Formerly Used Sites Remedial Action Program (FUSRAP) W. R. Grace Feasibility Study (FS) Alternative Development Process Challenges And Successes
- U.S. Army Corps of Engineers - Baltimore District, Baltimore, Maryland (United States)
- EA Engineering, Science, and Technology, Baltimore, Maryland (United States)
Monazite sand processing was conducted at the W. R. Grace Curtis Bay Facility (Baltimore, Maryland) in the mid 1950's under contract to the Atomic Energy Commission (AEC), for the extraction of source material in the form of thorium, as well as rare earth elements. The processing was conducted in the southwest quadrant of a five-story building (Building 23) in the active manufacturing portion of the facility. Building components and equipment in the southwest quadrant of Building 23 exhibit residual radiological activity remaining from the monazite sand processing. Waste materials from the processing operations (termed gangue) were disposed in the non-manufacturing portion of the facility, in the area referred to the Radioactive Waste Disposal Area (RWDA). Approximately 19,880 cubic meters (m{sup 3}) of radioactive gangue was buried within the RWDA. Waste was believed to be buried at various depths up to 2.7 meters (m), and possibly as deep as 7.6 m. The RI and a supplemental investigation have been completed for the RWDA and adjacent boundary areas. A Feasibility Study (FS) to address residual radioactivity in soils at the RWDA is in the process of being finalized. The chemical-specific Applicable, Relevant, and Appropriate Requirement (ARAR) was selected for the FUSRAP contaminants, and Remedial Goals (RGs) were calculated for the cleanup. The RGs were developed based upon guidance provided in the selected ARAR, 10 Code of Federal Regulations (CFR) 40, Appendix A, Criterion 6(6). This standard is designed to provide an acceptable level of protection to the average member of a critical group who may be exposed to radium in soil for a given scenario. Scenarios, critical group members, and RGs were established in consultation with stakeholders. Dose assessment calculations were performed in accordance with the ARAR to establish derived concentration guideline levels (DCGLs) for each radionuclide in the 232-Thorium ({sup 232}Th) and 238-Uranium ({sup 238}U) chain for both surface and subsurface soils. A sum of the ratios calculation (also called the unity rule) will be utilized (with the DCGLs) to assure compliance with the benchmark doses associated with the radium standards. Six alternatives (including no action) were considered in the FS and included the following technologies: soil washing, segregation, capping/covering, excavation/disposal, and site restrictions. A bench scale study was conducted by USACE to assess the efficacy of soil washing at the site. Results of the study showed reduction of radiological activity in soil. Segregation can be implemented using traditional sampling/analytical routines or automated (gate) segregation and it is likely to reduce the waste stream by at least 30%, while providing a more complete characterization of the soil with a particularly high level of confidence. Challenges for the FS phase of the project included: managing stakeholder input and expectations, defining separate and distinct alternatives for the FS in accordance with the CERCLA process, and selecting the most appropriate ARARs. The challenges were handled successfully, and USACE is finalizing a robust document acceptable to the stakeholders, which will allow USACE to meet the program milestone. In summary: Conducting the W.R. Grace FUSRAP site FUSRAP process has been challenging from a project management perspective, due in part to the nature and extent of impact at the site (residual radioactivity; active processing building and disposal area) and incorporating site owner involvement in the process. Through the use of mediation and mutual commitment to the project by both parties, USACE and the site owner were able to find agreement on fundamental issues and set a firm foundation for achieving successful remedial action and site closure using a 'forward thinking' approach. Currently, USACE is finalizing the RWDA FS to address contamination in soils at the RWDA. ARARs have been identified and selected as per CERCLA guidance. Although obstacles were encountered, the challenges were handled successfully, and USACE is finalizing a robust document acceptable to the site owner, the regulators, and the public, which will allow USACE to move forward successfully in the FUSRAP program. (authors)
- Research Organization:
- WM Symposia, 1628 E. Southern Avenue, Suite 9 - 332, Tempe, AZ 85282 (United States)
- OSTI ID:
- 21326097
- Report Number(s):
- INIS-US-10-WM-08255; TRN: US10V0494067462
- Resource Relation:
- Conference: WM'08: Waste Management Symposium 2008 - HLW, TRU, LLW/ILW, Mixed, Hazardous Wastes and Environmental Management - Phoenix Rising: Moving Forward in Waste Management, Phoenix, AZ (United States), 24-28 Feb 2008; Other Information: Country of input: France
- Country of Publication:
- United States
- Language:
- English
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