Remedial Action Report for the Tank Farm Interim … Revision 0 Project Nos. 020978 and 023614...

DOE/NE-ID-11209

Revision 0

Remedial Action Report for the Tank Farm Interim Action, WAG 3, OU 3-13, Group 1, Tank Farm Soils

June 2005

DOE/NE-ID-11209Revision 0

Project Nos. 020978 and 023614


June 2005

Prepared for the U.S. Department of Energy

DOE-NE Idaho Operations Office

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ABSTRACT

The purpose of this Remedial Action Report is to document the work performed, discuss modifications to the remedial action, and document the project’s completion and final certification status. The Operable Unit 3-13 Record of Decision required an interim remedial action for the Idaho Nuclear Technology and Engineering Center tank farm to protect human health and the environment. This action, as described by the Agreement to Resolve Dispute, was implemented through the Remedial Design/Remedial Action (RD/RA) Work Plan for Group 1, Tank Farm Interim Action, Revision 1. The objectives of this plan were to install and maintain institutional controls to prevent exposure to the tank farm soil and engineering controls to reduce water infiltration into the tank farm. To achieve this objective, (a) an asphalt cover was placed over three soil contamination sites within the tank farm to divert precipitation and reduce infiltration, (b) the storm water collection system around the tank farm was installed and improved, (c) a lift station was installed, and (d) an evaporation pond with a leak detection system was installed to serve as the collection point for the diverted run-off.

Installation of the project’s components began in Fiscal Year 2001, but, due to funding limitations, the project did not meet the enforceable completion date for the draft Remedial Action Report (May 2002). As a result, the Department of Energy was given a Notice of Violation for not demonstrating compliance with the requirements of the RD/RA Work Plan in accordance with the Federal Facility Agreement/Consent Order. The Environmental Protection Agency, Idaho Department of Environmental Quality, and the Department of Energy Idaho Operations Office settled the Notice of Violation in an agreement effective in February 2003, which required the Department of Energy Idaho Operations Office to complete the interim action activities as amended by the Agreement to Resolve Dispute.

The RD/RA Work Plan was revised in May 2003 to incorporate changes to the interim action design per the Agreement to Resolve Dispute and construction work resumed. Phase I of the interim action was completed and certified in September 2003. This included all work performed outside the tank farm fence (upgrading culverts, lining ditches, asphalting areas surrounding the tank farm, installing a lift station, and installing the evaporation pond). Construction on Phase II of the interim action began in spring 2004 and was certified complete in September of that year. This work included placing impermeable asphalt caps over three soil contamination sites and installing drainage piping from these caps to the existing storm water collection system.

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CONTENTS

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

ACRONYMS..............................................................................................................................................vii

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

1.1 Background ........................................................................................................................1-1

2. DISCUSSION OF REMEDIATION ACTIVITIES........................................................................2-1

3. CONSTRUCTION ACTIVITIES ...................................................................................................3-1

3.1 Construction Activities Performed .....................................................................................3-1

3.1.1 Storm Water Collection System.......................................................................3-13.1.2 Evaporation Pond .............................................................................................3-33.1.3 Grading and Paving..........................................................................................3-4

3.2 Issues During Construction ................................................................................................3-4

3.2.1 Sewer Lift Station ............................................................................................3-43.2.2 Trench Drain ....................................................................................................3-43.2.3 New Site Identifications ...................................................................................3-43.2.4 Asphalt Compaction.........................................................................................3-63.2.5 Deletion of CPP-31 Corner Section from Design ............................................3-6

3.3 Project-Generated Wastes ..................................................................................................3-6

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

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

6. MODIFICATIONS TO THE REMEDIAL ACTION.....................................................................6-1

7. PREFINAL AND FINAL INSPECTION .......................................................................................7-1

7.1 Phase I ................................................................................................................................7-1

7.2 Phase II ...............................................................................................................................7-1

8. OPERATION AND MAINTENANCE...........................................................................................8-1

9. FINAL TOTAL COSTS..................................................................................................................9-1

10. CERTIFICATIONS.......................................................................................................................10-1

11. DOCUMENTATION TO SUPPORT DELETION OF THE SITE FROM THE NPL.................11-1

12. ANNUAL OPERATIONS REPORT ............................................................................................12-1

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13. OBSERVATIONS AND LESSONS LEARNED .........................................................................13-1

14. CONTACT INFORMATION .......................................................................................................14-1

15. REFERENCES..............................................................................................................................15-1

Appendix A—As-Built Drawings.............................................................................................................A-1

Appendix B—Operation and Maintenance Plan for INTEC Operable Unit 3-13, Group 1, Tank Farm Interim Action ....................................................................................................................... B-1

Appendix C—Summary of Verification and Inspection Reports Generated for TFIA ............................ C-1

Appendix D—Photographs (Reference P-1227, Tank Farm Interim Action Photographs, October 11, 2000, to October 2004) ...............................................................................................D-1

FIGURES

1-1. Location of INTEC within the INL .................................................................................................1-2

3-1. TFIA component locations ..............................................................................................................3-2

TABLES

4-1. Tank Farm Interim Action chronology of events ............................................................................4-1

5-1. Remediation objectives compared to performance results ..............................................................5-1

5-2. Vendor data for TFIA Phase I .........................................................................................................5-2

5-3. Vendor data for TFIA Phase II ........................................................................................................5-3

9-1. Total cost for TFIA remedial action ................................................................................................9-1

14-1. Points of contact for the WAG 3, OU 3-13, Tank Farm Interim Action Project, Phase I .............14-1

14-2. Points of contact for the WAG 3, OU 3-13, Tank Farm Interim Action Project, Phase II............14-2

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ACRONYMS

ARD Agreement to Resolve Dispute

BBWI Bechtel BWXT Idaho, LLC

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CFA Central Facilities Area

CID construction interface document

CMP corrugated metal pipe

DEQ Department of Environmental Quality (Idaho)

DOE Department of Energy

DOE Idaho Department of Energy Idaho Operations Office

EPA Environmental Protection Agency

FFA/CO Federal Facility Agreement and Consent Order

HDPE high-density polyethylene

ICDF Idaho CERCLA Disposal Facility

ICP Idaho Cleanup Project

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Center

NPL National Priorities List

NSI New Site Identification

O&M operation and maintenance

OU operable unit

PEW process equipment waste

PVC polyvinyl chloride

RA remedial action

RD/RA remedial design/remedial action

RI/FS remedial investigation/feasibility study

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ROD Record of Decision

TFIA Tank Farm Interim Action

WAG waste area group

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1. INTRODUCTION

In accordance with the Idaho National Engineering and Environmental Laboratorya Federal Facility Agreement and Consent Order (FFA/CO) (DOE-ID 1991), the Department of Energy Idaho Operations Office (DOE Idaho) submits this interim Remedial Action (RA) Report for the Tank Farm Interim Action (TFIA) Project, designated as Waste Area Group (WAG) 3, Operable Unit (OU) 3-13, Group 1, of the Idaho National Laboratory (INL). The completed remedial design/remedial action (RD/RA) activities identified in this RA Report, as part of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) process, were conducted in accordance with the signed OU 3-13 Record of Decision (ROD) (DOE-ID 1999) and the RD/RA Scope of Work (DOE-ID 2000a) for WAG 3, OU 3-13 as modified by the Agreement to Resolve Dispute (ARD) dated March 4, 2003 (DOE 2003). The scope of this project is detailed in the Remedial Design/Remedial Action Work Plan for Group 1, Tank Farm

Interim Action (DOE-ID 2003a). The purpose of this report is to describe the work performed, discuss modifications to the remedial action, and document the current status of the project.

1.1 Background

The Idaho Nuclear Technology and Engineering Center (INTEC) facility, formerly known as the Idaho Chemical Processing Plant, is located in the south-central area of the INL in southeastern Idaho (see Figure 1-1). From 1952 to 1992, operations at INTEC primarily involved reprocessing spent nuclear fuel from defense projects, which entailed extracting reusable uranium from the spent fuels. Liquid waste generated from the reprocessing activities, which ceased in 1992, is stored in an underground tank farm at INTEC. Both soil and groundwater contamination has resulted from these previous operations. Under the FFA/CO, the Environmental Protection Agency (EPA), the Idaho Department of Environmental Quality (DEQ), and DOE Idaho (collectively referred to as the Agencies) are directing cleanup activities to reduce human health and environmental risks to acceptable levels. Per the FFA/CO, INTEC is designated as WAG 3. To facilitate remediation of INTEC, WAG 3 was further divided into OUs comprised of individual contaminant release sites.

Several phases of investigation have been performed at the OUs within WAG 3. A comprehensive remedial investigation/feasibility study (RI/FS) was conducted for OU 3-13 to determine the nature and extent of contamination and corresponding potential risks to human health and the environment under various exposure pathways and scenarios. Based on the RI/FS results, INTEC release sites were further segregated into seven groups based on contaminants of concern, accessibility, or geographic proximity to allow development and analysis of remedial action alternatives. The tank farm soils represent

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

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Figure 1-1. Location of INTEC within the INL.

