Loading...
HomeMy WebLinkAboutProfit Management PlanIS o�ea-•11;tee, r4 . A.) s (,C), f/( I c �ec- 5* 2' 1- Soo - 1 --G,fic ; 2nd DRAFT DRAFT MANAGEMENT PLAN FOR UNDERGROUND UTILITY CORRIDORS STREETS AND PROPERTIES WHERE SUPPLEMENTAL STANDARDS, OR AVERAGING HAVE BEEN APPLIED OR WHERE PREVIOUSLY UNKNOWN CONTAMINATION IS DISCOVERED. NOTE: This plan is intended as a guidance only. Different organizations will have differing needs and structures. It is not necessary that all positions described in this plan be adopted by the affected cities and counties.One or more of the positions can be consolidated with others depending on the circumstances existing in individual communities. It is important, however, a member of senior management be the Program Administrator to ensure adherence to the Plan. DEFINITIONS Affected Street or Utility corridor: Any street or portion of a street including curb, gutter and sidewalk or an underground utility trench or corridor or any area of contamination designated by the U.S. Department of Energy as an area of supplemental standards. Averaged Area: Any area designated by the DOE containing contaminated material meeting EPA standards by virtue of arithmetic averaging. City: All governing agencies and operating divisions authorized by the appropriate city Charter. County: All governing agencies and operating divisions authorized by the (legislation?) creating the county. Contaminated Material: Any material containing Radium -226 in a quantity exceeding U.S. Environmental Protection Agency (EPA) standards of 5 picoCuries per gram above background in the surface 6 inch thick layer and 15pico Curies above background in any six inch thick layer greater than 6 inches below the surface. Contractor: A contractor licensed to perform work on or under City and County streets and underground utilities. The conditions and requirements of this plan also apply to an unlicensed contractor or other entity performing work on or under City or county streets or underground utilities. Controlled Area: (Exclusion Zone) Any area of disturbance of an affected street of utility corridor as defined above with the addition of a buffer zone of sufficient size to allow for safe operation and protection of the public health and environment, as determined by the on-site safety representative. Disposal: Permanent placement of contaminated material at the Cheney Disposal Cell (CDC) located near Grand Junction, Colorado. Division Representative (DR) The person within each Public Works Division appointed to coordinate and implement work activities on or under an affected street of utility corridor. Interim Storage Facility (ISF): The facility designated by the Colorado Department of Public Health and Environment for the temporary storage of contaminated material awaiting transport to the Cheney Disposal Cell. Non -contaminated material: Materials which are not contaminated material as defined above. Program Administrator: A manager in the (insert department) responsible for implementation and adherence to the Plan, directing the activities of the Safety Representative and concurring on site- specific safety plans of outside contractors. Safety Representative: The city or county representative responsible for monitoring and documentation of work activities conducted on affected streets or utility corridors. The safety representative may be a full-time employee of the city or county or a retained individual or firm at the discretion of the city or county. Supplemental Standards Area: Any area designated by the DOE containing contaminated material in excess of the EPA standards. Work Supervisor: A line supervisor directly responsible for. assignment and/or direction of maintenance and construction activities described on the work order. 1.0 INTRODUCTION The Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA), P.L. 95-604 mandated the removal and disposal of uranium mill tailings from 24 specifically designated former uranium mill sites and associated properties. Nine uranium mill sites and the great majority of associated properties are located in Colorado. The United States Department of Energy (DOE) and the Colorado Department of Public Health and Environment (CDPHE) are responsible for this task in Colorado. The United States Nuclear Regulatory Commission (NRC) is the regulator of the program and the United States Environmental Protection Agency (EPA) developed the standards to which the program must perform. In the state of Colorado, more than 15 million cubic yards of uranium mill tailings will be removed to controlled disposal cells when the Uranium Mill Tailings Remedial Action Program (UMTRAP) program is completed in 1998. However, the EPA standards have allowed UMTRAP to leave in place an estimated 1 million cubic yards of uranium mill tailings in Colorado communities by means of the application of "supplemental standards" or by "averaging" as defined by the EPA. Supplemental standards may be applied under circumstances where: • No public health risk can reasonably be expected. • Removal cannot be accomplished without substantial risk to the life and health of workers. • Removal will cause environmental harm far in excess of any benefit derived by their removal. o The cost of removal is far in excess of any health benefit derived, Averaging of uranium mill tailings deposits over a 100 square meter area is allowed in circumstances similar to supplemental standards: o the structural integrity of the contaminated structure is threatened by removal. • Removal would jeopardize the health and safety of the workers. • Removal would result in substantial environmental harm. While supplemental standards or averaging of a tailings deposit allows compliance with EPA standards, problems may arise if these remaining deposits are not properly managed. For example, if an area of contamination located outside a structure is incorporated, by an addition, within the interior, a higher Radon Daughter Concentration may be created. Exposure to Radon poses the largest health risk associated with uranium mill tailings. Mill tailings are routinely encountered in the affected communities, an experience expected to continue for many years. Repair and replacement of utility lines, streets, curbs and gutters are situations where these materials have been disturbed. Continuing concern for the potential creation of a public health hazard has called for the development of management procedures to limit public and worker exposure and ensure the ultimate disposal of the contaminated material in a designated repository. There are several approaches that may be used to control these contaminated materials. They include: 1. Leaving the contaminated material in place, undisturbed. 