Health and Safety Plan for the Operable Unit 7-13/14 ... · working on the subsurface investigation activities for the Operable Unit 7-13/14 Project in the Subsurface Disposal Area

Idaho National Engineering and Environmental Laboratory

INEEL/EXT-98-00857Revision 1

May 1999

Health and Safety Plan forthe Operable Unit 7-13/14Subsurface Investigation

Bruce Miller

LOCKHEED MARTIN

INEEL/EXT-98-00857Revision 1

Health and Safety Plan for theOperable Unit 7-13/14 Subsurface

investigation

Published May 1999

Idaho National Engineering and Environmental LaboratoryEnvironmental Restoration Department

Lockheed Martin Idaho Technologies CompanyIdaho Falls, Idaho 83415

Prepared for theU.S. Department of Energy

Assistant Secretary for Environmental ManagementUnder DOE Idaho Operations Office

Contract DE-AC07-941D13223

INEEL/EXT-98-00857Revision 1May 1999

Health and Safety Plan for the Operable Unit 7-13/14Subsurface Investigation

Approved by:

D. K.a----liJorgen , aste and LandfillRestoration Department Manager

J. D. Dus in, Parson I & T Project Manager

0/ate97

(0/io/99

Date

ABSTRACT

This health and safety plan establishes the procedures and requirementsthat will be used to eliminate or minimize health and safety hazards to personsworking on the subsurface investigation activities for the Operable Unit 7-13/14Project in the Subsurface Disposal Area of the Radioactive Waste ManagementComplex , as required by the Occupational Safety and Health AdministrationStandard, 29 Code of Federal Regulations, CFR 1910.120/1926.65, HazardousWaste Operations and Emergency Response. It contains information about thehazards involved in performing the work as well as the specific actions andequipment that will be used to protect personnel while working at the task site.

A safety assessment Unit 7-13/14 subsurface investigation activities isbeing drafted to evaluate potential accident and consequence scenarios.Additionally, an Unreviewed Safety Question Safety Evaluation Screen ofsubsurface investigation activities under the existing Radioactive WasteManagement Complex Safety Analysis Report (LMITCO 1994) is beingprepared. Accordingly, the subsurface investigation activities for the OperableUnit 7-13/14 Project will be performed in accordance with the Radioactive WasteManagement Complex safety authorization basis (safety analysis report) andAddendum (if required)as defined by United States Department of Energy Order5480.23.

The Operable Unit 7-13/14 subsurface investigation tasks addressed bythis health and safety plan will involve transuranic mixed waste. Specializedengineering and work procedures have been developed to isolate sources ofcontamination from personnel performing intrusive activities into the buriedwaste at the Subsurface Disposal Area. In keeping with defense in depthstrategies, "glove bae type confinement will be used to insert/remove itemsfrom the drill string enclosure personnel will initially wear Level B protectiveequipment during corehole sampling and instrument installation tasks.

Continuous monitoring of the Operable Unit 7-13/14 subsurfaceinvestigation work environment will be conducted for radiological andnonradiological contaminants. Specific action levels for both types ofcontaminants have been established. If monitoring indicates action levels havebeen exceeded, work will be stopped and additional controls will beimplemented.

Finally, emergency response planning and actions are described forvarious contingencies during the Operable Unit 7-13/14 subsurface investigationactivities. Both project site and offsite emergency situations are discussed.

iii

iv

CONTENTS

ABSTRACT

ACKNOWLEDGMENTS

ACRONYMS

iii

xi

1. INTRODUCTION 1-1

1.1 INEEL Site Description 1-1

1.2 RWMC Site Description 1-1

1.3 OU 7-13/14 Task Site Description 1-1

1.4 Scope of Work 1-1

1.4.1 OU 7-10 Drilling Lessons Leamed 1-11.4.2 Site Preparation and Premobilization 1-11.4.3 OU 7-13/14 Subsurface Investigation Project Site Mobilization 1-11.4.4 Installation of Cased Probeholes 1-11.4.5 Geophysical and Radiological Probehole Logging 1-11.4.6 Sonic Core Drilling and Sampling 1-1

1.5 General Project Information 1-1

2. PROJECT MANAGEMENT RESPONSIBILITIES 2-1

2.1 Task Site Responsibilities 2-1

2.1.1 Parsons Construction Engineer 2-12.1.2 Field Team Leader 2-22.1.3 Health and Safety Officer 2-22.1.4 Environmental Coordinator 2-32.1.5 Quality Engineer 2-32.1.6 Job-site Supervisor 2-32.1.7 Subcontractor Job-site Supervisor 2-32.1.8 Radiological Control Technician 2-32.1.9 Radiological Engineer 2-32.1.10 Industrial Hygienist 2-32.1.11 Fire Protection Engineer 2-42.1.12 Safety Engineer 2-42.1.13 Field Team Members 2-42.1.14 Non-Field Team Members 2-52.1.15 Visitors 2-5

2.2 ER Management Responsibilities 2-6

2.2.1 Environmental Restoration Director 2-62.2.2 ER ESH&QA Manager 2-7

2.2.3 ER Quality Assurance Compliance Officer 2.2.4 LMITCO WAG-7 Project Manager 2.2.5 LMITCO OU 7-13/14 Remedial Investigation Project Manager 2.2.6 Parsons Project Manager 2.2.7 Parsons Construction Manager

2-72-72-82-92-9

3. RECORD KEEPING REQUIREMENTS 3-1

3.1 Industrial Hygiene and Radiological Monitoring Records 3-1

3.2 FTL Logbook and Site Attendance Logbook 3-1

3.3 Administrative Record and Document Control Office 3-1

4. PERSONNEL TRAINING 4-1

4.1 Support Zone Personnel Access 4-2

4.2 Subsurface Investigation Exclusion Area Access 4-2

5. OCCUPATIONAL MEDICAL SURVEILLANCE PROGRAM 5-1

5.1 Subcontractor Workers 5-2

5.2 Injuries on the Task Site 5-2

5.3 Substance-Specific Medical Surveillance 5-3

6. ACCIDENT PREVENTION PROGRAM 6-1

6.1 Voluntary Protection Program 6-1

6.2 General Safe-Work Practices 6-1

6.3 ALARA Principles 6-3

6.3.1 External Radiation Dose Reduction 6-36.3.2 Internal Radiation Dose Reduction. 6-4

6.4 Nonradiological Contaminant Exposure Avoidance 6-5

6.5 The Buddy System 6-6

7. SITE CONTROL AND SECURITY 7-1

7.1 Exclusion Zone 7-4

7.2 Contamination Reduction Zone and Corridor 7-5

7.3 Support Zone 7-6

7.4 Designated Eating and Smoking Area 7-6

vi

8. HAZARD ASSESSMENT 8-1

8.1 Cold Test Activities 8-1

8.2 OU 7-13/14 Site Activities 8-1

8.3 Routes of Exposure 8-2

8.4 Environmental and Personnel Monitoring 8-22

8.4.1 Industrial Hygiene Monitoring 8-228.4.2 Radiological Monitoring 8-248.4.3 RADCON Engineer/IH Exposure Assessments 8-27

8.5 Phys cal Hazards Evaluation, Control, and Monitoring 8-30

8.5.1 Temperature Extremes 8-308.5.2 Noise 8-338.5.3 Fire, Explosion, and Reactive Materials Hazards 8-348.5.4 Biological Hazards 8-368.5.5 Confined Spaces 8-368.5.6 Safety Hazards 8-378.5.7 Inclement Weather Conditions 8-39

8.6 Other Task Site Hazards 8-39

9. PERSONAL PROTECTIVE EQUIPMENT 9-1

9.1 Respiratory Protection 9-1

9.2 Personal Protective Equipment Levels 9-3

9.2.1 Level D Personal Protective Equipment 9-69.2.2 Level C Personal Protective Equipment 9-79.2.3 Level B Personal Protective Equipment 9-79.2.4 Level A Personal Protective Equipment 9-8

9.3 Protective Clothing Upgrading and Downgrading 9-9

9.4 Inspection of PPE 9-10

10. DECONTAMINATION PROCEDURES 10-1

10.1 Contamination Control and Prevention 10-1

10.2 Personnel and Equipment Decontamination 10-2

10.2.1 Personnel Decontamination 10-210.2.2 Decontamination in Medical Emergencies 10-410.2.3 Equipment Decontamination 10-4

vii

10.3 Doffing PPE and Decontamination 10-6

10.3.1 Level B and C PPE Decontamination (Transition tent area) 10-710.3.2 Personnel Radiological Contamination Monitoring 10-9

10.4 Disposal of Contaminated PPE and Equipment 10-10

10.4.1 Storage and Disposal of Contaminated Materials 10-1010.4.2 Site Sanitation and Waste Minimization 10-10

11. EMERGENCY RESPONSE PLAN FOR THE OU 7-13/14 Subsurface InvestigationTASK SITE 11-1

11.1 Pre-event Planning and Drills 11-1

11.1.1 OU 7-13/14 Subsurface Investigation Project Site Events(Notification Only) 11-2

11.1.2 OU 7-13/14 Subsurface Investigation Project Site Events (INEEL EmergencyResponse Organization Required) 11-3

11.1.3 OU 7-13/14 Subsurface Investigation Project Site Events (OU 7-13/14Project Site Evacuation Required) 11-4

11.1.4 Spills 11-511.1.5 Emergency Drills 11-6

11.2 Emergency Recognition and Prevention 11-6

11.3 Emergency Facilities and Equipment 11-6

11.4 Personnel Roles, Lines of Authority, and Communication 11-7

11.4.1 Project Personnel 11-911.4.2 Construction Engineer 11-911.4.3 RWMC Emergency Coordinator 11-911.4.4 Emergency Communications 11-1011.4.5 Notifications 11-10

11.5 INEEL Alarms and Responses 11-12

11.5.1 Take Cover 11-1211.5.2 Total Area Evacuation I 1-13

11.6 Evacuation Routes and Procedures 11-13

11.7 Reentry and Recovery 11-14

11.7.1 Reentry 11-1411.7.2 Recovery 11-17

11.8 Critique of Response and Follow-up 11-17

V I

11.9 Telephone/Radio Contact Reference List for OU 7-13/14 SubsurfaceInvestigation Project 11-18

12. REFERENCES 12-1

Appendix A—OU 7-13/14 Subsurface Investigation Health and Safety Plan Training Acknowledgment

Appendix B—HAZWOPER 24 Hour Supervised Field Experience Acknowledgment Form

FIGURES

1-1. Map of the INEEL Site 1-1

1-2. Map of the SDA (Pits 4, 6, & 10) at the RWMC 1-1

1-3. Drill string enclosure on drill rig 1-1

2-1. Field organization chart for OU 7-13/14 project 2-2

2-2. High-level organizational chart, OU 7-13/14 project 2-6

7-1. General work zones for the OU 7-13/14 subsurface investigation project site 7-2

7-2. A generalized Radiological Control Area configuration for OU 7-13/14 project task sites 7-3

10-1. A generalized Radiological Control Area configuration for OU 7-13/14 project task sites 10-9

11-1. Incident Command System functions 11-9

11-2. WMC SDA evacuation routes, take cover locations, and RWMC assembly areas 11-15

11-3. Route to the CFA Medical Facility (Building 1612) from RWMC 11-16

TABLES

1-1. Specifications for selected Pits 1-1

1-2. Activity for Pits 4, 6, and 10 radiological inventory 1-1

4-1. Required training for OU 7-13/14 subsurface investigation project site personnel 4-3

8-1. Pits 4, 6, and 10 activities and associated hazards 8-3

8-2. Dominant radiological contaminants of concem at the Pits 4, 6, and 10 project site 8-6

8-3. Dominant nonradiological contaminants of concem at the Pits 4, 6, and 10 project site 8-7

8-4. Evaluation of radiological and nonradiological contaminants at the Pits 4, 6, and 10project site 8-9

8-5. Pits 4, 6, and 10 radiological and nonradiological hazards to be monitored 8-23

ix

8-6. Equipment to be used for monitoring radiological and nonradiological hazards 8-25

8-7. Action levels and associated responses for OU 7-13/14 subsurface investigation projecthazards 8-28

8-8. Heat stress signs and symptoms 8-31

9-1. Respiratory and protective clothing selection 9-2

9-2. OU 7-13/14 subsurface investigation project task-based PPE requirements andmodifications 9-4

9-3. Assigned respiratory protect on factors 9-6

9-4. PPE inspection checklist 9-10

11-1. Emergency response equipment to be maintained at the OU 7-13/14 subsurfaceinvestigation project site 11-7

11-2. Responsibilities during a OU 7-13/14 project event or RWMC/INEEL emergency 11-8

11-3. OU 7-13/14 project internal and backup emergency signals 11-11

11-4. OU 7-13/14 project emergency contact list 11-19

11-5. OU 7-13/14 project notification responsibilities 11-20

Y.

