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FINAL

OPERATIONS WORK PLAN
COLONIE FUSRAP SITE

AUGUST 2002 (REVISION 5)

U.S. ARMY CORPS OF ENGINEERS NEW YORK DISTRICT OFFICE ¯ FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM

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TABLE OF CONTENTS
Section
Page

1-1 1.0 INTRODUCTION ........................................................................................................................... 1.1 PLAN OBJECTIVE ................................... . ................................................... ~ .............. : ................ 1-2 1-3 1.2 SITE BACKGROUND ................................................................................................................ ~ .......... 1-4 1.3 SITE DESCRIPTION ....................................................................................................... 1-5 1.4 PREVIOUS INVESTIGATIONS ................................................................................................. . 1.5 CONTAMINANTS OF CONCERN ............... ............................................................................. 1-6. 1-6 1.6 REMEDIAL AREAS .................................................................................................................... Landfilled Western Area .............. ...................................................... ~. ................................ 1-7 1.6.1 Building Slab, East Loading Dock, and Bay 1 Area ............................................. . .............. 1-7 1.6.2 1-7 1.6.3 Trailer Complex Area ..........................................................................................................

1.6.4 East Parking Lot ................................................................... ~ .............................................. 1-8 1-8 1.6.5 Vicinity Properties ............................................................................................................... 1.7 INHERITED STAGED. MATERIAL ............................................................................................. 1-8
2.0 2-1 PROJECT ORGANIZATION, PERSONNEL, KEY SUBCONTRACTORS .................................. UNITED STATES ARMY CORPS OF ENGINEERS ................................................................. 2-2 2.1 2-2 2.2 iT CORP. TOTAL ENVIRONMENTAL RESTORATION CONTRACT (TERC) TEAM .............. 2.3 IT CORPORATION ON-SITE COLONIE PROJECT TEAM ......................................................2-2 PRE-REMEDIATION ACTIVITIES ................................................................................................ 3-1 3-1 3-2 3-2

3.0

3.1 TEMPORARY FACILITIES ........................................................................................................ 3.2 SITE CONTROLS. ..................................................................................................................... 3.2.1 Control Zones .....................................................................................................................

3-2 3.3 NOTIFICATIONS AND ACCESS FOR VICINITY PROPERTIES .............................................. 3.4 SITE IMPROVEMENTS ................................................ 3-3 3-3 3.4.1 Roads.................................................................................................................................. 3:4.2 3.4.3 3,4.4 3.4.5 3.4.6 3.4.7 3-3 Utilities Relocation .............................................................................................................. Treatability Study and Soil Stabilization System ................................................................. 3-4 Groundwater Treatment System ........................................................................ ; ................ 3-4 3-5 Compost Pad ...................................................................................................................... . .................................................................. 3-5 Chemical Management Building Removal ................................................ i .......................... 3-5 Rail Facilities .................................................... 4-1 4-1

REMOVAL OF IMPACTED MATERIAL ....................................................................................... 4.0 4.1 SEQUENCE OF REMED AL ACTIVITIES ..............i ..................................................................

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GENERAL EXCAVATION PROCEDURE .................................................................................. 4.2 4.2.1 Pre-Excavation Surveys ............................................................................. ......................... 4.2.2 4.2.3 4.2.4 4.3 4.4 4.5. 5.0

4-2

4-3 Initial Radiological Excavation ..................... : ................ . ....................................................... 4-4 Continuing Excavation ........................................................................................................ 4-4 Lead Excavation Depth Limitation .......... ................................................................ ~ ........... 4-4

POST EXCAVATION FINAL STATUS SURVEYS ......... .......................................................... 4-4 ~ DEBRIS...................................................................................................................................... 4-5 FREE PRODUCT REMEDIATION ............................................................................................. MATERIAL HANDLING ..................................................................................... 4-6

: ............. ; ............ 5-1 5-1 5-2 5-2

5.1 MATERIAL SEGREGATION ...................................................................................................... 5.2 ON-SITE TREATMENT ............................................................................................................. 5.2.1 Treatment Confirmation ....................................................................................................... 6.0 SUPPORTING OPERATIONS ..'. ......................................................................................

~ ............ 6-1 6-1 6.1 ENVIRONMENTAL CONTROL SYSTEMS AND MONITORING PROGRAM .......................... 6.1.1 6.1.2 6.1.3 6-1 Erosion and Sedimentation Controls .................................................................................. Storm Water Runoff ....................................................................... i .................................... 6-1 Water Treatment Facility Operation ..................................... : .............................................. 6-1 6-2

6.2 DUST SUPPRESSION ..............................................................................................................

