appendix a supporting documents - inel … a supporting documents winco letter, wrg-17-85, “pcb...

Appendix A

Supporting Documents

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Appendix A

Supporting Documents WINCO letter, Wrg-17-85, “PCB Contaminated Soil in ICPP Substation”, June 3, 1985

WINCO letter, Pal-1585 “Procedure for Cleanup of PCB Contaminated Material”, June 26, 1985

Construction Interface Document “Remove PCB/Radioactive Contaminated Soil and XFR Pad Z”, July 10, 1985

“Guidelines for the Cleanup of the PCB Spill From the Transformer near CPP-6 13”

Raunig, Dennis E., LMITCO, to Roger K. Jones, LMITCO, February 17,1998, “Disposition of an Investigative Derived Waste (IDW) - DER-001-98,” File Code 6105.

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* *

0 v? From : Phone : Rats : Subject:

To :

cc:

Westinghouse ldaho Nuclear Company, Inc.

Wrg-17-85

F. K. Wrigley 6- 108.5 June 3, 1985 PCB Contaminated Soil in ICPP Substation

R. J. Secondo, DOE-ID L. c, Lewis C. E. Clark, DOE-TD W. C. Mallory G. H. Hanson, EG6C W. G. Mansfield T. M. Nash, M-K R. J. Marcinko P. J. Hult w. P. Palica K. Krivanek T. F. Pointer

H. U. Johansen F. K. Wrigley - 2 Project Central Files

The attached guidelines have been prepared by R. J. Second0 for handling the PCB contaminated material In the ICPP Substation. Please review and p3an to attend a meeting on Thursday, June 6 at 11:00 a.m. in CPP-652 to review comments and suggestions. After the meeting, WINCO Nuclear and Industrial Safety will prepare directions for handling the material based on discussions and decisions made at this meeting.

Project Manager

Attachment

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UREP Substatian PCB Contamination

Att aclxnent Page 1 of 4 Wrg-17-U

Issues :

Radioactive contaminated soil. PCB contaminated soil. PCB contaminated concrete. Appropriate samples, hold points, etc., for accomplishing goals.

Goals:

Separate radioactive soil such that it shall not go off site.

Sampling techniques and measurements for PCB shall be equiva- lent to EPA standards. Remove all soil above KPA limit of 10 ppm as PCB rontaminated. Below 10 ppm PCB containing soil can be left as is.

Pood For Thought:

1. Excavate the top layer of radioactive contaminated soil - approximately 6” and box per RUM requirements. (It is also PCB contaminated. )

2. Chip off the PCB contaminated concrete from the existing transformer pad. Assure thia concrete material is not radlo- active contaminated for off-site shipments. If radioactive contaminated, then it ishould go in the same container with the top layer of soil and ship to RWKC.

3. Excavate for the new transformer foundation - Control this this excavatioa activity by the following actions:

a. This excavated dirt will require a storage system (see Sketch No. 1).

controlled temporary

b. As this dirt is excavated, it shall be identified by the location it came from and organized in controlled piles in the protected system.

c.

d.

Represent pile.

Analysis shall be done per the EPA procedures so that readings will correlate to the EPA limits of 10 ppm.

shall be taken for each controlled

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Attachment Page 2 of 4 Wrg-17-85

e. When the excavation is complete, additional sampling shall be done in the bottom and sides of the excavation to confirm that no soil is contaminated above the EPA limit af 10 ppm (see Sketch No. 2).

f. The project is on hold sample analysis results.

at this po‘int, waiting for the

4. If all samples come back less than 10 ppm per EPA's limit, then the project can proceed and all dirt excavated can be used for back fill. (Note: Except for the top layer that was boxed, left over material from this excavation shall be disposed of appropriately - clean per CPP standard; if there is PCB traces and there is room available in the RWMC box, it can be placed there. If samples come back greater than 10 ppm, then so21 shall be boxed for disposal and handled as PCB contamianted soil.)

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II ** ! I . t 1 I

I _ “--.“- * ! Attachment Page 4 of 4

I

wrg-iTj’-g~ I- -.,I___--.. .’

