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Ewy, Ann

Publications and source records attributed to Ewy, Ann.

Excavation Volume Growth Factors at Environmental Remediation Sites - 20318

The U.S. Army Corps of Engineers (USACE) manages numerous environmental remediation projects in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act, otherwise known as CERCLA. These include projects for the Formerly Utilized Sites Remedial Action Program (FUSRAP). Utilizing the CERCLA framework to address these projects requires detailed cost estimates and a significant portion of costs are associated with the volume of material to be excavated and that material's final disposition. Accordingly, understanding the expected volumes and uncertainty associated with those volumes is vital to project cost estimating. These estimates are completed at various stages of the CERCLA process, thus the project team has varying degrees of information available from which to develop these estimates depending on how far along the project is. Understanding the factors contributing to volume growth (increase in volume of material from that originally estimated) is a crucial element to determining volume and cost uncertainty. This paper presents a case study of a FUSRAP site which involves excavation and offsite disposal of contaminated soils from complex commercial, industrial, and residential properties. Original volume estimates were compared to post excavation volumes on a property by property basis. Reasons for differences are determined along with magnitude of impacts to cost estimating. For both residential and commercial property types, volume estimating factors, uncertainty considerations, and methods to account for each are discussed with emphasis on volume growth considerations. Cost estimating model input considerations are discussed with specific emphasis on accounting for volume uncertainty at the Feasibility Study (FS) phase of CERCLA. Underestimating or overestimating costs at the FS phase has repercussions under CERCLA that may impact project close out or completion schedule. Discussions presented will be helpful to both reviewers and preparers of cost estimates involving excavations. Additionally, project planners may be able to use the information to plan for volume growth contingencies. (authors)

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Radiological Soil Sorting Considerations and Applications - 19363

A number of methods are available for soil sorting, specifically sorting of radiological materials. These methods have been applied from the Feasibility Study stage of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) in pilot study operations to full scale operations in the post Record of Decision stages at Formerly Utilized Sites Remedial Action Program (FUSRAP) sites. This application of sorting at multiple sites and under many different conditions has provided the United States Army Corps of Engineers (USACE) with many challenges and lessons learned. Mechanical soil sorting has had varying degrees of success and many factors have been evaluated. Some factors include the type of material that is best suited for sorting, contaminant distribution, and pre-screening of materials. Community acceptance is another non-technical issue that can be key in applying sorting to a FUSRAP cleanup. This paper will discuss multiple types of radiological soil sorting to include reversing belt conveyor, segmented gate, and manual as well as technical considerations and the factors impacting each type. Additionally, how and when soil sorting is applied to FUSRAP operations is discussed. The FUSRAP is conducted in accordance with CERCLA and the impacts to how sorting is applied in terms of considering it treatment under CERCLA will also be discussed. This paper and presentation will be useful for any project considering using radiological soil sorting. (authors)

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Radiological Soil Sorting Pilot Study Results - Middlesex Municipal Landfill - 19394

The U.S. Army Corps of Engineers (USACE) conducted a pilot scale study of radiological sorting technology at the Formerly Utilized Sites Remedial Action Program (FUSRAP) Middlesex Municipal Landfill (MML) site in Middlesex, New Jersey. Residual uranium ore pieces or 'nuggets' and associated soil contamination are present at the MML site as a result of the nation's early atomic energy program. Study questions and objectives of the MML Pilot Study project were to 1) evaluate the accuracy with which contaminated soils can be separated from uncontaminated soils using a radiologic soil sorting system, 2) determine the optimal full-scale operational process throughput rate that might reasonably be achieved, 3) determine the waste volume reduction that might be expected when operating at full scale, and 4) help establish the feasibility of implementing soil sorting as a potential remedy to other areas of the site. To accomplish the objectives soils were processed through the sorting system in a series of 30 different sorting experimental (test) runs utilizing approximately 917 cubic meters [1200 cubic yards (CY)] of material. The test runs included varying parameters such as belt speeds, soil layer thicknesses, and alarm criteria, all in varying combinations. Test runs also included engineered tests to evaluate point source segregation issues. This paper presents the challenges, results, lessons learned, and recommendations of the radiological soil sorting pilot study. The technical aspects and evaluation of the results of the test runs will also be discussed. (authors)

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Radon Considerations at Environmental Remediation Sites - 19469