ACRONYMS

ACGIH American Conference of Government Industrial Hygienists

AL action level

ALARA as low as reasonably achievable

ANL-W Argonne National Lab — West

ANSI American National Standards Institute

anti-C anticontamination

APF assigned protection factor

APR air-purifying respirators

ARDC Administrative Record and Document Control

ASAP Abbreviated Sampling and Analysis Plan

bls below land surface

CA contamination area

CAM constant air monitor

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CE construction engineer

CFA Central Facilities Area

CFR Code of Federal Regulations

CFM cubic feet per minute

CM construction manager

COCA Consent Order and Compliance Agreement

COPC contaminants of potential concerns

CP command post

CRC contamination reduction corridor

CRZ contamination reduction zone

DAR Data Analysis Report

xi

D&D decontamination and dismantlement

dBA decibel A-weighted

DC document control

DOE Department of Energy

DOE-ID DOE Idaho Operations Office

DOT Department of Transportation

DSE drill string enclosure

EAM emergency action manager

EC emergency coordinator

ECC Emergency Communications Center

EDF Engineering Design File

EDTA ethylenediaminetetracetic acid

EM electromagnetic

EO Environmental Operations

EOC Emergency Operation Center

EPA United States Environmental Protection Agency

ER environmental restoration

ERO Emergency Response Organization

ERP Environmental Restoration Plan

ES&H environmental, safety, and health

EWP enhanced work planning

EZ exclusion zone

FFA/CO Federal Facility Agreement and Compliance Order

FPE Fire Protection Engineer

FR Federal Register

FS feasibility study

xii

FTL field team leader

FUM Facilities, Utilities, and Maintenance

FY fiscal year

HASP Health and Safety Plan

HAZMAT hazardous materials

HAZWOPER Hazardous Waste Operations and Emergency Response

HEG homogeneous exposure group

HEPA high-efficiency particulate air (filter)

HPGe high-purity germanium

HSO health and safety officer

ICPP Idaho Chemical Processing Plant

ICS Incident Command System

i.d. inside diameter

IDHW State of Idaho Department of Health and Welfare

IDLH immediately dangerous to life and health

IDW Investigation Derived Waste

IH industrial hygienist

INEEL Idaho National Engineering and Environmental Laboratory

INTEC Idaho Nuclear Technology and Engineering Center (previously ICPP)

IRA interim remedial action

JSA Job Safety Analysis

JSS job-site supervisor

LEL lower explosive limit

LLW low-level waste

LLRW low-level radioactive waste •

LMITCO Lockheed Martin Idaho Technologies Company

MAP mixed activation product

MCP management control procedure

MFP mixed fission product

MORT Management Oversight and Risk Tree

MSDS Material Safety Data Sheet

NEPA National Environmental Policy Act

NIOSH National Institute of Occupational Safety & Health

NPL National Priorities List

NRTS National Reactor Testing Station

OMP Occupational Medical Program

OSHA Occupational Safety and Health Administration

OU operating unit

Parsons Parsons Infrastructure and Technologies Group, Inc.

PCM personal contamination monitor

PEL pennissible exposure limit

PHA preliminary hazards assessment

PID photoionization detector

PM project manager

POD plan-of-the-day

PPE personal protective equipment

PRD Program Requirements Directive

PVA polyvinyl alcohol

QA/QC Quality Assurance/Quality Control

QAPjP Quality Assurance Project Plan

QPP Quality Program Plan

xiv

RADCON Radiological Control

RAM remote area monitor

RBA radiological buffer area

RCIMS Radiological Control Information Management Systems

RCRA Resource Conservation and Recovery Act

RCT radiological control technician

RD/RA Remedial Design/Remedial Action

REM roentgen equivalent man

RFP Rocky Flats Plant

RI remedial investigation

RMA radioactive material area

ROD Record of Decision

RWMC Radioactive Waste Management Complex

RWMIS Radioactive Waste Management Information System

RWP radiological work permit

SAP Sample Analysis Plan

SAR supplied air respirator

SCBA self-contained breathing apparatus

SDA Subsurface Disposal Area

SE safety engineer

SIA Staged Interim Action

S&H safety and health

SRPA Snake Rive Plain Aquifer

SS shift supervisor

SWP Safe Work Permit

SZ support zone

xv

TAN Test Area North

TLD thermoluminescent dosimeter

TLV threshold-limit value

TPR technical procedure requirement

TRA Test Reactor Area

TRU transuranic

TSA Transuranic Storage Area

TWP Transuranic Waste Program

USCG United States Coast Guard

USQ Unreviewed Safety Question

VOC volatile organic compound

VPP Voluntary Protection Program

WAC Waste Acceptance Criteria

WAG Waste Area Group

WCC Warning Communication Center

WERF Waste Experimental Reduction Facility

xvi

Health and Safety Plan for the Operable Unit 7-13/14Subsurface Investigation

1. INTRODUCTION

This health and safety plan (HASP) establishes the procedures and requirements that will be usedto eliminate or minimize health and safety hazards to persons working on the subsurface investigationactivities for the OU 7-13/14 Project in the Subsurface Disposal Area (SDA) at the Radioactive WasteManagement Complex (RWMC). This HASP meets the requirements of the Occupational Safety andHealth Administration (OSHA) standard, 29 Code of Federal Regulations (CFR) 1910.120/1926.65,"Hazardous Waste Operations and Emergency Response (HAZWOPER)." Its preparation is consistentwith information found in the National Institute of Occupational Safety and Health(NIOSH)/OSHA/United States Coast Guard (USCG)/Environmental Protection Agency (EPA)Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (NIOSH 1985);Lockheed Martin Idaho Technologies Company (LMITCO) Safety and Health Manuals; the IdahoNational Engineering and Environmental Laboratory (INEEL) Emergency Plan/Resource Conservationand Recovery Act (RCRA) Contingency Plan; and LMITCO Radiological Control and RadiologicalControl Manuals. OU 7-13/14 project activities addressed in this HASP will be evaluated by a SafetyAssessment and an Unreviewed Safety Question (USQ) Safety Evaluation Screen to the RWMC SafetyAnalysis Report. Accordingly, the subsurface investigation activities will be performed in accordancewith the RWMC safety authorization basis (Safety Analysis Report) and any required addendum asdefined by the United States Department of Energy Order 5480.23.

This HASP governs all work performed at the OU 7-13/14 Project subsurface investigation tasksites that are performed by employees of LMITCO and Parsons Infrastructure and Technology Group,Inc. (Parsons), subcontractors to LMITCO and Parsons, and personnel of other companies or Departmentof Energy (DOE) laboratories. This HASP is prepared in accordance with MCP-255, "Preparation ofTask-Specific Health and Safety and Limited Scope and Hazard Characterization Plans," reviewedaccording to MCP-240, "Internal/Independent Review of Documents," and revised according to MCP-230, "Environmental Restoration Document Control Center Interface." Participants include the OU 7-13/14 Project health and safety officer (HSO) in conjunction with the field team leader (FTL), theconstruction engineer (CE), and necessary Environmental Restoration (ER) and RWMC environmental,safety, health, and quality professionals to ensure the effectiveness and suitability of this OU 7-13/14subsurface investigation HASP.

1.1 INEEL Site Description

The Idaho National Engineering and Environmental Laboratory (INEEL), formerly the NationalReactor Testing Station (NRTS), encompasses 2,305 km2 (890 mi2), and is located approximately 58 km(34 mi) west of Idaho Falls, Idaho (see Figure 1-1).

The United States Atomic Energy Commission, now the DOE, established the NRTS (INEEL) in1949 as a site for building and testing a variety of nuclear facilities. The INEEL has also been the storage

1-1

To

A rco

RWMC

\ To Selman

How Idaho 33

'Big LostRiver

NRF

ARVFS

Fire Training Experimental& NOAA Facility Fiala Station

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ANL-WARAARWSBORAXCFAEBR4INTECErLADE'MWSFNOTFNRFPBFRWMCSPFRTSTFTANTRAwERFWRRTF

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Argotvic Navonal Laaxaory-WestAuxiliary Res= ArtaArmy Reran Vanua Facility SIXBoding Wax Reamx &pram=Central Nokias ArcaEwer:roma Bread& Reactor-ILava) Nuclear Technoloyp & Engineering Casainitial Eng= TestLoss-of-Etna-Tex FaultyMiura waste Samar FaalayNaval Priam. Tau F acilayNava Reactor FanlayPower Bunt hoaryRachman< Wasie MniaNameritCompleaSpinal Power amnion Reactor TatSeamy Training FacilityTot Arca NorthTest Reactor ArtaWale Experimental Reduction FacilityWater Rain& RaseanhT est Facilay

ARA

Atomic City

4

LEGEND

abets

RRTF

INEEL

ANL -VNk:61

To Blackfoot

Roads

— Streams and Rivers

Railroads

'NEEL Boundary

Cilies

[NEEL Fasilities

net, Lake

To Rax burg

Tu Mello Fens

5 10 Miles

Dale Drawn; Sepumber 09, 199B

(Nmpcutineelflocafion_maps: me tharchilight_rwmmaplivit aml )

Figure 1-1. Map of the LNEEL Site.

1-2

facility for transuranic (TRU) radionuclides and low-level radioactive waste (LLRW) since 1952. Atpresent, the INEEL supports the engineering and operations efforts of DOE and other federal agencies inareas of nuclear safety research, reactor development, reactor operations and training, nuclear defensematerials production, waste management technology development, and energy technology andconservation programs. The DOE Idaho Operations Office (DOE-ID) has responsibility for the INEEL,and designates authority to operate the INEEL to govemment contractors. LMITCO, the current primarycontractor for DOE-ID at the INEEL, provides managing and operating services to the majority of INEELfacilities.

A Consent Order and Compliance Agreement (COCA) was entered into between DOE and theEPA pursuant to the Resource Conservation and Recovery Act (RCRA) Section 3008(h) in August 1987.The COCA required DOE to conduct an initial assessment and screening of all solid waste and/orhazardous waste disposal units at the INEEL and set up a process for conducting any necessary correctiveactions. On July 14, 1989, the INEEL was proposed for listing on the National Priorities List (NPL)(54 Federal Register [FR] 29820). The listing was proposed by the EPA, under the authorities granted tothe EPA by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of1980 as amended by the Superfund Amendments and Reauthorization Act of 1986. The final rule thatlisted the INEEL on the NPL was published on November 21, 1989, in 54 FR 44184. As a result ofhaving the INEEL on the NPL list, DOE, EPA, and the Idaho Department of Health and Welfare (IDHW)entered into the Federal Facility Agreement and Consent Order (FFA/CO) on December 9, 1991.

Under the FFA/CO, the INEEL is divided into 10 waste area groups (WAGs). The WAGs arefurther subdivided into operable units (OUs). The RWMC has been designated WAG 7 and consists of14 OUs. OU 7-13/14 is the combined scope and schedule for the OU 7-13 transuranic pits and trenchesremedial investigation/feasibility study (RI/FS) and the OU 7-14 comprehensive RI/FS for WAG 7.OU 7-13 does not include the OU 7-10 Staged Interim Action (SIA) Project (i.e., Pit 9), which is aseparate task. Most of the subsurface investigation tasks performed for the two OUs will be similar, andseveral procedures will be generated that are applicable to both OUs.

1.2 RWMC Site Description

The RWMC was established in the early 1950s as a disposal site for solid, low-level waste (LLW)generated by INEEL operations. The RWMC is located in the southwestern portion of the INEEL asshown in Figure 1-1. Within the RWMC is the SDA (35.6-ha [88-acre]) where radioactive wastematerials have been buried in underground pits, trenches, soil vault rows, one aboveground pad (Pad A),and the TSA where interim storage TRU waste is in containers on asphalt pads. TRU waste was disposedin the SDA from 1952 to 1970. Rocky Flats Plant (RFP) TRU waste was received for disposal in theSDA from 1954 through 1970. The RFP is a DOE-owned facility located west of Denver, Colorado thatwas used primarily for the production of components for nuclear weapons.

Subsurface monitoring at the RWMC, to determine if radionuclides or other hazards contaminantshad migrated into the subsurface, began in the early 1970s and is cun•ently ongoing. Analytical resultsindicate that minute amounts of manmade radionuclides have migrated from the SDA toward the SnakeRiver Plain Aquifer (SRPA). An independent review of all analytical data from core drilling in the basaltbelow the SDA supports the conclusion that Am-241, Co-60, Pu-238, Pu-239, and Pu-240 are present inthe clay/soil interbed sediments 33.5 m (110 ft) below the surface. The results of the data analyses do notsupport the presence of manmade radioisotopes neither in the discontinuous interbed at 9.1 m (30 ft)below ground level nor the clay/soil interbed sediments at 73.2m (240 ft) below ground level(DOE-ID 1993).

1-3

The major studies used to develop the RI/FS rationale for WAG 7 are summarized in the WorkPlan (Becker et al. 1996). A description of each OU within WAG 7 includes a summary of the FFA/COassessments (DOE-ID 1991) using Track 1, Track 2, RI/FS, and interim action methodologies. TheWAG 7 data gaps and their associated resolutions are also tabulated. Historical investigations also arereferenced and summarized in the IRA report (Becker et al. 1998a).

1.3 OU 7-13/14 Task Site Description

The Addendum to the WAG 7 Comprehensive RI/FS Work Plan (DOE-ID 1998) selected earthenwaste disposal Pits 4 and 10 as the principle locations for installing and logging cased probeholes,collecting core samples, and installing downhole monitoring instruments (see Figure 1-2). Based oninventory record reports, shipping manifests, and disposal records these are the most probable locations ofCOPCs associated with Rocky Flats waste and sludge (DOE-ID 1998). Pit 6 was chosen as an alternativelocation for these activities. Therefore, this HASP includes Pit 6 as one of the OU 7-13/14 subsurfaceinvestigation task sites even though Pit 6 may not be investigated. In addition, Pit 6 was also selected forboth stabilization and ISV in situ treatability studies that are to be covered under a separate HASP.