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principal-threat wastes due to (a) direct radiation exposure to workers or the public and (b) potential leaching and transport of contaminants to the perched water or the Snake River Plain Aquifer, a sole source aquifer. A final remedy for the Tank Farm Soils release sites has been deferred pending further characterization and coordination of any proposed remedial actions with the Idaho High-Level Waste &

Facilities Disposition Environmental Impact Statement (DOE 2002). A separate RI/FS, Proposed Plan, and ROD will be prepared for the Tank Farm Soils under OU 3-14. Interim actions were evaluated to provide protection until a final remedy is developed and implemented. The selected interim action for the Tank Farm Soils is institutional controls with surface water control. This interim action, named Tank Farm Interim Action (TFIA), was designated as Group 1 within OU 3-13. The Group 1 soils are located within the tank farm fence and adjacent to the process equipment waste (PEW) evaporator building. The initial major components of this interim action remedy included (1) restricting access to control exposure to workers and prevent exposure to the public from soils at the tank farm until implementation of the final remedy under OU 3-14, (2) accommodating a 1-in-25-year, 24-hour storm event with surface water run-on diversion channels, (3) minimizing precipitation infiltration by grading and surface-sealing the tank farm soils sufficient to divert 80% of the average annual precipitation falling on the Tank Farm Soils area, and (4) improving the exterior building drainage to direct water away from the contaminated areas (DOE-ID 2000b). This interim action was to be implemented in two phases, described as

Phase I, consisting of repairing and lining of the existing surface water drainage system and constructing a new lined evaporation pond, all utilizing a gravity-flow system.

Phase II, consisting of the implementation of engineering controls within the tank farm perimeter fence to reduce infiltration. Options to be evaluated included resurfacing with asphalt or other impermeable surfaces, temporary enclosures, and spray-on membranes.

This initial intent and list of components were modified as documented in the RD/RA Work Plan, Revision 1, (DOE-ID 2003a) and as detailed in Section 2, Discussion of Remediation Activities, of this report.

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2. DISCUSSION OF REMEDIATION ACTIVITIES

The RD/RA Work Plan for Group 1, Tank Farm Interim Action, Revision 0 (DOE-ID 2000b), was finalized and distributed to the Agencies in September 2000. The plan provided the framework for defining the remedial design requirements, preparing the design documentation, and defining and implementing the construction and operations phases of OU 3-13 TFIA that were to be performed at INTEC. The plan detailed the design developed to support the interim action activities, selected in the final ROD for OU 3-13, as well as the management approach to conduct the interim action, the work elements for the interim action, and associated schedule and documentation.

The design criteria for the remedial action were divided into three major components:

Improving the storm water drainage system in and around the tank farm

Installing a storm water evaporation pond to collect the storm water run-off

Installing a surface seal over the unpaved surfaces within the tank farm and the majority of the unpaved surfaces within a 150-ft control zone surrounding the tank farm (see Section 3, Figure 3-1).

Construction on the TFIA project began in October 2000 as per the design in the RD/RA Work Plan and continued until August 1, 2001, when, due to funding limitations, the subcontractor was directed to halt construction of the evaporation pond and leak detection system. Work continued on the storm water collection system to allow the project to be put into a safe condition. On November 29, 2001, the subcontractor demobilized and construction activities stopped.

The RD/RA Work Plan called for construction of the TFIA to be completed by September 28, 2001, and a draft RA report was to be completed and submitted by July 29, 2002. An extension was requested but was denied by the Agencies. In February, work began on the RA Report for the work completed. The document described the work performed as part of the TFIA, described the work outlined in the RD/RA Work Plan that had not been accomplished, and documented the current status of the project (Hain 2002). A draft of the document was completed in May 2002 and submitted to the Agencies for review. The RA Report was rejected and on December 4, 2002, a Notice of Violation and Penalty Assessment was delivered. The Notice of Violation alleged a violation of failing to submit the RA Report for OU 3-13, Group 1, in accordance with the established deadline. Specifically, the Notice of Violation alleged violations due to the failure to complete work as required under the RD/RA Work Plan for the Group 1 Tank Farm Interim Action (Kreizenbeck 2002). Ensuing discussions resulted in the creation of an ARD that was created and transmitted to the Agencies (Bowhan 2003) on March 4, 2003. In this ARD, the following statements were agreed upon, changing the content of the RD/RA Work Plan:

Complete and put into operation the following work outside the tank farm fence: lining ditches, installing culverts, and lining the evaporation pond

Place an infiltration barrier over the affected areas of release sites CPP-28, CPP-31, and CPP-79 in the tank farm.

In March 2003, an agreement was reached among the Agencies on the areas that needed to be covered outside the tank farm. Some of the areas outside the tank farm fence that were originally shown in the RD/RA Work Plan (DOE-ID 2000b) as being covered with an infiltration barrier will not need the covering. The ARD (DOE 2003) did not require the entire tank farm surface inside the fence be covered.

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Therefore, some of the areas outside of the tank farm fence did not need to be covered, as surface water infiltration will not be diverted to those areas. Also, some of these areas are small and do not impact the overall reduction of infiltration or are problematic and cannot be covered.

It was agreed that the remedial action objectives of the TFIA would not be impacted by these modifications and the cover installed will accomplish the 80% reduction in surface water infiltration as required by the OU 3-13 ROD (DOE-ID 1999). These modifications, and those for Phase II, were included in the revised RD/RA Work Plan which was completed and distributed in September 2003.

The RD/RA Work Plan design includes the following:

Storm Water Drainage System - This work activity involves (a) the upgrading of selected ditches and replacement of culverts around the tank farm and (b) all activities associated with this work. The specific components include

All existing storm water collection ditches around the tank farm and out to the specified discharge point are to be graded and lined with concrete.

Selected existing culverts around the tank farm and out to the specified discharge point are to be replaced with larger culverts to accommodate the expected increase in storm water flow, resulting from improved storm water collection.

Concrete headwalls and endwalls are to be constructed throughout the lined drainage system.

Three concrete-lined ditches are to be constructed that are either partly or fully within the tank farm to collect and direct precipitation run-off to the surrounding storm water collection system.

A lift station is to be constructed at the intersection of Beech Street and Olive Avenue to pump storm water to a location where it would drain freely to the specified discharge point.

Three manholes are to be installed as part of the storm water collection system.

A trench drain is to be installed on the east side of Beech Street near Building CPP-756.

Storm Water Evaporation Pond - A lined storm water evaporation pond is to be constructed to collect storm water run-off from the tank farm and 150-ft control zone. The pond is to be located east of the INTEC perimeter fence and south of the existing sewage treatment plant. The pond will be

approximately 21 ft deep, with bottom dimensions approximately 240 320 ft and will be double-lined with a leak detection system. All storm water drainage ditches and culverts within the scope of this project will be routed to this pond, which will be surrounded with a new chain-link fence as a wildlife and personnel safety precaution.

Surface Sealing - An asphalt covering will be applied to Sites CPP-28, CPP-31, and CPP-79 within the tank farm fence and to the majority of the unpaved surfaces within the 150-ft control zone to minimize infiltration into the underlying soils.

Section 3.3.1 of the ARD identified that the Agencies will work collaboratively to expedite a phased implementation of the Tank Farm Soils permanent remedy. The date identified in the ARD for preparation of the OU 3-14 Record of Decision was December 31, 2006, with an acknowledgement that this date would be revised with the establishment of the data quality objectives. Section 3.3.3 of the ARD identified that, if pursuing an early permanent remedy for OU 3-14 is not possible, the operation and

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maintenance (O&M) plan will include a plan and schedule for installation of an infiltration barrier over the remaining areas of the tank farm as the tanks are closed. Because the Department of Energy (DOE) intends to pursue an early permanent remedy as identified in the ARD, the O&M plan does not include a plan and schedule for the infiltration barrier. If conditions change and an early permanent remedy is not achievable, the O&M plan will be revised.

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3. CONSTRUCTION ACTIVITIES

This section describes the construction activities performed to meet the remedial action objectives as specified in the ROD and listed in Section 5, Performance Standards and Construction Quality Control.

3.1 Construction Activities Performed

This interim action was designed to provide institutional controls to capture and redirect surface water run-off away from the tank farm and into an evaporation pond (see Figure 3-1). Sections 3.1.1 through 3.1.3 list and describe the components installed in support of this interim action.

3.1.1 Storm Water Collection System

The storm water collection system was upgraded around the tank farm and out to the discharge point (evaporation pond). This upgrade included grading and constructing new ditches, regrading and lining the existing ditches with concrete, installing a trench drain along Beech Street, and replacing existing culverts with larger culverts to accommodate the expected increase in storm water flow. This upgrade also included constructing concrete headwalls and endwalls as necessary throughout the lined drainage system and constructing a lift station.

