435.36 federal facility agreement and … · 435.36 10/27/2011 rev. 10 federal facility agreement...

435.36 10/27/2011 Rev. 10

FEDERAL FACILITY AGREEMENT AND CONSENT ORDER (FFA/CO) NEW SITE IDENTIFICATION (NSI)

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!PART A NSl-25188 I 1. Site Title:

Shallow Injection Wells (32-TRA and 33-TRA) at TRA-655 ISite Code: TRA-75

2. Description of Suspected New Site and Location: (Summarize site characteristics, process knowledge, hazardous materials, existing data •. radiological surveys, etc. Include site map and coordinates.)

Site TRA-75 consists of two shallow injection wells (SIWs) (32-TRA and 33-TRA) formerly used as drains in the floor of the Engineering Test Reactor (ETR) Air Intake Building (TRA-655). Both were constructed as French drains and drained to the soil under the building. Figure 1 shows the location of Building TRA-655 and both SIWs. The building was originally designed and built in 1957 as an air intake and filter building for an experimental air system which provided filtered air to two large air compressors associated with the ETR. The air coming into the building would have been uncontaminated. In 1981, the experimental studies were complete and the ETR shut down. The filters were removed and the building was used as a storage area. Contents stored in the building are unknown.

Drawing 1014.20 (Kaiser 1957) and the sample logbook (!NEEL 1999) provide information on the SIWs in Building TRA-655. SIW 32-TRA was located in the north end (air intake end) of the building. It consisted of two sections (unknown length} of 12-in. concrete pipe filled with gravel. It was located in the center of the 10- >< 10-ft concrete floor slab, and the top of the well was at ground level. A slotted metal drain cover was installed in the top portion of the well and, beneath it, was an 8-in.-diameter x 5-in.-deep perforated metal cup installed as a strainer to the well. ·

SIW 33-TRA was located in the south end of the building at the bottom of a concrete sump 10 ft square x7 ft deep (confined space). It was configured similar to Well 32-TRA but had only one section of concrete pipe. Both drains were designed to receive condensation from the air compressors.

In the early 1980s, the general radiation levels ·in the air intake building were less than 0.1 mR/hour except for a measurement of 0.6 mR/hour at the southern SIW (33-TRA) (Jones 1998). On August 30, 1999, during entry into the confined space containing the southern SIW, samplers discovered that 33-TRA contained 1 ft of a brown liquid on top of a 1-in. sediment layer. The sediment was collected and analyzed·for gamma spectroscopy gross alpha, and total Sr in order to prepare a Radiological Work Permit. Floor fines (soil, lint, and plant material) were also collected from the NE corner of the sump and analyzed for gamma spectroscopy, gross alpha, and total strontium. The northern SIW (32-TRA) strainer was dry and contained gravel.

In September 1999, samples were collected from both SIWs and from the floor fines. In the southern SIW(33-TRA), both liquid and sediment were collected. One sample was described in the logbook as a sludge ("oily/gooey substance") but by the laboratory as "more liquid-like than sludge-like"; consequently, some of the analyses were run on the liquid fraction and some on the solid fraction. The liquid was analyzed for gross alpha; volatile organic compounds (VOCs); semivolatlle organic compounds (SVOCs); and benzene, toluene, ethylbenzene, and xylenes (BTEX). The sediment was analyzed forgamma spectroscopy, gross alpha, total Sr, total metals, polychlorinated biphenyls (PCBs), and toxicity characteristic leaching procedure (TCLP) (metals. VOCs, and SVOCs). Gravel from the northern SIW (32-TRA) and floor fines from near the northern SIW were analyzed for gamma spectroscopy, gross alpha, total Sr, total metals, and TCLP metals.

The highest Cs-137 concentration was 203 ±16 pCi/g (August 1999 sample ti-om the southern SIW 33-TRA) (McGriff 1999). Cs-137 concentration in the northern SIW (32-TRA) was 11 ±0.4 pCi/g (Environmental Data Warehouse, sample number ETR44001 RR). Both of these exceed the acceptable risk-based concentration of 6 pCi/g.

In March 2005, TRA-655 unc;lerwent decontamination and decommissioning (D&D). The strainer basket from the northern SIW (32-TRA) was removed, and the fill material beneath the strainer was inspected. The fill material consisted of 3-in. cobblestones, tree of stains or residue. The fill material In the south drain (33-TRA) was not inspected. The D&b crew removed Building TRA-655 and the concrete floor slab. Upon completion of D&D, the area was covered with clean soil and graded to match the surrounding area.

Due to the elevated Cs-137 concentrations, there is evidence of a CERCLA release to the SIWs. The SIWs are recommended for inclusion as a new site (TRA-75). Temporary institutional controls will be implemented in accordance with· DOE-ID (2010) to control disturbance of this site. No additional sampling is required.

References: DOE-ID, 201 O, /NL Site-Wide Institutional Controls, and Operations and Maintenance Plan for CERCLA Response Actions, DOE/ID-11042, Rev. 6, U.S. Department of Energy Idaho Operations Office, July 2010.

Kaiser, 1957; "E.T.R. Intake-Air Building Plans, Elevations, and Section," ETR5528MTR655-S-1, EDMS Drawing 101420, Kaiser Engineers for the U.S. Atomic Energy Commission, Idaho Operations Office, May 1957.

435.36 10/27/2011 Rev. 10


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Jones, R. W., 1998, Field Sampling Plan for Test Reactor Area ETR GEEL Air System, INEEUEXT-98-00191, Rev. 0, Idaho National Engineering and Environmental Laboratory, May 1998.

INEEL, 1999, "Environmental Operations Sample Logbook, Engineering Test Reactor," ER-86-99, Idaho National Engineering and Environmental Laboratory, September 1999.

T. W. McGriff, Idaho National Engineering and Environmental Laboratory, Interoffice Memorandum, to G. R. Rodman, Idaho National Engineering and Environmental Laboratory, November 8, 1999, "Transmittal of the L&V Report Pertaining to the Radiological Analysis Data in Support of ETR GEEL Air System Project, SDG: ETR46001R5," TWM-111-99.