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Westinghouse Idaho Nuclear Company, Inc.

Box 4000 Idaho Falls, Idaho 83403

Pal-15-85

June 26, 1985

Mr. R. J, Secondo, Chief Process and Waste Management Branch Engineering 6: Construction

Management Divlsion Idaho Operations Office, DOE-ID 550 Second Street Idaho Falls, Idaho 83401

Dear Mr. Seconcio:

Subject: Procedure for Cleanup of RX Contaminated Hater&al

This will confirm that a procedure for rleaa up of PCB contaminated material (DREP Substation Phase II) was hand carried to you on June 25, 1985.

If you have any questions, please call me at C-1086.

Very truly yours,

l+zfuxL~?n W. P. Palica, reject Engineer Line Item Projects

,bcc: B. J. Bliss

j P. J. Hult 8. U. Johansen

I I?. K. Wrigley

f W. P. Palica - 2 Project Central Files

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. U.S. DEPARTMENT OF ENERGY

tEMH0 QpERATIopQ& QFFCE

15, DfSPOSJllON: Fielcl Change-Order 0 Subcontract #a Change Order No. Pursuant to the changes artfcfe the s&contractor Is hereby directed to proceed as foltows:

---___ - - . - “ . . . .-L__ - . - - - . . _ I -_- __________ _ ^-.” ^. .” x- - - .” _“__ l_l . - . , . - .

Subcontract Admlnislra~ate - - - - - . “. . - . l . . . - - - - lP ..“_.” --.-l-^_“... ,... _I__-

Construction EngtneerlDate Subcontractor Representafwe!Date -- -- I_

1.

2.

3.

4.

5.

6.

7.

8,

0.

10.

11.

12.

13.

14.

15.

INSTRUCTI * PREPARATRM Of CIO-Ml FB400.A a

Name and NEL Location (eg., CFA 670, HQ 202, CPP 637, MTR 603) person that is to receive the CID. CID’s shoujd be 8ddreSS%d to: Constfuctior\ Engineer - When to Construction ?&anqement Proiect MaaagwfEngineer - When to Operating Contractor

Name of PtoJec!.

Date tha: CID is originated.

Project idertrifrcation number aeslgned by construction management contractor.

SeqU8fIt~i) ritimb8r aSSignt3d by C~stWtiOtI mtiwgement cOntr’aCtOr.

The interso~tract~r work authorization number sssigned to the job by the operating contractor.

Name nnd leca?ion of originator.

Phonc3 number or originator. ,

Orlginritor’s organization.

Date that response to CID is required.

Drawtngs, sf scificztfons, letters that may aid addressee in dt$posltion of CID.

Clear. concise. wmmary descttption of problem. I

fndicatn tk iyps and reasons for problem and give a CMtaiied description.

Oriptrwro- prepaws recommendation and solutions. Indicate if clarification in #14 8 #Xi. Recipient must sign off approva’

Copy 3 v;ill w3 given to subcontractor fepreeantatiw. Copy 2 for construction files, original subcontract admi?istratcr fiir. Construction Engineer must sign upon prepamUon SA on receipt. Subcontractor upon final dispos:!ion z,nd prior to distribution.

D~B~R~BU~~OFJ NAME \I LOCATION

CM. stte Mp. a ,

0.c Prof. Mgr _. -_- _. ..m.

0.0. Fi8id COWd -e/tiftt

Subcontractor - Home Olftse

--

,-

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GJIDELINES FOR THE CLEANUP,OF THE PCB SPILL FRDN THE TRANSFORMEH NEAR CPP-613

These guidelines represent the procedures requtred for the cleanup of a PCB spill near CPP-613 and also procedures for sampling and anal- ysfs of this spill. Emphasis wit1 be placed on the sampling and analysis methods used to verify that the PC8 spill site has been properly decontaminated-

Cleanup of the site contaminated with fluid containing polychlorinated biphenyl's (PC&) which has spilled from the transformer will consist of the following activitiesi [I) preparing guidelInes for the cleanup; (II) cleaning up the spill site and restoratfon of the site; (III) sampling; (IV) analysis; (V) inspection of the site, and (VI) final documentation. General guidelines for performing each of these activities are Presented in this document.