The storm water collection system was designed and constructed to accommodate the peak discharge from a 25-year storm. The major components of the storm water collection system constructed during this phase of the project are described below:

Storm Water Collection Ditches: A total of 20 ditches were upgraded/installed and lined with concrete. Ditches are located both inside and outside the tank farm and primarily located next to Beech Street, Cypress Avenue, Palm Avenue, Hemlock Street, Cedar Street, Fir Street, and Olive Avenue (see Figure 3-1).

Trench Drain: One trench drain (approximately 185 ft) was installed along Beech Street, north of the Olive Avenue and Beech Street intersection.

Culverts: A total of 20 culverts were either installed, upgraded, and/or incorporated in the TFIA system, which connects the lined drainage ditches together (see Figure 3-1).

Manholes: A total of three manholes were installed as part of the storm water collection system. One manhole is located near the corner of Olive Avenue and Beech Street and the other two are located along the east perimeter road connecting the final culverts together that ultimately discharge into the evaporation pond.

Headwalls and Endwalls: These were installed at the entrance to and exit from each culvert in the TFIA drainage system.

Lift Station: The storm water lift station was constructed at the intersection of Beech Street and Olive Avenue. The lift station is 10 ft in diameter and 15.8 ft deep with a storage volume of approximately 3,500 gal. Major components of the storm water lift station are as follows:

- Pumps: There are two 5-horsepower centrifugal, nonclog, submersible sewage pumps. Each pump is sized to accommodate a flow of 603 gpm, the design flow from a 2-year storm event. Combined, the pumps are able to accommodate the design flow from a 25-year storm,

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Figure 3-1. TFIA component locations.

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approximately 1,230 gpm. Each pump was fitted with a Grip Eye System for use to allow raising and lowering the pump without requiring personnel to enter the lift station.

- Force Main: The flow from the pumps is directed through an 8-in.-diameter polyvinyl chloride (PVC) pipe approximately 400 ft long. This 8-in.-diameter force main is required to limit head loss within the pipe. The last 10 ft are upsized to a 12-in. diameter to keep discharge velocities at acceptable levels. The force main runs east along Olive Avenue and discharges into the storm water collection ditch just east of Fir Street (see Figure 3-1).

- Controls: Each pump has a 480-V circuit breaker, a starter, overload relays, a hand/off/auto switch, an intrinsically safe pump controller with a pump alternator, a pump run light, and a time meter. The level of water in the lift station is monitored using an ultrasonic level controller transducer. The pumps are configured to alternate pumping and operate simultaneously in the event of high water levels in the lift station. A high-level alarm with a flashing light and an audible alarm was also installed and certified operational.

3.1.2 Evaporation Pond

The storm water evaporation pond was constructed outside the INTEC fence, approximately 300 ft north of Building CPP-698. Major activities and components of the evaporation pond are as follows:

Excavated and graded the pond, berm, and access road. The pond excavation consisted of roughly 57,000 yd3 of excavated material, with 11,000 yd3 of the excavated material being replaced for construction of the berm. The remaining 46,000 yd3 of soil met the reuse criteria, <23 pCi/g Cs-137 (DOE-ID 2003b), and was stockpiled south of INTEC for reuse. The pond is 21 ft deep with 3:1 side-slopes, and the top of the berm is approximately 6 to 8 ft above the existing surface. The outer berm was constructed at a 2:1 side-slope down to the existing grade. Topsoil was then placed on the outside of the berm to decrease the side-slope to 3:1. All disturbed areas around the pond and on the outer berm were revegetated.

Installed an 8-ft-high chain-link security fence around the perimeter of the pond.

Installed the 48-in. inlet of the evaporation pond, which was made from corrugated metal pipe (CMP) culvert.

Installed two 24-in. CMP culverts, canal gates, a riprap-lined ditch, a concrete pad, and a “V” ditch at the outlet of the pond.

Constructed concrete aprons surrounding the inlet and outlet culverts and a concrete slab located at the high-level discharge ditch outside the pad.

Installed electrical work at the evaporation pond, which consisted of the duct bank and conduit work from Substation CPP-1703 to the control panel location.

Installed the high-density polyethylene (HDPE) double-liner system, consisting of two 60-mil HDPE geomembranes, a nonwoven geotextile, a geonet, and a ballast system.

Installed the leak-collection sump and associated components, consisting of a sump pump, discharge piping, a level sensor, a totalizer, and an electrical control panel.

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3.1.3 Grading and Paving

Unpaved/gravel surfaces within the tank farm and surrounding the tank farm, as designated in the RD/RA Work Plan, were sealed with asphalt to prevent water infiltration and divert surface water toward the storm water collection system. Select areas outside the tank farm (see Figure 3-1) were covered with asphalt which sloped in the direction of nearby concrete-lined storm water collection ditches. These areas are located along the west side of Beech Street between Cypress Avenue and Olive Avenue, on both sides of Olive Avenue from Beech Street to Building CPP-659, and north of the tank farm along Cypress Avenue and Cedar Street.

Areas within the tank farm that were covered with asphalt included soil contamination area CPP-31 (10,428 ft2) and combined soil contamination areas CPP-28 and CPP-79 (4,029 ft2). These areas are sloped toward CMP outlets that are connected to flexible HDPE pipe that directs surface water run-off to discharge piping that transports it to the storm water collection lined ditches along the perimeter of the tank farm (see Figure 3-1). The HDPE pipe is laid above ground (to allow for temporary removal) and held in place with ballast tubes located approximately every 30 ft and within 10 ft of each discharge point. The drainage pipe inlets are screened to prevent animals or debris from entering, and each discharge point has a filter sock installed to prevent sediment from discharging into the lined drainage ditches. All asphalt within the tank farm was seal-coated twice to ensure an adequate infiltration barrier.

3.2 Issues During Construction

The section describes the issues that were encountered during the construction of the TFIA components and the resolutions of these issues.

3.2.1 Sewer Lift Station

The original design called for one lift station (the main storm water lift station); however, a second (sewer) lift station was installed east of Hemlock Street, near Building TR-35. This installation was necessary due to interference from a 6-in. piece of PVC piping that was discovered during culvert installation which connected two pieces of 36-in. CMP. This PVC pipe, along with an adjacent duct bank and telephone lines, made it necessary to replace the existing sewer lift station. A replacement lift station was installed at an increased depth to prevent freezing. Lowering the lift station also enabled the CMP to be installed as designed.

3.2.2 Trench Drain

The original design called for only one trench drain (running north to south on the east side of Beech Street); however, a second trench was installed in the southwest corner of the tank farm when it was identified that the original area could not be graded to drain adequately due to load restrictions on an underground structure. The second trench drain was installed adjacent to the filter tank, CPP-766, on the north side and flows east to west. It discharges into an underground 8-in. PVC pipe and ultimately discharges into the main storm water lift station at the corner of Beech Street and Olive Avenue.

3.2.3 New Site Identifications

During the course of the remedial action, three areas of unexpected contamination were encountered as detailed below. The New Site Identification (NSI) process was initiated for all three sites to either become new FFA/CO sites or revisions to existing sites. Two of the new site identifications have been approved (CPP-58 and CPP-37C); the third, a petroleum contamination site (CPP-100), is still under evaluation.

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3.2.3.1 Site CPP-58 – Nitric Acid and Radiological Contamination. Soil contaminated with nitric acid was discovered within the boundaries of Site CPP-58E, and radiological contamination was discovered southwest of Site CPP-58W. Descriptions of these two contamination areas are given below:

Nitric Acid. On April 14, 2001, a moist, dark brown material was discovered while excavating a trench along Olive Avenue to install the force main that led from the storm water lift station. The area where the material was discovered is within CPP-58E, a CERCLA site that was contaminated from a 1976 release of PEW overhead lines resulting from a failure in a transfer pipe. PEW overhead lines contain concentrated nitric acid and radionuclide constituents.

Radiological Contamination. While excavating the lift station near the intersection of Olive Avenue and Beech Street, radiological contamination averaging 200 to 300 counts per minute up to a high of 500 counts per minute was encountered. The area of this excavation is to the south and west of the CERCLA site identified as CPP-58W in the FFA/CO Action Plan (DOE-ID 1991).

The NSI process was initiated for these contaminated areas to clearly document the nitric acid contamination as part of existing Site CPP-58E and to revise the boundary of CPP-58 to include the newly identified radiological contamination and the need to further investigate the extent of contamination in this larger area. The NSI form was submitted to the Agencies for their consideration and has been approved.

3.2.3.2 Petroleum Contamination. Petroleum (fuel oil) contamination was discovered in the INTEC soil on April 24, 2001. This release was encountered when the gravel and soil near the fuel pumping station (Building CPP-701) was scraped away in preparation for paving. The location of the petroleum contamination is on the southeast corner of the intersection of Beech Street and Cypress Avenue (see Figure 3-1).

This site was recommended for inclusion as a FFA/CO site, titled Petroleum Contamination in Proximity to CPP-701, and given the site number of CPP-100. To date, this recommendation is currently under evaluation by DEQ.