Historical records and the average surface elevation inside the SDA of 5,010 ft were used toestimate the depths to basalt for the SDA. The depths to basalt inside Pits 4, 6, and 10 were estimated torange from 10 to more than 18 ft (DOE-ID 1998). The periods of operation, surface areas, volumes, andapproximate depth to the basalt for the selected pits are given in Table 1-1. Because of the wide potentialrange of depths to basalt and the depth limitations of some of the potential treatability study altematives, aseismic survey will be conducted after the initial corehole siting to validate depth-to-basalt information.The survey will be used in conjunction with any drilling to determine depths to basalt. If the depthsderived from the drilling and the refraction survey differ significantly from the historical records, thedrilling and survey depths will be used because they have been verified by two techniques.

Initially, each pit was excavated to the basalt bedrock, and approximately 1.1 m (3.5 ft) of soil wasplaced on the bedrock before the waste was placed into the pit. While these pits were operational, drumsand boxes were generally dumped in the pits by truck or bulldozer and large items were placed in bycrane. Soil cover was applied over the waste after daily or weekly operations, depending on the requiredprocedures at the time of disposal. After the waste was placed in a pit, the pit was backfilled with anotherlayer of soil. It is believed that, approximately 1.8 m (6 ft) of clean soil overburden is located on top ofthe buried waste.

The inventory of contaminants in these pits is based on available shipping records, processknowledge, written correspondence, and the Radioactive Waste Management Information System(RWMIS). The east end of Pit 4 has the highest organic vapor concentrations based on soil gas surveydata (EG&G 1992). A review of the shipping records indicates over 10 shipments to the east end of Pit 4with a total of 600 drums of 740 series RFP sludge disposed there. Pit 6 also received 740 series RFPsludge.

Pit 10 documentation contains the most inclusive shipping records of the selected pits. The recordsindicate that approximately 500 drums containing 740 series sludge from RFP were shipped between9/18/68 and 10/18/68. The burial location of these 740 series drums in Pit 10 also corresponds to thelowest area of soil gas concentrations in the pit. Pit 10 was selected as the ideal pit for these activitiesbecause of the potential presence of first 741 and second 742 stage sludges from RFP. Records indicatethat only about 12% of the total sludge shipped contained 743 sludges. Pit 10 also received twoshipments containing over 5 tons (i.e., 1.6 Ci) of depleted uranium. Two co-located shipments of Pu/Am,both with high Pu content and a high density for the Pu disposed (Ci/total volume), are located in Pit 10.

1-4

Roads and Buildings

Railroad Tracks

)C X Fences

Pils

0 200 400 600 800 1000 FeetDate Drawn: November 03.1998

sprojecatomokis_e_eiaseatat ada_pitsup-el_vissa0

Figure 1-2. Map of the SDA (Pits 4, 6, & 10) at the RWMC.

Table 1-1. Specifications for selected Pits.

Pit Period of Operation*Surface Area'

(ft')volume

(ft')

Depth (ft ) to Basalt(Approximate)]

4 January 1963-September 1967 111,732 1,581,284 10 to 18

6 May 1967-October 1968 54,984 780,773 10 to 18

10 June 1968-July 1971 111,732 1,586,594 10 to 18

a. (Becker et aI. 1998a)

Shipping records indicate a total of 58,954 g (130 lb) of Pu (i.e., 3,661 Ci) and 5,072 g (11 lb) of Am (i.e.,17,280 Ci) disposed in Pit 10.

The TRU radionuclides plutonium (Pu)-238, Pu-239, Pu-240, Pu-241, americium (Am)-241, andneptunium (Np)-237 compose 99.9% of the radioactivity originally buried in Pits 4, 6, and 10. Alsopresent are the following uranium (U) and thorium (Th) isotopes: U-234, U-235, U-236, U-238, andTh-234. Other categories of radionuclides in pits are mixed activation products (MAPs) and mixedfission products (MFPs). Cobalt (Co)-60 is the MAP of concem and barium (Ba)-137, cesium (Cs)-137,strontium (Sr)-90, and yttrium (Y)-90 are the MFPs of concern. A summary of the radiological inventoryis listed on Table 1-2 and discussed further in the Hazard Assessment (Section 8). This inventory is notdecay corrected.

Table 1-2. Activity for Pits 4, 6, and 10 radiological inventory.'

Isotope

EstimatedActivity in

Pit 4(Ci)

CorrespondingMass

(g)


Pit 6(Ci)

Correspond ngMass

(g)


Pit 10(Ci)

CorrespondingMass

(g)U-234 3.18E-00 5.14E+02 1.31E-00 2.12E+04 6.17E-00 9.97E+02

U-235 4.99E-01 2.33E+05 7.32E-02 3.42E+04 4.44E-01 2.07E+05

U-238 6.47E-00 1.94E+07 2.94E-00 8.83E+06 8.44E-00 2.53E+07

Pu-238 4.33E+02 2.51E+01 4.74E+01 2.59E+00 1.75E+02 1.02E+01

Pu-239 9.51E+03 1.52E+05 1.58E+03 2.53E+04 5.69E+03 9.10E+04

Pu-240 2.19E+03 9.46E+03 3.53E+02 1.55E+03 1.27E+03 5.59E+03

Pu-241 5.72E+04 5.72E+02 9.53E+03 9.53E+01 3.49E+04 3.49E+02

Pu-242 1.31E-02 3.33E+00 2.14E-02 5.43E+00 7.68E-02 1.95E+01

Am-241 2.2E+04 6.39E+03 3.66E+03 1.06E+03 1.33E+04 3.86E+03

Np-237 1.31E-01 1.86E+02 1.38E-02 1.96E+01 1.76E-01 2.49E+02

Co-60 1.25E+05 1.10E+02 3.42E+04 3.02E+01 2.25E+05 1.99E+02

Cs-137 (MAP)b 2.8E+04 3.24E+02 5.93E+03 6.85E+01 3.98E+04 4.60E+02

Sr-90 (MFP)` I .7E+04 1.22E+02 5.52E+03 3.97E+01 1.84E+04 1.32E+02

Y-90 (MFP)c 1.13E+03 2.08E-03 1.23E+03 2.26E-03 4.37E+03 8.04E-03

a. Bruce Becker 1998 correspondence. This inventory is not decay corrected.

b. MAP = mixed activation products.

c. MFP = mixed fission products.

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Sludge drums buried in Pits 4, 6, and 10 contributed organic (e.g., carbon tetrachloride) andinorganic compounds to their contents. A summary of organic and inorganic constituents is listed inTable 8-3 and discussed further in Section 8. This information on waste constituents describes the natureof the waste when it was buried in Pits 4, 6, and 10. No account is made for any damage or deteriorationof the waste containers and their contents, decomposition of organic material, or mixing of containercontents that may have occurred after the pits were closed.

1.4 Scope of Work

The OU 7-13/14 subsurface investigation activities will be performed to obtain material foranalyses to fulfill WAG 7 RI/FS data gaps addressed in the Work Plan (Becker et al. 1996) and obtainmaterial for ex situ and in situ grouting bench-scale tests. Several activities will be completed during thisportion of this project. Principal activities at Pits 4 and 10 include:

• site preparation and mobilization,

• soil gas surveys,

• surface geophysical mapping,

• probehole installation,

• downhole logging,

• core sampling, packaging and shipping samples,

• installation of monitoring instruments, and

• decontamination (as required).

In the event the subsurface investigation activities cannot be performed or sufficient probeholelogging data or material for analysis cannot be obtained, the activities will be performed at Pit 6 asneeded.

There are five target areas of interest, two in Pit 4 and three in Pit 10. Information from soil gassurveys and surface geophysical mapping of Pits 4 and 10 will be used to determine the final probeholelocations. Soil gas surveys will be conducted to identify areas of elevated organic vapor concentrations inthe overburden soils. Surface geophysical mapping will be conducted to determine waste zoneboundaries and to distinguish large discrete objects and collections of smaller objects within individualtarget waste zones. A maxinium of 70 probeholes will be installing in targeted waste zones in Pits 4 and10 as described in the Probehole Plan (Becker et al. 1999). Downhole logging activities include gammalogs and radiological profiles that will be used to site the core sample locations. As stated previously, Pit6 will only be investigated if deemed necessary. Locations for drilling the coreholes will be selectedbased on the results of the logging activities. The Field Sampling Plan for the coreholes is to beaddressed in (Holdren et al. 1999).

The same drill rig, remote control trailer, drilling materials, and personnel (to the extent possible)used at the OU 7-10 SIA Project, Stage I site are anticipated to be used for the OU 7-13/14 subsurfaceinvestigation activities. The drill rig and support equipment is planned for mobilization to the OU 7-13/14 site following conclusion of the OU 7-10 SIA Project, Stage I activities.

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All OU 7-13/14 subsurface investigation activities will be conducted in accordance with PLN-494,"General Procedures for Subsurface Investigation Operations at Pits 4 and 10". The RWMC and the OU7-13/14 Project will establish an interface agreement or modify the existing OU 7-10 SIA Projectinterface agreement (LIMITCO 1998). This interface agreement will delineate OU 7-1314/RWMC rolesand responsibilities for project activities.

1.4.1 OU 7-10 Drilling Lessons Learned

Before mobilizing the drilling apparatus to the OU 7-13/14 subsurface investigation site, lessonslearned from Sage I of the OU 7-10 SIA Project will be reviewed. This will provide valuable informationwhere improvements can be made in the engineering controls and work procedures. Technicalmodifications and lessons learned will be solicited from all participants, evaluated, and the resultantrecommendations incorporated into procedures, equipment design, and operation parameters for theOU 7-13/14 subsurface investigation activities.

1.4.2 Site Preparation and Mobilization

Before project personnel initiate mobilization activities, they will all receive project-specifictraining as described in Section 4. Training requirements will be based on the nature of work to beperformed and location of this work (required zone access). In addition, all personnel performing workinside the exclusion zone (EZ) will be required to meet the internal dosimetry requirements identified inSection 5. All site preparation and mobilization tasks at the OU 7-13/14 subsurface investigation site willbe conducted in accordance with TPR-178, "OU 7-13/14 Site Preparatioe.

Mobilization of equipment will consist of moving the drill rig, control trailer, crane and drillingsupport materials to the OU 7-13/14 project site. The only intrusive tasks that will occur during sitepreparation and mobilization will be to anchor trailers an secure the geomembrane over the exclusionzone of the effected Pit. The geomembrane serves as an all-weather working surface and a barrierbetween the overburden soil and all equipment and personnel. It also, provides a solid surface to collectradiological contamination swipes and conduct surveys. Site boundaries or "zones" will be established toensure that project and nonproject personnel are aware of restricted and potential hazard areas. Section 7describes these zones in detail. OU 7-13/14 subsurface investigation personnel will enter the RWMCthrough existing main gates (by main guard gate WMF-637). Access and egress from the specific projectsite EZ will be through the RADCON trailer and specified entry control points.

The RADCON trailer will be located in a radiologically and chemically "clean" area (within theSDA) adjacent to the OU 7-13/14 subsurface investigation task site area. An outage request/excavationpermit will be obtained from the RWMC outage coordinator if project trailer(s) are placed and anchoredin the support zone (SZ, Figure 7-1), prior to driving any anchors. Trailers serve as a project meetingarea, radiological survey station (when exiting contamination reduction corridor), instrumentstorage/calibration area, and personnel clothing change area. These trailer(s) include mobilecommunication equipment such as hand-held radios and cellular phones and may include a landline phone(if installed). The RWMC-657 trailer will equipped with other administrative support equipment forsubsurface investigation activities. All work will be conducted in accordance with RWMC work controlprocesses.

Electrical power will be needed at the OU 7-13/14 subsurface investigation site. Any interruptionof existing facilities or electrical services will be arranged with RWMC management, powermanagement, or other applicable personnel and organizations. Additional service activities will include,as needed, modifying existing roadways, ditches, electrical transmission lines and hookups, fencing, andculverts to permit personnel and equipment access through the RWMC to the OU 7-13/14 subsurface

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investigation site. All changes to existing drainage systems and roadways will be coordinated through theRWMC, and appropriate changes made to existing LMITCO and RWMC environmental plans (e.g.,RWMC Storm Water Plan). A permanent fire protection system will not be required for OU 7-13/14subsurface investigation activities. Fire protection resources and water will be supplied for probehole andcoring activities with mobile equipment. The project fire protection engineer will assess the need foradditional fire protection resources. The nearest source of extinguishing water (fire hydrant DM-04) islocated outside the SDA, approximately 30 m (100 ft) southeast of the OU 7-10 SIA Project (i.e., Pit 9).

The sonic drill rig will be inspected by LMITCO safety personnel in accordance with thesubcontractor's equipment operational manual prior to its mobilization to the OU 7-13/14 subsurfaceinvestigation site. Baseline radiological surveys will be conducted and mechanical fluid samples (i.e., oil)may be collected by RADCON personnel to demonstrate the radiological status of the rig (i.e.,radiologically "clean" or at some contamination level) prior to entering the OU 7-13/14 subsurfaceinvestigation project site. This baseline sample will be maintained until the end of the OU 7-13/14subsurface investigation activities, when a final post-project sample will be collected to document theabsence or level of intemal contamination in the engine components.

1.4.3 Soil Gas Surveys

The strategy for selecting locations for coreholes and treatability studies is to begin with theavailable historical shipping and disposal records, previously collected geophysical data, and additionaldata from volatile organic compound (VOC) mapping to identify areas of interest and of potential for highgamma radiation fields in Pits 4 and 10 (and Pit 6 if investigated).

Shallow soil gas surveys may be perfonned on a gridded pattern within Pits 4, 10 and 6 (ifrequired) to aid in the site selection of the probeholes to increase the likelihood of obtaining Rocky Flatssludge that contain VOCs. Active soil vapor surveys will be conducted in the subsurface to locatesignificant masses of chlorinated hydrocarbons, that are associated with Rocky Flats sludge and otherorganic waste streams. The soil gas survey will be conducted using active air extraction methods forsampling from shallow drive points. Air samples of the drive points will be collected using tedlar bagsand analyzed for chlorinated hydrocarbons.