Legend () Shallow Injection Wells

C=:J Buildings lllllTanks ~--~~::; Former Location

ofTRA-655 --Roads >:-. - Fences -- Jersey Barriers

2\ N EJicm-===--== Foot

0510 20 :io-!() 50 M'fl Ptt~tllDl':WtMtt Johy ois AMftlt. DW1 Mlhnwnl . Dat.~tVC/20Q7 D11ct.lmtr: C*ftlad tht SAL Ii ll'°n:» flat'

lnfcnn9hn~rh•tl••~ tnltUJlllp.

::1~~:·~~~:~3:Wt'}:l~1.Nml

// I

( .. , '• .,,

/

/

00

... · .....

3. Is the site a Solid Waste Management Unit? 181 Yes D No

4a. Decision

D Do not include as a new FFA/CO site. This site DOES NOT warrant further investigation, does not meet the criteria for acceptance (i.e., no release of CERCLA hazardous substance), and should not be included under FFA/CO Action Plan.

ER Director concurrence:

Name (printed) Signature Date

2

435.36 10/27/2011 Rev. 10


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DOE-ID FFA/CO Responsible Program Manager concurrence:

Name (printed) Signature Date

New Site Identification (NSI) process is complete. Enter NSI information and decision in the CERCLA database and send an information copy to the State of Idaho and EPA remedial project managers.

4b. [gJ Recommend including as new FFA/CO site. This site DOES meet the criteria for acceptance (i.e., evidence of a release of CERCLA hazardous substance), may warrant further investigation, and should be included under the FFA/CO Action Plan (complete the remainder of Part A).

Additional sampling recommended?

D Yes - Submit Part A and Field Sampling Plan to the Agencies

cg] No - Proceed to Part B

ER Director concurrence: ~f / J I 1 1 JA /l Frank L. Webber ~ Wk{/"{1~

______ N_a_m_e_(_p-rin-t-ed_)______ Signature

3

··435,35 10/27/2011 Rev. 10 Use with MCP-3448

PART A Site Title:


Site Code: Shallow Injection Wells (32-TRA and 33-TRA) at TRA-655 TRA-75

5. FFA/CO Responsible Program Managers' (RPMs') Concurrence

DQE-ID FFA/CO RPM: &'.'["Concur with recommen ation. Dd not co cur with the recommendation,

· N \. UJ\£. \A e\nai~· -e<~ -~~I..!-""'.-~~~==· :..i-- . 5fz d tz_ . Name (piir:ited) Signature Date

Explanation:

EPA FFA/CO RPM' ~nou•wlth •eoommendeHon. · D Do not oonou•wtth the moommendetion.

V~\))2? .~ ~ . 7/.y"L Name (printed) Signature loate ·

Explanation:

Name (printed}

Explanation:

4

435.36 05/12/2014 Rev. 14


Use with MCP-3480 Site Title: I Site Code: TRA-75 Shallow Injection Wells (32-TRA and 33-TRA) at TRA-655 I Document Number: t..lSI-.:!51 <I>~

PARTB

1. Data Analysis and Risk Assessment: See attachment

2. OU 10-08 Recommendation ~Yes D No

D No Action 0 No Further Action with Institutional Controls ~ Removal and Disposal Plug-in Remedy (meets remedy profile)

3. Assignment to Operable Unit Recommendation

Assign waste area group 0f'JAG) and operable unit (OU):

WAG: 10 OU: 08

~ Explanation of Significant Differences D Record of Decision Amendment D Remedial Investigation/Feasibility Study 7 Record of Decision D Removal Action 7 Action Memorandum ~ Plug-in Remedy Memorandum D Minor Change Memorandum D Memorandum to File D NSI Only (i.e., no change to previous decision for an existing site)

4. Prepared By:

Lorie S. Cahn ~5GJ__ July 2, 2014 Name (printed) Signature Date

5. Idaho Cleanup Project Environmental Restoration Direct r Concurrence: ~ P. Fv-&•· k We.\-,~ev .- /i t»-· .· l -zi, z/-co1'(

Name (printed) ...._

Signature ate

435.36 05/12/2014

-Rev.14--.---Use with MCP-3480

Site Title:

PARTB

FEDERAL FACILITY AGREEMENT AND CONSENT ORDER (FFA/CO) _____ __ NEW_SITE LOJ:NTlfl~ATJOti(~SI) __________ _________ _

Document Number:

6. FFA/CO Remedial Project Manager (RPM) Concurrence:

DOE-m FFA/CO ~M: , .. ~ Concur with recommendation. D 'Do not concur with recommen?ation . . J. N 1 wL1:: \3rLoo\LS

04Cilu ~ 7 -1?-IF

Name (printed) . ~ Signature Date

Explanation:

EPA FFA/CO RPM: ~ ~ t \~cur~~ndation. , D Do not concur with recom_mend lion.

C)f N 0 \$ ~~,Jr--.- ~ Lr-.._ ~2 - _ 6; f L -~ Name (prin ed) ··--'SIQn'ature ~ · Oat~

Explanation:

Explanation:

2

1

TRA-75 NSI-25188 Part B Attachment

ADDITIONAL INFORMATION

Additional information was obtained since the New Site Identification form Part A was signed in July 2012 (NSI-25188). The site covers the footprint of the former Engineering Test Reactor (ETR) air intake building (TRA-655), which is wholly within Site TRA-80.

Building TRA-655 consisted of a plenum room in the northern part that is designed to hold air and a concrete sump in the southern part; these are separated by an east-west-oriented filter bank in the middle of the building. Figure 1 is a drawing of the building (Drawing 101420). Ambient air was drawn into the plenum room through louvers. The louvers are visible in Figure 2, which is a photograph of Building TRA-655. The air moved through the filter bank and entered the 7-ft-deep 10- × 10-ft concrete sump. The filtered air left the building through three 36-in.-diameter underground pipes (air ducts) in the wall of the sump and ended up in Building TRA-643 (ETR Compressor Building) where the air compressors were located.