3.2.3.3 Site CPP-37C – Radiologically Contaminated Construction Debris. Duringexcavation of the trench for the 48-in. culvert used to connect the storm water upgrade system to the new evaporation pond, an area with radiologically contaminated materials (construction debris) was discovered. This culvert installation took place during a 1-week period between November 20, 2000, and November 27, 2000, and was performed along the east perimeter road between the two INTEC perimeter fences. The contaminated materials were located just inside the outer fence and to the southeast of CPP-37B, a CERCLA site that was previously a debris landfill. At approximately 5 to 6 ft below ground surface, debris was encountered consisting primarily of lava rock, gravel, and soil and minor amounts of concrete, plywood, pipe, and plastic. Only the excavation necessary to install the culvert was performed. When this debris was first discovered, work was stopped and field radiation surveys were performed. No radioactively contaminated material was found during these surveys. Since this material was unsuitable for backfill, it was staged for later disposal. Since no radioactive contamination was identified during the initial field surveys, additional surveys were not performed on the material prior to transport to the Central Facilities Area (CFA) Landfill. Transportation of the debris to the CFA Landfill began on May 1, 2001, and was halted on May 9, 2001, when contamination was discovered during a random spot check. All suspect debris at that time located at the CFA Landfill was segregated from the remainder of the landfill debris and roped off as a radiation material area. This debris was spread out and surveyed; all radioactively contaminated materials were returned to INTEC. This material was boxed and placed in the project’s CERCLA Staging and Storage Annex. The wastes have been characterized and the waste profiles prepared. Upon acceptance of the waste profiles by the Idaho

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CERCLA Disposal Facility (ICDF), the wastes will be scheduled for treatment, if necessary, and disposal at ICDF.

3.2.4 Asphalt Compaction

Design specifications for the application of asphalt over the soil contamination areas required compaction until the pavement density is 90% (SPC-472) and confirmation in the field using a nuclear densiometer. Due to tank farm load limitations, no rollers or heavy equipment was allowed in the area, and background radiological contamination prevented the used of the densiometer to confirm that proper compaction was achieved. In response to this issue, a field design change was prepared and approved that allowed hand-compacting machines to be substituted for heavy equipment and required the compacting machines pass over the asphalt five or six times to assure good, solid compaction.

3.2.5 Deletion of CPP-31 Corner Section from Design

Providing proper drainage of the southwest corner of Site CPP-31 presented a problem. The 310-ft2 area was surrounded and segregated by existing duct banks (see Drawing #624402 in Appendix A). To create proper drainage, the area would need to be built up to exceed the height of the duct banks, and the existing valve box would need to be raised. The extra load over the underground storage tanks would severely impact the sampling and tank farm closure project’s ability to perform work at the same time. Because the area was small and not over the soil contamination area and because of the loading and project conflict issues, a request was made to the Agencies during a late June 2004 conference call to have the area deleted from the infiltration barrier design. This request was accepted, and the area was eliminated from the construction activities.

3.3 Project-Generated Wastes

Project-generated waste was managed following the requirements of the Waste Management Plan

for INTEC Operable Unit 3-13, Group 1, Tank Farm Interim Action, Phases I and II (DOE-ID 2003b). The Waste Management Plan was revised in September 2003 at the same time the RD/RA Work Plan for Group 1, Tank Farm Interim Action, was being revised to incorporate changes made to the interim action as a result of the ARD. The ARD also forced changes to be made to the Waste Management Plan. Construction issues encountered during the installation of Phase I components prompted change to the section that discusses the management and disposition to wastes encountered. Supplementary detail and specific changes made to the Waste Management Plan are listed in Appendix N, page N-10, of the RD/RA Work Plan for TFIA (DOE-ID 2003a).

Uncontaminated waste generated by the TFIA project included paper, excess materials, soil that was not used for fill material, and miscellaneous scrap metals. This waste was transported to the CFA Bulky Waste Landfill for disposal. In addition, approximately 46,000 yd3 of soil that met the reuse criteria, <23 pCi/g Cs-137 (DOE-ID 2003b), were stockpiled south of INTEC for reuse.

All other wastes were listed as radiologically contaminated and mixed (hazardous and radiologically contaminated) waste. For Phase I, 146 containers (9,360 ft3) of contaminated soil and four containers (256.67 ft3) of debris were generated. For Phase II, a total of 79,000 lb of soil was removed. Of this, 41,000 lb were redistributed inside the tank farm and 38,000 lb were bagged. In addition, four containers (10 ft3) of debris were generated. For the entire project, containerized soil and debris were transported to the CERCLA Staging and Storage Annex. These wastes have been characterized and the waste profiles prepared. Upon acceptance of the waste profiles by ICDF, the wastes will be scheduled for treatment, if necessary, and disposed of at ICDF.

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4. CHRONOLOGY OF EVENTS

Table 4-1 is a chronology of events for the project.

Table 4-1. Tank Farm Interim Action chronology of events.

Date Event

1997 Parsons design for tank farm surface water control is completed.

October 7, 1999 Final ROD for the Idaho Nuclear Technology and Engineering Center signed.

November 29, 1999 Work begins on the Approved for Construction Package for TFIA, Phase I.

February 2000 RD/RA Scope of Work for Waste Area Group 3, Operable Unit 3-13 finalized.

September 2000 Revision 0 of the RD/RA Work Plan finalized (DOE-ID 2000b).

October 1, 2000 The OU 3-13 TFIA schedule and budget are approved to meet the enforceable milestone of July 29, 2002.

October 2000 Construction work begins on Phase I.

April 14, 2001 Nitric-acid-contaminated soil discovered while excavating trench along Olive Avenue.

April 24, 2001 Petroleum-contaminated soil discovered near the fuel pumping station (Building CPP-701).

May 2001 The remainder of the TFIA project is canceled due to funding concerns. Relief is requested from the Agencies regarding the enforceable milestone for the OU 3-13 Group 1 draft RA Report (July 29, 2002).

May 1, 2001 Transportation of debris material to the CFA Landfill began.

May 9, 2001 Radiological contamination found on some materials that were removed from the trench for the 48-in. culvert used to connect the storm water upgrade system to the new evaporation pond.

June 14, 2001 The project’s baseline was reduced by $3,042K to de-scope all remaining construction work except that required to return the INTEC facility to a safe condition.

June 19, 2001 Discovery of nitric acid spill contamination and low-level rad waste being sent to the CFA Landfill. Baseline increase by $557K to address this discovery.

August 1, 2001 Subcontractor directed to halt construction on the evaporation pond and leak detection system.

August 30, 2001 DOE-ID submits a letter to IDEQ and EPA formally requesting an extension on the milestone for submittal of the Draft RA Report from July 2002 to July 2005 as a result of funding limitations.

September 6, 2001 DOE-ID receives a letter from IDEQ stating that they do not agree with the decision to delay the work on the TFIA project and do not grant the request to extend the milestone until July 2005 (EPA is in agreement with IDEQ).

October 1-18, 2001 Fertilizing and reseeding performed on the pond berm and inside the tank farm fence.

November 28, 2001 Storm water lift station pump startup test completed, reports submitted.

Table 4-1. (continued).

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Date Event

November 29, 2001 Subcontractor demobilizes upon completion of punch list items.

February 21, 2002 Work begins on an Interim Remedial Action Report and prefinal inspection to document the work completed, facilitate project restart, and show good faith to the EPA/IDEQ by addressing the July 29, 2002, enforceable milestone.

July 26, 2002 Draft RA Report submitted to the Agencies (DOE-ID 2002).

July 30, 2002 Draft RA Report received by IDEQ.

August 15, 2002 EPA sends letter to DOE stating that the submitted RA Report fails to satisfy the requirements of the FFA/CO.

August 30, 2002 IDEQ sends letter to DOE stating that the submitted RA Report fails to satisfy the requirements of the FFA/CO.

September 12, 2002 Responses to the Agency comment on the TFIA Interim Remedial Action Report were sent to DOE-ID.

December 4, 2002 Notice of Violation and Penalty Assessment received by DOE.

February 21, 2003 Agreement to Resolve Dispute is effective.

June 2, 2003 Subcontractor Phenix Construction was given Notice to Proceed.

June 4, 2003 Mobilization began and grading work in the evaporation pond was initiated.

June 9, 2003 Agreement reached between the Agencies on the areas to be covered by asphalt outside the tank farm fence (EM-ER-03-140). (Hain 2003a)

June 20, 2003 Grading work in the evaporation pond is complete. A survey using a portable germanium detector is performed.

July 24, 2003 Excavating and grading work around the calciner stack is complete. Sixty-four boxes of soil have been generated and stored in the Staging and Storage Annex to date.

August 7, 2003 Installation of the evaporation pond liner system is complete. Construction of the concrete headwalls and endwalls is complete.

August 8, 2003 Grading and paving of areas to receive asphalt are complete.

August 21, 2003 Final installation and testing of the evaporation pond leak detection system are conducted.

August 29, 2003 All physical construction for Phase I is complete.

September 23, 2003 DOE, IDEQ, and EPA conduct a prefinal inspection of the Phase I area. No issues identified that would prevent operations.