6-2 6.3 PERIMETER AIR MONITORING ................................................................................................ 6.3.1 Total Particulate Emissions ......................................... : .................................................. ....6-2 6-3 6.3.2 Perimeter Monitoring - Radiation ....................................................................................... Perimeter Monitoring - Lead ............................................................................................... 6.3.3 6.4 - HEALTH, SAFETY, AND RADIATION PROTECTION .............................................................. 6.4.1 6.4.2 6.4.3 6-3 6-3

On-Site Laboratory and Radiation Control Operations .......................~: .............................. 6-4 Decontamination and Free Release Operations .................................................. ~ .............. 6-4 Vehicle/Railcar/Container Decontamination ........................................................................ 6-5 6-5 6-5

6.5 QUALITY CONTROLS ................................................................................................................ 6.6 CIVIL SURVEY ........................................................................................................................... 7.0

~ ............... 7-1 SITE CLOSURE ; ........................................................................................................... 7.1 SITE RESTORATION ............................................. : ......................................... ~.. ..................... 7-1 7 7.2 PERSONNEL, EQUIPMENT, AND 'FACILITIES DEMOBILIZATION ........................................ -1 SCHEDULE .......................... , .............................................................................................. ; ..... ....8-1 9-1

8.0
9.0

REFERENCES .......................... ~ ...................................................................................................

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LIST OF FIGURES Figure 1. Site Location Map 2. Original Conditions Topography (May 1998) 3. Current Conditions Site Base Map (December 2001 update) 4. One Foot Mosaic Drawings 5. USACE Colonie Team Organizational Chart 6. IT Corporation Colonie Team Organizational Chart 7. Material Segregation F~ow Chart .

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LIST OF TABLES Table 1. Summary of Key Colonie FUSRAP Site Reports/Plans 1998-2001 2. Key Metrics Completed Through December 2001 3. Well 19S LNAPL Monitoring Data Table

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LIST OF APPENDICES Appendix A Project Scl~edule 3-29-02 B Sediment and Soil Erosion Control.Plan C Construction Specifications D Waste Transportation & Disposal Plan E Regulatory Plan F Drawings . G Technical Memorandum Collocation of Contaminants Plots

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LIST OF ACRONYMS AEC ............... Atomic Energy Commission ALARA ...........As Low As Reasonably Achievable ClSS .............. Colonie Interim Storage Site CFR ............... Code of Federal Regulations mz .................. cubic meters CMB ...............Chemical Management BuildingCOC .............. Contaminants of concern Conrail .... ....... Consolidated Rail Corporation cpm ................counts per minute CQC ......... : .... Construction Quality Control CQCP ............Construction Quality Control Plan CSXT .... : .........Consolidated Rail Corporation yd~ ................. cubic yards DA .................Designated Area DNAPL..........Dense Non-Aqueous Phase Liquid DOE ............... Department of Energy EE/C/k ............Engineering Evaluation and Cost Analysis FID.. ...............Flame Ionization Detector FIDLER ..........Field Instrument for 13etecting Low Energy Radioactivity FSSP ............. Final Status Survey Plan FUSRAP ........ Formerly Utilized Site Remedial Action Program HASP .............Health and Safety and Emergency Response Plan HAZWOPER.. Hazardous Waste Operations and Response HPGe............. High Purity Germanium LCYD ............Loose Cubic Yard LDR ...............Land Disposal Restrictions MARSSIM...~.. Multi-Agency Radiation Survey and Site Investigation Manual LNAPL ........... Light Non-Aqueous Phase Liquid mg/L ..............milligrams per liter Mg/Kg...........Milligrams per Kilogram NiMo .............. Niagara Mohawk Power Corp. NL..................National Lead Industries ¯ NRC ............... Nuclear Regulatory Commission NYSDEC ........ New York State Department of Environmental Conservation ORNL ............ Oak Ridge National Laboratory OSHA ............ Occupational Safety and Health Administration pCi ................. picoCudes PCE ............... tetrachloroethene (also known as perchloroethene) PID ................ Photoionization Detector PPE ............... Personnel Protective Equipment QC ................. Quality Control RCRA ............Resource Conservation Recovery Act SAP ...............Sampling and Analysis Plan ,m2 .................. quare meters s SOP ............... Standard Operating Procedure SPDES .......... State Pollution Discharge Elimiriation System TCE ............... tdchloroethene
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TCLP ............. Toxicity Characteristic Leaching Procedure TERC ............. Total Environmental Restoration Contract Th .................. Thorium U .................... Uranium USACE .......... United States Army Corps of Engineers USEPA .......... United States Environmental Protection Agency VOC............... Volatile Organic Compound VPs ................ Vicinity Properties WAC ..............Waste Acceptance Criteria XRF ............... X-Ray Fluorescence Spectroscopy 1,2-DCE ......... 1,2-dichloroethene