There were two French drains in Building TRA-655 that are considered shallow injection wells (SIWs). Because snow and rain would have entered the building through the louvers, these floor drains were designed to drain any incidental moisture that collected in the bottom of either the plenum room or the concrete sump. Although a 1982 characterization report (Kaiser 1982) and subsequent documents that quote the report imply that the condensate from the air compressors was sent down the TRA-655 SIWs, this is incorrect. The air compressors were housed in a separate building, the ETR Compressor Building (TRA-643). The operating manual for the experimental air system (NRTS 1962) states that the condensate from the air compressors was collected in a tank and then drawn off through an overflow line to a floor drain in the ETR Compressor Building (TRA-643) sump.

After the filters were removed from Building TRA-655 (prior to 1982), the three air ducts in the sump were blanked off. The building was decontaminated and used as a storage area to store ladders and metal scaffolding (Bollander, Meale, and Johnson 1992). The building was considered a nonnuclear facility (Thomas and Landman 1991). The contamination in the floor drains is likely from mud or other soil from stored ladders and scaffolding that fell to the floor and was washed down the drain from precipitation that would have entered the TRA-655 building through the louvers.

The northern floor drain (SIW 32-TRA) (air intake end of building) was at the center of a 4-in. floor slab, which formed the bottom of the plenum room. The northern SIW (32-TRA) consisted of two sections of 12-in.-diameter concrete pipe filled with 1-1/2-in. clear gravel (gravel that has been “cleared” to eliminate fine particles and ensure evenness of size) according to Drawing 101420. This was confirmed in 1999 when samplers recorded in the logbook (ER-86-99) that they found gravel to within 2 in. of the top of the SIW. In September 1999, samplers collected a sample of the gravel in the drain. The gravel sample is assumed to have been collected from the top of the gravel infill. A sample was also collected of the floor debris (dirt, lint, and weeds) from around northern drain. The length of the pipe sections is unknown. Concrete pipe sections are 4-, 6-, or 8-ft sections (McPherson 2014). Assuming that 4-ft pipe sections were used, the bottom of the drain was 8 ft below the floor slab, which is assumed to be about 10 ft below current grade. Figure 3 shows a north-south cross section through the site.

2

Figure 1. Engineering Test Reactor air intake building (TRA-655).

3

Figure 2. Photo of Building TRA-655 showing air louvers.

Figure 3. North-south cross section through Site TRA-75.

The southern floor drain (SIW 33-TRA) consisted of one section of 12-in. concrete pipe at the bottom of the 7-ft-deep 10- × 10-ft concrete sump (confined space). Although Drawing 101420 indicates that the drain was filled with clear gravel, the samplers found no gravel and recorded in the logbook (ER-86-99) that the drain was filled with 3 ft 10 in. of an oily liquid with 1 in. of sediment in the bottom (as measured on a stick inserted to the bottom of the drain). In September 1999, a sediment sample was collected from the bottom 1 in. of the SIW. Assuming that the concrete pipe section was 4 ft long, the bottom of the floor drain would have been at least 11 ft below former grade. Samplers also collected a sample of the liquid (media classified as “sludge” and analytical units represent a solid rather than a liquid sample). The sludge samples were much lower in concentration than the sediment samples (media recorded as a solid).

4

The solid samples were analyzed for metals, radionuclides by gamma spectroscopy, gross alpha, total Sr, and toxicity characteristic leaching procedure (TCLP) metals. The liquid samples were analyzed for metals; radionuclides by gamma spectroscopy; total Sr; gross alpha; volatile organic compounds (VOCs); semivolatile organic compounds (SVOCs); benzene, toluene, ethylbenzene, and xylene (BTEX); and polychlorinated biphenyls (PCBs).

In 2005, the building underwent decontamination and decommissioning (D&D). The steel grating over the sump area was removed. The work order (88042) specified that the French drains must not be disturbed or damaged. Each floor drain was covered with a piece of ¼-in. carbon steel plate that was attached (either with silicone caulk or with a minimum of two expansion anchor bolts per plate). The 4-in. floor slab in the plenum room was removed except immediately around the northern SIW. The building was demolished and the remaining foundation was removed to about 1 ft below grade. The Facility Change Form (FCF-7489) indicates that the surfaces of the sump were to be surveyed and decontaminated if needed to meet the requirements of Table 2-2 of PRD-183, “Radiological Control Manual,” prior to backfilling with soil to grade. A marker was installed above the sump drain to indicate its below-grade location. The area was covered with additional backfill that is reportedly about 2 ft above original grade.a The Idaho National Laboratory (INL) SIW status report (INL 2005) stated that the method of abandonment would be determined through the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process.

The analytical results from sampling in 1999 that will be used in risk assessment are presented in Table 1 (metals) and Table 2 (radionuclides). The analytical results of the sample of the floor fines (from the northern room) are not used in risk assessment due to D&D activities in 2005. D&D removed the northern floor slab, which would have removed the floor fines. TCLP sample results cannot be used for risk assessment but are useful to indicate whether waste generated during remediation might be characteristic waste. As shown in Table 3, the sample of the gravel in the northern drain (sample number ETR44001TI) failed TCLP for cadmium (result was 1.73 mg/L and the limit is 1 mg/L). All other TCLP metals from both floor drains were below regulatory limits. The results of 1999 liquid sampling will be used to qualitatively evaluate potential impact to groundwater. No information has been found on whether liquid remained in the southern floor drain SIW 33-TRA when D&D covered the drain in 2005.