2. Re -burying the contaminated material in the excavation from which it came. 3. Removing the contaminated material to an approved interim storage area for eventual transportation to the Cheney Disposal Cell. 4. Removing the contaminated material directly from the excavation to the Cheney Disposal Cell for permanent burial. Note: Current planning calls for the establishment of Interim Storage Facilities (ISF) to provide locations for the safe temporary storage of small quantities of contaminated materials awaiting transport to the CDC. DOE will provide 15 cubic yard containers to store and transport the material. The individual communities must provide a secure location for the ISF as well as transport the containers to the CDC at city or county expense. These ISFs are intended for the temporary storage of small quantities of contaminated material generated from removals on private property or during emergency repairs to public streets or utilities. Public renewal projects which expect to encounter larger quantities of contaminated material in supplemental standards areas must be coordinated with the DOE to allow direct transport of the material to the CDC. The affected city or county will transport the contaminated material to the CDC at city or county expense. The affected cities and counties and CDPHE have responsibility for development and implementation of this management plan. This Plan will apply to any and all work occurring in areas where supplemental standards or averaging have been applied. 2.0 REGULATED ACTIVITIES All activities resulting in the penetration of streets, utility trenches or any other area designated as a supplemental standards or averaged area will be subject to this plan. Examples of such activities include but are not limited to the following: 2.1 City and County Operating Divisions • Pavement profiling (rotomilling) which removes the entire thickness of pavement to within 2 inches of the sub -base. o Pavement repairs that will penetrate within 2 inches of the sub -base (pothole squaring and cold patching). • Pavement removal/replacement (removal and hot mix replacement) • Pavement boring/testing programs o Utility cuts - water supply - sanitary sewer - storm sewer - manhole alignment • Accidental or catastrophic damage to pavement,utility trench or line, curb or gutter as a result of human error or act of God • Emergency response related to any of the above. 2.2 Public Utilities and Outside Service • pavement repairs • pavement removal/replacement • pavement boring/testing programs • utility cuts (private services), including, but not limited to: - natural gas - electric - telephone - water - sanitary sewer - storm sewer - cablevision • utility cuts (contractor) - new service/repair/modification of water and sewer taps ▪ curb, gutter and sidewalk removal/replacement • handicap ramps • driveway entrances o accidental or catastrophic damage to pavement, curb and gutter and sidewalks as a result of human error or act of God. o emergency response related to the above 2.2.1 Emergency activities Certain city and county divisions, utilities, and private entities (as determined by the individual cities and counties) are allowed to perform emergency work in areas where contaminated material is located without prior work permits. The organizations having authority to perform emergency work include the following: • (list appropriate agencies) The appropriate Division Representative from each organization performing emergency work in supplemental areas will, at the earliest possible time, contact the Program Administrator and advise him of the emergency and provide any other information required to assist the implementation of this plan. All personnel responding to such emergency shall conduct all activities in accordance with an approved emergency response plan and shall be properly trained and equipped with appropriate personal protective equipment. The Program Administrator shall notify the Safety Representative and request his presence on site. On arrival, the Safety Representative will establish appropriate health and safety monitoring, exclusion zones, oversee material handling procedures and document site activities. 2.2.2 Removals From Private Property NOTE: Many private properties included in the UMTRA Program have some degree of mill tailings contamination remaining after remediation is complete. This can occur in several ways: o By averaging the contaminated material over a 100 square meter area such that it meets EPA standards. o Some deposits remain undiscovered despite the best efforts of the Program. o Some property owners have refused to participate in the Program. Many deposits left in place by averaging present little if any human health hazard in their present state. However, disturbance or modifications that incorporate additional quantities of contaminated material into, or increase the energy efficiency of, the structure may increase the indoor Radon Daughter Concentration (RDC) beyond that recommended by the EPA (4 picoCuries/liter). Previously unknown deposits of contaminated material continue to be found in affected communities. Structures built on or near these deposits may also develop indoor RDCs in excess of EPA standards if the deposits are not removed or the Radon mitigated. Properties whose owners refused to participate in the UMTRA Program may contain sufficient contamination to exceed EPA standards. In some instances, the owner refused to continue in the program after examination by the DOE confirmed such contamination. In others, little is known about the radiologic condition of the property. When contaminated properties change hands, the new owners may wish to remove the contaminated material from those properties. More than 4400 of the roughly 5000 private properties in Colorado contaminated with uranium mill tailings are located in Mesa County. The remainder are located in Durango, Gunnison, Rifle, Naturita, Slick Rock and Maybell. Currently, CDPHE, in cooperation with the Mesa County Planning Department, supports a program which identifies and assesses the potential health hazards of properties containing deposits of contaminated material in Mesa County. The Building Permit Survey (BPS) allows CDPHE to aid the owner in in making a descision whether to remove or mitigate contaminated material found on his property. Over the past 20 years, CDPHE has performed more than 35,000 of these surveys, identifying and removing approximately 47,000 cubic yards of contaminated material. The cost of removal or mitigation is borne by the property owner. Until 1993, contaminated materials removed from private properties in Mesa County were transported to the State Repository located at the Grand Junction Millsite. Now that the Repository has closed, the DOE provides a 15 cubic yard container for loading by the landowner. When filled, the DOE will transport the container to the CDC at DOE expense. Private citizens are not allowed to transport contaminated material to the CDC. If more than 15 cubic yards of contaminated material is removed, the owner must hire a trucking company whose drivers have received DOE training to transport the material to the CDC. This program of DOE -assisted transport to the CDC will terminate at the end of the UMTRA Program in 1998. This Plan will establish an Interim Storage Facility operated by (blank) which may be used by citizens performing private removals.. 