1.4.4 Surface Geophysical Mapping

After soil gas surveys are conducted, additional surface geophysical mapping will be performed todefine waste zone boundaries more accurately. This data will also provide some control on thedistribution of waste in the x, y plane, which will complement z component information obtained fromgeophysical logging. A suite of high-resolution geophysical surveys including magnetic field, timedomain electromagnetic induction, frequency domain electromagnetic induction, and seismic refractionsurveys will be performed.

For each of the following survey methods, a balance has been attempted to weigh the limitations ofthe measurement, the properties of the instruments, and benefit from additional data. Data collectionspacing shall be as follows:

• Magnetic Field Survey-0.15 m x 0.5 m (0.5 ft x 1.6 ft)

• Time Domain Electromagnetic Induction (TDEM)-1 m x 0.25 m (3.2 ft x 0.8 ft)

• Multiple Frequency Domain Electromagnetic Induction (EMI)-1 m x 0.5 m (3.2 ft x 1.6 ft)

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Seismic Refraction Survey—data collected along an estimated 8,000 11 (2,400 m) of profiledistributed over the 8-acre (3 ha) site with 50 ft (15 m) between profiles. Depth values will be generatedat approximately 6.5-ft (2-m) intervals. This method shall yield approximately 1,200 depthdeterminations to generate a depth to basalt contour map.

1.4.4.1 Overview of Geophysical Methods and Application

• Magnetic Field Survey—Distribution offerrous objects

Magnetics is among the most popular methods for locating, mapping, and characterizingburied waste. The method is a passive measurement of the earth's magnetic field. Compactmagnetic objects produce location variations in the earth's field. By mapping the characterof the field it is possible to delineate the depth and location of objects producing thoselocalized changes. The method is more sensitive and has a higher resolution than othercompeting metal detection methods in sensing buried ferrous objects. The subcontractor(Sage Earth Science or other subcontractor) shall use its proprietary magnetic field mappingsystem, the Rapid Geophysical Surveyor (RGS) to collect data on a 0.15 m x 0.5 m (0.5 ft x1.6 ft) data spacing resulting in approximately 25,000 data points per acre. The highresolution magnetic field data will be used to generate accurate locations of buried ferrousobjects, primarily steel drums, and to develop depth estimates to individual objects withinthe pit boundaries as necessary.

• Time Domain Electromagnetic Induction TDEM—Distribution of metallic objects

Unlike magnetics, shallow TDEM methods are effective metal detectors that respond to arange of metal types, not only ferromagnetic metals and alloys. A transmitter generates anelectromagnetic pulse that induces an eddy current in metallic objects. The eddy currentdecay produces a secondary magnetic field measured by the receiver coil. By taking ameasurement at a relatively long time after the start of the decay, the cun•ent induced in theground has fully dissipated and only the current in the metal is still producing a secondaryfield. The secondary field response is sensed and recorded. The method can detect a single55-gallon drum at a depth of over 10 ft (3 m) yet is relatively insensitive to nearbyinterference, making it good choice for characterizing complex waste sites.

The subcontractor shall perform a TDEM survey over the 8-acre (3 ha) site on a 1 m x0.25 m (3 ft x 0.8 ft) station spacing. The 1 m (3 ft) profile spacing is largely a considerationof the 1 m (3 ft) wide sensing coil. The 1 m (3 ft) profile spacing will provide virtuallycontinuos coverage over the waste pits.

• Multiple Frequency, Frequency Domain Electromagnetic Induction Survey (EMI)—Distribution of metallic objects and distribution of soil conductivity (soil moisture)

Measurement of ground resistivity is one of the oldest geophysical techniques. Groundresistivity is a function of soil moisture, soil type, high levels of conductive contaminants,and the presence of buried metal. The basic principle of method is simple. A transmittercoil located at one end of the instrument induces oscillating eddy current loops in the earth.The magnitude of the current is directly proportional to the conductivity in the vicinity of theloop. Each current loop generates a magnetic field. The induced magnetic field is sensed bythe receiver coil of the instniment. The depth of investigation is a function of the transmittedfrequency and the transmitter/receiver coil spacing. By measuring the apparent conductivity

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at multiple frequencies, the depth of investigation will vary, yielding depth information toconductive bodies.

In addition to multiple frequencies, two components of the field shall be measured. First isthe quadrature-phase, which yields ground conductivity as described above. The second isthe inphase component. The inphase component is, however, significantly more sensitive toburied metal and is hence useful for locating metal objects. Used together, the inphase andquadrature phase make an effective tool for mapping the distribution and depth of buriedmetal objects as well as mapping soil moisture and soil type changes laterally and with depthwithin the survey area.

A multiple frequency EMI survey shall be conducted over the 8-acre (3 ha) site on a lmx0.5 m (3 ft x 1.6 ft) station spacing. The 1 m (3 ft) wide profile spacing is a practicalconsideration based on 1.3 m (4.3 ft) intercoil spacing or "footprint" of the instrument. Thedata will yield both the horizontal and vertical distribution of metal objects and containers.In addition, in those areas where the signal is not dominated by metallic objects, qualitativeinformation related to the horizontal and vertical variability of soil moisture will beachieved. These data can be used to guide intrusive or direct soil moisture measurementsand enhance those measurements by adding to the understanding of horizontal and verticaldistribution of soil moisture, which is typically limited by the small number of measurementpoints of intrusive methods.

• Seismic Refraction Survey (Depth to Rock)

This method relies on the fact that seismic energy is transmitted through the underlyingbasalt bedrock at a higher seismic velocity than through the overlying sediments and waste.In order to determine the depth to rock, a seismic impulse will be introduced into the ground.The time required for the impulse to travel to a series of motion sensing devices (geophones)will be monitored and recorded. The travel time and distance information is used tocalculate the depth to rock and seismic velocities at each geophone location.

For this project, data shall be collected along an estimated 8,000 ft (2,400 m) of profiledistributed over the 8-acre (3 ha) site at 50 ft (15 m) between profiles. Depth values will begenerated at 6.56 ft (2 m) intervals. These data will be used to generate the depth to rockbeneath the profile locations. The individual profile data of approximately 1,220 depthdeterminations will be used to generate a contour map of the depth to rock underlying thesite.

1.4.5 Installation of Cased Probeholes

Soil gas survey and surface geophysical mapping data will be used to site probehole locations. Amaximum of 70 probeholes will be installed through targeted waste zones in Pits 4 and 10 as described inthe Probehole Plan. These activities will be conducted in accordance with TPR-179, "ProbeholeInstallatioe. The probe shall be driven to allow for maximum advancement with the least disturbance tosubsurface soils. The drill rig will be remotely operated from a control trailer and unprotected fieldworkers (drill helpers, radiological control technicians [RCTs] and IH [industrial hygienist]) will be aminimum of 15 m (50 ft) from the drill rig during probe advancement and in accordance with TPR-179.

Video cameras will also be mounted on the drill rig to enable the operator to visually view the drillrig and helpers on monitors positioned in the control trailer. Direct communication with the drill helpers,RADCON personnel, and the FTL will be achieved using radio communication. All radio

communication will be clear and concise as stated in TPR-179 and as required by MCP-2976,"Operations Communication."

The installed probehole casing will be 10 cm (4 in.) inside diameter (i.d.) high-carbon steel andhave a disposable point for advancing the probehole. Probeholes will be installed through theoverburden, waste, and underburden to the top of basalt (a depth estimated to range from 10 ft to morethan 18 ft) and be left in place and temporarily capped until the downhole logging tasks are completed. Ifa probehole must be abandoned due to refusal (as determined by the FTL and driller), an additionalprobehole may be installed in a nearby location. The proximity of probeholes will be limited to 1.8 m (6ft) unless probeholes are abandoned with sand or bentonite (to minimize criticality concems) as describedin TPR-179. As previously mentioned, Pit 6 is only included as a contingency pit and most likely will notbe investigated..

1.4.6 Downhole Logging

Following probehole installation, downhole logging tasks will be conducted to further defineRocky Flats waste and sludge zones of interest where core samples will be collected. Probehole loggingwill be performed to investigate waste conditions as a function of depth. These activities will beconducted in accordance with PLN-496, "Downhole Logging Procedures for OU 7-13/14" and approvedsubcontractor logging procedures (if required). Specifically, it is desired to select corehole locations withthe following properties:

• Coreholes will not intersect large metal objects (as identified in previous geophysicalsurveys)a

• Recovered cores will not have excessively high radiation fields (greater than 200 mR/hr,

• Recovered cores will contain some RFP 740 Series sludge

• Recovered cores will contain at least 10 nCi/g of TRU radionuclides

• Recovered cores will contain some VOC waste component

• Recovered cores will contain a variety of waste forms including uranium.

Nuclear logging methods are further described in Subsection 4.3.1.2 of the OU 7-13/14 Work PlanAddendum (DOE-ID 1998) and the OU 7-13/14 Probehole Plan (Becker et al. 1999).

a Should a probehole intersect a large metal object, the probehole will be abandoned and a new location selected for placement ofthe probehole. Probeholes will be abandoned as described in a TPR-179, "Probehole Installatioe and the OU 7-13/14 ProjectWork Plan Addendum (DOE-ID 1998).

b A core barrel sample is raised to the surface in 2-ft increments. If the increment raised exceeds 200 mR/hr, the core barrel israised no further until the task site is re-evaluated by the RCT (see Section 6).

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Probehole caps will be removed and the selected logging tool positioned over the probehole withthe tripod/sheeve assembly. The selected tool will then be lowered using the logging truck winch systemat the desired rate to obtain data from the detector. When each probehole has been logged, the tool willbe raised and surveyed for contamination (as deemed appropriate by RADCON). After the logging tool iscompletely removed, the probehole cap will be placed back on the cased probehole.

The logging subcontractor vehicle and assortment of tools and detectors will be used to loginstalled cased probeholes as described above. Tools to be used will consist of both active and passivedetectors. The neutron source for activated logging tasks may consist of a sealed source. Additionally, averification source may be used daily as part of the overall logging calibration and quality controlprocess. LMITCO MCP-137, "Radioactive Source Accountability and Contror will be followed for allsource handling and storage operations. If any sealed source is determined to be special nuclear material(SNM) is required, it will be handled and stored accordingly. A RWMC RADCON representative willserve as the source custodian when it is not in use. All radioactive sources will be shipped in accordancewith 49 CFR 171-177.

Direct communication between the logger, logging technician, FTL, and support personnel will beachieved using radio communication, direct verbal communication (when possible) or hand signals. Allcommunication will be clear and concise as required by MCP-2976, "Operations Communication."

1.4.7 Sonic Core Drilling and Sampling

All sonic drilling and core sampling tasks to be performed for the OU 7-13/14 subsurfaceinvestigation will be conducted in accordance with TPR that will be generated and the OU 7-13/14 fieldsampling and analysis plans (Becker et al. 1999, Holdren et al. 1999). TPRs will cover these activities are:TPR —TBD, "Corehole Installatimr, TPR-TBD, "Handling, Storage, and Shipping Core Samples".Sonic core drilling and collection of core samples will be done as a single task unless refusal occurs andthe corehole must be abandoned.

1.4.7.1 Sonic Core Drilling. Core samples will be collected to support characterization efforts ofRocky Flats waste, uranium waste, and other waste materials. Coreholes will be drilled through theoverburden, waste and underburden including some 13 to 30 cm (6 to 12 in.) of the underlining basalt.The advancement will be achieved using an outer casing of 15.2 cm (6 in.) i.d. of high-carbon steel, asteel core barrel, and Lexan inner tubes; and advanced in 0.63-m (2-ft) increments to allow for maximumcore retention and to minimize contaminant migration. Cores will be double-contained in the inner corebarrel as well as an outer steel liner and confined by the use of a disposable core catcher.

The drill rig will be remotely operated from a control trailer and field workers (drill helpers,radiological control technicians [RCTs] and IH [industrial hygienist]) will be a minimum of 15 m (50 ft)from the drill rig during probe advancement. Video cameras will also be mounted on the drill rig andinside the drill string enclosure (DSE) to enable the operator to visually view the drill rig and helpers onmonitors positioned in the control trailer. Direct communication with the drill helpers, RADCONpersonnel, and the FTL will be achieved using radio communication. All radio communication will beclear and concise as stated in MCP-2976, "Operations Communication."

A DSE (Figure 1-3) will be used during all corehole drilling activities and is designed to preventrelease of contaminants at the source during drilling and sample recovery operations. This will beaccomplished by fully enclosing the drill string from the ground surface through the top head to the upperwinch enclosure. Additionally, the material transfer port, located on the bottom of the steel body of theDSE, will be sealed at all times in accordance with MCP-199, "Total Glove Bags". Monitoring of the drill

1-13

string as well as a break between coring sections is provided by windows constructed of clear plasticmaterial located on the steel body of the DSE (see Figure 1-3).

The DSE provides a confinement for contaminants adhering to outer surfaces of the sampling corebarrel up the drill string. The DSE will consist of a double walled configuration that is under negativepressure and filtered through a high-efficiency particulate air (HEPA) filter vacuum system located on thewinch enclosure and the upper portion of the steel body of the DSE (where it attaches to the sonic head).

Drill String Enclosure(upper inch enclosure tothe material transfer

Figure 1-3. Drill string enclosure on drill rig.