After the spill site had been secured and the boundaries of'contamination had been determined, a set of guidelines had to be prepared to direct the spill cleanup. The spill cleanup activities will include:

. Health and safety precautions . Physical removal of contdminated gravel . Decontamination of equipment . Removal of the transformer pad . Additional decontamination procedures . Samplfng . Analysis.

I. CLEANUP GUIDELINES

A. Health and Safety

Human exposure to polychlorinated biphenyls (RIBS) will be minimized to protect the health and safety of workers involved in the sampling and spill cleanup activities. Sampling personnel will be required to obtain a Hazardous Uork Permit for each shift. Excavation personnel will be required to obtain a Construction Safe Work Permit ' for each shift.

. TC

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A preconstruction meeting will be required of all personnel who wil.1 be involved with the removal of the PCB-contaminated material. The meeting will cover general health and safety hazards assocdated with

%*lcaey+ *

w@ ur"~ 3 PCfi contamination and the appropriate safeguards and work practices to be followe'd This training will*be coordinated through the IrM4(cQ, ~~n%~urrz~ Productit&l Training SeCtion.

1. Protective Clothing

Protective clothing that is impervious to PC&s will be worn in situ- ations where workers may come into contact with PC& or PCB-contami- natcd materials. This clothing consists of impervious paper-like coveralls (Saranex Tyvek-laminated coveratls), plastic overshoes, rubber-like gloves (such as Viton), andfor an impervious apron. After completion of PC8 handling an< cleanup operations, the dispos- able work clothing will be removed immedfately. The contanihated clothing will be placed in a leak-proof contafner and properly disposed of as PC&contaminated material.

2. Eye Protection

Chemical safety goggles will be worn during any operation In which liquid PCBs are present. Safety glasses with side shields will be worn during any operation in which solid PC& are present. If liq- uids or solids containing PC8s contact the eyes, the eyes shall be irrigated immediately with large quantities of water and then be examined by a physician or other fY?SpQnSfble medical personnel. Portable eyewash units will be located at the cleanup site.

"b- 3. Respiratory Protection

-49 Based on the,preliminary laboratory analysis, it has been d&ermined by Industrial Safety that no respiratory protectfon 15' required for excavation and sampling activities. However, respirators must be worn if breakup of the transformer pad is necessary but will be necessary only during that portion of the actfvities. the recon- mended respirator for an outside PC8 spill is a full-face respirator with an acid/gas/organic vapor cartridge with a high-efficiency prefil ter.

3. General Health and Safety

. Facilities for shower baths will be provided for workers exposed to PC8s. After working with PC&, workers will

. shower before changing into street Clothing,

* Workers exposed to PC8s will be advised to wash their hands and exposed skin before eating, drinking, smoking, or using toilet facilities.

. Food, drink, or smoking materials will not be permitted in c areds where PCBs dre handled.

2

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I T o r e d u c e in jur ies, h a r d ha ts wil l b e worn , a n d safe Hofk pract ices wi t1 b e fo l lowed.

II. C L E A N I N G U P S P ILL S ITE

S i n c e the spi i l s i te h a s b e e n secu red , m e n ~ b @ r s of the M IS a n d Techn ica l Depa r tmen ts h a v e taken S O i1 S a m p l e s a n d h a v e r u n ana lyses to d e t e r m i n e the b o u n d a r i e s of con tamina t ion . T h e t rans fo rmer h a s b e e n r e m o v e d a n d the spi l l s i te is n o w r e a d y to b e c l e a n e d up . Spi l l c l e a n u p wil l inc lude, bu t no t necessar i l y b e l imi ted to, the fo l low ing activit ies:

.

. D e v e l o p m e n t of a s c h e d u l e of act ivi t ies l Phys ica l r e m o v a l of con tam ina ted g rave l l T e m p o r a r y cove r i ng of decon tam ina t i on a r e a s * R e m o v a l of t he conc re te t rans fo rmer p a d . Backf i l l ing . . . Decon tam ina t i on of e q u i p m e n t : . S a m p l i n g . Analys is .