RISK ASSESSMENT

The surrounding site, TRA-80, cannot be released for unrestricted land use due to contamination at depths of 6 to 20 ft that exceeds cleanup levels (NSI-26011). However, a risk evaluation was performed to determine if contaminants exceed risk-based levels for a current worker or a future resident in 2095. These exposure scenarios are based on the Operable Unit (OU) 10-08 Record of Decision (DOE-ID 2009), which assumes residential use could begin on the INL Site no earlier than 2095. Therefore, the contaminants of potential concern will be compared to risk-based levels for outdoor workers in the OU 10-08 Remedial Design/Remedial Action (RD/RA) Work Plan (DOE-ID 2010) until 2095 and to risk-based levels for hypothetical residents in 2095. The contaminated material in the southern drain is approximately 13 ft below current grade and therefore below the level that is assumed to be disturbed in a future residential use scenario. However, the data are carried forward into the risk evaluation to provide information needed for SIW closure per State of Idaho requirements and to determine whether institutional controls will be required under CERCLA.

a. T. Huebner, CH2M-WG Idaho, LLC, personal communication to L. Cahn, CH2M-WG Idaho, LLC.

5

Table 1. Metals data in soil from Site TRA-75.

Sample Location

Depth Below Current Grade

(ft) Date

Collected Constituent Concentration Units Laboratory Qualifier

Validation Qualifier

Field Media

Analytical Method

Sample Number SDG Number

S. drain 13 9/21/99 Aluminum 3.3 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Aluminum 6,470 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Aluminum 3,990 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Antimony 0.01 mg/kg U Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Antimony 8.4 mg/kg * Gravel SW3050B ETR44001LA ETR46201LA

S. drain 13 9/22/99 Antimony 2.9 mg/kg * Solid SW3050B ETR46801LA ETR46201LA

S. drain 13 9/21/99 Arsenic 0.01 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Arsenic 13.4 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Arsenic 4.3 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Barium 0.15 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Barium 315 mg/kg J Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Barium 97.7 mg/kg J Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Beryllium 0.0048 mg/kg U Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Beryllium 0.46 mg/kg U Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Beryllium 0.51 mg/kg U Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Cadmium 0.07 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Cadmium 63.3 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Cadmium 16.4 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Calcium 82.8 mg/kg N J Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Calcium 33,600 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Calcium 39,800 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Chromium 0.16 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

Table 1. (continued).

6

Sample Location


(ft) Date



Field Media

Analytical Method


N. drain 2 9/22/99 Chromium 137 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Chromium 131 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Cobalt 0.02 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Cobalt 9.6 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Cobalt 5.6 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Copper 0.07 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Copper 116 mg/kg J Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Copper 51.6 mg/kg J Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Iron 15.5 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Iron 48,000 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Iron 15,700 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Lead 0.13 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Lead 4,590 mg/kg Gravel SW3050B ETR44001LA ETR46201LA

S. drain 13 9/22/99 Lead 58.7 mg/kg Solid SW3050B ETR46801LA ETR46201LA

S. drain 13 9/21/99 Magnesium 10.7 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Magnesium 4,780 mg/kg N J Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Magnesium 3,310 mg/kg N J Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Manganese 0.69 mg/kg N J Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Manganese 395 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Manganese 283 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Mercury 0.0002 mg/kg U Sludge SW7470A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Mercury 0.11 mg/kg Gravel SW7471A ETR44001LA ETR46201LA

S. drain 13 9/22/99 Mercury 0.09 mg/kg U Solid SW7471A ETR46801LA ETR46201LA


7

Sample Location


(ft) Date



Field Media

Analytical Method


S. drain 13 9/21/99 Nickel 0.04 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Nickel 138 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Nickel 16.8 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Potassium 133 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Potassium 2,340 mg/kg EN J Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Potassium 1,630 mg/kg EN J Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Selenium 0.0018 mg/kg U Sludge SW3020A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Selenium 0.19 mg/kg UN* UJ Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Selenium 0.2 mg/kg UN* UJ Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Silver 0.005 mg/kg U Sludge SW7760A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Silver 1.6 mg/kg Gravel SW3050B ETR44001LA ETR46201LA

S. drain 13 9/22/99 Silver 0.23 mg/kg U Solid SW3050B ETR46801LA ETR46201LA

S. drain 13 9/21/99 Sodium 70.5 mg/kg N J Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Sodium 559 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Sodium 214 mg/kg U Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Thallium 0.0018 mg/kg U Sludge SW3020A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Thallium 0.19 mg/kg UN* UJ Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Thallium 0.2 mg/kg UN* UJ Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Vanadium 0.02 mg/kg Sludge SW3010A ETR46701LA ETR46201LA

N. drain 2 9/22/99 Vanadium 44 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Vanadium 14.7 mg/kg Solid SW3051 ETR46801LA ETR46201LA

S. drain 13 9/21/99 Zinc 0.77 mg/kg N J Sludge SW3010A ETR46701LA ETR46201LA


8

Sample Location


(ft) Date



Field Media

Analytical Method


N. drain 2 9/22/99 Zinc 809 mg/kg Gravel SW3051 ETR44001LA ETR46201LA

S. drain 13 9/22/99 Zinc 185 mg/kg Solid SW3051 ETR46801LA ETR46201LA

Laboratory qualifiers:

* = Duplicate analysis was not within control limits.

E = Reported value is estimated because of the presence of interference or exceeds the analysis range.

N = Spiked sample recovery was not within control limits.

U = Analyte was analyzed for but not detected. Analyte result was below the contract-required detection limit.

Validation qualifiers:

J = Estimated value.

U = Analyte was detected at or above the detection limit. However, the value was less than 5 times the highest laboratory blank.

UJ = Material was analyzed for but not detected. Value is an estimate.

SDG sample delivery group

9

Table 2. Radionuclide data in soil from Site TRA-75.