The DSE will be equipped with a low-pressure aneroid gauge (i.e., MagnehelicTM, inches of water)to monitor negative pressure inside the DSE (with respect to the ambient environment). This gauge willbe mounted on the side of the DSE and will serve as a real-time indicator if there is a break in the sealingsurfaces or a IIEPA vacuum malfunction or loading. An additional gauge will be located at the remotecontrol panel and installed prior to core drilling operations.

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1.4.7.2 Core Sample Collection. All sample cores will be collected directly from the DSEthrough a port to ensure outer contaminated core surfaces do not come into contact with samplingpersonnel and the environment. Sample cores will consist of waste material inside a inner core barrel thatis seated inside the steel outer tube. The inner core will be used to keep the cores intact, serve as samplecontainer until split for visual inspection. Cores will be capped while inside the DSE confinement thenremoved through the material transfer port with double layers of sleeving to ensure that contamination isnot spread when the core sample is removed from the DSE (glovebag removal operation). Once sleevedsamples are removed from the DSE transfer port they will be placed directly in to the transfer bag.Capped cores will be surveyed for radiological dose rate and surface contamination of sleeving and willbe labeled prior to being placed in the radiological transition tent area. Cores will then be bagged out ofthe contamination area and taken to the assay station before being placed in storage or shipping drumsdestined for a subsampling facility, depending on the project requirements.

1.4.7.3 Downhole Instrument Installation

Downhole instruments will be placed in several of the coreholes following sampling tasks inaccordance with "TPR-175, "Instrument Installation in Coreholee. All instrument installation operationswill be conducted through the DSE. Specific instruments to be installed are describe in section 4.3.8 ofthe Addendum to the Work Plan for the OU 7-13/14 WAG 7 Comprehensive RI/FS Study (Becker et al.1998).

1.4.8 Treatability Sample Transportation and Splitting.

The subsampling facility will unpack the containerized core samples in a HEPA-filtered glovebox,split samples, and perform radiochemistry analysis. All radiochemistry will be performed at thesubsampling facility. Additional subsamples may be analyzed for organic, inorganic, and radiochemistrysuites at the initial subsampling facility or sent to other laboratories for analyses. Data from theseanalyses will be used to meet the quality objectives in the OU 7-13/14 Field Sampling and Analysis Plan(Holdren et al. 1999).

All core handling and shipping tasks will be conducted in accordance with a TPR that will begenerated addressing the handling, storage, and shipping of core samples; and with 49 CFR 171-177regulatory requirements. Cores will be containerized in U.S. Department of Transportation (DOT)approved radioactive material shipping drums for transport to the subsample facility. All drums will benonintrusively screened at the project site using a high-purity germanium detector, a gamma spectroscopytechnique used to determine the fissile gram equivalents in each core. Additionally, a passive/activeneutron monitor may be used to confirm the screening using gamma spectroscopy techniques. Thescreening will determine if the cores contain less than 200 Fissile Gram Equivalents.

Laboratory analyses will be used to develop treatability studies. These treatability studies arediscussed further in Section 5 of the Addendum to the Work Plan for OU 7-13/14.

1.5 General Project Information

The OU 7-13/14 Subsurface Investigation Project will involve a field team of approximately 10 to15 individuals (see Section 2, Figure 2-1). Project personnel will consist of the drilling team, samplingteam, construction engineer, construction manager, Radiological Control (RADCON) support (engineersand technicians), health and safety professionals (HSO, industrial hygienist UHL safety engineer [SE]),project management (PM), and support personnel. Currently, OU 7-13/14 subsurface investigationactivities are scheduled to begin in 1999.

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The current configuration of the project site will require the drill rig to be carefully moved to eachlocation due to existing structures and physical features (fences, ditches, berm, roads, etc.). Every effortwill be made to minimize the disturbance of adjacent structures and operations. Extensive planningduring site preparation will lessen potential impact on ongoing RWMC and other SDA operations.

• Prepare National Environmental Policy Act (NEPA) documentation, including anenvironmental checklist

• Prepare the storm water pollution prevention plan, as necessary

• Prepare work control documentation/integrated planning sheets

• Prepare a job safety analysis

• Prepare unreviewed safety question(s)

• Prepare a waste characterization report and L-0435 forms for waste disposal, as necessary

• Prepare a fire hazards analysis based on a graded approach.

• Abide by MCP-2798 "Maintenance Work Contra' (where appropriate).

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2. PROJECT MANAGEMENT RESPONSIBILITIES

The organizational structure for the OU 7-13/14 subsurface investigation project is divided into twofunctional areas, task site and ER managerial responsibilities. Each of these areas is described in thissection.

2.1 Task Site Responsibilities

The organizational structure for the OU 7-13/14 subsurface investigation project reflects theresources and expertise required to perform the work, while minimizing risks to worker health and safety,and the environment. Task site positions and lines of responsibility and communication are shown inFigure 2-1. The subsequent sections outline the responsibilities of these task site personnel. The namesof key individuals for emergency contact purposes are listed in Table 11-4.

2.1.1 Field Team Leader

The field team leader (FTL) will be a Parson employee who represents the ER organization at thetask site with ultimate responsibility for the safe and successful completion of the project. The FTLworks with the Parsons CE to manage field operations and execute the work plan activities (i.e.,Probehole Plan and Field Sampling Plan). The FTL enforces task-site control, documents attendance andactivities, and may conduct the POD briefings at the start of the shift. Task site duties specificallyidentified for the FTL (e.g., core sample/waste packaging, storage, and transport), CE, and otherindividuals are explicitly identified in project plans (PLN) and technical procedures (TPRs). Additionally,the FTL may conduct or delegate the performance of scheduled or targeted self assessments in accordancewith MCP-8, "LMITCO Self Assessment Process for Continuous Improvement." Health and safety issueswill be brought to the attention of the FTL.

If the FTL leaves the task site, an altemate individual will be appointed to act as the FTL. Personsacting as FTL on the task site must meet all the FTL training requirements outlined in Section 4. Theidentity of the acting FTL shall be conveyed to task-site personnel and communicated to the facilityrepresentative when appropriate. The FTL may also serve as the project geologist based on technicalqualifications. The FTL will provide technical support to the RWMC command post during emergencyevents for the OU 7-13/14 project.

2-1

Parson Environmental Field Team Health & ProjectConstruction Coordinator Leader Safety Officer QualityEngineer Assurance

Drilling Logging Fire Explosive Industrial RADCONSubcontractor Subcontractor Protection Safety Hygienist

Engineer

Figure 2-1. Field organization chart for OU 7-13/14 project.

2.1.2 Parsons Construction Engineer

The Parsons CE is the individual representing Parsons RD/RA management at the OU 7-13/14project site. The CE reports to the Parsons CM. This responsibility involves ensuring that all thenecessary equipment and facilities are made available to implement the provisions of this plan. The CEenforces site control, serves as the field interface for all subcontractors, and may conduct the daily plan-of-the-day (POD) safety briefings at the start of the shift. All health and safety issues at the task site mustbe brought to the CE's attention.

When the nature of the field work requires involvement or field team staffing by RWIVICequipment operators, laborers, or other crafts a representative from the organization supplying theseadditional resources will interface with the CE to provide work supervision. The CE will serve as theprimary interface with subcontractor personnel at the project site. Additionally, the CE will also serve asthe primary area warden for personnel accountibility.

2.1.3 Health and Safety Officer

The HSO is the person assigned to the task site who serves as the primary contact for health andsafety issues. The HSO advises the CE and FTL on all aspects of health and safety, and is authorized tostop work at the task site if any operation threatens worker or public health and/or safety. The HSO maybe assigned other responsibilities, as stated in other sections of this HASP, as long as they do not interferewith the primary responsibilities. The HSO is authorized to verify compliance to the HASP, conductinspections in accordance with MCP-3449, "Safety and Health Inspections", decontamination procedures,and require corrections, as appropriate. The HSO is supported by ESH&QA professionals at the task site(safety engineer, Ili, RCT, radiological engineer, environmental coordinator, and facility representative,as necessary).

Persons assigned as the HSO or alternate HSO must be qualified (per the OSHA definition) torecognize and evaluate hazards, and will be given the authority to take or direct actions to ensure thatworkers are protected. While the HSO may also be the IH, SE, or in some cases the FTL or CE(depending on the hazards, complexity and size of the activity involved, and required concurrence fromthe ER ESH&QA manager) at the task site, other task-site responsibilities of the HSO must not conflict(philosophically or in terms of significant added volume of work) with the role of the HSO at the tasksite.

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If it is necessary for the HSO to leave the site, an alternate individual will be appointed by the HSOto fulfill this role, the identity of the acting HSO will be communicated to task-site personnel.

2.1.4 Environmental Coordinator

The assigned LMITCO environmental affairs coordinator oversees, monitors, and advises the PMand CE performing task-site activities on environmental issues and concerns by ensuring compliance withDOE orders, EPA regulations, and other regulations concerning the effects of task-site activities on theenvironment. The environmental affairs coordinator provides support surveillance services for hazardouswaste storage and transport, and surface water/storm water runoff control.

2.1.5 Quality Engineer

A LMITCO quality engineer provides guidance on task-site quality issues, when requested. Thequality engineer observes task-site activities and verifies that task-site operations comply with qualityrequirements pertaining to these activities. The quality engineer identifies activities that do not comply orhave the potential for not complying with quality requirements and suggests corrective actions.

2.1.6 Radiological Engineer

The radiological engineer is the primary source for information and guidance relative to theevaluation and control of radioactive hazards at the task site. The radiological engineer will provideengineering design criteria and review of confinement structures and makes recommendations tominimize health and safety risks to task-site personnel. Responsibilities of the radiological engineerinclude (1) performing radiation exposure estimates and as low as reasonably achievable (ALARA)evaluations; (2) identifying the type(s) of radiological monitoring equipment necessary for the work;(3) advising the HSO and RCT of changes in monitoring or PPE; and (4) advising personnel on task-siteevacuation and reentry. The radiological engineer may also have other duties to perform as specified inother sections of this HASP, or in the LMITCO Radiological Control Manual.

2.1.7 Radiological Control Technician

The assigned LMITCO RCT is the primary source for information and guidance on radiologicalhazards and will be present at the OU 7-13/14 subsurface investigation task site during all operations.Responsibilities of the RCT include radiological surveying of the task site, equipment, and samples;providing guidance for radioactive decontamination (DECON) of equipment and personnel; andaccompanying the affected personnel to the nearest INEEL medical facility for evaluation if significantradiological contamination occurs. The RCT must notify the FTL and HSO of any radiologicaloccurrence that must be reported as directed by the LMITCO Radiological Control Manual. The RCTmay have other duties at the task site as specified in other sections of this HASP, or in LMITCO PRDsand/or MCPs.

2.1.8 Industrial Hygienist

The assigned LMITCO IH is the primary source for information regarding nonradiologicalhazardous and toxic agents at the task site. The IH assesses the potential for worker exposures tohazardous agents according to the LMITCO Safety and Health Manual MCPs and accepted industry IHpractices and protocol. By participating in task-site characterization, the IH assesses and recommendsappropriate hazard controls for the protection of task-site personnel, operates and maintains airbomesampling and monitoring equipment, reviews for effectiveness, and recommends and assesses the use ofPPE required in this HASP (recommending changes as appropriate).

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Following an evacuation, the IH in conjunction with other recovery team members, will assist theFTL in determining whether conditions exist for safe task-site reentry as described in Subsection 11.7.Personnel showing health effects (signs and symptoms) resulting from possible exposure to hazardousagents will be refen•ed to an Occupational Medical Program (OMP) physician by the III, their supervisor,or the HSO. The IH may have other duties at the task site, as specified in other sections of this HASP, orin LMITCO PRDs and/or MCPs. During emergencies involving hazardous materials, airborne samplingand monitoring results will be coordinated with members of the Emergency Response Organization(ERO).

2.1.9 Are Protection Engineer

The assigned LMITCO fire protection engineer (FPE) reviews the work packages and fire hazardanalysis, conducts pre-operational and operational fire hazard assessments, and is responsible forproviding technical guidance to OU 7-13/14 project personnel regarding all fire protection issues.Additionally, the assigned project fire engineer may provide fire protection support for the developmentand review of project fire protection documentation (e.g., pre-fire plan, fire hazards analysis, etc.).

2.1.10 Safety Engineer

The assigned LMITCO safety engineer reviews work packages, observes site activity, assessescompliance with the LMITCO Safety and Health Manual, signs safe work permits (SWPs), advises theFTL and CE on required safety equipment, answers questions on safety issues and concems, andrecommends solutions to safety issues and concerns that arise at the task site. The SE may conductperiodic inspections in accordance with MCP-3449, "Safety and Health InspectionCand may have otherduties at the task site as specified in other sections of this HASP, or in LMITCO PRDs and/or MCPs.

2.1.11 Logging and Assay Subcontractors

Logging and core assay tasks will be conducted by subcontractor personnel assigned during OU 7-13/14. The subcontractor representatives or supervisors will report to the FTL for technical issues and theCE for all other logistics and administrative matters. Subcontractor representatives, along with the FTL.and CE, work as a team to accomplish day-to-day logging and assay operations at the task site, identifyand obtain additional resources needed at the site, and interact with the HSO, III, SE, radiologicalengineer (RE), and RCT on matters regarding health and safety. The subcontractor representative orsupervisor will provide information to the CE and HSO regarding the nature of their intended tasks,hazards and mitigation work for the daily POD meeting.