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EXECUTIVE SUMMARY
Starting in 1998 and continuing today, the United States Army Corps .of Engineers (USACE) has issued task orders associated with the Baltimore District's Total Environmental Restoration Contract (TERC) for the restoration of the Colonie, NY Site under the Formerly Utilized Sites Remedial Action Program (FUSRAP). The original task order was issued to ICF Kaiser Inc., and the IT Corporation (IT), a member of The IT Group, assumed responsibility for the work on or about April 9, 1999. The task orders direct IT to complete remedial activities at the Colonie Site. As part of these requirements, IT has prepared this revised Operations Work Plan with the intent to provide a working guidance for site activities. A cooperative partnership between the USACE, IT, and federal and local regulatory agencies will ultimately determine the successful implementation of this work plan. This revision of the Site Operations Work Plan supercedes all previous versions of the Operations Work Plan. This revision has been prepared in response to the USACE's execution of a Final Action Memorandum (USACE, December 2001) and their supporting Technical Memorandum (USACE, June 2001)o Taken together these documents significantly alter the remedial action requirements at the Colonie FUSRAP Site. More specifically, the former on-site designated disposal area has been eliminated from the scope, and all waste materials encountered are now destined for off-site disposal. Additionally, the Final Action Memorandum added specific clean-up goals for lead, copper and arsenic as well as a decrease in the specified thorium-232 clean-up goal to 2.8 picoCuries/gram (pCi/gm). This Operations Plan summarizes the project organization, current and relevant historic project information, and current status of site remedial work activities as of December 2001. Initially, USACE and IT compiled site information obtained under former contracts to provide a working understanding of the remedial direction necessary to develop and implement earlier versions of the Site Operations Work Plan. This information provided an overview of the radiological and chemical contaminants of concern and an estimated volume of material that is potentially contaminated. With the execution of the Final Action Memorandum and in accordance with the .Technical Memorandum's requirements,previous plans are replaced with this revision which provides updated guidance to ensure the work is completed in a logical, systematic and efficient manner, consistent with the new remedial requirements. The primary focus of this document is to guide site construction and remedial activities in conjunction with the most recent versions of the supporting stand alone documents such as the Colonie Site Health and Safety and Emergency Response Plan, as well as the Contractor Quality Control Plan. The revised Operations Plan highlights the scope of work aspects such as planning, site layout, remedial activity specifications, and site restoration. The key to site remediation is the Operation Work Plan's approach to the sequence of excavation, treatment, and the final disposition of the waste materials. In association with the USACE project team, IT is implementing a phased remedial approach that includes excavation, final status surveying, soil arld water treatment, off-site disposal, and site restoration to original grades with clean backfill materials. The construction specifications and drawings contained within this plan have been and continue to be used to guide IT's field crews and subcontractors during the course of the remedial activities. This revised Site OPerations Plan builds on the numerous reports and supporting documents developed over the course of the project. Key phases of the work completed under .earlier
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. Executive Summary

versions of the work plan included the disposal, of inherited material stockpiles, chemicals; and debris; the design, construction and continued operation of the on-site treatment systems (for RCRA soils and for waters); and initial excavation and off-site disposal of contaminated materials. Table 1 contains a listing of major or key reports and/or documents developed over the period 1998through 2001. Readers are referenced to these documents for ahy necessary background, performance or supplemental data not contained herein. Copies of all project related documents are maintained on file and available for review at the Colonie FUSRAP Site offices upon request. Table 2 presents a summary level presentation of the key metrics completed to date during the remediation of the Colonie Site. Total amounts completed for off-site disposal volumes, excavation totals, and amounts of soil and water treated in the on-sita ti'eatment systems are included. An additional resource available for information on the Colonie FUSRAP Site is the New York District's Colonie FUSRAP website (web~ead.anl.gov/Colonie). This website contains weekly progress meeting notes, select project documents, listing of team members, aerial ¯ photographs, and site photographs documenting the steady remedial progress at the Site.