September 26, 2003 DOE submits certification to IDEQ and EPA for completion of the work outside the tank farm fence per Section 3.2.1 of the ARD. (Hain 2003b)

September 30, 2003 Revision 1 of the RD/RA Work Plan finalized (DOE-ID 2003a), transmitted to IDEQ and EPA.

October 9, 2003 Acknowledgement received from IDEQ and EPA for completion of Phase I.

June 7, 2004 The contractor is given a Notice to Proceed and begins mobilizing to the tank farm.


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Date Event

June 8, 2004 Herculite coverings are removed for Sites CPP-28, -31, and -79. Initial land survey performed.

June 23, 2004 Contaminated soil is encountered during site preparation grading. As a result, the project is placed on hold until a contingency plan could be developed to deal with the contaminated soil.

July 1, 2004 IDEQ and EPA agree to have the southwest corner of Site CPP-31 removed from the paving plan due to tank farm loading and drainage issues.

July 14, 2004 Grading and site preparation resumed following the development of a contingency plan.

July 22, 2004 First load of asphalt arrives on the tank farm.

July 28, 2004 Asphalt installed over soil contamination areas CPP-28, -31, and -79.

July 29, 2004 First top coat applied to the asphalt inside the tank farm.

July 30, 2004 The drainage pipes are installed at release sites CPP-28, -31, and -79.

August 17, 2004 Construction Component Acceptance Test is performed on the Phase I components. The soil bags from the tank farm area are transferred to the Staging and Storage Annex.

August 18, 2004 IDEQ and EPA conduct a prefinal inspection on the Phase II components.

September 1, 2004 Asphalt curbing raised on the north end of Site CPP-28 and partly around Site CPP-31.

September 8, 2004 Silicone calking applied to each CMP/HDPE joint in the tank farm.

September 9, 2004 The findings identified by the Agencies during the prefinal inspection are closed out. The Agencies are notified that the area is ready for the final inspection.

September 22, 2004 Final inspection is conducted by IDEQ and EPA.

September 30, 2004 DOE submits certification to IDEQ and EPA for installation of tank farm infiltration barrier per Section 3.2.2 of the ARD. (Hain 2004) DOE transmits copies of the Prefinal Inspection Report for OU 3-13, Tank Farm Interim Action, Phase II.

November 23, 2004 Screens are installed in the inlets to the CMP pipe draining the asphalt in the tank farm to prevent animal intrusion and debris accumulation.

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5. PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL

The principal threats at the tank farm soils release sites are external exposure to radiation and potential leaching and transport of contaminants to the perched water or the Snake River Plain Aquifer. To meet the remedial action objectives stated in the OU 3-13 ROD, the RD/RA Work Plan (DOE-ID 2003a) identified the remediation goals for the TFIA to be met. These remediation goals and their performance results are listed in Table 5-1.

Construction quality control is managed through the vendor data process and the construction quality process which are described below.

Vendor Data Process - Vendor data are subcontractor-furnished information required by the subcontract. The vendor data process controls the acquisition of supplier and subcontractor documents to ensure that those documents are technically correct and available for project, engineering, construction, operations, and maintenance activities. The vendor data process begins with specifying needed vendor data and continues through acquiring, processing, reviewing, dispositioning, and storing vendor data as records. In the tables below are the vendor data for Phase I (Table 5-2) and Phase II (Table 5-3). All line items received an acceptable disposition code.

Table 5-1. Remediation objectives compared to performance results.

Remediation Objectives Performance Results

Restrict access to control exposure to workers and prevent exposure to the public from soils at the tank farm until implementation of the final remedy under OU 3-14

Engineering controls are in place (fencing and asphalt barriers) and maintained to restrict access to contaminated soils in the tank farm.

An O&M plan is in place, with regular inspections and maintenance being performed on the TFIA components until the final remedy is initiated under OU 3-14. (see Appendix B)

Accommodate a 1-in-25-year, 24-hour storm event, with surface water run-on diversion channels

The TFIA storm water collection system was designed using hydrological data recorded from 1950 through 1999. The evaporation pond is sized to hold approximately twice the volume of expected average run-off. Surface water run-off collection ditches and piping are properly sized to contain and direct a 1-in-25-year, 24-hour precipitation event.

Minimize precipitation infiltration by grading and surface-sealing the tank farm soils located at selected Sites CPP-28, CPP-31, and CPP-79 sufficient to divert 80% of the average annual precipitation falling on these sites

Soil contamination areas CPP-28, CPP-31, and CPP-79 have been covered by an infiltration barrier consisting of asphalt and two seal coats. Drainpipe, located along the downgradient edges of the infiltration barrier, direct surface water toward lined concrete ditches along the outside perimeter of the tank farm.

Improve drainage systems surrounding the tank farm to direct water away from the contaminated soil areas

Twenty concrete-lined ditches and 20 culverts were either installed, upgraded, and/or incorporated in the TFIA storm water collection system that collects surface water run-off both within and surrounding the tank farm and delivers it to the evaporation pond.

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Table 5-2. Vendor data for TFIA Phase I.

Item #

Clause/Article or Drawing/ Specification

Reference Item Description Receipt

DateDisposition

Codea

1 01051 Land surveyor Professional Engineer registration 6/3/03 A

2 01051 As-built survey data 8/27/03 A

3 02598 Pond liner quality control plan 6/23/03 A

4 02598 Pond liner proposed panel layout drawings 8/7/03 A

5 02598 Pond liner product data (ballast tubes) 6/20/03 A

6 02598 Pond liner material certifications 7/9/03 A

7 02598 Pond liner product data (safety ladders) 7/28/03 A

8 02598 Pond liner final as-built panel layout drawings 8/29/03 A

9 02598 Pond liner test procedures and reports 7/28/03 A

10 02598 Pond liner personnel qualifications 6/20/03 A

11 02598 Pond liner warranty 9/3/03 A

12 02742 Mix design test reports 6/11/03 A

13 03300 Concrete mix design report 6/10/03 A

14 15401 Sump pump operation and maintenance manuals for flow totalizer

8/11/03 D

15 15401 Sump pump operation and maintenance manuals for pump

8/11/03 D

16 15401 Sump pump calibration data for flow totalizer 8/20/03 D

17 15600 Pressure-testing procedure for HDPE pipe 6/17/03 A

18 15600 Hydrostatic pressure-testing report for HDPE pipe

9/8/03 A

19 15600 Pump construction component test procedure 8/21/03 A

20 15600/ 16000

Pump construction component test report 9/10/03 A

21 16109 Receptacle test results 8/29/03 A

22 16120 Test reports for end-to-end continuity and megger

9/3/03 D

23 16124 Cable pull sheet 8/27/03 D

24 16124 Installer qualifications 7/10/03 A

25 PRD-4001 Initial chemical inventory and material safety data sheet

6/2/03 A


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Item #



DateDisposition

Codea

26 PRD-4001 Quarterly chemical inventory list 8/11/03 D

27 PRD-4001 Final chemical inventory list 9/3/03 D

28 SC-20 Schedule of values (material, labor, equipment costs)

7/3/03 A

a. Disposition codes:

A = Work may proceed.

B = Revise and resubmit. Work may proceed subject to incorporation of changes indicated.

C = Revise and resubmit. Work may not proceed. (Note: No items given this disposition code.)

D = Review not required. Work may proceed.

Table 5-3. Vendor data for TFIA Phase II.

Item #



DateDisposition

Codea

1 01051 Land surveyor Professional Engineer registration 5/20/04 A

2 01051 As-built survey data 8/11/04 A

3 01051 Grade control plan 5/27/04 A

4 02200 Excavation/grading plan 5/28/04 A

5 02430 Product data 5/20/04 A

6 02576 Certification-seal coat material 7/29/04 A

7 02741 Plant mix/pavement mix design test reports 5/20/04 A

8 02741 Paving plan 5/28/04 B

9 PRD-4001 Initial chemical inventory and material safety data sheet

5/20/04 A

10 PRD-4001 Quarterly chemical inventory list 8/2/04 A

11 PRD-4001 Final chemical inventory list 8/2/04 A

12 SC-20 Schedule of values (material, labor, equipment costs)

5/20/04 A

a. Disposition codes:

A = Work may proceed.

B = Revise and resubmit. Work may proceed subject to incorporation of changes indicated.

C = Revise and resubmit. Work may not proceed. (Note: No items given this disposition code.)

D = Review not required. Work may proceed. (Note: No items given this disposition code.)

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Construction Quality Process - Title III (approved for construction) inspections and verifications are conducted in the field during and upon completion of construction activities. The designated quality inspection engineer reads and compares project inspection plans with the drawings and specifications and then performs field inspections to verify that work being performed meets or exceeds drawing and specification requirements. The field engineer develops a verification checklist that incorporates the project’s required inspection activities. All inspections specifically required by the project’s controlling documents are to be verified complete to ensure adequate quality control and project completeness. Both the field and verification inspections were extensively performed for the TFIA project; and the observations, descriptions, and results of these are listed in Appendix C.