Sample Location


(ft) Date

Collected Constituent Concentration Uncertainty Units Validation Qualifier

Field Media Sample Number SDG Number

N. drain 2 9/22/99 Americium-241 0.1 0.4 pCi/g UJ Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Americium-241 0.03 0.14 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Antimony-125 0.06 0.08 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Antimony-125 0.4 0.4 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Cerium-144 -0.14 0.17 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Cerium-144 0.2 0.5 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Cesium-134 0.03 0.04 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Cesium-134 0.27 0.17 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Cesium-137 11 0.4 pCi/g Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Cesium-137 82.3 0.6 pCi/g Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Cobalt-58 0.04 0.03 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Cobalt-58 -0.03 0.16 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Cobalt-60 8.5 0.2 pCi/g J Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Cobalt-60 441 2 pCi/g J Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Europium-152 0.02 0.09 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Europium-152 -0.2 0.3 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Europium-154 0.01 0.03 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Europium-154 0.08 0.2 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Europium-155 -0.04 0.02 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Europium-155 -0.5 0.2 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Gross alpha -1.11 0.994 pCi/g U Gravel ETR44001RRR ETR42201RR

S. drain 13 9/22/99 Gross alpha 0.632 0.728 pCi/g U Sludge ETR46801RRR ETR42201RR


10

Sample Location


(ft) Date



N. drain 2 9/22/99 Manganese-54 -0.003 0.02 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Manganese-54 0.05 0.18 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Niobium-94 0.0285 0.0303 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Niobium-94 1.2 0.12 pCi/g Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Niobium-95 -0.008 0.03 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Niobium-95 -0.05 0.11 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Radium-226 0.6 0.3 pCi/g UJ Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Radium-226 -0.2 1.8 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Ruthenium/ Rhodium-106

0.07 0.3 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Ruthenium/ Rhodium-106

0.4 1.3 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Ruthenium-103 -0.005 0.02 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Ruthenium-103 -0.03 0.13 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Silver-108 meta-stable


S. drain 13 9/22/99 Silver-108 meta-stable

0.53 0.07 pCi/g Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Silver-110 meta-stable



0.14 0.14 pCi/g U Sludge ETR46801RR ETR40701RR

S. drain 13 9/22/99 Total strontium 1.09 0.139 pCi/g Sludge ETR46801RRR ETR42201RR

N. drain 2 9/22/99 Total strontium 0.0924 0.121 pCi/g U Gravel ETR44001RRR ETR42201RR

N. drain 2 9/22/99 Uranium-235 -0.01 0.05 pCi/g U Gravel ETR44001RR ETR40701RR


11

Sample Location


(ft) Date



S. drain 13 9/22/99 Uranium-235 -0.2 0.7 pCi/g U Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Zinc-65 0.07 0.05 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Zinc-65 2 0.5 pCi/g UJ Sludge ETR46801RR ETR40701RR

N. drain 2 9/22/99 Zirconium-95 0 0.05 pCi/g U Gravel ETR44001RR ETR40701RR

S. drain 13 9/22/99 Zirconium-95 0.1 0.2 pCi/g U Sludge ETR46801RR ETR40701RR

Validation qualifiers:

J = Mean difference of laboratory duplicate for Co-60 was >3. Value is an estimate.

U = Undetected.

UJ = False positive, radionuclide is not present.


12

Table 3. Toxicity characteristic leaching procedure data and regulatory limits.

Sample Location

Date Collected Constituent Concentration Units

Laboratory Qualifier


TCLP Limit (ug/L)

Field Media

Analytical Method


N. drain 9/22/99 Lead 1,660 µg/L 5,000 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Arsenic 5 µg/L U 5,000 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Cadmium 1,730 µg/L 1,000 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Chromium 13.5 µg/L B 5,000 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Silver 10 µg/L UN 5,000 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Barium 902 µg/L B U 100,000 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Mercury 0.2 µg/L U 200 Gravel SW3010A ETR44001TI ETR46201LA

N. drain 9/22/99 Selenium 11.6 µg/L B 1,000 Gravel SW3010A ETR44001TI ETR46201LA

S. drain 9/22/99 Lead 23.3 µg/L B 5,000 Solid SW3010A ETR46801TI ETR46201LA

S. drain 9/22/99 Arsenic 13.5 µg/L B 5,000 Solid SW3010A ETR46801TI ETR46201LA

S. drain 9/22/99 Cadmium 10.2 µg/L B 1,000 Solid SW3010A ETR46801TI ETR46201LA

S. drain 9/22/99 Chromium 189 µg/L B 5,000 Solid SW3010A ETR46801TI ETR46201LA

S. drain 9/22/99 Silver 11.8 µg/L UN 5,000 Solid SW7760A ETR46801TI ETR46201LA

S. drain 9/22/99 Barium 1,007 µg/L U 100,000 Solid SW3010A ETR46801TI ETR46201LA

S. drain 9/22/99 Mercury 1.14 µg/L U 200 Solid SW7470A ETR46801TI ETR46201LA

S. drain 9/22/99 Selenium 20.5 µg/L B 1,000 Solid SW3010A ETR46801TI ETR46201LA

Note: Gray shading and bold text indicate value exceeds TCLP regulatory limit.

Laboratory qualifiers:

B = Value was less than the contract-required detection limit but greater than or equal to the instrument detection limit.

N = Spiked sample recovery was not within control limits.

U = Analyte was analyzed for but not detected. Analyte result was below the contract-required detection limit.

Validation qualifier:

U = Analyte was detected at or above the applicable detection limit. However, the value was less than 5 times the highest laboratory blank.

SDG sample delivery group TCLP toxicity characteristic leaching procedure

13

The metals data presented in Table 1 were screened as follows:

• Eliminate essential elements. Five of the major dietary elements in humans (Ca, Fe, Mg, K, and Na) were eliminated in accordance with EPA (1989).

• Eliminate nondetects (one Sb result, Be, two Hg results, Se, two Ag results, and Tl).

• Eliminate metals at concentrations less than background in Rood, Harris, and White (1996) (Al, Co, Mg) (see Table 4 for the northern drain and Table 5 for the southern drain).

• Eliminate metals that are less than the cleanup levels in the OU 10-08 RD/RA Work Plan, Table 6 (DOE-ID 2010) (Sb, As, Ba, Cd, Cr, Cu, Fe, Hg, Ni, As, V, and Zn) (see Table 4 and Table 5).