2.1.12 Field Team Members

All field LMITCO, Parsons, and subcontractor team members (drillers, logging and assaypersonnel, equipment operators, and other personnel called out by position in this section) shallunderstand and comply with the requirements of this HASP. The CE, FTL, or HSO will brief the fieldteam members at the start of each shift. During the POD, all daily tasks, associated hazards andmitigation, engineering and administrative controls, required personal protective equipment (PPE), workcontrol documents, and emergency conditions and actions will be discussed. Input from the project SE,IH, and RADCON persoimel to clarify task health and safety requirements will be provided. Allpersonnel are encouraged to ask questions regarding site tasks and provide suggestions on ways toperform required tasks in a more safe and effective manner based on the lesson learned from previousday's activities.

Once at the OU 7-13/14 task site, personnel are responsible for identifying any potentially unsafesituations or conditions to the FTL, CE, or HSO for corrective action. If it is perceived that an unsafe

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conditions poses imminent danger, any field team member or other project personnel areauthonzed to stop work immediately, then notify the FTL, CE or LISO of the unsafe condition.

2.1.13 Non-Field Team Personnel

All persons who may be on the OU 7-13/14 project sites to complete limited tasks (maintenance,refueling, vender services, etc.), inspections or assessments or do not perform required tasks at the projectsites are considered non-field team personnel for the purposes of this project. A person shall beconsidered "onsite when they are present in or beyond the designated SZ. Non-field team personnel or"occasional site workers" under 29 CFR 1910.120/1926.65, and must meet minimum trainingrequirements for the area they have a demonstrated need to access at the OU 7-13/14 project site asidentified in Section 4. Since the hazards associated with coring and downhole instrument placementoperations into Pit waste may result in changing field conditions, all personnel (field team and non-fieldteam personnel) who enter the EZ must have 40-hour Hazardous Waste Operations and EmergencyResponse (HAZWOPER) and Radiological Worker II training. Non-field who have a demonstrated needto routinely access the project site will complete 3 days of supervised field experience in accordance with29 CFR 1910.120(e) in order to become a field team member.

2.1.14 Visitors

All visitors with official business at the OU 7-13/14 project sites (including LMITCO personnel,representatives of DOE, and/or state or federal regulatory agencies) may not proceed beyond the SZwithout meeting the following requirements:

• Receiving OU 7-13/14 site-specific HASP training

• Signing a HASP training acknowledgment form, providing proof of meeting all trainingrequirements specified in Section 4 of this HASP for the area to be accessed

• Signing applicable radiological work permits, safe work permits and job safety analysis forthe area(s) to be accessed.

• Wearing the appropriate PPE.

Note: Visitors may not be allowed beyond the SZ during certain OU 7-13/14 project site high hazardtasks (e.g., probehole completion, drill rig movement, core drilling, instrument installation, and others asdetermined by the HSO) to minimize safety or health hazards or as an ALARA consideration. Thedetermination as to any visitor's "neee for access beyond the SZ at the OU 7-13/14 project site will bemade by the HSO in consultation with RWMC RADCON personnel.

A fully trained task-site representative (such as the FTL or CE or HSO, or a designated alternate)will escort visitors when entering the OU 7-13/14 project site beyond the SZ during low hazard activitiesand as deemed appropriate by the FTL.

A casual visitor to the OU 7-13/14 task sites is a person who does not have a specific task toperform or other official business to conduct at the task site. Casual visitors are not permitted on OU7-13/14 project sites.

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2.2 ER Management Responsibilities

An overview of the direct managerial positions and lines of responsibility and communication foroverseeing the OU 7-13/14 project is shown in Figure 2-2. The responsibilities for these positions areoutlined in this section. The names of key management individuals for emergency contact purposes arelisted in Table 11-4.

2.2.1 Environmental Restoration Director

The LMITCO ER director has the ultimate responsibility for the technical quality of all projects,maintaining a safe environment, and the safety and health of all personnel during field ztivitiesperformed by or for the Environmental Restoration Program. The ER director provides technicalcoordination and interfaces with the DOE-ID Environmental Support Office. The ER director ensuresthat:

• Project/program activities are conducted according to all applicable federal, state, local, andcompany requirements and agreements.

• Program budgets and schedules are approved and monitored to be within budgetaryguidelines.

ERDirector

ERESH&QAManager

ERQuality

AssuranceCompliance Officer

LMITCOWAG 7

Project Manager

LMITCOOU 7-13/14

Remedial InvestigationProject Manager

ParsonProject Manager

ParsonConstructionManager

Figure 2-2. High-level organizational chart, OU 7-13/14 project.

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Key

RWMC AreaDirector

Waste OperationsESH&QAManager

Indirect lines of responsibilityand communication

• Personnel, equipment, subcontractors, and services are available.

• Direction is provided for the development of tasks, evaluation of findings, development ofconclusions and recommendations, and production of reports.

2.2.2 ER ESH&QA Manager

The Environmental Restoration Program Environmental, Safety, Health, and Quality Assurance(ESH&QA) Manager is responsible to manage resources to ensure that ESH&QA programs, policies,standards, procedures, and mandatory requirements are planned, scheduled, implemented and executed inthe day-to-day operations for the Environmental Restoration Program operations conducted at the INEEL.The Manager directs the ESH&QA compliance accomplishment of all activities by providing technicaland administrative direction to subordinate staff and through coordination with related functional entities.The ER ESH&QA Manager reports to the ER Director. Under the direction of the ER Director, the ERESH&QA Manager represents the ER Directorate in all ESH&QA matters. This includes responsibilityfor ER Program ESH&QA management compliance and oversight for all ER CERCLA and D&Doperations planned and conducted at TAN (WAG 1), TRA (WAG 2), INTEC (WAG 3), CFA (WAG 4),ARA/PBF (WAG 5), Borax (WAG 6) , RWMC (WAG 7) and other nongeographic facility locations(WAG 10) and for ER Program INEEL-wide Environmental Monitoring activities.

The ER ESH&QA Manager is responsible for the management of the following technicaldisciplines and implementation of the programs related to these disciplines:

• Radiological Control personnel

• Environmental Support personnel

• Industrial Safety personnel

• Fire Protection personnel

• Quality Assurance personnel

• Industrial Hygiene personnel (Matrixed)

• Emergency Preparedness personnel (Matrixed).

2.2.3 ER Quality Assurance Compliance Officer

The ER Quality Assurance Compliance Officer is responsible for ensuring that quality complianceprograms, policies, standards, procedures, and mandatory requirements for ER are planned, scheduled,implemented and executed in the day-to-day operations for the Environmental Restoration Programoperations conducted at the INEEL. The QA compliance officer may interface with the quality engineerto identify activities that do not comply or have the potential for not complying with quality requirementsand provide suggestions for corrective actions.

2.2.4 LMITCO WAG-7 Project Manager

The LMITCO WAG-7 PM shall ensure that all activities conducted during the project comply withLMITCO MCPs and program requirements directives (PRDs); all applicable OSHA, EPA, DOE, DOT,and State of Idaho requirements; and that tasks comply with LMITCO Quality Program Plan for theEnvironmental Restoration Program, PLN 125 (LMITCO 1997a), the Quality Assurance Project Plan

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(QAPjP), this HASP, and the applicable Sampling and Analysis Plans (SAP). The ER WAG-7 PM isresponsible for the overall work scope, schedule, and budget.

2.2.5 LMITCO OU 7-13/14 Remedial Investigation Project Manager

The LMITCO OU 7-13/14 PM is responsible for the scope, schedule, and budget for theseactivities; interfacing with and supporting the LMITCO WAG-7 PM for tracking purposes. TheOU 7-13/14 PM shall ensure that all activities conducted during the project comply with the projectprocedures, applicable LMITCO MCPs and PRDs, and all applicable OSHA, EPA, DOE, DOT, and Stateof Idaho requirements. The PM shall ensure that tasks comply with the LMITCO Quality Program Planfor the Environmental Restoration Program, PLN-125 (LMITCO 1997a), the QAPjP, this HASP, and theapplicable SAPs. The PM coordinates all document preparation, field, laboratory, and modelingactivities.

This PM will interface with RWMC management and implement the RWMC Remediation Projectrequirements and ensure work is performed as planned for the OU 7-13/14 subsurface investigationproject. This project manager is responsible for (a) developing resource-loaded, time-phased ControlAccount Plans based on the RWMC Remediation Project technical requirements, budgets, and schedules;and (b) assigned OU 7-13/14 subsurface investigation project tasks. Other functions and responsibilitiesof this project manager include the following:

• Ensuring the technical review and acceptance of all OU 7-13/14 documentation

• Developing documentation required to support the OU 7-13/14 tasks

• Developing site-specific plans required by the DOE Remediation Program such as workplans, ESH&QA plans, sampling and analysis plans, etc.

• Ensuring that project activities and deliverables meet schedule and scope requirements asdescribed in the FFA/CO Action Plan and applicable guidance

• Identifying requirements, scheduling, and supporting CERCLA and NEPA public reviewand comment processes

• Identifying, planning, justifying, executing, and controlling post-ROD treatability study tests

• Identifying remediation subproject technology needs

• Coordinating and interfacing with the units within the Program Support organization onissues relating to QA, ESH&QA, and NEPA support

• Collecting site-specific data, reviewing for technical adequacy, and inputting data to anapproved database such as the Environmental Remediation Information System

• Interfacing and coordinating risk assessments

• Coordinating and interfacing with the project to ensure milestones are met, adequatemanagement support is in place, technical scope is planned and executed appropriately, andproject costs are kept within budget.

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2.2.6 Parsons Project Manager

The Parsons PM is responsible for the scope, schedule, and budget for Parsons subcontractedOU 7-13/14 project activities; interfacing with the LMITCO OU 7-13/14 RI PM for tracking purposes.The Parsons PM shall ensure that all activities conducted during the project comply with projectprocedures, subcontract conditions, applicable LMITCO MCPs and PRDs, and all applicable OSHA,EPA, DOE, DOT, and State of Idaho requirements. The PM shall ensure that tasks comply withPLN-125, "Quality Program Plan for the Environmental Restoration Program," the QAPjP, this HASP,and the applicable SAP. The PM coordinates all document preparation, field, laboratory, and modelingactivities.

The PM interfaces with the LMITCO ER RI PM, reports to the Parsons RD/RA management, andis responsible for the scope, schedule, and budget for Parsons activities outlined in the Parsons task orderplan.

2.2.7 Parsons Construction Manager

The Parsons construction manager (CM) is responsible for field implementation of the project.This responsibility involves ensuring that all OU 7-13/14 project tasks receive appropriate health andsafety review before commencement, and that the necessary equipment and facilities are made availableto implement the provisions of this plan. The CM may delegate any or all of the above responsibilities,and reports to the Parson OU 7-13/14 Project Manager.

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3. RECORD KEEPING REQUIREMENTS

3.1 Industrial Hygiene and Radiological Monitoring Records

The IH will record airborne monitoring and/or sampling data (both area and personal) on LMITCOHealth and Safety (HAS) System. All monitoring and sampling equipment shall be maintained andcalibrated per LMITCO procedures and the manufacturer's specifications. Industrial hygiene airbornemonitoring and sampling data is treated as limited access information and maintained by the III perLMITCO Safety and Health Manual procedures. Any airborne monitoring or sampling done bynonindustrial hygiene/safety personnel will be reviewed by the IH.

The RCT maintains records of all radiological monitoring, daily task-site operational activities, airsamples, surveys, and instrument calibrations. Radiological monitoring records are maintained accordingto the LMITCO Radiological Control Manual procedures.

IH and RCT monitoring and sampling (both area and personal) data will be made available totask-site personnel or their representative upon request.

3.2 FTL Logbook

The FTL will keep a record of daily task-site events in the FTL logbook. The FTL logbook must beobtained from ER Administrative Record and Document Control (ARDC). Completed logbooks aresubmitted to ARDC along with other documents at the project's completion. Logbooks will bemaintained in accordance with MCP-231, "Logbooks."

3.3 Site Attendence Rceord

This site attendance record will be used to keep a record of all personnel (workers and nonworkers)who are onsite each day and be used to assist the area warden with conducting personnel accountabilityshould an evacuation take place (see Section 11 for emergency evacuation conditions). Personnel willonly be required sign in and out of the attendance record once each day. The CE is responsible formaintaining the site attendance record and ensuring all personnel on the project site sign in.

3.4 Administrative Record and Document Control Office

The ARDC shall organize and maintain data and reports generated by ER program field activities.The ARDC maintains a supply of all controlled documents and provides a documented system for thecontrol and release of controlled documents, reports, and records. Copies of the Management Plans forthe ER program, this HASP, the LMITCO Quality Program Plan for the Environmental RestorationProgram, PLN-125 (LMITCO 1997a), the QAPJP, and other documents pertaining to this work aremaintained in the project file by the ARDC. All project records and logbooks, except IH and RCTrecords, must be forwarded to ARDC within 30 days after completion of field activities.

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4. PERSONNEL TRAINING

All OU 7-13/14 subsurface investigation project site personnel shall receive training as specified inOSHA 29 CFR 1910.120/1926.65, the LMITCO Safety and Health Manuals, LMITCO TrainingRequirements Matrix Manual, the LMITCO Training and Qualifications Manual-12, and RWMCMCP-1764. Radiation workers shall be trained according to the LMITCO Radiological Control Manual,MCP-126, "Training." Table 4-1 summarizes the project-specific training requirements for task-sitepersonnel based on position and required access into the specific areas at the task site. Specific trainingrequirements for each worker may vary depending on the hazards associated with their individual jobassignment and required access into radiologically controlled areas. Changes to the trainingrequirements listed on Table 4-1 (adding or elminating) may be necessary based on changing fieldconditions or work scope. Any changes to the those listed on Table 4-1 must be approved by the HSOwith concurrence from the FTL, PM and RADCON (as applicable).