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6. MODIFICATIONS TO THE REMEDIAL ACTION

Several field changes to the RD/RA Work Plan were required during the course of the project due to changes in field conditions and/or new information brought to the attention of the project team. None of these changes impacted the overall function of the remedial design; only field changes based upon differing conditions identified in the field were implemented. Each change was documented using the construction interface document (CID) procedure. Summaries of CIDs that resulted in changes to the RD/RA Work Plan design are given below. Additional CIDs were issued during the course of the project that provided clarification or resolution of discrepancies between the documents (resulting in no changes to the remedial action). Summaries of these are not included in this section.

CID # TFIA-001

Action Changed Detail 12 on Drawing C-33 to be 7.2 in. deep in order to match the Detail 11 slope on Drawing C-33. This change allowed the subcontractor to use the same screed (concrete form) for both the Type 1 and the Type 2 ditches.

Comments The function of the system was not impaired, because the system remains able to accommodate the calculated flow.

CID # TFIA-005

Action Changed the outlet elevation of the ACO trench drain along Beech Street, shown on Drawing C-11, because the prefabricated ACO trench drain components were not compatible with the design elevations. This change did not affect the performance of the drainage system.

Comment The function of the system was not impaired because the system remains able to accommodate the calculated flow.

CID # TFIA-006

Action Relocated the 48-in. culvert from the east perimeter road to the area between the INTEC security fence and the outer animal control fence due to interference with an existing sewer line. The depth of the sewer line would have been sufficiently close to the new culvert installation to require the subcontractor to undermine and risk breaking the sewer line.


CID # TFIA-012

Action Changed the floor slab of the storm water lift station from precast, as shown on Drawing C-46, to cast in place in order to take advantage of a cost savings suggestion submitted by the subcontractor. Rather than excavate a large enough hole to install the entire lift station, the subcontractor installed it in 4-ft sections by setting each section and excavating inside it.

Comment This allowed the subcontractor to only disturb the soil required to be removed. The function of the system was not impaired because the system remains able to accommodate the calculated flow.

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CID # TFIA-022

Action Added 72 ft of new trench drain and approximately 82 ft of 8-in. PVC in the southwest corner of the tank farm.

Comment This change was incorporated to supply additional drainage for this area of the tank farm. The function of the system was not impaired because the system remains able to accommodate the calculated flow.

CID # TFIA-025

Action Relocated a drop inlet at the corner of Olive Avenue and Beech Street due to underground interference with an existing concrete duct bank and other existing piping. Drop inlet Number 1, and the associated 12-in. PVC pipe, were relocated to the north side of the electrical duct bank.


CID # TFIA-042

Action Dropped the elevation of existing sewer piping and installed a new sewer lift station in order to install the CMP as designed. During installation of the Alignment 2 CMP east of Hemlock Street, underground interfaces were encountered, including duct banks and direct-buried conduit, making this modification necessary.


CID # TFIA-043

Action Installed 18 ft of 8-in. ductile iron pipe instead of PVC pipe because the existing 4-in. steam line would damage PVC. This existing steam line was closer to the intended location of the new PVC line than what was shown on the INTEC drawings.


CID # TFIA-049

Action Added an additional 3 ft to the design for the concrete splash pad slab located at the evaporation pond discharge.

Comment This was necessary to protect the pond liner, because it was found that the discharge pipe extended further than anticipated. The function of the system was not impaired because the system remains able to accommodate the calculated flow.

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CID # TFIA-052

Action Discovered underground obstructions outside of the utility tunnel that runs north-south across Olive Avenue. In order to avoid these obstructions, the 8-in. force main piping was rerouted to run through the tunnel rather than under it.


CID # TFIA-065

Action Uncovered petroleum-saturated soil while grading for paving installation at the corner of Beech Street and Cypress Avenue. The spill was investigated and determined to be a legacy oil spill. The subcontractor discontinued work in the area to allow a Bechtel BWXT Idaho, LLC (BBWI) -directed subcontractor to box the disturbed portion of the soil and transfer it to the Staging and Storage Annex.

Comment The paving in this area was completed during the Final Phase I construction activities in 2003.

CID # TFIA-103

Action Compacted and backfilled certain storm water ditches prior to closing construction at the request of the INTEC facility.


CID # TFIA-104

Action Discovered an electrical duct bank, located north of Palm Avenue, to be routed directly through the storm water flow line. The INTEC drawings indicated it to be at a lower elevation than it actually was.

Comment This interference was resolved when Phase I construction activities resumed in 2003 (reference Design Drawing 623757).

CID # 115103

Action Due to the conditions and contamination of the area, no rollers or heavy equipments are allowed, only hand compaction will be applied. The dens-meter cannot be used to read the density of compaction due to contamination.

Comment A hand-compacting machine will be used; it will be applied over the asphalt five or six passes to assure good, solid compaction.

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CID # 115205

Action During post-construction testing, leakage was observed between the asphalt and the CMP culverts and at the coupler joining the CMP culvert to the corrugated HDPE (inside the tank farm).

Comment Direction provided by the design engineer to create a ½ × ½-in. reservoir at the asphalt/culvert interface in the asphalt for sealant to be placed. Apply DAP blacktop Asphalt Filler and Sealant at the interface, filling the reservoir to seal the culvert to the asphalt.

CID # 115816

Action One load of asphalt was dumped on the tank farm just prior to the Take Cover Alert that was a result of the gas cylinder leak on July 26, 2004. The load cooled approximately 4 hours before personnel were allowed to resume work. Spreading and compacting of the

load continued. Asphalt temperature was not between 250 and 300 F.

Comment A 4-hour delay occurred after placement but before the compaction was completed per the inspection plan, causing this area to be more openly graded than desired. In order to mitigate these concerns, two seal coats were added over the entire paved area and a third seal coat was added over the rougher areas to reduce possible infiltration through the asphalt.

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7. PREFINAL AND FINAL INSPECTION

Prefinal and final inspection activities took place separately for Phase I and Phase II as discussed below.

7.1 Phase I

The DEQ and EPA staff performed a prefinal inspection of the Phase I Tank Farm Interim Action work on September 23, 2003, to concur with the determination that DOE Idaho has completed and put into operation work required outside the tank farm fence, including lining ditches, installing culverts, and lining the evaporation pond in conformance with the revised Remedial Design/Remedial Action Work Plan (Pierre and Nygard 2003). A walk-down of the Phase I area took place and a prefinal checklist was completed. No deficiencies were identified during this prefinal inspection. However, the inspection did raise one question concerning the performance of the ditches with the storm water collection system. The concern expressed by the Agencies was that ongoing maintenance and cleanout of the ditches will be required due to erosion of the earth and gravel banks above the concrete portion of the ditches. In order to observe any effects of sedimentation on the operation of the storm water collection system, the frequency of the collection system monitoring should be changed to monthly during the first year of operation. This request was performed from October 2003 through September 2004 (first year of operation) as documented in the FY-04 Annual Operations Report for INTEC Operable Unit 3-13,

Group 1, Tank Farm Interim Action (DOE-NE-ID 2004).

No deficiencies were identified during the prefinal inspection of the Phase I components, and the Agencies agreed that the prefinal inspection would also serve as the final inspection for the Phase I Tank Farm Interim Action (Pierre and Nygard 2003).

7.2 Phase II

A prefinal inspection was conducted by the DEQ, EPA, DOE Idaho, and BBWI representatives for the Phase II of the TFIA on August 18, 2004, and documented in the Prefinal Inspection Report for

the Operable Unit 3-13 Tank Farm Interim Action, Phase II (ICP 2004). The inspection consisted of a complete walk-down of all Phase II components inside the tank farm and the completion of a prefinal checklist. During the inspection, ongoing discussion was held between the Agency representatives and DOE Idaho/BBWI to obtain early identification of issues and obtain clarification of Agency comments. Following the prefinal inspection, the Agencies submitted written comments to DOE Idaho/BBWI for resolution. The comments received, along with the action taken and completion dates, are as follows:

Agency Comment #1 “Pipe boots need to be installed, at all drain lines, where the lines interface

with the asphalt to prevent leakage at the joint.”

Action Taken As recommended by the project’s design engineer and with Agency concurrence during the Agency conference call (dated August 26, 2004), an

adhesive sealant (DAP Blacktop Asphalt Filler and Sealant) was applied between each corrugated metal pipe (CMP) and the underlying asphalt to create a water-tight seal.

Completion Date September 9, 2004.

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Agency Comment #2 “Some drain lines are not yet placed in the final position; thus, these lines do

not have a continuous downgradient invert flow line.”

Action Taken All high-density polyethylene (HDPE) drainpiping has been placed in the final positions as per Design Drawing (DWG 624401). Excavations beneath drainpiping at Zones A-1 and A-5 (DWG 624402) and at Zone D-6 (DWG 624403) have been reworked to provide a continuous downgradient flow pathway for surface water run-off.


Agency Comment #3 “Not all drain lines have ballast placed at 30 foot intervals.”