The results of metal screening for the northern drain (SIW 32-TRA) are shown in Table 4. Pb is the only metal that is above risk-based levels. Pb (4,590 mg/kg) at approximately 2 ft below grade is above the cleanup level of 800 mg/kg for an industrial use area and above the cleanup level of 400 mg/kg for a hypothetical future residential use area. To determine whether any metals in the southern drain (SIW 33-TRA) at a depth of approximately 13 ft below grade are above criteria for unrestricted land use, the data are compared to the 10-4 cleanup level for residential soil in Table 6 of DOE-ID (2010). As shown in Table 5, the metals meet cleanup levels for unrestricted land use.

The radionuclide data presented in Table 2 were screened as follows:

• Eliminate nondetects (Am-241, Sb-125, Ce-134, Cs-134, Co-58, Eu-152, Eu-154, Eu-155, gross alpha, Mn-54, Nb-95, Ra-226, Ru/Rh-106, Ru-103, As-110m, U-235, Zn-65, and Zr-95).

• For the remaining radionuclides, decay the 1999 radionuclide sample results to determine the concentration in 2095 and year when contaminant will meet unrestricted use level. The northern and southern drains are considered separately due to the different depths of contamination and the different exposure scenarios that apply:

− Northern drain (SIW 32-TRA): As shown in Table 6, all radionuclides are currently (in 2014) below the risk-based level for an outdoor worker (DOE-ID 2010). Cs-137 (11 pCi/g) was below the risk-based level (11.3 pCi/g) in 1999 and Co-60 has decayed (1.2 pCi/g) to below the risk-based level (6.02 pCi/g). The concentration required for unrestricted land use and unlimited exposure is 6 pCi/g for Cs-137 and 3.61 pCi/g for Co-60. Cs-137 will remain above this level until 2025 and Co-60 is already below this level. In 2095, at the start of the future residential scenario, all radionuclides will have decayed below the 10-4 risk-based level for a hypothetical future resident.

− Southern drain (SIW 33-TRA): The depth of contamination in the southern drain is 13 ft below grade, which is below the depth that a hypothetical future resident is assumed to be exposed. The first step is to eliminate radionuclides that are currently less than the concentration that would be required for unrestricted land use and unlimited exposure (equivalent to the residential soil cleanup levels in the OU 10-08 RD/RA Work Plan, Table 6 [DOE-ID 2010]). Although the laboratory reported total isotopic Sr, the only remaining beta-emitting Sr isotope would have been Sr-90. Sr-89 has a short half-life of about 50 days (0.14 years). The ETR was shut down in 1981 (Stacy 2000). Eighteen years later when the sample was collected, Sr-89 would not have been detectable in the sample. Therefore, for the purposes of evaluating whether the contamination in the southern drain is at levels that could be released for unrestricted land use, the total Sr concentration is compared to the Sr-90 risk-based level. As shown in Table 7, Ag-108m and Sr-90 are already at acceptable levels for unrestricted land use. The only detected radionuclide that is not listed in Table 6 of

14

Table 4. Human health risk evaluation for metals from the northern drain.

Sample Location


(ft) Constituent Concentration Units Laboratory Qualifier


Worker Risk-Based Concentration

Residential Risk-Based

Concentration

Above Risk-Based

Level?

N. drain 2 Aluminum 6,470 mg/kg 24,000a 24,000a No

N. drain 2 Antimony 8.4 mg/kg * 410b 31b No

N. drain 2 Arsenic 13.4 mg/kg 160b 21.6b No

N. drain 2 Barium 315 mg/kg J 190,000b 15,000b No

N. drain 2 Cadmium 63.3 mg/kg 800b 70b No

N. drain 2 Chromium 137 mg/kg 140,000b 28,000b No

N. drain 2 Cobalt 9.6 mg/kg 18a 18a No

N. drain 2 Copper 116 mg/kg J 41,000b 3,100b No

N. drain 2 Lead 4,590 mg/kg 800b 400b Yes

N. drain 2 Manganese 395 mg/kg 23,000b 1800b No

N. drain 2 Nickel 138 mg/kg 20,000b 1,500b No

N. drain 2 Vanadium 44 mg/kg 7,200b 550b No

N. drain 2 Zinc 809 mg/kg 310,000b 23,000b No

Note: Grey shading and bold text indicate contaminant above risk-based level.

a. INL Site background concentration from Rood, Harris, and White (1996).

b. From DOE-ID (2010).

Laboratory qualifier:




INL Idaho National Laboratory

15

Table 5. Evaluation to determine if southern drain can be released for unrestricted use.

Sample Location


(ft) Constituent Concentration Units Laboratory Qualifier


Unrestricted Use Concentrationa

Above Unrestricted Use

Level?

S. drain 13 Aluminum 3,990 mg/kg 24,000b No

S. drain 13 Antimony 2.9 mg/kg * 31c No

S. drain 13 Arsenic 4.3 mg/kg 21.6c No

S. drain 13 Barium 97.7 mg/kg J 15,000c No

S. drain 13 Cadmium 16.4 mg/kg 70c No

S. drain 13 Chromium 131 mg/kg 28,000c No

S. drain 13 Cobalt 5.6 mg/kg 18b No

S. drain 13 Copper 51.6 mg/kg J 3,100c No

S. drain 13 Lead 58.7 mg/kg 400c No

S. drain 13 Nickel 16.8 mg/kg 1,500c No

S. drain 13 Vanadium 14.7 mg/kg 550c No

S. drain 13 Zinc 185 mg/kg 23,000c No

a. Unrestricted use concentration equivalent to residential soil cleanup level from DOE-ID (2010).

b. INL Site background concentration from Rood, Harris, and White (1996).

c. Cleanup level for residential soil from OU 10-08 Work Plan, Table 6 (DOE-ID 2010).

Laboratory qualifier:




INL Idaho National Laboratory OU operable unit

16

Table 6. Human health risk evaluation for radionuclides from the northern drain.