C l e a n u p activit fes wfll p r o c e e d as s o o n as poss ib le . A l t h o u g h r ap id c l e a n u p is a key object ive, the ex is tence of fad io log ica I - _ con tamina t ion in con junc t ion wfth P C 3 con tamina t ion h a s d e l a y e d the c l e a n u p activit ies. T h e aer ia l ex tent of t he rad io log ica l con tamina t ion h a d to b e d e t e r m i n e d b e f o r e excava t ion activi t ies cou ld beg in . Howeve r , a n y iso la ted rad io log ica l con tamina t ion wil l b e c l e a n e d u p b e f o r e excava t ion activit ies. A d d d t i o n a l de lays wil l u e caused by avo id i ng c l e a n u p d u r i n g ra iny wea the r , at n ight , o r w h e n w i n d s p e e d is g rea te r t h a n 2 5 m p h . D u r i n g a fdin, con tdmind ted soi l h a s a g rea te r c h a n c e to b e s p r e a d by runof f , e x p a n d i n g the con tami - n $ i e d a rea . In ddd i t Ion , spi l ls a r e diff icult to ident i fy at n igh t O F w h e n the g r o u n d is W e t wi th water , W ind s p e e d s g rea te r t hdn 2 5 n p h increase. the c h a n c e of sofl b e c o m f n g a i r b o r n e d u r i n g c l e a n u p activit ies, s p r e a d i n g con tamina t ion . If t he spi l l c l e a n u p ' IS in p r o g r e s s w h e n d a r k n e s s sets in o r w h e n h i g h w inds o r ra infa l l oc - curs, the d fea that is visibly con tam ina ted wil l b e covered by H e i g h t e d plast ic a n d the c l e a n u p activi t ies de layed . T h e plast ic wilt b e s u r v e y e d by H P p e r s o n n e l a n d If t he plast ic is rad ioact ive ly con tam ina ted it wil l b e b o x e d as m ixed waste . If the plast ic is no, t rad ioact ive ly con tam ina ted it wil l d i s p o s e d of as P C B - c o n t a m i n a t e d waste. -

A . R e m o v a l of C o n t a m i n a t e d G r a v e l

T h e g e n e r a l ru le for r e m o v i n g P C & c o n t a m i n a t e d g rave l is to u s e a hor izon ta l sk imming techn ique , ra the r t h a n a vert ical d i g g i n g tech- n ique . Howeve r , in Spi ' l ' lS wh ich a r e concen t ra ted a r o u n d the b a s e of a conc re te p a d ra the r t h a n those d is t r ibu ted o v e r a b r o a d sur face a rea , d e e p e r d i g g i n g is requ i red . S O i1 sha l l b e r e m o v e d to at least e igh t (8 ) i nches b e l o w t he d e e p e s t s igns of con tan ina ted o i l o r con- tm ina t ion g rea te r t h a n O r e q u a l to ID p p n . the excavat ion ~ 1 1 1

c

3

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also extend laterally at least three (3) feet beyond the area that ' is visibly contaminated. This depth will be achieved through scraping off the first few inches, Ckaning the shovel, scraping of the next few inches, and cleaning Off the Shovel to prevent cross contamination.

1, The following procedure for removing the contaminated gravel will b.e-foTlawed after-o

York Per&it afning a proper excavation and Hazardous

L through th dustrial Safety section. Soil samples will be obtained by NCIS approximately every l-l.5 ft. .

(Irsnk- LLcnw &Lcslsr \J\ C~R..W.&& W& The top 6 inches of gravel on the east side of the transformer

Pad and

shall be removed PCS-contaminated)

and .

boxed as a mixed waste (radioactive

i.:

3.

. These boxes shall be label ed) and radi oactive waste.

ed as both toxic ( PCB-contaminat-

This mixed waste shall be placed on a sheet of Visqueen and stored in a location such that fain, snow, etc., drains away from the storage site; thfs 'location should also have a roof, walls, and d floor to protect the boxes from the weather. The storage area should be well posted and locked if po'ssible. This mixed waste will be stored by WINGI) until its ffnaf disposition is determined. The final storage location must be approved by N&IS. .