Action Taken Additional ballast tubes were fabricated and placed along each HDPE drainpipe at 30-ft intervals and within 10 ft of each discharge point. HDPE drainpipe has been permanently marked at 30-ft intervals to assist with adequate ballast placement and as an aid to properly replace ballasts if temporary removal is required to accommodate ongoing construction (see photo, Figure D-25, Appendix D).


Agency Comment #4 “As-built drawings are not yet completed and submitted.”

Action Taken As-built drawings are located in Appendix A of this report.

Completion Date February 16, 2005.

Agency Comment #5 “Survey data is not yet completed and submitted.”

Action Taken As-built survey data were transferred to the vendor data coordinator on August 10, 2004, and recorded as “received and completed” on August 11, 2004. The submittal received a Disposition Code of “A” (highest approval for mandatory submittal requirements) (see Vendor Data, Table 5-2, Item #2 in Section 5).

Completion Date August 11, 2004.

Agency Comment #6 “Curbing at various locations, at drain pipe inlets in particular, is not

adequate to prevent run-off from the asphalt. This comment also applies to

the CPP-28, -79 areas. The current raised edge/curb of the asphalt, in

several locations, does not take into account the effect of snow and ice

accumulation and spring snow melt/rain events. DEQ and EPA consider this

issue to be critical to the performance and intended function of the asphalt

cover.”

Action Taken Asphalt was increased/heightened at Zones D-2 through D-7 (DWG 624402), A-1 through A-6 (DWG 624402), and D-4 through D-7 (DWG 624403).


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A final inspection for the TFIA Phase II (components installed inside the tank farm perimeter) took place on September 22, 2004, to review the open items that were previously identified during the prefinal inspection performed on August 18, 2004. In attendance were representatives from DEQ, EPA, DOE Idaho, and BBWI. The asphalt caps over soil contamination areas CPP-28, -31, and -79 were reinspected along with the associated drainage piping. An agreement was obtained during this final inspection through discussions that all issues identified during the prefinal inspection have been satisfactorily closed, that the remedial action meets the RD/RA requirements, and that no further Agency inspections are required. A total of three observations were made by the Agencies during the final inspection. These observations are listed below along with the action taken and completion date:

Observation #1 The Operation and Maintenance (O&M) Plan will need to address the

inspection and maintenance of the pipe connections to the asphalt and the pipe

joints sealed with RTV (silicone rubber).

Action Taken An inspection activity was added to the “Inspection Form for Components Inside the Tank Farm Perimeter” in Revision 3 of the TFIA O&M Plan which reads, “1) Seal between asphalt and piping is intact, 2) Piping is intact…”. The inspector is directed to mark either “Normal Condition” or “Off-Spec Condition.” (Appendix B is the O&M Plan.)

Completion Date December 18, 2004.

Observation #2 Several OU 3-14 probeholes penetrated the asphalt since it was installed.

Pictures will be sent to the Agencies illustrating the repair/sealing of these

probes to the asphalt and discussed in the Remedial Action Report.

Action Taken All of the probeholes installed in soil contamination areas CPP-15, CPP-28, CPP-31, and CPP-79 were repaired as part of an INTEC-wide asphalt installation activity (see photo, Figure D-26 in Appendix D).

Completion Date November 24, 2004.

Observation #3 The drain from the top of CPP-79 will be directed toward the west, in the

direction of the surface run-off. Pictures will be sent to the Agencies

illustrating this alignment and then discussed in the Remedial Action Report.

Action Taken The drainpipe from the top of Site CPP-79 (Figure D-24 in Appendix D) was rerouted to the west to allow drainage to be captured in the Phase II HDPE drain lines (Figure D-27 in Appendix D).

Completion Date November 24, 2004.

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8. OPERATION AND MAINTENANCE

The TFIA components will be operated and maintained per the requirements of the Operation and

Maintenance Plan for INTEC Operable Unit 3-13, Group 1, Tank Farm Interim Action (DOE/ID-10771) (located in Appendix B) until replaced by the final remedy under OU 3-14.

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9. FINAL TOTAL COSTS

Table 9-1 summarizes the total costs for the remedial action. The initial planned cost of the TFIA was stated as $15.2M (Fiscal Year 1997 dollars) in the OU 3-13 ROD (DOE-ID 1999, Section 11), which did not reflect changes to the project as described in the ARD.b

Table 9-1. Total cost for TFIA remedial action.

Description Subtotal Total

Initial Phase I $3,460,000

Project management, engineering, construction support $1,100,000

Subcontract $2,360,000

Final Phase I $1,205,000

Project management, engineering, construction support $456,000

Subcontract $749,000

Phase II $411,000

Project management, engineering, construction support $211,000

Subcontract $200,000

Project total $5,076,000

b. The interim remedy, as described by the OU 3-13 ROD (DOE-ID 1999) was altered by the ARD dated March 2003. Details of the interim action can be found in the ARD. The cost estimates were revised to reflect the changes that were made to the interimaction. The revised cost estimates are located in Appendix J of DOE-ID (2003a). The original cost estimate is in Appendix J-1, the cost estimated for Phase I is in Appendix J-2, and the cost estimate for Phase II is in Appendix J-3. The revised cost estimates are closer to the actual cost of the project.

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10. CERTIFICATIONS

Construction for all of the Phase I components was completed in September 2004 and the system was put into operation. As stated in the RD/RA Work Plan, certification is required to show that this work was performed. This was provided by DOE Idaho to the EPA and DEQ in a letter (Hain 2003b, “Certification of Construction Completion of the OU 3-13, Group 1 Tank Farm Interim Action – Phase I – (EM-ER-03-245)”). In summary, the letter stated that the TFIA components, located outside the tank farm fence were constructed and put into operation. The work included lining ditches, culvert installation, and lining the evaporation pond. The work was completed prior to the planned date of September 30, 2003, as stated in the ARD. This certification was confirmed in a joint letter from DEQ and EPA to DOE Idaho stating that (Pierre and Nygard 2003)

…based on observations during the prefinal inspection conducted on September 23, 2003, EPA and DEQ concur with the determination that DOE has completed and put into operation work required outside the tank farm fence, including lining ditches, culvert installation, and lining the evaporation pond in conformance with the revised Remedial Design and Remedial Action Work Plan.

For Phase II, certification that the work was performed is documented in the letter from DOE Idaho to EPA Region 10 and DEQ (Hain 2004) stating that placement of an infiltration barrier over the affected areas of release sites CPP-28, CPP-31, and CPP-79 in the tank farm has been completed and that this letter certifies completion of this work by the enforceable milestone of September 30, 2004.

This interim action consists of institutional controls with surface water control and was completed to provide protection until a final remedy is developed and implemented. The system is fully functional and operational and meets the requirements of the RD/RA Work Plan (DOE-ID 2003a).

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11. DOCUMENTATION TO SUPPORT DELETION OF THE SITE FROM THE NPL

Per the requirement stated in Part XXV of the FFA/CO (DOE-ID 1991), a remedial action report shall contain documentation necessary to support deletion of the site from the National Priorities List (NPL) as defined by CERCLA. However, this RA Report describes an interim action which was undertaken to achieve significant risk reduction quickly and which was not inconsistent with nor precluded the implementation of the final remedy.

This interim action is defined in the RD/RA Work Plan (DOE-ID 2003a) as “Institutional Controls with Surface Water Control” to provide protection to the groundwater until a final remedy is developed and implemented. A final remedy for the TFIA release sites has been deferred pending further characterization and coordination of any proposed remedial actions with DOE (2002). This interim action does not contain documentation that will support the deletion of the site for the NPL but provides a level of protection until the final remedy is implemented.

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12. ANNUAL OPERATIONS REPORT

A requirement listed in the TFIA O&M Plan is to prepare and submit an annual operations report to the EPA, DEQ, and DOE Idaho for the duration of the interim action (see Appendix B). The annual report should include the following, at a minimum:

A summary of the inspections performed, including evaporation pond monitoring data

A summary of pond sediment sampling and analysis results for sediment to be removed

A summary of maintenance activities performed

Projected maintenance activities required for the next year.

The first report, FY-04 Annual Operations Report for INTEC Operable Unit 3-13, Group 1

Tank Farm Interim Action, (DOE-NE-ID 2004) was prepared in fall 2004 and submitted to the Agencies in December 2004. The report documented the observations noted during monthly inspections conducted from October 2003 through September 2004. The report contained a summary of the fiscal year’s inspections, monitoring, surveys, and maintenance performed on the existing TFIA components. Discussions of the surface-sealed areas and associated drainage piping within the tank farm perimeter were not included in this report since construction of these items was not completed until September 2004. Discussion of them will be included in the next year’s annual report. These annual reports will be generated for the duration of the interim actions until the final remedy for the contaminated soil sites within the tank farm is selected and implemented as part of the OU 3-14 RI/FS process (DOE-ID 2004).