Radon and how it is regulated poses many challenges to the U.S. Army Corps of Engineers (USACE) in executing the Formerly Utilized Sites Remedial Action Program (FUSRAP). These challenges include:, terminology; radon measurement methods and limitations; state certification and testing requirements; limited and potentially conflicting federal guidance; background considerations; and limited experience regarding application of guidance; among others. These challenges and others are discussed in detail. The FUSRAP Maywood Superfund Site (FMSS) is presented as a case study demonstrating these challenges and considerations to mitigate or address the challenges. The USACE, U.S. Environmental Protection Agency (USEPA), and the New Jersey Department of Environmental Protection (NJDEP) (NJDEP) have spent several years working on and continue to work through the radon issues at FMSS. The FMSS experience, information, and solutions presented in this paper will be helpful to other environmental sites with radium and thorium contamination. (authors)

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Radioactive Waste Disposal Strategies within the US Army Corps of Engineers FUSRAP - 18328

The U.S. Army Corps of Engineers' (USACE) highest priority is the protection of human health and the environment and public and worker safety during the cleanup, transportation, and disposal of Formerly Utilized Sites Remedial Action Program (FUSRAP) material. In addition to following all appropriate federal and state rules and regulations, the USACE has its own safety program that ensures that we are being protective. One aspect of the USACE FUSRAP is the radioactive waste disposal strategies that we must consider. The USACE will only dispose of FUSRAP material in a facility that is licenses/permitted to accept it. The estimated exposures to facility workers and members of the public from the permitted disposal of FUSRAP wastes is evaluated as part of this process. The USACE uses the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process to study and remediate FUSRAP sites. An evaluation is performed to decide whether it is best to manage the waste on-site or off-site and the requirements for disposal. The action selected must be protective of human health and the environment and must comply with regulations. When making the decision, there are several other factors taken into consideration including cost of the disposal and whether the public and state agencies support the action. Prior to determining disposal options, wastes must first be characterized. This involves an evaluation of both site history and analytical data. Determining the proper disposal requirements and subsequent disposal option involves: Characterizing the waste as stated above. This is important because there are several regulatory agencies which may oversee management of the waste. The US Nuclear Regulatory Commission, the US Environmental Protection Agency (US EPA), the US Department of Transportation, and state hazardous waste and/or radiation protection agencies may all have varying degrees of involvement. Identifying disposal requirements. Certain wastes must be disposed at licensed radioactive waste disposal facilities. Wastes containing US EPA regulated hazardous waste must be disposed at permitted hazardous waste disposal facilities. Certain wastes must be disposed at facilities licensed/permitted for both radioactive and hazardous waste. Some lower activity wastes may be accepted for disposal at other types of landfills. Considering acceptance criteria of the disposal facility. Radionuclides and/or hazardous constituents in the waste, as well as physical and chemical form of the waste, are evaluated to ensure they meet the acceptance criteria of the receiving facility's license and/or permit. If they don't, another disposal location must be used. Considering the accessibility and location of the disposal facility. Some facilities are able to accept shipments only by truck and others can accept material via railcar as well. The distance to a disposal facility impacts the risk of transportation accidents and efficient use of project resources such as the number of trucks required to perform the transportation. These factors are also important in evaluating whether material can be cost effectively shipped to a disposal facility. Evaluating the compliance status of the receiving facility. It is not assumed that just because a facility has a license or permit that it is acceptable for the USACE' waste. Prior to selecting a facility for disposal of FUSRAP waste, a site visit, audit and consultation with the US EPA is required to determine whether there are any known relevant violations at the facility. Facilities that have violations that negatively impact the USACE or US EPA approval of the facility are not used for disposal of FUSRAP waste. Once a facility is selected. The USACE procures contracts, or utilizes existing contracts, to facilitate the transportation and disposal action. Additionally, the USACE continues to consult with US EPA routinely to confirm the compliance status of the facility. Considering state acceptance of wastes to a facility. The USACE seeks to obtain written authorization from the facility state regulator indicating the action is compliant with existing licenses, permits, laws, and regulations. Each of these factors is considered by the USACE in selecting a FUSRAP disposal location. The goal is to provide safe, cost effective disposal which is protective of human health and the environment and which complies with all regulatory requirements. These steps all feed in to the disposal strategy consideration that USACE must go through for our FUSRAP waste streams. There are a number of challenges in the process to include In order to achieve the Congressional mandate of completing cleanup work under FUSRAP in a more cost effective, timely manner, while assuring protection of public health and safety. USACE must determine all disposal options that are available for the types of waste at each FUSRAP site. As a solution, completion of a disposal strategy document can help ensure this goal is met and will foster consistency across the FUSRAP. (authors)