2.2.3 Building Permit Survey Procedure NOTE: It is not expected or intended that private owners be subject to the provisions of this Plan other than this section. However, basic radiation protection methods can be instituted at minimal additional cost and should be encouraged. As in removals from public streets and right-of-ways, matching the equipment to the size and geometry of the deposit is a key to reducing the volume of contaminated material removed. Applications for a building permit will be reviewed to determine if the property has a history of mill tailings contamination. This determination will be made by consulting the records of the UMTRA Program and CDPHE. If the property is: • Included in the UMTRA Program. • Excluded from the UMTRA Program but contains contaminated materials. • Located two addresses either side of or across a street or alley from a property known to have been contaminated. o In rural areas, located within 1/4 mile of a property known to have been contaminated. • If the propety is an "owner 'refulsal" . then, a gamma scintillometer survey of the footprint of the proposed structure plus ten feet will be conducted. NOTE: In Mesa County, this survey is currently performed by CDPHE. CDPHE is willing to perform these surveys in other affected cities and counties if some means of funding the cost can be obtained. Other options include CDPHE training of local personnel to perform surveys in their communities. UMTRA and CDPHE records are available on microfiche and electronic form on request. If contaminated material is found within the footprint of the proposed structure plus ten feet, a determination of the concentration and volume of contaminated material must be made. As a general rule, if a one cubic yard volume of material is greater than 20% above background, removal, removal and burial on-site or radon mitigation (passive or active vent systems) is recommended. Adherence to CDPHE recommendations is currently voluntary, not mandatory. NOTE: To establish regulatory authority, a model building code requiring removal of contaminated material or Radon mitigation exists and is available from CDPHE on request. Should removal of contaminated material be indicated, trained personnel should assist the property owner by informing him of the procedures for removal and transport to the nearest ISF. Minimization of the volume of contaminated material removed must be emphasized. Costs to the property owner and the affected cities and counties will be minimized with this approach. If a property does not meet any of the criteria listed above, the usual building permit process is followed. 2.3 Responsibilities All adherence to the Plan shall be carried out under the authority of the Program Administrator and in conformance with all aspects of the Plan. Administration of the Plan shall be in accordance with the organization structure depicted in Figure (blank) 2.3.1 Program Administrator The Program Administrator will be a person in the (insert organization). The Program Administrator will have adequate radiation safety training and experience (as defined in Section (?) of this plan) and will be the individual who is responsible for implementation and adherence to the Plan, managing the activities of the Safety Representative and providing city or county sign -off on site-specific safety plans if the Safety Representative is an outside contractor. In addition, the Program Administrator will act as the point of contact for employee concerns related to individual worker exposures and related issues. 2.3.2 Division Representative Each operating division within the Department of Public Works will designate a person to oversee Plan aspects related to operation in their respective divisions. The Division Representative (DR) will be responsible for the coordination of the activities of Work Supervisors and maintainance of training records and Divisional files related to this Plan. The DR will have adequate radiation safety training and experience in accordance with the training requirements described in Section (insert) of this plan. 2.3.3 Safety Representative The cities and counties shall appoint or retain a City/County Safety Representative (SR); reporting directly to the Program Administrator on matters of radiation safety and occupational health. The SR may be a city or county employee or a retained individual or firm, at the discretion of the city or county. The SR will be responsible for the adequacy and correctness of the Site Health and Safety Plan and is responsible for supervising and observing the day-to-day work and emergency activities in the affected streets and utility corridors. The SR will have the responsibility and authority, through line management, to suspend, postpone or modify any unsafe work activity potentially in violation of the Site Health and Safety Plan or Management Plan. The SR should possess a combination of training and relevant experience in radiation protection as defined in Section (insert) of this Plan. The responsibilities of the SR include. • Development of the site specific health and safety plans for individual work sites. o Monitoring and supervision of work crews performing work in affected streets and underground utilities. • Training of work crews, work supervisors and other personnel required to work in affected streets and underground utilities. o Document relevant work activities related to re -burial, removal, transportation and disposal of contaminated material. 2.3.4 Work Supervisor The Work Supervisor (Supervisor) is the field supervisor responsible for the accomplishment of the assigned work. The supervisor will: o Cooperate with the SR in developing the Site Specific Health and Safety Plan. • Observe and supervise the workers conducting work in a Supplemental standards area and assist the SR in carrying out the Site Specific Health And Safety Plan. Assure compliance with the Supplemental Standards Procedures in affect at the work site. Minimize contaminated material removed from the site Establish and maintain an exclusion zone around the work area and ensure contaminated materials remain in the exclusion zone, secure from public exposure and disturbance from the elements. 