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13. OBSERVATIONS AND LESSONS LEARNED

Below are specific examples of observations and lessons learned as a result of this project’s construction activities:

The selection of asphalt as the infiltration barrier over soil contamination sites CPP-28, -31, and -79 proved to be an excellent choice over other materials originally considered during the planning of this project (see DOE-ID 2003a, Appendix D), for a discussion of surface cover options evaluated for covering tank farm soils). The asphalt was found to be relatively easy to install, was simple to shape into curbing that would direct surface water towards drainage ditches, and (after two coats of a surface seal material) became an effective infiltration barrier. Initial compaction issues during construction were resolved by the addition of fines to the existing tank farm soils, and the final surfaces became durable work surfaces that integrated well with other tank farm activities (e.g., routine facility operations).

The contaminated soils encountered in and around CPP-58E emphasize the importance of performing excavations within the INTEC perimeter with caution due to potential unknown concerns and lateral extents of known contamination not being precisely defined. The project’s work control process was an effective tool for providing hazard mitigation plus health and safety guidance that worked in providing worker protection and a process for responding to newly encountered hazards.

Due to the heterogeneity of the contaminated debris uncovered at Site CPP-37C (see Section 3.2.3.3 of this report), some radioactively contaminated materials were incorrectly transported to the CFA Landfill. When first encountered, the initial uncovered material was surveyed and determined not to be radioactively contaminated. As a result, later surveys were only performed periodically or as unusual materials were uncovered. The lesson learned from this event was that, by the nature of the debris, radiological contamination and levels are not evenly dispersed. Continuous surveys are necessary to accurately characterize the excavated material.

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14. CONTACT INFORMATION

Points of contact for the WAG 3, OU 3-13, Tank Farm Interim Action Project are listed in Table 14-1 for Phase I and Table 14-2 for Phase II.

Table 14-1. Points of contact for the WAG 3, OU 3-13, Tank Farm Interim Action Project, Phase I.

Contact Title Affiliation Address Phone Number

Doug Kuhns WAG 3 project manager

BBWI (primary contractor)

2525 Freemont Ave Idaho Falls, ID 83415

208-526-8022

Marty Doornbos WAG 3 project engineer



208-526-0676

Lee Davison SP-6 project lead



208-526-3770

Jody Landis/ Bruce Birk

Subcontracttechnicalrepresentative



208-526-6311/ 208-526-7134

Rachel Hall DOE Idaho WAG 3 project manager

DOE Idaho 1955 Freemont Ave Idaho Falls, ID 83415

208-526-1661

Wayne Pierre EPA WAG 3 project manager

EPA Region 10 1200 Sixth Ave. Seattle, WA 98101

206-553-1200 (EPA, Region 10)

Margie English DEQ WAG 3 project manager

DEQ 1410 N. Hilton Boise, ID 83706

208-373-0306

John Arrington Supervisor Arrington ConstructionCompany (subcontractor)

1519 Casseopeia Idaho Falls, ID 83402

208-522-1990

Lance Kelsey Supervisor Phenix ConstructionCompany (subcontractor)

3695 Professional Way Idaho Falls, ID 83402

208-524-6488

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Table 14-2. Points of contact for the WAG 3, OU 3-13, Tank Farm Interim Action Project, Phase II.

Contact Title Affiliation Address Phone Number

Doug Kuhns WAG 3 project manager



208-526-8022

Marty Doornbos WAG 3 project engineer



208-526-0676

StevenButterworth

SP-5 project lead



208-526-3705

Trent Harris Subcontract technicalrepresentative



208-526-7138

Rachel Hall DOE Idaho WAG 3 project manager

DOE Idaho 1955 Freemont Ave Idaho Falls, ID 83415

208-526-1661

Dennis Faulk EPA WAG 3 project manager

EPA Region 10 712 Swift Blvd., Suite 5 Richland, WA 99352

509-376-8631

Ted Livieratos DEQ WAG 3 project manager

DEQ 1410 N. Hilton Boise, ID 83706

208-373-0217

Lance Kelsey Supervisor Phenix ConstructionCompany (subcontractor)

3695 Professional Way Idaho Falls, ID 83402

208-524-6488

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15. REFERENCES

Bowhan, 2003, Letter From Brett B. Bowhan to Darrel G. Early and Cyndy Mackey, “Final Original Copy of Agreement to Resolve Dispute Waste Area Group 3, Operable Unit 3-13,” OCC-03-025, March 4, 2003.

DOE, 2002, Idaho High-Level Waste & Facilities Disposition Final Environmental Impact Statement,U.S. Department of Energy, DOE/EIS-0287, September 2002.

DOE, 2003, United States Environmental Protection Agency, Idaho Department of Environmental

Quality, United States Department of Energy, in the Matter of: the December 04, 2002, Notice

of Violation and the December 20, 2002, Statement of Dispute, Agreement to Resolve Dispute,U.S. Environmental Protection Agency, Idaho Department of Environmental Quality, U.S. Department of Energy, February 21, 2003.

DOE-ID, 1991, Federal Facility Agreement and Consent Order for the Idaho National Engineering

Laboratory, Department of Energy Idaho Field Office, Environmental Protection Agency Region 10, State of Idaho Department of Health & Welfare, December 1991.

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

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

DOE-ID, 2000a, Remedial Design/Remedial Action Scope of Work for Waste Area Group 3, Operable

Unit 3-13, DOE/ID-10721, Rev. 1, U.S. Department of Energy Idaho Operations Office, February 2000.

DOE-ID, 2000b, Remedial Design/Remedial Action Work Plan for Group 1 Tank Farm Interim Action,DOE/ID-10772, Rev. 0, U.S. Department of Energy Idaho Operations Office, September 2000.

DOE-ID, 2002, Interim Remedial Action Report for the WAG 3, OU 3-13, Group 1, Tank Farm Interim

Action (Draft), DOE/ID-11007, Rev. 0, Draft, U.S. Department of Energy Idaho Operations Office, July 2002.

DOE-ID, 2003a, Remedial Design/Remedial Action Work Plan for Group 1, Tank Farm Interim Action,DOE/ID-10772, Rev. 1, U.S. Department of Energy Idaho Operations Office, September 2003.

DOE-ID, 2003b, Waste Management Plan for INTEC Operable Unit 3-13, Group 1, Tank Farm Interim

Action, Phases I and II, DOE/ID-10770, Rev. 3, U.S. Department of Energy Idaho Operations Office, September 2003.

DOE-ID, 2004, Operable Unit 3-14 Tank Farm Soil and Groundwater Remedial Investigation/Feasibility

Study Work Plan, DOE/ID-10676, Rev. 1, U.S. Department of Energy Idaho Operations Office, June 2004.

DOE-NE-ID, 2004, FY-04 Annual Operations Report for INTEC Operable Unit 3-13, Group 1, Tank

Farm Interim Action, DOE/NE-ID-11206, Rev. 0, U.S. Department of Energy Idaho Operations Office, December 2004.

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Hain, 2002, Letter from Kathleen Hain to Wayne Pierre (EPA Region 10) and Dean Nygard (DEQ), “Transmittal of the Draft Interim Remedial Action report for the OU 3-13, Group 1 Tank Farm Interim Action (EM-ER-02-124),” July 26, 2002.

Hain, 2003a, Letter from Kathleen Hain to Wayne Pierre (EPA Region 10) and Dean Nygard (DEQ), “Documentation of Agreement to Modify Phase I of the Tank Farm Interim Action (EM-ER-03-140),” June 9, 2003.

Hain, 2003b, Letter from Kathleen Hain to Wayne Pierre (EPA Region 10) and Dean Nygard (DEQ), “Certification of Construction Completion of the OU 3-13, Group 1, Tank Farm Interim Action – Phase I –(EM-ER-03-245),” CNN 45288, September 26, 2003.

Hain, 2004, Letter from Kathleen Hain to Nicholas Ceto (EPA Region 10) and Daryl F. Koch (DEQ), “Certification of Installation of Tank Farm Infiltration barrier and Transmittal of the Prefinal Inspection Report for OU 3-13, Tank Farm Interim Action, Phase II, (ICP/EXT-04-00602, Rev. 0 September 2004) – (FMDP-FFA/CO-04-029)” CNN 52690, September 30, 2004.

ICP, 2004, Prefinal Inspection Report for the Operable Unit 3-13 Tank Farm Interim Action, Phase II,ICP/EXT-04-00602, Rev. 0, Idaho Completion Project, September 2004.

Kreizenbeck, 2002, Letter from R. Kreizenbeck (EPA) to Warren Bergholz (U.S. DOE), “Notice of Violation and Penalty Assessment,” CCN 24768, December 4, 2002.

Pierre and Nygard, 2003, Letter from Wayne Pierre (USEPA) and Dean Nygard (DEQ) to Kathleen Hain (U.S. DOE), “Tank Farm Interim Action Phase I – Prefinal Inspection,” October 9, 2003.

SPC-472, 2004, “Construction Specification, OU 3-13 Group 1 Tank Farm Interim Action, Phase 2,” Rev. 1, Idaho National Engineering and Environmental Laboratory, April 2004.

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