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Multi-Faceted Approach to Evaluate Discharge Locations at a FUSRAP Site - 18421

Following the completion of a Soil and Groundwater Remedial Investigation by USACE at a FUSRAP site located in Nassau County, New York, groundwater data indicated the presence of contaminant source(s) that had not been identified. As a result, a targeted investigation was undertaken to understand how materials were handled and disposed of at a site located in Nassau County, Long Island, New York. The FUSRAP site is a 4.3-hectare (10.5-acre) site encompassing three parcels which had historically been utilized as a nuclear materials manufacturing facility (e.g., cores, slug, and fuel elements) for reactors used in both research and electric power generation in early 1950's until late 1960's; however, the targeted investigation was on the southern-most parcel known as the '70 Property' (the Site). The 70 Property contained a building that was used for atomic fuel-element manufacturing from 1958 until 1966 under license to the Atomic Energy Commission (AEC), and involved the use of natural, enriched, and depleted uranium as well as lesser amounts of thorium. The major contaminants of concern are tetrachloroethene, nickel, uranium and thorium. During the RI, significant sources of contamination were not found in Site soils despite records indicating that chemicals and radionuclides had been disposed of on the property. In addition, downgradient groundwater data indicated a source(s) on the 70 Property that could not be identified by known sources on other the other FUSRAP parcels or from adjacent sites. This conclusion was further supported following development of groundwater contaminant transport and flow models. The main objective of the targeted investigation was to evaluate the potential discharge points on the 70 Property that may have been utilized for liquids waste disposal. However, several challenges existed including 1) lack of building construction details; 2) historical changes to Site building and property; 3) the use of the Site by various tenants; and 4) the commingling of Site contaminants with impacts from multiple sources. To overcome these challenges, historic documents/reports with information about the handling and disposal of liquid wastes were reviewed to evaluate quantities, contents and locations of waste disposal. Thereafter, an investigation was undertaken that included geophysical surveys; pipe tracing and video inspection; in-situ smoke and water testing; installation of test trenches and soil borings; and, sampling sludge residuals, soils and water within the various drainage structures that were located. This paper describes the multi-faceted investigation approach that was utilized to overcome the challenges faced during the investigation as well as insights into the waste disposal practices of the time period and the findings of the investigation. (authors)

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A Comparison of Select USDOE and USEPA Risk and Dose Assessment Tools Utilized at Two FUSRAP Projects - 17388

The US Army Corps of Engineers (USACE) utilizes several computer programs and models to conduct risk and dose assessments at Formerly Utilized Sites Remedial Action Program (FUSRAP) projects. In the past, the USACE has primarily relied on the US Department of Energy (USDOE)'s Argonne National Lab (ANL) RESidual Radioactivity (RESRAD) computer code for performing dose and risk assessments involving radiological contamination in onsite soils and the US Environmental Protection Agency (USEPA) Preliminary Remediation Goal (PRG) and Dose Compliance Calculator (DCC) for radiological contamination in ground water. Recent USEPA guidance requires use of USEPA calculators for all media at National Priority List sites, which includes some FUSRAP sites. The USACE recently utilized both RESRAD and the USEPA PRG and DCC calculators in assessments at two FUSRAP projects for all media in order to evaluate differences in the models and determine adjustments to potentially resolve differences. The two projects involve soil and groundwater assessments and address typical FUSRAP contaminants such as uranium, radium, thorium and their progeny. This paper discusses differences between the models, lessons learned, and methods used to address stakeholder and other concerns regarding these assessments. The paper's discussions are useful for anyone performing risk or dose assessments for radiological contamination and especially those using RESRAD and the PRG and DCC calculators. (authors)

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Overcoming Vicinity Property and Ground Water Challenges at the FUSRAP Middlesex Sampling Plant Project - 17529