Sample Location


(ft) Date

Collected Constituent

Concentration in 1999

(Concentration in 2095) Uncertainty Units


Outdoor Worker Soil

Cleanup Level in

2095a

Residential Soil Cleanup

Level in 2095a

< Risk-Based Levels by

2095?

Year When Unrestricted

Use OK?

N. drain 2 9/22/99 Cesium-137 11 (1.2) 0.4 pCi/g 11.3 6 Yes 2025

N. drain 2 9/22/99 Cobalt-60 8.5 (2.8E-05) 0.2 pCi/g J 6.02 3.61 Yes Now

a. From DOE-ID (2010).


J = Mean difference of laboratory duplicate for Co-60 was >3. Value is an estimate.

Table 7. Evaluation to determine when area over southern drain can be released for unrestricted use.

Sample Location


(ft) Date

Collected Constituent

Concentration in 1999

(Concentration in 2095) Uncertainty Units


Residential Soil Cleanup

Level in 2095a

< Risk-Based Level by

2095?

Year When Unrestricted

Use OK?

S. drain 13 9/22/99 Cesium-137 82.3 (9.1) 0.6 pCi/g 6 No 2113

S. drain 13 9/22/99 Cobalt-60 441 (1.5E-03) 2 pCi/g J 3.61 Yes 2036

S. drain 13 9/22/99 Niobium-94 1.2b 0.12 pCi/g 1.6c Yes Now


0.53b 0.07 pCi/g 1.68 Yes Now

S. drain 13 9/22/99 Total strontium

1.09b 0.139 pCi/g 23.1d Yes Now

Note: Gray shading and bold text indicates contaminant above risk-based level.

a. From DOE-ID (2010) except as noted.

b. 2095 concentration not calculated because 1999 concentration less than residential soil cleanup level.

c. No value in DOE-ID (2010). Preliminary remediation goal from EPA (2010) multiplied by 100 for 1E-04 risk-based level.

d. Risk-based level for Sr-90. No significant other beta-emitting Sr isotope left in sample (Sr-89 has half-life of 0.14 yr).


J = mean difference of laboratory duplicate for Co-60 was >3. Value is an estimate.


17

DOE-ID (2010) is Nb-94. It is compared to the preliminary remediation goal (EPA 2010) multiplied by 100 to obtain the level that would be required for unrestricted land use (equivalent to the 10-4 risk-based level). As shown in Table 7, Nb-94 is also at an acceptable level. The only two radioactive contaminants that are currently above acceptable concentrations required for unrestricted land use are Cs-137 (above 6 pCi/g) and Co-60 (above 3.61 pCi/g) (DOE-ID 2010). Cs-137 will decay to the unrestricted land use level of 6 pCi/g in 2113 and Co-60 will decay to 3.61 pCi/g in 2036.

An ecological evaluation will not be performed because the site is within an industrial facility, and the contamination is within concrete French drains. The northern SIW is full of gravel, which is not a suitable ecological habitat. The sludge in the southern SIW is deeper than 10 ft below grade.

To evaluate whether the SIWs could potentially pose a risk to groundwater, the list of mobile groundwater contaminants in Table 7 of the OU 10-08 Work Plan (DOE-ID 2010) is considered. The liquid in the southern drain was analyzed for a large list of constituents including VOCs and metals. Three of the groundwater contaminants of potential concern (I-129, Sr-90 + daughters, and Cr) can be eliminated because there is no driving force to accelerate migration to the groundwater. Total isotopic Sr in the southern floor drain liquid sample was 5.24 ±0.78 pCi/L, which is below the maximum contaminant level for Sr-90, and all of the total isotopic Sr in the liquid in 1999 is assumed to be Sr-90 as discussed previously. Cr concentration in the liquid was less than the contract-required detection limit. No evidence indicates any of the other mobile contaminants were discharged to the floor drain. All VOCs were nondetect and the analytes included three of the groundwater contaminants of potential concern (carbon tetrachloride, trichloroethene, and tetrachloroethene). Although not analyzed for in the liquid, there is no reason to suspect that the remaining groundwater contaminants of potential concern (H-3, Tc-99, nitrate, and 1,4-dioxane) were discharged to the floor drain. Furthermore, the only contaminants of concern in soil (Pb, Cs-137, and Co-60) are known to have high distribution coefficients and are not expected to be mobile. Due to the inconsequential amount of liquid that would have ended up in the floor drains of the building (the drains received no known discharges and no pipes were connected to the drains), groundwater is eliminated as a concern for Site TRA-75 and the two SIWs.

REMEDIAL RECOMMENDATION FOR TRA-75

Because Pb in the top 2 ft of the northern SIW (32-TRA) exceeds the risk-based cleanup level for industrial soil in Table 6 of the OU 10-08 Work Plan (DOE-ID 2010), SIW 32-TRA will require remedial action. As shown in Table 8, the northern drain (32-TRA) meets the OU 10-08 plug-in remedy profile for removal and disposal. The contamination in the southern drain (33-TRA) is approximately 13 ft below current grade, which is below the depth of the worker and residential exposure scenarios, and will not require removal and disposal under CERCLA. Cs-137 contamination in the southern drain will decay to a level that will be acceptable for unrestricted use by risk-based levels by 2113 and Co-60 will decay by 2036. CERCLA will require institutional controls over these two drains until the contamination in the top 2 ft of the northern SIW is removed and the deeper contamination in the southern SIW decays to acceptable levels. Under the OU 10-08 plug-in remedy, the State of Idaho standards for abandonment of SIWs (IDAPA 37.03.03) is an applicable or relevant and appropriate requirement. CERCLA will need to permanently abandon the SIWs and meet the substantive requirements of the State of Idaho. The removed gravel in the northern SIW (32-TRA) may be characteristic hazardous waste for Cd and require disposal at a facility off the INL Site. The U.S. Department of Energy Idaho Operations Office will prepare a plug-in remedy memorandum and an Explanation of Significant Differences for a removal and disposal plug-in remedy to remove 2 ft of contaminated gravel from the northern drain (32-TRA), properly plug and abandon both SIWs, and maintain institutional controls until the risks have been reduced to acceptable levels.