4.1 General Training

All project personnel are responsible for meeting required OU 7-13/14 training (includingapplicable refresher training) and evidence of training will be maintained at the OU 7-13/14 project site orelectronically (e.g., TRAIN) at the OU 7-13/14 administrative trailer. Nonfield team personnel andvisitors must be able to provide evidence of meeting required training for the area they wish to accessprior to being allowed into control project areas. Examples of acceptable written training documentsinclude: LMITCO, "40 Hour OSHA HAZWOPER Card," LMITCO, "Respirator Authorization Card,""DOE Certificate of Core Radiological Training II Card," "Medic/First Aid Training Card," and/or a copyof an individual's or department's (LMITCO/Parsons only) TRAIN System printout demonstratingcompletion of training. Upon validation, a copy of training certificate issued by an approved non INEELtraining vender or institution is also acceptable proof of training. The DOE radiological worker trainingmust be documented on an official authorized card (blue DOE seal in upper left corner) and have thedesignated INEEL site-specific training stamped or written on the card.

4.2 Project Site-Specific Training

Before beginning work at the OU 7-13/14 subsurface investigation task site, site-specific trainingwill be conducted by the CE or HSO. This training will be applicable to the Pit being investigated, i.e.,Pit 4, 10, or 6. Pit 6 is included in this HASP but may or may not be investigated. This training willconsist of a complete review of this HASP and attachments, applicable job safety analysis, safe workpermit(s), and other applicable work control documents with time for discussion and questions. At thetime of this training, personnel training records will be checked and verified to be cun•ent and completefor all required training shown in Table 4-1. Upon completing OU 7-13/14 project site-specific training,personnel will sign the Training Acknowledgement Form (Appendix A of this HASP) indicating that theyhave received this training, understand the project tasks, associated hazards/mitigation, and agree tofollow all HASP and all other applicable work control and safety requirements.

4.3 HAZWOPER Supervised Field Experience

All newly HAZWOPER trained 40-hour or 24-hour field personnel or those personnel who do nothave documented supervised training will have their performance monitored by the CE or HSO to meetthe 3 days of supervised field experience in accordance 29 CFR 1910.120(e)/29 CFR 1926.65(e). TheSupervised Field Experience Verification Form (Form #361.47, Appendix B) will be completed and acopy given to the employee and provided to the OU 7-13/14 training coordinator for entry into theEmployee TRAIN System Records.

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The LMITCO training records shall be forwarded to the LMITCO Environmental Operations(EO) training coordinator (MS 3902) for retention in the employee training records (TRAIN) and a copymaintained by the FTL/CE at the project trailer. In addition, the completed and signed originalOU 7-13/14 subsurface investigation HASP training acknowledgement (Appendix A) and HAZWOPER24-hour Supervised Field Experience Acknowledgement forms (Appendix 13) will be sent to the LMITCOEO training coordinator (MS 3902).

4.4 Daily Plan of the Day and Lesson Learned Meeting

A daily POD meeting will be conducted by the FTL, CE or HSO with input from the RCT, RE, andSE as applicable. During this meeting, daily tasks are to be outlined, hazards and contrcls/mitigationidentified, PPE requirements discussed, new controlled work areas identified, and employees' questionsanswered. At the completion of this meeting any new work control documents will be read and signed(e.g., SWP[s], RWP[s], JSA[s], etc.). Particular emphasis will be placed on lessons leamed from theprevious day's activities and how tasks can be completed in the safest, most efficient manner. Allpersonnel will be asked to contribute ideas to enhance worker safety and mitigate potential exposures atthe OU 7-13/14 project sites throughout the project.

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Table 4-1. Required training for OU 7-13/14 subsurface investigation project site personnel.

Training FTL CE

RCTs,1H

SamplersDriller

Helper(s)HSO,SE, RE

DrillOperator,LoggingTeam

Access to SZ(non-field teampersonnel only)

Access to EZ but notRadiological CA.(non-field teampersonnel only)s

Access toRadiological CA(non-field team.personnel only)l"

40-hr HAZWOPERa Y Y Y Y Y Y I Y Y

24-hr HAZWOPER' I I I I I I I Y` I8-hr HAZWOPER Refresher Y Y Y Y Y Y I Y Y

HAZWOPER Supervisor Y 1' I I HSO I I I ISite-Specific HASP Trainingd Y Y Y Y Y Y 1' Y Y

RW I (INEEL site-specific) I I I I I I y` Y` IRW II (INEEL site-specific) Y Y Y Y Y Y I l

yti

Fire Extinguisher — Awareness I I I Y Y I I Y

Fire Extinguisher - Practical (includesawareness)

Y Y Y Y I I I I I

CPR/Medic first aid Y 11 RCTs I HSO I I I IRespirator Training (OU 7-13/14 Projectairhood system)

Y Y Y Y I I I II yi

HAZMAT Employee General Awareness Y I Y I I I II I IGlove Bag Use Y I `it Y I I I I IGlove Bag Installation/Removali Y I Y Y I I I I IRWMC Area Warden Training Y Y I I HSO I I I I

RWMC Command Post Technical Support Y Y HSO I ITPR Trainingg Y Y Y Y Y V I Y Y

INEEL Blue or Orange Card ES&H Training Y Y Y Y Y Y 17 Y YRWMC Access Training Y Y Y Y Y Y Y1 Y1 Yi

Table 4-1. (continued).

Training

RCTs,IH Driller HSO,

FTL CE Samplcrs Helper(s) SE, RE

DrillOperator,LoggingTeam

Access to SZ(non-field teampersonnel only)

Access to EZ but notRadiological CA.(non-field teampersonnel only)h

Access toRadiological CA(non-field teampersonnel only)ly

a. Includes 24-hour or 8-hour supervised field experience (as applicable) and current 8-hour refresher (as required).

b. For field team members and others requesting access beyond the SZ during core drilling, sampling, handling, storage, packaging, and assay activities.

c. During probehole activities this is the minimum requirement for access beyond SZ.

d. Includes project-specific HAZCOM, site-access/security, decontamination and emergcncy response actions.

e. Escort only as authorized by project RE.

f. Escort in RW 11 area only as authorized by the project RE.

4,=•g. Only training applicable to specific job function at the OU 7-13/14 project site. Reading and signing for additional PLN, LST and/or MCPs may also be conducted based on job function.

h. 1-1S0 authorization required.

i. Project RE authorization required.

CA = contamination area, CE = construction enginecr, EZ -- exclusion zone, FTL = ficld tcam leader, HSO — health and safety officer, IH = industrial hygienist,

RBA = radiation buffer area, RCT = radiological control technician, RE = radiological engineer, SE = safety engineer, SZ = support zone.

Gray shading indicates not applicable.

5. OCCUPATIONAL MEDICAL SURVEILLANCE PROGRAM

LMITCO task-site personnel shall participate in the INEEL OMP, as required by DOEOrder 5480.8a and OSHA 29 CFR 1910.120/1926.65. Medical surveillance examinations will beprovided before assignment, annually, and after termination of hazardous waste site duties oremployment. This includes personnel who are or may be exposed to hazardous substances at or above theOSHA permissible exposure limit (PEL) or published exposure limits, without regard to respirator use,for 30 or more days per year. Personnel who wear a respirator in performance of their job, or who arerequired to take respirator training to perform their duties under this plan, must participate in the medicalevaluation program for respirator use at least annually as required by 29 CFR 1910.134 (1910.139 whenfinal rule becomes effective). This HASP, task hazard analysis, required PPE, and other exposure relatedinfonnation must be provided to an OMP physician for each employee participating in OU 7-13/14project site activities. Exposure monitoring results and hazard information furnished to the OMPphysician must be supplemented or updated annually as long as the employee is required to maintain ahazardous waste/hazardous material employee medical clearance.

The OMP physician shall evaluate the physical ability of an employee to perform the workassigned, as identified in the OU 7-13/14 subsurface investigation HASP or other job-relateddocumentation. A documented medical clearance (physician's written opinion) will be provided to theemployee and line management stating whether the employee has any detected medical condition thatwould place him/her at increased risk of material impairment of his/her health from work in hazardouswaste operations, emergency response, respirator use, and confined space entry (as applicable). Thephysician may impose restrictions on the employee by limiting the amount and/or type of workperformed. OMP responsibilities, with regard to personnel assigned to hazardous waste site activities,include, but are not limited to:

• Providing current comprehensive medical examinations (as determined by the examiningphysician) at an INEEL medical facility for full-time personnel

• Obtaining records/reports from employee's private physicians, as required by the OMPdirector

• Performing a medical evaluation on return-to-work cases following an absence in excess ofone work week (40 consecutive work hours) resulting from illness or injury

• Conducting a medical evaluation in the event that management questions the ability of anemployee to work or if an employee questions his/her own ability to work.

NOTE: Employees will not be permitted to work on projects unless line management has received amedical clearance form.

The attending physician will evaluate all information provided including medical questionnaires,physical exam findings, blood chemistry and urinalysis results, preexisting medical conditions, nature ofwork to be performed, actual and potential hazards and exposures, and other factors deemed appropriateby the physician for determining the following for each employee:

• Ability to perform relevant occupational tasks

• Ability to use respiratory protection

• Ability to work in other PPE and heat/cold stress environments

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• Requirement for entry into substance-specific medical surveillance programs.

If the OMP does not have sufficient inforination to complete a medical evaluation before respiratortraining, the employee's supervisor will be notified. The employee will not be permitted to fit test untilthe needed information is provided and any additional examination or testing is completed.

5.1 Subcontractor Workers

Subcontractor task-site personnel shall participate in a subcontractor medical surveillance programthat satisfies the requirements of OSHA 29 CFR 1910.120/1926.65. This program must make availablemedical examinations before assignment, annually, and after termination of hazardous waste duties. Thephysician's written opinion will serve as documentation that subcontractor personnel are fit for duty.

Medical data from the subcontractor employee's private physician, collected pursuant to hazardousmaterial worker qualification, shall be made available to the LMITCO OMP physicians upon request.Also, subcontractor employee past radiation exposure histories must be submitted to LMITCO radiationdosimetry and records section, in accordance with the LMITCO Radiological Control Manual, MCP-188,"Issuance of Thermolumincescent Dosimeters (TLDs) and Obtaining Personnel Dose History$ andMCP-2381, "Personnel Exposure Questionnaire."

5.2 Injuries on the Task Site

It is LMITCO's policy that an OMP physician examine all injured LMITCO personnel, if theinjury occurs on the job. The OMP will examine subcontractor injuries, will stabilize subcontractoremployee injuries (as required), then refer the injured to the subcontractor's physician for further and finaltreatment. An OMP physician will examine all personnel, including subcontractor personnel, if anemployee is experiencing signs and symptoms consistent with exposure to a hazardous material, or ifthere is reason to believe that an employee has been exposed to toxic substances or physical orradiological agents in excess of allowable limits.

In the event of a known or suspected injury or illness due to exposure to a hazardous substance orphysical or radiological agent, the employee(s) shall be transported to the nearest LMITCO medicalfacility for evaluation and treatment, as necessary. The CE is responsible for obtaining as much of thefollowing information as is available to accompany the individual to the medical facility:

• Name, job title, work (task-site) location, and supervisor's name and phone number

• Substances, physical or radiological agents (known or suspected); material safety data sheet(MSDS), if available

• Date of employee's first (known) exposure to the substance, physical or radiological agent

• Locations, dates, and results of any airbome exposure monitoring and/or sampling

• PPE in use during this work (for example, type of respirator and cartridge used)

• Number of days per month PPE has been in use

• Anticipated future exposure to the substance, physical or radiological agent.

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Further medical evaluation will be determined by the treating/examining physician according to thesigns and symptoms observed, hazard involved, exposure level, and specific medical surveillancerequirements established by the OMP director in compliance with 29 CFR 1910.120/1926.65.

The RWMC shift supervisor will be contacted if any injury or illness occurs at any OU 7-13/14project site. As soon as possible after an injured employee has been transported to the LMITCO medicalfacility, the CE or designee will make notifications as indicated in Section 11.4.5 of this HASP.

RADCON personnel will evaluate all actual and/or suspected abnormal radiological exposures inexcess of allowable limits and will establish the follow-up actions. For internal uptakes (as calculatedcommitted effective dose equivalent values), LMITCO EDF- INEL003, "Established Levels ofRadionuclide Intake for Consideration of Medical Interventioe will be used as the basis for thisevaluation and follow-up actions. All wounds will be examined by an OMP physician to determine thenature and extent of the injury. The physician will determine if the wound can be bandaged adequatelyfor entry into a radiological contamination area in accordance with Article 542 of the LMITCORadiological Control Manual.

Baseline and project termination bioassay samples will be submitted by selected project personnel(as determined by RADCON) due to Pu isotopes being present in the Pits 4 and 10 (or Pit 6 ifinvestigated). If any uptake event is suspected, an additional sample will be submitted for analysis inaccordance with MCP-191, "Radiological Intemal Dosimetiy."

5.3 Substance-Specific Medical Surveillance

The only contaminants of concern at Pits 4 and 10 (or Pit 6 if investigated) that would potentiallyrequire additional substance-specific regulatory medical surveillance are asbestos, cadmium, lead, andberyllium. The release potential from these contaminants is considered low, and no occupationalexposures approaching the regulatory substance-specific action limits are anticipated. This is based onthe potential quantity of material present (Table 8-3), distribution and mixing of these contaminants fromflooding and subsidence events, material matrix (contained core samples) and manner that they will bebrought to the surface (compacted core samples inside inner Lexan or metal two piece), engineering andadministrative controls, and worker training. Section 8 details specific contaminants and evaluates thepotential for exposure for each in Table 8-4.