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1.0 INTRODUCTION The U.S. Army Corps of Engineers (USACE) has been designated to remediate the former Colonie Interim Storage Site (CISS) and three adjacent vicinity properties (VPs), hereafter referred to as the Colonie FUSRAP Site. This remedial effort falls under the USACE's Formerly Utilized Sites Remedial Action Program (FUSRAP), which was established to identify, investigate, and clean up or control sites previously used by the Atomic Energy Commission (AEC) and its predecessor, the Manhattan Engineer District. The IT Corporation (IT), a member of The IT Group, under the USACE Total Ehvironmental Restoration Contract (TERC) No. DACA 31-95-D-0083, (currently Task Order NO. 40), is the Remedial Action Contractor for the Colonie Site.
The Colonie FUSRAP Site is located in the Town of Colonie, Albany County, New York State. Figure 1 presents the general site location. Figure 2 is the topographic survey conducted in May 1998 and represents the original site conditions at the time the USACE initiated field work. Figure 3 presents the current site conditions mapping and infrastrqcture in place as of December 2001. The goal of this remedial effort is to .efficiently achieve the remedial objectives as described in the December 2001 Action Memorandum and in accordance with the June 2001 supporting Technical Memorandum for the Colonie Site (U.S. Army Corps of. Engineers or USACE, 2001). Please refer to the Baseline Risk Assessment contained within the Technical Memorandum itself for discussion of the selection and. appropriateness of the current clean-up goals. The soil removal effort includes: The excavation and off-site disposal of site material(s) with Uranium-238 (U-238) levels greater than or equal to 35 picoCuries/gram (pCi/g), regardless of the depth at which these materials are encountered. The excavation and off-site disposal of site material(s) with Thorium-232 (Th-232) levels greater than or equal to 2.8 pCi/g, regardless of the depth at which these materials are encountered. ¯ The excavation and off-site disposal of site material(s) with total Lead levels greater than or equal to 450 mg/kg AND encountered at depths of nine (9) feet or less below original grade. The excavation and off-site disposal of site material with total Copper greater than or equal to 1,912 mg/kg AND encountered at depths of nine (9) feet or less below original grade. The excavation and off-site disposal of site material with total Arsenic levels greater than or equal to 7.4 mg/kg AND encountered at depths of nine (9) feet or less below original grade. The excavation of a minimum of six inches of material from the entire site, fenceline to fenceline, prior to the execution of Final Status Survey(s) over the entire site. The placement of a minimum of six inches and an average of two (2) feet of clean backfill soil over the site.

"I

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Section 1.0 Introduction

Key pro-remedial activities completed under previous versions of the Operations Work Plan consisted of plan preparation and submission, regulatory and property notifications, and support facilities construction. Several key documents and plans for the successful implementation of the work are contained as appendices to this work plan, including the current project schedule, Sediment and Soil Erosion Control Plan, Construction Specifications, Waste Transportation and Disposal Plan, Regulatory Plan, Project Drawings and Technical Memorandum contaminant plots. Several key stand alone planning documents are being revised in the same manner as. this Site Operations Plan. These documents include revisions to the Sampling and Analysis Plan (SAP: IT Corp., April 2000), Final Status Survey Plan (FSSP: IT Corp., January 2002), Health and Safety and Emergency Response Plan (HASP: IT Corp, September 2000), and Contractor Quality Control Plan (CQCP: IT Corp., June 2000). The Site Operations Plan and these stand alone plans are complimentary to and further supported by the key documents/reports listed in Table 1. All waters [esulting from remedial effortsl including decontamination water, water resulting from dewatering of excavations, and storm water from. exposed areas, will be collected, treated, and discharged in accordance with the Colonie Site State Pollution Discharge Elimination System (SPDES, Permit #NY-0261084, effective July 1, 1999 through July 1, 2004). A separate groundwater remedial investigation is ongoing at the site. For details on the site geology, hydrogeology and associated items, the reader is referred to the various groundwater remedial investigation related work plans and reports, including the eight (8) biannual groundwater monitoring reports completed by USACE .since 1998. The results of the investigation work completed to date are summarized by various stand-alone documents listed in Table 1. It is acknowledged by the USACE and state regulatory personnel that the mass removal of contaminated soils and the associated dewatering activities will in all likelihood improve groundwater quality. 1.1 PLAN OBJECTIVE

The objective of this revised Operations Work Plan is to provide guidance for completing field activities required to meet the remediation goals specified in the Action Memorandum and in accordance with the supporting Technical Memorandum. This plan details the general procedures being followed for ongoing remedial activities, to confirm cleanup levels have been achieved, for disposing of waste, and to complete final site restoration actions. Any additional plans, if required based on site progress or events, will be attached as an addendum. All such modifications will be discussed in the weekly progress meetings prior to implementation. Formal modifications to this plan (if required) will be submitted to USACE for approval prior to implementation, and where appropriate, to applicable state agencies for regulatory approval. The key focus of the revised Operations Plan is to achieve site closure and return the property to viable use. With this objective in mind, remedial action is driven by the requirements stated in the Action Memoas well as regulatory and public concern(s). The FSSP will be implemented to determine if the post excavation surfaces have achieved site clean-up. This final status surveying program is based on use of the Multi=Agency Radiation Survey and Site Investigation Manual (MARSSIM, EPA, 1997) statistical approach to sampling the remaining soils.