3.0 SUPPLEMENTAL STANDARDS AREAS The location and extent of supplemental standards areas is depicted in Figures (insert). The limits of supplemental standards areas were determined during the UMTRA Program, discussions with various utility agencies and other historical sources. It must be understood that Figures (insert) may not show the entire extent of uranium mill tailings contamination. Contamination may extend beyond the known contaminated area and areas not previously known to be contaminated may be discovered. Maps indicating the extent of contamination must be updated to reflect actual field conditions. Discovery of a previously unknown area of contamination should cause suspicion the entire utility corridor or street is contaminated, particularly if it is of the same age. Any extension of known areas of contamination or the discovery of new areas of contamination requires notification of the Program Administrator. NOTE: Gamma radiation at the energy levels associated with uranium mill tailings is easily shielded from detection at the surface by layers of asphalt, concrete, soil, clean fill materials etc. As a general rule, any uncorrected gamma scintillometer reading 20% above background or more detected on contact with surface material should be investigated for possible tailings contamination. If, after excavation, the gamma scintillometer reading increases, investigation and additional excavation should continue until a determination of the contamination status can be made. It may be necessary to sample the suspect materialwith an Opposed Crystal System (OCS) to determine the Ra -226 concentration and the need to manage it. It is not intended htat excavation occur merely to determine the extent of contamination. Only within the contextof planned work is it necessary to dermine the extent of contamination. Surplus OCS systems and the training necessary to operate them may be available from the DOE as the UMTRA Program winds down. 4.0 WORK ORDER/PERMITTING PROCEDURES 4.1 General Assignment of specific work orders will be delegated by a Supervisor. Prior to assignment of a work order, the Supervisor will verify through the appropriate DR the work is or is not planned in a known supplemental standards area. The DR will provide the Supervisor written notice of the contamination status prior to the commencement of any work activity in the area. If it is determined that work will take place in a area of supplemental standards, the DR will notify the Supervisor, in writing, all work in the area must comply with this Plan. The Supervisor will place, in a conspicuous location on the work order, notice indicating that "Supplemental Standards Procedures" are in effect. Supplemental Standards Procedures for the following work categories are contained in Appendix (insert) of this document. General Activity Category Procedure Pavement Repair, Replacement and Modification 1 Trenching and Utility Cuts 2 Pavement Profiling (Rotomilling) 3 When the Supervisor delivers a work order specifying supplemental standards procedures must be used, the Supervisor will refer to the Procedures Manual to determine the specific procedure to be followed. The Supervisor will ensure all personnel assigned to the work effort have adequate training in accordance with Section (insert) of this plan. The Supervisor will contact the SR, providing all necessary information for the preparation of a Site Health and Safety Plan no less than 48 hours prior to initiation of work, except in the case of an emergency response as defined in Section 4.1.3. The Supervisor will brief all members of the assigned work party on the major aspects of the Procedure, reasons for the procedure, operational considerations and contaminated material handling. Where an emergency response is required. the Supervisor will brief the work crew prior to commencement of work. In a non -emergency situation, the SR will provide an overview of the Site Health and Safety Plan. The presentation will allow for a question and answer period and provide clarification to the satisfaction of the work crew. 4.1.1 Work Initiation It is the responsibility of the Supervisor to ensure compliance with the Supplemental Standards Procedure and provide documentation thereof. Job site responsibility rests with the Supervisor. Any deviation from the supplemental standards procedure requires clearly defined written authorization from the Divisional Representative (DR). The Supervisor will notify the Program Administrator and the SR of work initiation a minimum of 48 -hours in advance and provide the following information: Work location Date and duration of work Description of work and applicable procedure Any cancellation or changes in location, date or scope of work requires notification of the Safety Representative. 4.1.2 Emergency Response Any activity defined in Section 2.2.1 is an Emergency Response if one or more of the following occurs: The situation is an immediate and substantial threat to life, health or property. The situation requires initiation of work prior to the minimum 48-hour advance notice required in the Plan. Emergency Response Procedures will be used only for true emergencies and not for routine operations. The following situations are the only justifications for an emergency response: Gas main break Water main or water service line break o Sanitary sewer break o Accidental or catastrophic damage caused by human error or acts of God that result in major disruptions to traffic control, communications or electrical power. All other activities require approval of the Program Administrator in writing before an emergency response is initiated. When an emergency response is necessary, the Program Administrator and the SR must be notified immediately. All emergency crew members must have completed all mandatory training required in Section (insert). Under the direct observation of a properly trained Supervisor, the emergency work crew will make every effort to comply with this Plan until such time the Plan is fully implemented. 4.1.3 Work Observation and Documentation The SR will observe and document all field activities including re- burial or removal of contaminated material to the ISF or the CDC. The SR will have authority to direct work activities related to contaminated materials to assure worker and public health and safety and proper management of the contaminated materials. The SR will prepare documentation including such items as photographs, contamination readings, volumes etc. in accordance with the specific procedure. All documentation will maintained in the files of the Program Administrator and Safety Representative. 5.0 PERMITTING PROCEDURES FOR PUBLIC UTILITIES, CONTRACTORS AND OUTSIDE SERVICES. 5.1 General Article (insert) of Chapter (insert) of the city of (insert) and the (insert proper county codes) require a written permit to disturb the ground or pavement in any public right-of-way including any streets or alleys. The applicant for a permit will adhere to the procedures defined in the citations above. In addition, the applicant will conform to the following procedures. All applications shall be reviewed by the city and/or county to make a determination as to the need for implementation of supplemental standards procedures. These procedures have been developed to identify work activities that may disturb contaminated materials in supplemental standards areas. These procedures also ensure •that all activities conducted on or in supplemental standards areas are directly observed by the SR who will provide complete documentation of work activities stipulated in this Plan. 5.2 General Permitting Procedures All applicants will be required to initiate the permitting process at (insert) NOTE: It is thought this can included in the current city/county permitting process by incorporation. 