18

Table 8. Comparison between Operable Unit 10-08 remedy profile and 32-TRA.

Removal and Disposal Site

Parameter Operable Unit 10-08 Plug-In Remedy Bounding Condition 32-TRA Shallow Injection Well

Meets Remedy Profile?

Contaminated media

Soil Soil Yes

Contaminated materials

Not applicable No contaminated materials at 32-TRA Yes

Contaminants of concern

Metals listed in Table 6 of Work Plan (DOE-ID 2010) include lead

Lead Yes

Risks Excess residential lifetime cancer risk greater than 10-4 or hazard index greater than 1

No consensus reference dose for lead, but lead exceeds industrial soil cleanup level in Table 6 of Work Plan (DOE-ID 2010)

Yes

Dimensions Contaminated soil volume up to 2,700,000 ft3

<2 ft3, which is the volume contained in a 2-ft section of 1-ft-diameter concrete pipe

Yes

Depth less than 47 ft below ground surface

In the top 4 ft, contaminated soil exists at a depth of approximately 2–4 ft below grade

Area less than 2,500,000 ft2 <1 ft2, which is the cross-sectional area of the 1-ft-diameter pipe

REFERENCES

Bollander, Thane W., Babette M. Meale, and Deborah A. Johnson, 1992, Hazards Identification and Tentative Classification of Selected Facilities at the Test Reactor Area, EG&G Internal Technical Report, PG-T-92-128, EG&G, Idaho, Idaho National Engineering Laboratory, December 1992.

DOE-ID, 2009, Operable Unit 10-08 Record of Decision for Site-Wide Groundwater, Miscellaneous Sites, and Future Sites, DOE/ID-11395, Rev. 0, U.S. Department of Energy Idaho Operations Office; U.S. Environmental Protection Agency, Region 10, Idaho Department of Environmental Quality, September 2009.

DOE-ID, 2010, Operable Unit 10-08 Remedial Design/Remedial Action Work Plan, DOE/ID-11418, Rev. 0, U.S. Department of Energy Idaho Operations Office, August 2010.

Drawing 101420, 1969, “ETR MTR-655 ETR Intake – Air Bldg Plans Elevations + Section,” Rev. 4, National Reactor Testing Station, October 1969.

EPA, 1989, Risk Assessment Guidance for Superfund, Volume 1, “Human Health Evaluation Manual (Part A), Interim Final,” EPA/540/1-89/002, PB90-155581, U.S. Environmental Protection Agency, December 1989.

19

EPA, 2010, Preliminary Remediation Goals for Radionuclides, http://epa-prgs.ornl.gov/radionuclides/download.html, “Outdoor Worker Soil PRG Supporting Tables in activity (pCi) units,” U.S. Environmental Protection Agency, Web page dated August 2010, Web page visited June 2, 2014.

ER-86-99, 2000, “Environmental Operations (EO) Sample Logbook - Engineering Test Reactor (ETR) - August 09, 1999 - June 07, 2000 (08/09/1999 - 06/07/2000),” Idaho National Engineering and Environmental Laboratory, February 2000.

FCF-7489, 2005, “TRA 655 ETR Air Intake Building D&D,” Rev. 0, Idaho Completion Project, Idaho National Laboratory, March 2005.

IDAPA 37.03.03, 2013, “Rules and Minimum Standards for the Construction and Use of Injection Wells,” Idaho Administrative Procedures Act, Idaho Department of Environmental Quality, April 2013.

INL, 2005, 2005 Idaho National Laboratory Site Shallow Injection Well Verification and Status Report, INL/EXT-05-00518, Idaho National Laboratory, August 2005.

Kaiser, Linda L., Ronald L. Rolfe, Bobby J. Sneed, Everet L. Wills, 1982, “Characterization of the Engineering Test Reactor Facility,” EGG-PR-5784, EG&G Idaho, Idaho National Engineering Laboratory, September 1982.

McPherson, 2014, McPherson Concrete Products, Inc., Pipe Specifications, http://www.mcphersonconcrete.com/pipe-specs.htm, Web page visited June 3, 2014.

NRTS, 1962, Experimental Air System Operating Manual, PPC-802, Rev. 1, Philips Petroleum Company, National Reactor Testing Station, August 1962.

NSI-25188, 2012, “Shallow Injection Wells (32-TRA and 33-TRA) at TRA-655,” Part A, Idaho Cleanup Project; U.S. Department of Energy Idaho Operations Office; U.S. Environmental Protection Agency, Region 10; Idaho Department of Environmental Quality, July 2012.

NSI-26011, 2014, “TRA Courtyard Area,” Part A, Idaho Cleanup Project; U.S. Department of Energy Idaho Operations Office; U.S. Environmental Protection Agency, Region 10; Idaho Department of Environmental Quality, April 2014.

PRD-183, 2013, “Radiological Control Manual,” Rev. 21, Idaho Cleanup Project, September 2013.

Rood, S. M., G. A Harris, and G. J. White, 1996, Background Dose Equivalent Rates and Surficial Soil Metal and Radionuclide Concentrations for the Idaho National Engineering Laboratory, INEL-94/0250, Rev. 1, Idaho National Engineering Laboratory, August 1996.

Stacy, Susan M., 2000, Proving the Principle, A History of the Idaho National Engineering and Environmental Laboratory 1949-1999, DOE/ID-10799, U.S. Department of Energy Idaho Operations Office, October 2000.

Thomas, Roderic W. and William Landman, 1991, Safety Analysis Report for the Engineering Test Reactor Facility in an Inactive Status, T-127, Issue 004, Idaho National Engineering Laboratory, July 1991.

435.36 federal facility agreement and … · 435.36 10/27/2011 rev. 10 federal facility agreement...

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