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Section 1.0 Introduction

A key section of the revised Operations Plan is the project master schedule. A planned, logical schedule is critical to the continued successful implementation of this work plan. Key project tasks are outlined in the schedule and provide guidance to systematic implementation of Site activities. The project master schedule is discussed during the weekly progress meetings. The schedule is formally updated and distributed on a monthly basis. The master project schedule as of December 2001 is included in Appendix A.. This master project Schedule contains the schedule for the additional efforts being undertaken in support of the Colonie FUSRAP site: supporting community relations efforts, for the separate groundwater remedial investigation efforts by Argonne National Laboratory (ANL), and for the separate Risk Assessment/Feasibility Study by URS Corporation (URS) and by USACE themselves. 1.2 SITE BACKGROUND

Industrial operations on-site began in approximately 1923 when the Embossing Company purchased a portion of the present day site to construct a facility to manufacture wood products and toys. In 1927, Magnus Metal Company, Inc. purchased the property and converted the facility to a brass foundry for manufacturing railroad components. Magnus Metal Company, Inc. cast the brass components in sand molds and manufactured brass bearing housings with surfaces of babbitt metal (an alloy of lead, copper and antimony). In 1937, National Lead Industries (NL) purchased the facility and continued the brass foundry operations initiated by Magnus Metal Company, Inc. At some point before 1941, NL purchased an adjacent lot that contained a portion of Patroon Lake and began filling Patroon Lake with used casting sand. After World War I!, the plant began casting aluminum parts and frames for aircraft. In 1958, the nuclear division of NL began producing items manufactured from uranium and thorium under a license issued by the AEC. NL discontinued its. brass foundry operation in 1960. From 1958 through 1984, NL carded out a number of processes using radioactive materials consisting primarily of depleted uranium but also of thorium and enriched uranium. The plant handled enriched uranium from approximately 1960 to 1972. From 1966 to 1972, NL held several contracts to manufacture fuel from enriched uranium for experimental nuclear reactors. Operations were conducted at the I~lant to reduce depleted uranium-tetrafluoride to depleted uranium metal, which was then fabricated into shielding components, ballast weights, and projectiles. Other processes conducted at the plant included an electroplating operation for plating uranium with nickel and cadmium. Chemicals used in the plating operation included nickel sulfamate, sodium cyanide, ferric chloride, nitric acid, silicate phosphate, iridite (chromium brightener), cadmium metal, nickel metal, boric ,acid, and tetrachloroethene (also known as perchloroethene, or PCE). How or where most of these materials were disposed is unknown; very few disposal records have been located. NL letters indicate that under an AEC license, approximately 42 cubic meters (cm) of graphite, slag, refractory, uranium oxide, insoluble oil, metal scrap, and combustible trash were buried in the Patroon Lake area in 1961. Chemical wastes and packaged chemicals used at the site have included acids, bases, degreasing agents, carbon tetrachloride, benzene, polychlorinated biphenyls (PCBs), cyanide, and asbestos. The chemicals present on the Resource Conservation and Recovery Act (RCRA) Part A application permit were removed from the Colonie Site as part of this facility's closure as a designated "interim RCRA storage facility." This closure was documented in the 1995 RCRA Closure Report certified by both the DOE and an independent New York State Professional Engineer.
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SecSon 1.0 In~oduc~on

New York State officials closed NL in 1984 at which time Congress authorized the DOE to remediate the property. In February 1984, the Secretary of Energy accepted an offer from NL to donate the land, buildings, and equipment to the DOE in order to help expedite the cleanup. The USACE accepted the property on behalf of the DOE on February 29, 1984 and transferred the title to DOE. In 1985 the DOE acquired a portion of the Niagara Mohawk (NiMo) property bordering the Colonie-Site (existing power pole alignment and the "Keyhole" portion of the site) and subsequently designated it as part of the Colonie Site. The "Keyhole" portion of the site is that part of the site that resembles a "keyhole" in a door and is the irregular shaped, western most portion of the site through which the un-named tributary flows before entering the stormwater culvert. From 1984 to 1988, remedial efforts were completed by the DOE for 53 of the 56 VPs. From 1992 to 1996, the remaining NL Site buildings were demolished by DOE. Various debris, waste materials and machinery associated with demolition of the main building were left on-site at the time .USACE and their contractors initiated their remedial efforts. Under previously negotiated agreements, the DOE currently owns the former NL property. The owners of the three vicinity properties have been notified of the current work plans and access agreements and notification procedures are in place for access to their parcels and for remedial activities (if required) on these properties. 1.3 SITE DESCRIPTION