5.2.1 Description of Work Location The applicant will provide an accurate depiction of the work location in the sketch area provided in addition to a description of the street location to the (public works permit rep?) 5.2.2 Clearance Confirmation The (public works permit rep?) will identify the applicant's work location on the supplemental standards areas map. If the location is outside the supplemental standards area the (rep) will note in writing "Clear SSA" and initial. The applicant will then follow the regular procedures for obtaining a permit. As a final check, the permittee should use a gamma scintillometer to determine if the work is occurring in a previously unknown area of contamination. If contamination is encountered, the Supervisor and SR must be informed and procedures for work in supplemental standards areas enforced. When the applicant's work location is inside a known supplemental standards area or portion thereof, the (rep) shall note in writing "Subject to Supplemental Standards Procedures" and initial. The (rep) will then direct the applicant to the appropriate Designated Person, with a copy of the Permit Application. 5.3 Supplemental Standards Area Permitting Procedure Each city/county Public Works Division will establish a Division Representative (DR) to coordinate work activities on or in supplemental standards areas. Applicants seeking permits to perform work subject to supplemental standards procedures will be directed take their permit application to the appropriate DR with any supporting documentation deemed necessary by the DR. The DR will issue the permit subject to supplemental standards area procedures and provide the applicant with the appropriate procedure (1,2 or 3). The DR will review with the applicant the contents of the procedure and answer any questions that arise. When the applicant is confident he understands the requirements of the standards procedure, he will sign an affidavit stating the applicant has received and fully understands the procedures required to protect worker and public health, minimization of contaminated material, the process of re-burial or transport to the ISF or the CDC. NOTE: The importance of minimizing the volume of contaminated material transported to the ISE' and the CDC must be given special emphasis. A key component of this minimization is the matching of equipment to the size and geometry of the deposit. For example, the use of a front-end loader with a bucket six feet wide will almost certainly increase the total volume of contaminated material removed from a contaminated utility trench four feet wide. A better choice of equipment would be one with a bucket equal to or less than the width of the trench. Requirements to use equipment properly sized for the expected geometry of the deposit may need to written into the contract to avoid misunderstandings and disputes. The DR will inform the applicant of the absolute requirement to coordinate all work activities with the SR. 5.3.1 Work Initiation The contractor conducting work in a supplemental standards area will contact the SR no less than 48 hours (2 work days) prior to commencement of work (except in the case of an emergency as defined in 4.1.2) and provide the following minimum information: o Location of work o Date and duration of work • Description of work and applicable procedure • Site-specific Health and Safety Plan • Documentation of appropriate training for all assigned work crew. Any cancellation of scheduled work or changes in location, date or description of the work requires immediate notification of the SR. The contractor will prepare a site-specific Health and Safety Plan for review by the SR no later than 48 hours (2 work days) prior to the commencement of work. The site-specific Health and Safety Plan may be adapted from a model plan prepared for the supplemental standards areas and should require little modification. NOTE: Is this necessary, or a waste of time and paper? Would a generic safety plan be sufficient? Do the Cities/Counties durrently do this for site hazards such as power lines or trenches? The Contractor is responsible for assuring all personnel assigned to work in a supplemental standards area are properly trained in accordance with Section (insert) of this Plan. 5.3.2 Work Observation and Documentation do goo/0, The SR will observe and document all field work performed by the contractor related to contaminated material including disposition of the contaminated material whether by re -burial or transport to the ISF or Cheney Disposal Cell. The SR has the authority to oversee all aspects of work related to the handling of contaminated material in a manner that is protective of human health and 'ensures proper disposal of the contaminated material. The supervisor and SR will assist one another in accomplishing the work. The SR will collect and maintain written documentation of all work activities including photographs, contamination readings and volumes of contaminated material. WORKER HEALTH AND SAFETY 6.1 General Health and Safety training is essential to controlling and reducing risk in the work place. Workers cannot guard against risk if they are unaware of the hazard. There are several means (pathways) by which workers may be exposed to radiation while working in supplemental standards areas. These pathways are: 1. Direct (external) exposure to gamma radiation. 2. Inhalation of airborne radioactive particles (dust) 3. Ingestion of contaminated food or water Items 2 and 3 are internal exposures resulting from the inhalation or ingestion of radioactive gas or particles and are more hazardous than external gamma radiation at the levels associated with uranium mill tailings. Fortunately, internal exposures from pathways 2 and 3 can be easily controlled by good work habits. Keeping the contaminated material damp will limit fugitive dust and Radon emanation. A strict prohibition of eating, drinking, smoking and chewing of tobacco, gum etc. will further limit internal exposures through ingestion and inhalation. Workers leaving a contaminated area should thoroughly wash their hands before handling consumable substances. NOTE: In work involving exposure to radioactive materials, the principle of ALARA should be followed. ALARA is an acronym for As Low As Reasonably Achievable. In essence, this means no one should be exposed to ionizing radiation unnecessarily. There are three methods of limiting radioactive exposure. They are: ° 1. Time «61 11; . 