The US Army Corps of Engineers (USACE) is addressing the Formerly Utilized Sites Remedial Action Program (FUSRAP) Middlesex Sampling Plant Site (MSP) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The MSP has been an active FUSRAP site since the early 1980's and was listed on the National Priority List (NPL) in 1999. Two challenges that the project team are currently addressing are Ground Water (GW) movement through fractured bedrock and Vicinity Properties (VP) assessments. USACE and the US Environmental Protection Agency (USEPA) signed a Record of Decision (ROD) for soils remedial action in 2005 and USACE completed the soils remediation at MSP in 2008, however, VPs were not a part of the soils ROD. Additionally, the State of New Jersey recently identified a potential contaminated VP of the site. VPs are any property in the vicinity of a CERCLA 'facility.' The contaminated VPs of the MSP were addressed prior to the adoption of the CERCLA process to address FUSRAP sites. Since the 1980's many changes to potential Applicable or Relevant and Appropriate Requirements have occurred. As such USACE has begun reassessing the previously addressed VPs for inclusion under the soils ROD as part of the CERCLA process. USACE does expect to have to revisit and potentially remediate up to 12 VPs. This paper will discuss the approach, some challenges, and lessons learned in adequately addressing VPs both from a field work and a post ROD regulatory perspective. USACE is currently in the Feasibility Study phase of the CERCLA process for GW. The project team has encountered and overcome significant challenges with regard to contaminant plume bounding and groundwater movement through the secondary porosity of dipping bedding plane partings and fractured bedrock of the Passaic Aquifer beneath the site. This paper will discuss the challenges, the approaches used, and lessons learned while delineating these contaminants. This paper's discussions are useful for anyone addressing an environmental site with soils contamination on VPs or with delineating contaminants in fractured bedrock. (authors)

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Formerly Utilized Sites Remedial Action Program - Program Update - 17530

The legacy of the United States' early atomic energy program is an important piece of our Nation's history. That legacy however, left low-level radiological contamination at properties now owned and operated by commercial, private and/or local government entities. Although many of these contaminated sites were identified by the Government in the past, additional properties continue to be identified. The United States Government, thru the US Department of Energy (USDOE) and the US Army Corps of Engineers (USACE), is addressing these sites with the Formerly Utilized Sites Remedial Action Program (FUSRAP) and has been doing so since the 1970's. The USDOE and the USACE both have roles in the Program. The USACE FUSRAP Program has an important task but faces many challenges to achieve a success conclusion. Since the implementation of 'sequestration cap' budgeting by Congress in 2012, the annual budget for the Program has decreased significantly compared to the funding levels in prior years. The Program complies with USACE Civil Works budgetary reprogramming rules that requires close coordination between the project and program teams to appropriately and efficiently obligate and expend Program funding. The very nature of environmental remediation work results in consistently finding additional unknowns during each phase of a project. The Program is required to follow Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) guidance and conduct cost recovery activities but does not have authorities such as those held by the US Environmental Protection Agency (USEPA). In order to pursue cost recovery actions, conclude a settlement agreement or file an administrative order, USACE must engage the US Department of Justice or USEPA to act on their behalf as USACE does not have the authority to do so themselves. Twenty years later, USACE continues to carry out the FUSRAP mission and work in coordination with the USDOE Office of Legacy Management (DOE-LM) to ensure that the Government's responsibilities are addressed. Success is measured by finishing each site cleanup so they can be turned back to their property owner and stakeholders for safe use. USACE continues to seek new technologies and methods of approach to improve and expedite site investigations and clean ups. (authors)

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FUSRAP Maywood Site - Remediation of a Residential Property at 61 Trudy Drive, Lodi, NJ - 17533

The Formerly Utilized Sites Remedial Action Program (FUSRAP) is the U.S. government program started in 1974 to identify, investigate and clean up or control sites that became contaminated as a result of the nation's early atomic programs. The FUSRAP Maywood (New Jersey) Superfund Site (FMSS) consists of 92 designated property parcels known as vicinity properties. 61 Trudy Drive in Lodi, New Jersey is one such vicinity property. Construction planning for a recently-completed remedial excavation at 61 Trudy Drive was predicated on a fundamental question: to remediate the property with the existing home remaining in place or to demolish the exiting home. Answering this question involved detailed engineering and cost analyses, programmatic considerations, and stakeholder input. 61 Trudy Drive was originally addressed under FUSRAP in 1985 by the U.S. Department of Energy (DOE). However, subsequent remediation on an adjacent property by the U.S. Army Corps of Engineers (USACE) in 1998 suggested that residual contamination remained at depth at 61 Trudy. The property owner at that time declined to allow FUSRAP access to the property. However, a property transfer in 2012 presented USACE with an opportunity to address this property. Characterization of the property began in 2013; remedial activities were completed in 2015. The 61 Trudy Drive remediation required an intensive stakeholder communications program tailored for several audiences, including the affected property owner, local government officials and the neighboring community This paper will present the FUSRAP history at 61 Trudy Drive, to provide context for recent FUSRAP actions there. It will then focus on the challenges and complexities of performing environmental remediation in a suburban residential setting, focusing on both construction and communications. (authors)