As shown in Figure 1, the subject property is located at 1130 Central Avenue (New York State Route 5) in the Town of Colonie, Albany County, New York. The Colonie FUSRAP Site is an 11.2 acre parcel located, immediately north and west of the Albany City line. The CSXT Vicinity Property located adjacent to the site on our southern property line is entirely within the limits of the City of Albany. At the time of USACE's initial mobilization in 1998, approximately four acres of the site were paved with asphalt in varying physical conditions. Approximately four acres were vegetated with grasslands and/or tree/brushy areas. The slab of the main building covered the remaining portions of the parcel, approximately 3.2 acres in the central/southern portions of the Colonie Site. Figure 2 is a topographic survey map of the Colonie Site, based on May 1998 aerial photography and is generally understood to represent pre-remedial conditions, Figure 3 is the current site conditions and is based upon Figure 2 as modified for the numerous site infrastructure improvements and remediation completed through December 2001. The Colonie Site is bounded by a heavily wooded lot on the west (7 Railroad Ave), CSXT Transportation (formerly Conrail) rail tracks on the southwest and south, active commercial properties on the east/northeast, New York State Route 5/Central Avenue on the north, and a NiMo electrical substation on the northwest. The surrounding area consists of mixed residential and commercial properties. NiMo owns a revised easement for the high voltage lines in the western portion of the site and passing over the storm water drainage channel in the "Keyhole" area, located in the westernmost portion of the site. The current and former NiMo easements are both shown on Figure 3. The high voltage power lines and poles were installed in the new easement in CY2000. This occurred at the conclusion of agreements between USACE and NiMo to demolish the lines and power poles in the former alignment, in order to facilitate safe excavation of contaminated soils located below the former lines.
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Section 1.0 Introductlon

Three Vicinity Properties were subject to further action(s) at the time the responsibility for the Colonie FUSRAP Site was transferred from Department of Energy to USACE. These three VP's are: Town of Colonie Property. This property, located along the west central portion of the site, consisted of a O.3-acre vacant lot originally overgrown with weeds and small trees. Formal access agreements for this VP was inherited from DOE. This vicinity property is being remediated as an integral part of the main site remediation. Excavation efforts in 2001 have resulted in the removal of contaminated soils/materials from the Colbnie VP. Post excavation sampling has confirmed compliance .with the clean-up criteria and portions of the VP were backfilled and/or utilized for construction of the replacement stormwater culvert in the fall of .CY2001. CSXT (formerly Conrail) Railroad Property. This property, obtained by CSXT from Conrail in 1999, consists of two main. rail lines and spurs which once served NL and other local commercial enterprises. The spur is located inside the perimeter fence on the southern property line. As such this small portion of the VP is being managed as an integral part of the main site remediation. The VP property is approximately 6.5 acres in size, extending roughly 1,900 feet east to west and varies in width from approximately 80 to 180 feet north to south. An access agreement between the USACE and CSXT was executed in 2000. This agreement has been used to obtain Soil bodngs, groundwater quality and geophysical data from the VP in support of the ongoing groundwater remedial inv.estigation efforts. (See separate reports prepared to document the actions completed on this VP under USACE direction). USACE has authorized IT Corp to prepare a work plan for a site investigation of this VP. The schedule associated with the CSXT VP Site Investigation is included in the Colonie Master Schedule~

Niagara Mohawk Electrical Power Substation. This active substation occupies a 140 by 170 foot fenced lot located at the site's north/northwest corner. USACE directed radiological surveys and analytical sampling of this VP during 1998 and 1999. For details on these survey efforts and the current Status of this substation, please refer to the USACE Vicinity Property Report entitled. Final Draft, Focused Site Investigation Report, Niagara Mohawk Power Station, Colonie NY (USACE, April 2000).
1.4 PREVIOUS INVESTIGATIONS

.Several investigations and/or radiological contamination surveys of the site have been conducted since 1978 and prior to USACE's assumption of the lead agency for the site. While the plant was still operated and controlled by NL, a survey of the building was conducted by Atcor, Inc., in 1978 (Atcor, 1978). Teledyne Isotopes conducted two surveys o[ the site grounds for NL, one in 1980 and one in 1981 (Teledyne Isotopes, 1980, 1981). In 1984, Bechtel National, Inc. (Bechtel) conducted a preliminary geological investigation of the site and began performing routine environmental monitoring. Results are provided in separate annual environmental monitoring reports, Oak Ridge National Laboratory (ORNL) conducted a radiological survey of the former Conrail (now CSXT) VP in 1988 (ORNL 1988). From 1992 to 1995, Bechtel conducted additional characterization studies on site involving soil gas, soil, sediment, surface water, and groundwater sampling. A partial database of key historical information from previous DOE efforts is maintained on the site. USACE New York District maintains a full copy of the inherited DOE site database.

