Contract Overview: WESKEM provides environmental and waste management support services to various prime contractors such as Bechtel Jacobs at Department of Energy (DOE) and various commercial nuclear facilities. Under this contract with Brookhaven Science Associates (BSA) WESKEM provided waste management personnel and equipment in support of the remediation of six highly radioactive underground storage tanks and over twelve hundred cubic yards of contaminated overburden at Brookhaven National Laboratory (BNL), Upton NY. WESKEM provided waste management and planning activities; obtaining permits; coordination of work; management of hazardous materials/waste in compliance with state and federal regulations and BNL Standards Based Management System (SBMS); Sampling and laboratory analytical resources; quality control/quality assurance (QA/QC) and safety; transportation of soils and oversized underground storage tanks (USTs); hazardous waste determinations.

Project Summary: BSA is nearing the completion of a large environmental restoration program. One of the final projects was the removal of six under ground storage tanks used for the treatment of reactor and laboratory wastewater and removal of radioactively contaminated soils in the overburden and in adjacent yards. These ten-foot diameter tanks were located in individual concrete vaults under six feet of overburden. The overburden was characterized and then removed, and segregated for storage or disposal. The concrete vault tops were demolished and removed and the tanks extracted. The tanks were transported via truck to the disposal facility. A post removal sampling investigation was conducted under the concrete vault floors to determine the extent of residual contamination and verify the site clean up criteria was met. A final Status Survey was conducted of the concrete vault to determine if the clean up criteria was met and the vault could remain or if the vault itself had to be removed.

Work Plans. WESKEM developed or assisted in the development of a majority of the work plans and technical work documents used for this project. The primary responsibility of WESKEM was development of; The Field Sampling and Analysis Plan (FSAP) to direct post remedial investigation, The Transportation Plan, including a blocking and bracing plan for the oversized USTs to direct the logistics for contaminated soils, concrete and other material. WESKEM also assisted in development of the Final Status Survey Plan (FSSP) to direct the final closure and in the Technical Work Plan.

Site Characterization/Investigations. The site had been previously characterized and physical limits for remediation were developed. During the actual excavation WESKEM further defined the boundaries of contamination to minimize production of radioactive waste for disposal and maximize the amount of material, which could be reused. This characterization was for the soils overburden from the UST vaults and another area of the yards where a large amount of radioactive material had been spilled. After removal of the USTs, WESKEM investigated and characterized the soils below the concrete vault. WESKEM also completed an investigation of the six USTs prior to removal. This included NRC 10 CFR 61.56 and Utah State R313-15-1008 classification of radioactive waste and RCRA 40 CFR 261 characterization for disposal plus Department of Transportation classification for transportation.

WESKEM also investigated various waste streams to ensure the minimization of hazardous waste. WESKEM provided time, material and equipment to remove lead from pipe joints in one waste stream reducing the amount of hazardous waste by approximately 90%.

Engineering Support. WESKEM took the lead on developing a technically sound sampling and analysis plan for investigation of subsurface soils under previously contaminated concrete vaults. WESKEM clearly defined the steps used in the decision process to verify all clean up criteria had been met or if additional remediation would be required.

Planning. WESKEM participated in initial site activity planning and remedial design. WESKEM focused on planning all logistics for on-site and off-site transportation of soil, debris and the USTs. WESKEM also developed the investigation plan for characterization of soils below the concrete vault.

Remediation and Monitoring. During the execution the work plan, WESKEM assisted the excavation subcontractor by providing logistics for contaminated soil removal and transportation to the on-site trans-load facility. The contaminated soils were sampled and analyzed for characterization and final disposal as radioactive waste. WESKEM performed both characterization and verification sampling, and prepared all documentation for on site transportation. WESKEM further provided necessary documentation for off-site disposal including information used in manifesting and in preparing the disposal facility waste profile records. The contaminants of concern (COCs) at the 811 Tank Project were Cs-137 and Sr-90. To assist in ensuring a successful excavation WESKEM teamed with a partner and provided an In-Situ gamma spectroscopy unit. This provided near real time analytical results for Cs-137, a primary driver in the investigation.

Nearly 2500 tons of radioactively contaminated material was excavated, removed, loaded, transported and trans-loaded safely and compliantly. The waste was temporarily stored in BNL’s Former Hazardous Waste Management Facility and the loaded into gondola rail cars for transportation and disposal.

Innovative Approaches. WESKEM modeled the USTs such that residual material inside the tanks did not require removal from the tanks. This would have generated additional radioactive waste. For a small amount of material removed from the tanks, WESKEM navigated the regulatory pathway such that disposal options were available under already existing contracts and disposal facility profiles.

Value Engineering. WESKEM also relied on post removal surveys to design proper radiological shielding for the USTs. This saved the project $40,000 in shielding originally projected but found unnecessary. WESKEM also designed and constructed an oversized closed transport conveyance for DOT compliant transportation of two of the USTs with surface dose rates above 1000 mr/hr. Saving the project from establishing a radiological zone and demolishing the tanks on site.