41.41c ° 2. Distance ° 3. Shielding Time means the less time spent in a contaminated area, the lower the expgsure. Distance means the greater the distance from a contaminated area, the lower the exposure. Shielding refers to the use of dense materials, lead being the most common. In most cases, shieldingtis not practical for the kind of work and situations encountered in supplemental standards areas. A well thought-out work plan will perform the task in the minimum amount of time with the fewest number of people operating at the greatest possible distance from the contaminated material. No personnel other than those absolutely required to perform the task should be allowed in the contaminated area. All others should remain outside an established controlled area. 6.1.2 Radiation Exposure Concerns Health hazards caused by radiation are primarily due to the ionizing affect of alpha and beta particles and gamma rays. Ionization is a process by which electrons surrounding the nucleus of an atom are forced from their orbits. Human tissue is composed of chemical compounds made up of atoms. Exposure to ionizing radiation will displace electrons, causing physical damage to the cell in which these atoms are located. The longer the duration and the higher the concentration of exposure the greater the ionization and subsequent cell damage. Most damage caused to the cells by ionizing radiation is quickly repaired by the body's natural defense mechanisms. Uranium mill tailings contain, of course, Uranium. This element is unstable, causing it to change, over time, into other radioactive elements. This instability and change is called radioactive decay. The most common form of Uranium is called Uranium -238. While not particularly "hot", Uranium -238 decays to Radium -226 which then decays, in succession, to five short-lived radioactive particles known collectively as "Radon Daughters". These daughter products, emitting alpha and beta particles, attach themselves to dust and water particles. These particles, when inhaled or ingested, pose the greatest radiation danger to those working in supplemental standards areas. Alpha and beta particles have little ability to penetrate the human body. Alpha radiation is shielded by a few inches of air, the dead layer of cells that form the outer layer of skin or by one thickness of tissue paper. It is important to remember there is no layer of dead cells lining of the throat and lungs absorb alpha particles. It is this direct exposure of living cells to alpha particles that must be avoided. Beta particles are be stopped in about 10 feet of air, approximately one inch of flesh or a layer of sheet metal. High energy gamma rays can travel ninny hundreds feet in air, will pass completely through the human body and are shielded only by very dense materials such as lead, steel, concrete or water. The gamma rays associated with uranium mill tailings are less energetic and are easily shielded by thin layers of soil and other common construction materials. The Radiation Control Division of the Colorado Department of Public Health and Environment currently sets a limit of 500 milliREM/year for non -radiation workers. This is the limit to which the public may be exposed from non -natural sources. This Plan has chosen to follow a more conservative standard, consistent with ALARA, of 100 milliREM/year excluding background and x-rays. It is highly unlikely that workers will exceed that dose. NOTE: During the UMTRA program, the highest dose received by a worker in one year of near -constant work exposure was approximately 140 mi11iREM. The average annual dose to UMTRA workers is approximately 40 milliREM. City, county and contract personnel will spend much less time in contaminated areas than UMTRA workers and, consequently, will receive a lower dose. 6.1.3 Particulate (Alpha, Beta) Radiation Exposure Control The methods of limiting gamma radiation exposure have been discussed in Sections 6.0, 6.1, and 6.1.2 of this Plan. Whenever dust is generated within a supplemental standards area, measures must be taken to eliminate the dust source, up to and including, cessation of work. Water sprays and mists must be routinely applied to areas of contamination in supplemental standards areas to control dust. Measures such as covering of exposed areas of contamination during high wind periods may be necessary to reduce exposures to the worker and the public. UMTRA experience has shown that application of water at the point of excavation and the point where vehicles hauling the contaminated material are filled can effectively control dispersal of radioactively contaminated dust. Dust control is the key to reducing exposures and must be given the highest priority and constant attention. Efforts to limit handling of contaminated material and placing equipment and personnel up wind from the excavation will also reduce exposures. NOTE: The use of respirators to protect workers is a last resort, and will be considered only after all other methods have failed to reduce the dust hazard. The use of respirators greatly reduces the efficiency of workers and is very costly and difficult to manage. 7.0 CONTAMINATED MATERIAL DISPOSITION 7.1 General There are several options for the disposal of contaminated material encountered in areas where supplemental standards have been applied. The preferred option is to re -bury the material in the original excavation, taking care the contaminated material is placed in the correct relative position, i.e. it should be put back in the bottom of the excavation covered by a layer of clean fill material. It is necessary to segregate clean material and contaminated material from the same excavation. For example, if the upper two feet of a utility trench is composed of uncontaminated material, it should be carefully removed and stored separately from the contaminated material encountered deeper in the trench. This is necessary to minimize the total volume of contaminated material that must be managed. Employing equipment properly matched for the expected size and geometry of the deposit is imperative to reducing the amount of material transported to the ISF and the CDC. For example, a front- end loader with a six foot wide bucket would not be the appropriate equipment to excavate a four foot wide trench filled with mill tailings. At all times care must be taken to retain contaminated material within the exclusion zone, secure from public access. If contaminated materials cannot be re -buried or removed from the work site prior to the end of the work day, the material must be protected from dispersal by wind or rain until such time the material are re -buried or removed. NOTE: It is imperative to minimize the volume of material transported to the ISF and the CDC. The volume left at CDC after the end of the UMTRA Program will accommodate approximately 20 years of removal activity. Reducing the amount of uncontaminated material transported to Cheney will extend the useful life of the CDC greatly reduce the over-all cost of the program. The second option is to transport the contaminated material to the IDF for eventual disposal at the CDC. Transport to the ISF is warranted only when small amounts of material are expected from a scheduled work activity or a private removal. The IDF may also be used for the disposition of contaminated materials resulting from emergency situations described in this Plan. NOTE: Volumes that can be temporarily stored at the IDF may be severely limited. For projects planned in supplemental standards areas where large volumes of contaminated material are expected, coordination with the DOE to allow transport of the material directly to Cheney is mandatory. Projects must be planned and coordinated with the DOE such that Cheney is operated on an intermitant, scheduled basis. The fewer times the CDC is opened, the less the over-all cost of the program. Only volumes of material, exceeding the capacity of the ISF should be transported directly the CDC. When clean back fill is used in an area containing contaminated materials, best efforts to physically separate the materials must be made. This separation will prevent cross -contamination and a subsequent increase in the volume of contaminated material. A layer of heavy -gauge plastic sheet between the two materials has been found to be an effective barrier to cross -contamination. 