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Operations Work Plan Colonie FUSRAP Project Final

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Filed 07/02/2007

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Section 1.0 Introduction

1.5

CONTAMINANTS OF CONCERN

Based on the Technical Memorandum, the Action Memorandum and historic site characterization data, the Colonie Site contaminants of concern for soils were categorized into radiological and chemical Constituents. The radiological constituents consist of U-238 and Th232. The chemical constituents selected in the Technical Memorandum were lead, copper and arsenic. Please see the Technical Memorandum for the basis and discussion of the selection process utilized to select the specific contaminates of concern for soils and the associated clean-up levels to be achieved dudng the remedial effort. Material that has been generated during previous remedial activities conducted by DOE and DOE's contractors was stockpiled or otherwise staged on-site at the time of IT Corp's mobilization in Apdl 1998. These materials included concrete, brick, mixed debris, wood chips, soil, drums, derelict equipment, scrap metal, railroad ballast and personal protective equipment (PPE). Additionally, various chemicals and products were left within the former DOE chemical management building, a fabric/frame structure formerly located in the main parking lot of the site. As one of USACE% initial accomplishments at the site, these materials were further characterized for disposal purposes and was disposed of in an appropriate manner along with newly generated waste materials. Previous investigations and studies have identified the likely presence of buded drums and miscellaneous debris within the former Patroon Lake and other fill areas. Excavation actions routinely uncover drum remnants and large amounts of metallic debds. To date none of these items have been found intact or to have recoverable product due to the length of burial and the fluctuating groundwater table. Based on historical information, there is a potential to encounter pyrophoric uranium waste buried under the former bay 2 east loading dock. If encountered, these materials will be handled in a safe manner and the work plan amended to incorporate these activities. As the remedial work progresses, new data on air quality, ground water, surface water and soil concentrationslquantities are.being obtained. These data are routinely discussed in the weekly progress meetings. Meeting notes, task logs and numerous data tables are posted to the Colonie website (web address: web.ead.anl.gov/colonie) for ease of distribution and dissemination. Table 2 contains a summary of key site activities, including disposal actions completed under previous Operations Work Plans. 1.6 REMEDIAL AREAS

The Colonie Site has been divided into four general remedial areas. Figure 4 presents a one foot contour mosaic of.the expected contaminate profiles for Lead, Uranium and Thodum. This estimated depth and extent of excavation is based on modeling of the DOE's site characterization data using EarthVision software. It is generally understood that based on excavation efforts to date that the primary factor driving the excavation is the lead content of the soils. The co-locations of the primary contaminants was examined dudng the development of the Technical Memorandum. The collocation of contamination plots are reproduced in Appendix G. The four general remedial areas are the landfilled western areas, the building footprint areas, the trailer complex area and the east yard area. Of these areas, the vast bulk of waste materials are anticipated to come from the first two areas (Le., the landfilled area and the
Operations Work Plan Colonie FUSRAP Project Final

DACW41-01-D-0031 Task Order No. DA02 August 2002

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Section 1.0 Introduction

building footprint area). The following section includes the general physical features, chemicals of concern, and anticipated extent of excavation specific to each of these remedial areas. t.6.1 Landfilled Western Area This area is generally bound to the east by the former NL building foundation and by the site's western and southern fencetines. Historic information indicates contaminant depths vary from 3 feet to as deep as 20 feet, with the groundwater surface typically three feet below the existing ground surface. See the one foot mosaic drawing/Figure 4 and Appendix G for anticipated depths of excavation in this area. This landfilled western area was previously known as Patroon Lake, and has been filled with casting sands, concrete rubble, NL plant wastes, soil backfill and debris. Additionally, it has been reported that drums containing pyrophoric material may have been buried in the fill. Dewatering of soils has been and will continue to be required to complete the anticipated excavation and backfilling. This area includes the Town of Colonie VP, which will be remediated concurrently with this area. For a more detailed description of the buded wastes, please see the DOE Site Characterization Report (DOE, 1992) The storm water drainage channel on the extreme western side of the property, as well as the Niagara Mohawk utilities easement, are located in this area of the site. The Niagara Mohawk power lines were relocated in accordance with the technical direction of the USACE in FY2000. The former and current alignment of the power lines are shown on Figure 3, the December 2001 current site conditions map. In the fall of 2001, .the stormwater culvert was replaced in kind per USACE's technical direction. The former culvert was taken out of service and removed once the new culvert installation was complete. The former and current alignment of the stormwater culvert are shown on Figure 3. 1.6.2 Building Slab, East Loading Dock, and Bay I Area The building slab, east loading dock and bay 1 consist of approximately 11,300 m2 of concrete slab and 1,620 mz of unimproved dirt surface (from which the concrete slab has been partially removed).. The remaining concrete slab and concrete footing will be removed and processed for off-site disposal. Prior work in CY1999 provided sufficient sample data to confirm appropriate disposal of concrete materials. To date approximately 60% of the slab and footers have been demolished and shipped for off-site disposal at the US Ecology landfill in Idaho. Previous investigations have identified U-238 contamination up to nine feet deep below the slab, and lead contamination has been identified to depths of 30 feet below the slab. See the one foot mosaic drawing/Figure 4 and Appendix G for anticipated depths of excavation in this area. 1.6.3 Trailer Complex Area The north lawn, parking lot and trailer complex areal consists of approximately 4,600 m2 of grass surface, asphalt, structures, utilities and concrete pads. Lead contamination has been identified to depths of three feet. A previously conducted radiological walkover survey reportedly indicates that the paved surfaces are sporadically contaminated with fixed U-238 above 35 pCi/g. The trailer complex is located in the western portion of this area, and is scheduled to be remediated near the completion of the project. Excavation in the eastern portion of this area was initiated in CY2000 and subsequently abandoned while awaiting receipt of the Action Memorandum and its associated metals clean-up criteria. At that time this work was temporarily abandoned, the area was covered with approximately four inches (4") of
Operations Work Plan ColonieFUSRAP Project Final