. Boxes must be filled to maximum capacity to minimize the number of boxes generated.

.

Boxes must meet N&IS approval and have double liners instal- led before use. Each liner must be sealed after filling.

All equipment used in this portion of cleanup activities will be decontaminated to prevent cross contdmindtion.

The top 6 inches of gravel on the north, west, and south stdes of the transformer pad shall be removed and stockpiled for use as backfftl. This gravel contains radioactivity too high for disposal at the CFA landfill and too low for disposal at the RWMC, This low-level radioactively contaminated soil will be piled north of CPP-613 on plastic sheeting and covered by plastic sheeting until reused. The plastic sheeting will be surveyed by HP personnel and if sheeting is radioactively contaminated it will be stored with the mixed waste. if the plastic jheeting is not radioactively contaminated it will be disposed of as PC&contaminated waste. All equipment used in this portion of cleanup activities will be decontaminated to prevent cross contamination.

The gravel on the east side of the concrete pad between b inches+ and, 18 inches deep sha 11 be removed ana placed in barre 1s as a

.

4 . .

I

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shippable PlcY toxic material. These barrels will be removed 1 from the ICPP within 30 days from the start of cleanup1=\1 &&r>

Thi s gravel will be removed all ow adequate smp\ ing.

using a skimming technique to

* These barrels can be shipped off-site to a hazardous waste landfill provided aIT N&IS Safety Support procedures are met* 14+E g/+-52ncG&~ kzii\ DC t"cLvll*e& bq r+L.wJ

. This soil will be disposed of by Chem-Security System, Inc.

All equipment used in this portion of cleanup activities will be decontaminated to prevent cross contamination.

4. The Soil below 18 inches on the east side of the concrete pad will be removed in l-foot increments and stockplled on Visqueen underlaIn by 12 inch-high berms on all four sides. These 1 ifts wfll be individually segregated on the Visqueen and labeled and sampled by N&IS personnel. These piles ~111 be covered by Visqueen at the end of each work day to prevent water infiltra- tion into the soil below the berm. The Visqueen will be disposed of as PC&contaminated waste. p

c After analysis by the Radiochemistry group, the individual lifts will be disposed of in accordance wfth EPA Regfon 10 _ ’ guidelines:

(10 ppn PCS can be backfilled >lO ppm PCB must be disposed of off-site.

. Disposal methods for the >lO-ppm soil will follow the procedure outlined above for PCB-contaminated soil.

. . ,41

The <IO-ppm soil will be backfi lied acco for radi oact ively cvntami nated soil.

rding to procedures

. All'equi prnent used in this portion of c leanup .activjt will be decant .amina ted to prevent creSs contamination

ies l

5. All soil below 6 inches deep on the north, south, and west sides of the transformer pad contains no significant radtoactivity or PCB and can be considered clean. This soil can be used as back- fill without restrictions.

B. Tempbrary Cover for Decontaminated Areas

At the end of each day when the soil is being removed, the crew will cover the cleaned areas with fresh polyethylene sheets which wiTI be weighted down in place to prevent contamination spread. The polyethylene sheets will be disposed of as PCB waste unless it is determined by HP to be radioactively contaminated. If it is radioactively contaminated the sheets must be stored with the mixed

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waste. Also, the barricading and Warfling nOtiCeS MUSt Femain in ' place so as to restrict public access further and to warn the public of the excavation.

c, Reino~al of Concrete Transformer Pad

The transformer pad will be removed and disposed of as PCB-contaminated waste rather than by cleaning it because the effort involved in a cleanup-would be more expensive than would replacement. Also, cleanup m&y not be sufficient to decontaminate the pad fully.

The transformer pad will be removed from the hole and, depending on size constraints, may be broken up before being transported to an interm storage site selected by ProSects and agreed to by MIS, If it is necessary to break up the pad, a concrete saw or similar equipment will be used for this procedure. Al so, respirators must be worn by all excavation and construction personnel during this activity. A plastic enclosure will be built around the pad before any cutting activities.

The intern storage site must provide weather protection if necessary until the pad is shipped off-site (kithin 30 days) for disposal by Chem-Security Systems, Inc. All equipment used in this phase of the operation must be decontaminated to prevent cross contamination.