7.1.1 Transportation of Contaminated Material Equipment transporting contaminated material must be in good operational condition. Care must be taken to eliminate spillage of contaminated material from these vehicles while traveling to the IDF or CDC. Prior to filling , a heavy -gauge plastic sheet will be placed against the tail gate of the truck in such a way that contaminated material cannot leak from the tail gate. Vehicles transporting contaminated material must be carefully tarped to prevent wind -dispersal while traveling. All machinery leaving the contaminated area must be checked for contamination adhering to the tires, chassis or body. If found, this contamination must be removed before the vehicle is allowed to leave the exclusion zone. These efforts are designed to prevent the spread of contamination beyond the exclusion zone. When the site is ready for clean up, a visual as well as a gamma scintillometer survey of the site should be made to assure that contaminated material does not remain exposed at the surface. APPENDIX 1.0 PROCEDURE FOR TRENCHING IN SUPPLEMENTAL STANDARDS AREAS 1.0 Site and Area Monitoring This procedure is intended for use when contaminated materials are encountered during operations that disturb pavement, road base, subbase and basement soils in supplemental standards areas. These operations include but are not limited to: Pavement Repairs Installation of traffic control and signal devices Curb and gutter removal/replacement • Installation of handicap access ramps • Installation/removal of driveway entrances • Installation/removal of sidewalks Pavement boring/testing programs Prior to initiation of work, permitting procedures described in Section (blank) of this Plan must be followed. 1.1 Worker Health and Safety Worker and public health and safety requirements will be specified in the Site -Specific Health and Safety Plan. A model plan developed for supplemental standdards areas may be used and modified to address hazards unique to each site. In general, few modifications should be necessary. 1.1.1 Employee Training Requirements Workers must successfully complete the 16 -hour Radiation Worker II offered by the DOE through the Grand Junction Projects Office. Annual refresher courses lasting approximately 2 hours are also required. Employees who have not been trained will not be allowed access to the exclusion zone. A brief "tailgate" safety meeting will be held immediately prior to the start of work in the contaminated area. Workers should sign the site-specific Health and Safety Plan, acknowledging their understanding of the plan and recognition of any potential hazards associated with the site and the methods to minimize them. 1.1.2 Personal Monitoring The SR will determine which individuals require personal monitoring based on job classification and a quantitative assessment of potential exposure. Personal monitoring will consist of individual thermoluminescent dosimeters (TLDs). The SR will keep complete and current records of individual worker's presence during work in supplemental standards areas. NOTE: Whole body gamma exposures are assessed through the use of a TLD. A TLD measures gamma radiation exposure on a crystalline chip located in a TLD badge about the size of a match book. TLDs are analyzed by contract laboratories who report the exposure on a quarterly basis. The TLD badge must be worn on the front part of the torso, between the waist and neck. 1.1.3 Personal Protective Equipment Workers in the exclusion zone will wear personal protective equipment (PPE) as directed by the SR. In general, PPE will consist of steel toed boots, hard hats, gloves and work clothing in good condition. At times, coveralls and rubber boots and gloves will be adviseable. 1.2 Exclusion Zone A clearly defined zone will be established around the contaminated area to prevent entry of the general public and to define the area where supplemental standards procedures are in effect. The exclusion zone also marks a boundary beyond which contaminated materials are prohibited. Temporary fences, traffic cones or other effective and highly visible means are appropriate for establishing the boundaries of the exclusion zone. The SR, in cooperation with the supervisor, will determine the appropriate size of the exclusion zone. 1.3 Site Monitoring The Safety Representative will monitor radiologic conditions at the worksite and the immediate surrounting area. Monitoring activities include: 1. Establishing background gamma levels using a gamma scintillometer. 2. Determining if the material is contaminated (in excess of excess of 20% above background). 3. Documenting the result of this determination and an estimate of the volume of contaminated material. 4. Clearly marking (with spray paint, etc,) the surface expression of the elevated readings in order to inform the work crew where the contamination is located. 5. Assuring that contaminated and uncontaminated materials are separated, confirming only contaminated materials are transported to the ISF or CDC. 6. Monitoring excavation to minimize removal of contaminated material 7. Observing the workers within the exclusion zone to assure compliance with established radiologic safety procedures. 8. Assuring adequate dust control methods are used. 9. Assuring that only workers whose jobs require their presence are allowed in the exclusion zone. 10. Preventing the spread of contaminated material beyond the exclusion zone. 11. Assuring the work area is cleaned of contaminated materials when work is completed. NOTE: Only workers whose job requires their presence will be allowed in the exclusion zone. When not actually performing work, workers will leave the exclusion zone until their presence is again required. 