DACW41-01-D-0031 Task Order No. DA02 August 2002

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Section 1.0 JntroductJon

imported topsoil, and handseeded to control erosion. See Figure 4 and Appendix G for anticipated depths of excavation in this area. 1.6.4 East Parking Lot This area is located in the east section of the site property and consists of asphalt parking and driving areas. The surface area is approximately 7,000 m2 and the asphalt has been found to contain fixed radioiogical contamination. Additionally, sporadic U-238 contamination has been identified to approximately three feet below the asphalt. In accordance with an agreement between IT and CSXT, in CY1999 a rail loading facility was constructed on the southern boundary to facilitate loading of material into rail cars for off-site disposal. A portion of the east parking lot is used for the waste stabilization system equipment for treating the soils with leachable lead to below TCLP levels and/or land disposal requirements. As such the treatment system will be relocated prior to completion of excavation below the plant. A stockpile of excavated materials awaiting a determination on use as clean backfill is located in the east yard along with several storage conex boxes. See the one foot mosaic drawing/Figure 4 and Appendix G for anticipated depths of excavation in this area.

1.6.5 Vicinity Properties See Section 1.3 above for a general description of the remaining Vicinity Properties. The Town of Colonie VP is being remediated concurrently with the remediation of the site proper. As of December 2001, all excavation work in this area has been completed and the new stormwater culvert headwall constructed in this area.
In 1998, a site investigation/inspection of the NiMo electrical substation located along the northwest section of the site was performed for radiological contamination. A summary report of IT's survey results has been provided to the USACE. This survey did not discover contamination equal to or greater than 35 pCi/g U-238 or 15 pCi/g Th-232 in the surface soils, on any surfaces (Le., metal) or in sludge from the manhole, indicating that surface remediation of the substation area is not required based upon current radiological criteria. Please see USACE's Final Draft, Focused Site. Investigation Report, Niagara Mohawk Power Station, Colonie NY (USACE, April 2000) for details. Based on NYSDEC correspondence dated 31 August 2000, "the Department agrees with the conclusion that no further action under the FUSRAP program is required at this vicinity property". The CSXT VP is located along the southern property boundary. Surface soil samples (0 to 5 cm) previously collected by DOE from within the CSXT VP in the 1980's indicate contamination greater than 35 pCi/g U-238. Access agreements are in place between USACE and CSXT to permit sampling, surveying, and/or remediation of the CSXT VP. A separate work plan is being developed to govern the conduct of separate CERCLA based site investigation work on this VP. 1.7 INHERITED. STAGED MATERIAL

Based on waste charactedzation activities completed by IT during 1998, all waste materials generated by previous remedial activities have been properly disposed of at permitted off-site facilities. Over the period since mobilization, IT has packaged and shipped over 447,500 pounds of radiologically contaminated machinery, dry activated waste and/or other metallic objects for destruction/burial through GTS Duratek's Oak Ridge, Tennessee facility. Du.ring August and September of 1999, 952 yd3 of the most radiologically active RCRA materials and 27 drums of solidified uranium raffinates were shipped for treatment and ultimate disposal at
OACW41-01-D-O031 Task Order No. DA02 August 2002 1-8 Operations Work Plan Colonie FUSRAP Project Final

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Section 1o0 Introduction

Envirocare of Utah's permitted landfill through Zhagrus Environmental. Additionally, the vadous chemicals left inside the former chemical management building (CMB) were inventoried, packaged and shipped for offsite disposal/destruction or recycling (depending on the specific .chemical) in July 1999. The former CMB was decontaminated and free released for re-use as the building housing the curreht water treatment system equipment in September of 1999.

DACW41-01-D-0031 Task Order No. DA02 August 2002

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Operations Work Plan Colonle FUSRAP Project Final

G001465

Case 1:05-cv-01075-TCW

Document 61-17

Filed 07/02/2007

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