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FUSRAP Maywood Site Remediation of Redstone Park, Lodi, NJ - 17534

The Formerly Utilized Sites Remedial Action Program (FUSRAP) is the U.S. government program started in 1974 to identify, investigate and clean up or control sites that became contaminated as a result of the nation's early atomic programs. FUSRAP was administered by the U.S. Department of Energy (DOE) until 1997, when it was transferred to the U.S. Army Corps of Engineers (USACE) by congressional action. Redstone Park is a 1.5-acre municipal park located in a residential neighborhood in Lodi, Bergen County, New Jersey, USA. The park is a designated vicinity property of the FUSRAP Maywood Superfund Site. This paper will summarize the FUSRAP history of the property spanning over 20 years and then focus on the construction and community relations challenges of recent FUSRAP actions at the site. All of Redstone Park except for a portion bordering a residential property was remediated under FUSRAP in 1996. This remaining portion was remediated in 1998. The 1996 remediation included some hand-digging of surface contamination around the roots of several large mature trees in the park. As part of this action, the DOE proposed alternate cleanup standards whereby subsurface contaminated soil would remain in place around the root balls of the trees and in deeper areas (greater than 1.2 meters [m]) under a large storm drain pipe (or culvert) that runs through the park. This proposal was made to preserve the natural value of the trees and to protect the drainage pipe from damage. After careful review which included an assessment of potential health hazards, the U.S. Environmental Protection Agency (EPA) approved this proposal. The Borough of Lodi also supported the proposal as a way to preserve the trees for the enjoyment of park users. In 2009, EPA conducted a mandatory Five-Year Review of the FUSRAP Maywood Site. The review identified data gaps which prevented a full assessment of remedy effectiveness at Redstone Park. The USACE reviewed all the historic soil data from the park [1] and developed a characterization plan to address those gaps. Field surveys and sampling confirmed that the material around the tree roots and under the pipe did not comply with the current FUSRAP Maywood Site unrestricted use soil cleanup criteria (an average of 5 pico Curies per gram of radium-226 and thorium-232 combined above background) as established in the site's Soils and Buildings Record of Decision [2]. As noted earlier, USACE also considered the widespread uprooting of trees in the region during Hurricane Sandy in 2012 in its re-evaluation of the earlier decision to leave the trees in the park in place. That re-evaluation concluded it was in the best interest of all stakeholders to remove the residual contamination in Redstone Park. USACE subsequently excavated the soil under and around the drainage pipe as Phase 1 of a two-phased approach to address this residual contamination. 1,116 cubic yards of soil were removed for safe offsite disposal during this action in June-July 2016. Phase 2 (removal of contaminated soil around the tree roots) began in September 2016 with expected completion by December 2016. The work was staged in two phases so as not to impact the park during the summer school vacation months when park use is heaviest. (authors)

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Statistical Tools and Lines of Evidence Used to Differentiate FUSRAP/Non-FURAP Related Material at an Inactive Landfill - 17553

The Middlesex Municipal Landfill (MML) Site is a former municipal landfill in Middlesex, New Jersey that operated between approximately 1940 and 1974; it is currently part of FUSRAP. Because of the lack of waste management regulations at the time, unregulated disposal of municipal and industrial waste occurred, including the acceptance of radioactively contaminated soils from the Middlesex Sampling Plant (MSP) that were used as cover material on the northwest side of the landfill. The radioactive MSP contaminated soils are described as 'FUSRAP-related materials.' In some areas of the landfill, FUSRAP-related material exists comingled with other non-FUSRAP radioactive waste (such as an antique radio-luminescent marker and concrete construction material with elevated gamma readings). However, in other areas of the landfill (specifically the street's right-of-way, called Pershing Avenue, which borders the landfill), non-FUSRAP material is isolated. Several lines of evidence and statistical tools were used to differentiate FUSRAP-related materials from non-FUSRAP-related material, including Z-Score analysis, Tukey-Kramer Honestly Significant Difference test, box-and-whisker plots, Wilcoxon Signed Rank test, and Principal Component Analysis. (authors)

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