet below the building slab. No visible oils were encountered. A LNAPL monitoring effort was conducted during the month of September 1999. Weekly measurements including depth to LNAPL, depth to water, and thickness of LNAPL were made and recorded for five weeks. LNAPL thickness prior to removal via bailing ranged from 0.14 feet to 1.85 feet; with post removal measurements ranging from 0.05 feet to 0.1 feet. These efforts were re-instituted in 2000 and continue today. Table 3 contains a summary of the LNAPL monitoring conducted through December 2001 at well 19S. If encountered, soils impacted with LNAPL will be segregated at the time of excavation. These soils will be characterized as discussed in the SAP. Based on analytical results, these materials may be either treated on-site or shipped directly for off-site disposal.
DACW41-01-D-0031 Task Order No. DA02 August 2002
Operations Work Plan Colonie FUSRAP Project. Final
G001486
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