0. Restoration of the Site

The excavated soil will be backfilled in the following OFder;

ii: low-level contaminated gravel PCB-contaminated gravel (less than 10 ppm)

C. clean gravel to the level of the surrounding area.

No other site restoration is necessary for this project.

t L. Oecontaminating Equipment

All equipment used during the cleanup, including shovels, wiI1 be wiped down three times with solvent, mineral spirits, or an industrial cleaning agent. Sarbent pads or plastic sheeting will be utilized under any equipment being decontaminated to prevent release of PCB-contarni nated solvents. Such pads and sheeting will be disposed of as PCB waste.

III. SAMPLING

A. Sampling will be performed by N&IS.

General sampling methods are described below.

6

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1, Soil Sampling /

Samples will be collected by skimming the soil surfaie of each lift with a steei trowel or similar implement. The trowel will be wiped clean after each sample is collected. The soil or gravel will be collected by skimming the top 1 cm of surface in a specified N-cm by l&cm ared. This should yield at least 100 g of gravel. If more soil is required for this sample, the area will be expanded without sampling deeper. The samples will be collected in 8-ounce gl'ass jars which have been previously cleaned with Solvents and heated in a muffle furnace at 32U°C for a minimum of 24 hours. All jar tops will be fitted with Teflon liners. The samples will be stored at 4°C and analyzed as soon as possible.

2. Field Blanks

Field blanks will be coliected to demonstrate that the sample collection equipment has not been contaminated, A field blank will be generated by using the sampling equipment to collect a blank sample. The field blank will osti the same sampling technique to collect a soil sample at a non- PCB-contaminated area. w

3. Identification of Samples

Each sample will be assigned a unique identification numb& upon collection. This number shall be traceable to the layer of soil from whjch the sample was collected. In ad- dition, a sample data sheet will be prepared for each sample. This data sheet will describe the location, time of sampling, and other pertinent sample di+a. This data sheet wil.1 also serve as a formal chain-of-custody record and wfll be prepared by N&IS.

IV. ANALYflCAL TECHNlQUES

WINCO labs will perform the necessary analytical techniques as per U.S. Environmental Protection Agency (EPA) Region 10 guidelines for the gds chromatographic method.

A. Summary of Method

The soil will be extracted with acetone in a Soxhlet ex- tractor and the acetone evaporated to low volume* diluted with hexane, and dried over anhydrous sodium sulfate. After the hexane has been reduced in vofume, it 4s passed through , a Florisil gas column to separate the PC& from background . interference. Analysis of the extracts from the column is conducted with a gas chromatoyraph equipped with an electron- capture detector [GC/ECU).

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8. Qudlity Control a

Quplicate blanks and spiked samples will be used as quality control checks. WINCO labs will use a quality contr01

check sample that has been supplied by the EPA Region 10 laboratory. Replicate samples will involve one sample from each batch of 2.0 being analyzed in triplicate. The sample will be divided into three replicate subsamples carried through the analytical procedure. The results of these analyses must be comparable' within the limits required far spiked samples.

c. Quantitatian

At least 10% of all calculations must be checked. The results should be manually checked after any changes in computer quantitation routines.

. 0. Oocumentation and Records

The laboratory is responsible for maintaining compl&e records of the analysis. labbratory notebooks shall be used for handwritten records. Digital or other K/MS data must be archived on magnet'tc tape, disk, or a similar device. hard-copy printouts wfll also be kept by N&IS. Speci fit environmental data shall be retained indefinitely. VA records shall be maintained separately from sample analysis records.

The documentation must completely describe how the analysis was performed. Any variances from a standard protocol must be noted and fully described. Where a procedure lists options (e.g., sample cleanup), the option used and specific conditions (solvent volumes, digestion times, etc.) must be stated.

The ~remaining samples and extracts shall be archived for at least 2 months or until the analysis report is approved {whichever is longer) and then disposed of unless other ar- rangements are made. The naqnetic disks or tapes, hard-copy chromatograms, hard-copy spectra, guantitation reports, work sheets, etc., must be archived for at least 3 years.