1.4 Excavation Methods The equipment used to excavate a utility trench must be appropriately sized to match the expected size and shape of the trench. Minimizing the amount of contaminated material excavated will be emphasized. The uncontaminated material (as determined by the SR) will, by careful excavation, be isolated from the contaminated material by stockpiling in a separate area or by loading into a vehicle designated for that purpose or by any other reasonable means that will assure there is no cross -contamination .by contaminated material. The contaminated material removed from a trench should be loaded directly into a vehicle for transport directly to the IDF or the CDC. Stock piling of contaminated material on-site should be avoided. If stockpiling of contaminated material cannot be avoided, the stockpile must be protected from disturbance by the public and the elements by tarping or other means that will prevent dispersal. Equipment used for excavating and hauling contaminated material must not be used for hauling or placing clean backfill until all visible signs of contamination are removed. The SR in cooperation with the supervisor will confirm that all equipment is properly decontaminated. The SR will inspect and monitor all people and equipment leaving the exclusion zone to assure contaminated material is confined to the exclusion zone and not dispersed from the site. The Supervisor and the SR will assure only the amount of contaminated material necessary to perform the work is removed from the site. During backfill operations, the Supervisor and SR will assure clean backfill is isolated from contaminated material by the installation of a heavy gauge plastic sheet placed between the two materials. Appendix 2.0 Procedure for Rotomilling in Supplemental Standards Areas NOTE: Experience gained during the EXTRA Program indicates tailings contamination in supplemental standards areas under streets is usually confined to trench back fill, road base, curb and gutter and rarely, if ever, in the asphalt itself. However, if the asphalt was laid directly in contact with a contaminated base material, it is possible the asphalt near the contact will have absorbed some contamination. If the rotomilling operation will not excavate to within two inches of the base of the asphalt, supplemental standards procedures are not necessary. Care must be taken to avoid contact with contaminated material beneath the asphalt. Personnel trained in the use of a gamma scintillometer should be present to assist in preventing inadvertent spread of contamination. If the rotomilling operation, by design or accident penetrates the full thickness of asphalt in a supplemental standards area, it should be assumed the asphalt removed from that area is contaminated. Action must be taken to isolate this contaminated asphalt from uncontaminated asphalt. Contaminated asphalt will be managed as a contaminated material as described in this Plan. APPENDIX 3.0 PROCEDURE FOR STREET REPAIRS AND REPLACEMENT 1.0 General Street repairs and replacement in areas of known contamination must be perfomed according to this Plan and Procedure. All steps providing identification of the contaminated area, exclusion zones, training, protection of worker and public health and transport of contaminated materials described in this Plan apply. Paving materials in contact with contaminated base and/or sub- base will be considered contaminated. Best efforts must be made to seperate contaminated from non -contaminated materials. In many cases, the visual distinction of mill tailings contamination can be made by personnel familiar with their appearance. The sandy texture and the gray to purplish -gray color is often so evident as to allow personnel to distinguish the contact between contaminated and uncontaminated material. This information can assist personnel in separating the two materials. Uncontaminated or "clean" material must be physically separated from contaminated material during and after excavation to prevent cross -contamination and the creation of larger quantities of contaminated material. Contaminated material will be transported directly to the CDC or, if a small quantity (<15 cy), to the ISF. 8.0 THE INTERIM STORAGE FACILITY (ISF) 1.0 General Each affect city and/or county will establish a secure area for the construction of a temporary storage facility for contaminated materials. This facility will be constructed by a contractor to the DOE. The facility will include: A fully chain-link fenced, gated and locked area capable of holding two 15 cy containers and trailers provided by the DOE. The equipment necessary to load contaminated material from the ground into the containers. o Shelter from the elements (wind, rain) to prevent dispersal of contaminated material. o A means of decontaminating equipment used in the transport and loading of contaminated material. o The necessary radiation measuring equipment (gamma, alpha) to allow scanning (frisking) of equipment and the storage area for residual contamination from contaminated material. 2.0 Facility Maintenance 2.1 The facility will be: o Kept clean and free of contamination spills and trash. o Inspected monthly for condition of fence, fence poles, gate and lock. o Radiologically surveyed monthly for evidence of contamination from wind, precipitation or spills. 3.0 Facility Operating Hours 3.1 The state, city and/or county will have access to the facility on a 24-hour basis. T h e facility will be locked and secured when not in use. Public access will on an as -needed basis between the hours of 8:00 AM and 5:00 PM daily except on holidays. 4.0 Dumping at the Facility 4.1 Use of the facility will be supervised by an employee of the state, city and/or county trained in radiation protection techniques and the associated paper work. 4.2 Gate will be unlocked, then closed behind the vehicle will dumping is taking place. Only one vehicle will be allowed in the facility at a time. 5.0 Documentation 5 1 Records will be maintained indicating: o The origin of the contaminated material (address) • The presence or absence of any material other than mill tailings contaminated material. No hazardous materials will be allowed. o The material exceeds EPA standards 40 CFR 192> • Name of contactor or citized dumping the material. • Name of facility supervisor o Date of dumping. 6.0 Operations 6.1 Dump material in designated area or directly into container, ensuring no :spillage. Spilled material will be picked up and deposited in the designated area. 6.2 Scan (frisk) vehicle, container and any other equipment exposed to the contaminated material. If clean, vehicle may leave the facility area. If contaminated, clean with broom, shovel or high-pressure water until frisked clean. 6.3 Water used in contamination must be contained within the facility secure area and prevented from dispersal beyond controlled area. 7.0 Loading materials into containers 7.1 Inspect container for cracks, breaks or loss of integrity before loading container. 7.2 Untarp container and load material. 7.3 Do not exceed permissable load marked with painted line on interior of container. 8.0 Transportation of container to CDC 8.1 Vehicle and container must meet all DOT requirements for transportion of mill tailings (driver training, safety inspections, placarding etc.) 8.2 Container must be tarped to prevent dispersal of materials while in transit.