E. Reporting Results

Results of all analyses will be reported as microgram of PCB per gram of soil sample and wi'il be reported an a dry bdSiS.

.

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V. SITE INSPECTION J d

Rue to the isolated area in which the PCB spill has occurred and because ft is in a restricted access area, EPA Region 10 will most lfkely not inspect this spill site during cleanup. However, the site will probably be inspected once after the site restoration has been completed. This inspection will most likely be'performed during a routine inspection at the ICPP or at the XNEL. This visit may <involve sampling and independent analysis by EPA labs to ensure that a complete cleanup has been made.

VI. FINAL OOCUMENTATION

Upon completion of the PCB spi 11 cleanup, a final report wfll be prepared by RadJological and Environmental Safety [R&ES) and . Projects. This report should include:

detailed descriptions of the location, approximate time period, and type of PC5 spill, .

a detailed description (including drawings) of the spill si'ce and the boundaries of the spill,

descriptions of how the site was secured and cleaned up,,in- eluding descriptions of all PC&-contaminated materials removed, .

a detailed descriptfon of the mixed waste, including a description of the interim storage facility,

manifests materials

for tranSpOrtatiOn and disposal of PC&contaminated

sampling methods cation samples,

(fncluding drawings) to obtain verifi-

methods of sample analysis and results of the analyses, and

a description of how the site was restored,

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Lockheed Martin Idaho Technologies Company INTERDEPARTMENTAL COMMUNICATION

Date: February 17, I998

To: Roger K. Jones MS 3921 6-8590

From: Dennis E. Raunig MS 3953 6450 1

Subject: DISPOSITION OF AN INVESTIGATMZ DERIVED WASTIZ (IDW) - DER-00 l-98

The purpose of this letter is to document the methodology for disposition of an investigative derived waste (IDW) sample #UDWO300!.

In the pro&s of completing the Investigative Deiived Waste (IDW) disposition project foi WAG 3, analysis for PCBs was required for wastes from site CPP-61. Sample results indicated that the media was not hazardous and not TSCA regulated. However, one sampIe did reveal trace amounts of Pes at concentrations less than the regutatory limit.

Per the requirements, specified in the laboratory master subcontract, the sample was returned to the INEEL. The existing hazardous waste determination for this site (CPP-61) is attached. The determination will be used as the basis to return the sampk to the point of origin, (CPP-61). The sample has been placed in a TAA with a copy of the HWD and will remain there until disposition is

- - completed. The PCJ3 data is also attached as verification that the site is not TSCA regulated.

If you have questions, comments, or concerns please contact Dennis Raunig at 64501.

Approval:

j=

cc: R. Douglas Greenwell, MS 3953 ARDC File, MS 3922 File Code 6105 Dennis E. Ra-unig File

A-21

PESTICIDE O%XNICS &.LYSIS DATA Si?ZET Lab Name: CEIMIC Contract: Lab Code: CEIMIC TOS No.: ER-TOS-743 Matrix: (soil/water) SOIL ' SaInple~wt/vol~ 30.04 kMolsture: 4.81 (g/mu G Zxtraction:

decanted: (Y/N) N. (SepF/Cont/Sonc) SONC

Concentrated Extract Volume: 10000 (uL) In'ection Volume:

E GP Cleanup: ,l,oo WJ) .

(Y/N) N pH: 0.0.0

C96-180374 .Method: PCB8080

Lab Samle ID: Lab Tile ID:PlO

Date Received: 1 Date Extracted: Date Analyzed: 1 Dilution Factor: Sulfur Cleanup:

EPA SAMPLE NO. IDWO3001 1

cqs No: COMPOUND CONCENTRATION UNITS:- - tug/L or us/Kg) UG/KG

SDG No.: 2901 8361-02 103-3DB608317 *o/09/97

12674-11-2 Aroclor-1016 11104-28-2 Aroclor-1221 11141-16-s Aroclor-1232 53469-21-g Aroclor-1242 12672-29-6 Aroclor-1248 11097-69-l Aroclor-1254 11096-82-5 Aroclor-1260

FORM I PEST

. 4

A-22