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6. ACCIDENT PREVENTION PROGRAM

The OU 7-13/14 subsurface investigation project activities present numerous potential chemical,radiological, and physical hazards to personnel condueting the required tasks. It is critical that allpersonnel understand and follow the task-specific requirement of this HASP. Engineering controls,hazard isolation, specialized work practices, and the use of PPE will all be implemented to eliminate ormitigate all potential hazards and exposures. However, every person on the project site must play theirrole in the identification and control of hazards.

6.1 Voluntary Protection Program

The INEEL's safety process embraces the Voluntary Protection Program (VPP) criteria, principles,and concepts as part of Operational Excellence. All levels of management are responsible forimplementing safety policies and programs and for maintaining a safe and healthful work environment.OU 7-13/14 project personnel and subcontractors are expected to take a proactive role in preventingaccidents, ensuring safe working conditions for themselves and fellow personnel, and complying with allwork control documents and approved procedures.

VPP is a process that promotes and encourages continuous safety improvement. VPP is not arequirement of any regulatory agency. LMITCO and subcontractors participate in VPP voluntarily for thesafety of their employees. VPP incorporates five key elements:

1. Management Commitment to safety and health is demonstrated through their visibility in theworkplace and providing the necessary resources.

2. Employee Involvement means that employees have an active and meaningful role incontributing to the structure and operation of the safety and health program. Thisinvolvement results in ownership of the safety and health program by all employees.

3. Work Site Analysis includes analysis of new facilities and processes, comprehensive safetyand health surveys, routine self-assessments, a reliable system for employees to reporthazards, and an accident/incident investigation system and trend analysis.

4. Hazard Prevention and Control means that written safety rules and safe work practices mustbe in place to eliminate and/or control hazards.

5. Safety and Health Training is provided to all employees to ensure that they know what theirresponsibilities are and what is necessary to protect them from safety and health hazards.

6.2 General Safe-Work Practices

The following procedures are mandatory for all LMITCO and subcontractor personnel working onthe OU 7-13/14 project site. All site visitors entering the task site area (SZ and beyond) must followthese procedures. Failure to follow these practices may result in permanent removal from theOU 7-13/14 project site and other disciplinary actions. The CE and HSO are responsible for ensuringthese hazard control practices are followed at the OU 7-13/14 project site:

• Limit access to authorized LMITCO, subcontractor, and visitor personnel only.

• All personnel have the authority to initiate STOP WORK actions. LMITCO Safety andHealth Manual - 14A, MCP-553, "Stop Work/Shut Down Actiorr shall be used.

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• Absolutely no eating, drinking, chewing gum or tobacco, smoking, applying cosmetics, orany other practice that increases the probability of hand-to-mouth transfer and ingestion ofmaterials except in designated zone(s).

• Be aware of and comply with all safety signs, color codes, and barriers. Adhere to LMITCOSafety and Health Manual - 14A, MCP-2714, "Safety Signs, Color Codes, and Barriers."

• Be alert for dangerous situations, strong or irritating odors, airbome dusts or vapors, andbroken containers. Report all potentially dangerous situations to the CE or HSO.

• Avoid direct contact with potentially contaminated substances. Do not wall: through spillsor other areas of contamination. Avoid kneeling, leaning, or sitting on equipment or groundthat may be contaminated.

• Be familiar with the physical characteristics of the task site, including, but not limited to:

Wind direction

Accessibility of fellow personnel, equipment, and vehicles

Communications at the task site and with other nearby facilities

Areas of known or suspected contamination

Major roads and means of access to and from the task site

Nearest water sources and fire fighting equipment

Warning devices and alarms

Capabilities and location of nearest emergency assistance.

• Report all broken skin or open wounds to the HSO or CE. A LMITCO physician willdetermine if the wound presents a significant risk of internal chemical or radiologicalexposure. The OMP physician will consider how the wound can be bandaged and willrecommend PPE to be wom by the injured employee. Personnel with unprotected woundsshall not be permitted to enter chemical or radiological CAs, nor shall they handlecontaminated or potentially contaminated materials at the task site without havingbeen examined by a LMITCO OMP physician.

• Prevent releases of hazardous materials, including those used at the task site. If a spilloccurs, try to isolate the source (if possible and if this does not create a greater exposurepotential), then report it to the CE or HSO. The RWMC shift supervisor will be notified andadditional actions taken as described in Subsection 11.1.4. Appropriate spill response kits,or other confinement and absorbent materials, will be maintained at the task site.

• Avoid unnecessary and excessive movement during decontamination.

• Electrical equipment, wiring, cables, switches, and current overload protection will meetapplicable regulations and be maintained in a manner that provides protection for projectpersonnel from shock hazards, injury, and prevents property damage. Ground-faultprotection will be provided whenever outdoor electrical equipment is used.

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• Keep all ignition sources at least 15 m (50 ft) from explosive or flammable environmentsand use nonsparking, explosion-proof equipment if advised to do so by a safety professional.

• Personnel working in the exclusion or controlled access zone shall implement the "buddysystem" (see Subsection 6.5 of this HASP).

• Proceed directly to a radiological survey station upon leaving a radiologically contaminatedzone. Care should be taken not to touch the face, mouth, and eyes before a survey has beenperformed.

• Personnel who wear contact lenses shall comply with the LMITCO Safety and HealthManual - 14A, MCP-2716, "Personal Protective Equipment."

6.3 ALARA Principles

Radiation exposure of OU 7-13/14 personnel shall be controlled such that radiation exposures arewell below regulatory limits, and there is no radiation exposure without commensurate benefit.Unplanned and preventable exposures are considered unacceptable. All project tasks will be evaluatedwith the goal of eliminating or minimizing exposures. Following ALARA principles and practices is theresponsibility of all project personnel. All personnel working at the OU 7-13/14 project site must striveto keep both extemal and internal radiation doses ALARA by adopting the following practices.

6.3.1 External Radiation Dose Reduction

Sources for external radiation exposure at the OU 7-13/14 project site include waste in Pits 4 and10 (or Pit 6 if investigated), potential "shine from open coreholes, adjacent pits or trenches as determinedby the RCT, and core samples and equipment brought to the surface following down-hole advancement.Basic protective measures used to reduce extemal doses include minimizing time in radiation areas,maximizing the distance from the source of radiation, and using shielding whenever possible. Thefollowing are methods to minimize extemal dose:

Methods for Minimizing Time

• Use mock-ups and practice runs that will duplicate OU 7-13/14 subsurface investigationactivities.

• Plan and discuss the tasks prior to entering radiation area (including having all equipmentand tools prepared).

• Perform as much work as possible outside radiation areas and take advantage of lower doserate areas (as shown on the radiological survey maps).

• Take the most direct route to the tasks site and work efficiently.

• If problems occur in the radiation areas, hold technical discussions outside radiation areas,then retum to the work area to complete the task.

• If stay times are required, know your stay time and use appropriate signal andcommunication method to let others in the area know when the stay time is up.

• Know your current dose and your dose limit. DO NOT EXCEED YOUR DOSE LIMIT.

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Methods for Maximizing Distance from Sources of Radiation

• Use remote operational controls for the drill rig whenever possible.

• Follow administrative procedural controls for drilling operations (TPR-179) and downholelogging (PLN-496) and use the provided extension tool for placement of the sealed source inthe activated logging tool

• Stay as far away from the source of radiation as possible (extremely important for pointsources where, in general, if the distance between the source is doubled, the dose rate falls toVt the original dose rate).

• Know the most recent OU 7-13/14 subsurface project radiological survey map high and lowdose rate locations and take advantage of low dose rate areas.

Proper Use of Shielding

• Take advantage of the site equipment and enclosures for shielding yourself from radiationsources.

• Keep the logging sealed source in a secure shielded configuration (storage cask or loggingtool) when not in use

• Wear safety glasses and full-facepiece resp rator (depending on task) to protect eyes frombeta radiation

• Remove core sections for drill string and cap ends as soon as possible. Following corecapping, place cores in drum or other shielded container away from primary work area.

6.3.2 Internal Radiation Dose Reduction

An internal radiation dose potential exists at the OU 7-13/14 subsurface investigation project sitefrom radiological contamination present in the pits. Sources include sludges and debris, waste containers(bags, boxes, and drums), and contaminated soils surrounding breached containers. An intemal dose is aresult of radioactive material being taken into the body. Radioactive material can enter the body throughinhalation, ingestion, absorption through wounds or injection from a puncture wound. Reducing thepotential for radioactive material to enter the body is critical to avoid intemal dose. The following aremethods to minimize internal radiation dose:

• Wear respiratory protection required for the task, perform all leak checks, and inspect allPPE prior to entering contamination areas (CAs)

• Know the OU 7-13/14 subsurface investigation project's radiation exposure potential andknown high and low contamination sources, locations, and minimize or avoid activities inthese areas

• Use HEPA exhaust systems

• When inside CAs, do not touch your face (adjust glasses or PPE) or touch other exposed skin

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• When exiting CAs, follow all posted instructions and remove PPE in the order prescribed (ifquestions arise, ask RADCON personnel)

• Conduct whole body personal survey when exiting CA, then proceed directly to the personalcontamination monitor (PCM)

• Report all wounds or cuts (including scratches and scrapes) before entering radiological CAs

• Wash hands, face, etc., before eating, drinking, smoking, or other activity that may provide apathway for contaminants.

6.4 Nonradiological Contaminant Exposure Avoidance

The waste in Pits 4, 10, and 6 is a "mixer waste containing both radiological and nonradiological(organic and inorganic chemicals and hazardous materials) constituents. Table 8-3 in Section 8 lists thedominant nonradiological contaminants to be encountered by the subsurface investigation of Pits 4, 10,and 6. The same potential exposure pathways that exist for radiological contamination apply equally tothese nonradiological contaminants. Each contaminant has distinct physical, chemical, and mechanicalproperties that determine its toxicity. Threshold limit values (TLVs) have been established to provideguidelines in evaluating airborne and skin exposure to these chemicals and materials. They representlevels and conditions under which it is believed that nearly all workers may be exposed day after daywithout adverse health effects. Based on these TLVs, specific action limits have been established(Table 8-7) to further limit the potential for approaching these contaminant TLVs.

The same engineering controls employed to eliminate or mitigate airborne radioactivity (11EPAexhaust and isolating the waste material in inner cores) will serve to control nonradiological airbornecontaminants. Every effort will be made to isolate the source of these hazards through engineeringcontrols and confinement where feasible. Some of these contaminants pose other exposure hazards fromcontact and skin absorption and the implementation of avoidance practices will serve to minimize thepotential for exposures. Methods of exposure avoidance at the OU 7-13/14 subsurface investigationproject site include:

• Ensuring all HEPA systems are operating when the DSE must be opened or handled

• Collecting core samples directly into confinement bags to isolate the source ofcontamination

• Wearing all required PPE, inspecting all pieces before donning, taping all seams

• Changing gloves frequently (if contamination is detected) to prevent the spread ofcontamination

• Changing PPE if it becomes damaged or soiled with contaminant source material (sludge,waste residue, etc.)

• Containerize core samples in shipping containers to avoid handling twice

• Minimize time in known or suspected contamination areas (vapors, sludges, waste residue)

• Doff PPE following radiological instructions and perform personal whole body survey asdirected by the task RWP (if radiological contamination is present, it is likely that other

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nonradiological forms of contamination are also present—if contamination is found, performdecontamination for both)

• Wash hands, face, etc., before eating, drinking, smoking, or other activity that may provide apathway for contaminants.

6.5 The Buddy System

The "buddy system" will be used at the OU 7-13/14 subsurface investigation project site whenpersonnel are in the EZ. The buddy system requires employees to assess and monitor their buddy'smental and physical well-being during the course of the work day. Buddies must be able to:

• Provide assistance

• Verify the integrity of PPE

• Observe their partner for signs and symptoms of heat stress, cold stress, or contaminantexposure

• Notify other persoimel in the EZ if emergency assistance is needed.

Workers need to be able to see or hear and effectively communicate with their buddy at all timeswhen in the EZ. Task-site personnel will continually check their "buddy" while work is performed inthe EZ.

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7. SITE CONTROL AND SECURITY

Based on the known and expected levels of radiological and chemical contamination present in theburied waste, work zones/radiological areas will be established for the OU 7-13/14 subsurfaceinvestigation project task sites. The OU 7-13/14 subsurface investigation project task sites include, Pits 4and 10 (and Pit 6 if investigated). Entry into and exit out of task site work zones will be controlledthrough the appropriate use of barriers, signs, and other measures that are described in this section (MCP-2714, "Safety Signs, Color Codes, and Barriers" defines general requirements). Personnel not directlyinvolved with OU 7-13/14 subsurface investigation activities shall be excluded from entering work zones.Nonfield team members, such as inspectors, may be admitted to the OU 7-13/14 project task sitesprovided they are on official business, authorized by the HSO, and have met all the training requirementsfor the area they wish to access in accordance with Section 4 of this HASP.

Note: Visitors may not be allowed beyond the SZ during certain OU 7-13/14 project site high hazardtasks (e.g., probehole completion, drill rig movement, core drilling, instrument installation, and others asdetermined by the HSO) to minimize safety or health hazards or as an ALARA consideration. Thedetermination as to any visitor's "neee for access beyond the SZ at the OU 7-13/14 project site will bemade by the HSO in consultation with RWMC RADCON personnel.

Both radiological and nonradiological hazards (including industrial safety hazards) will beevaluated when establishing the initial zone locations and size. The entire work area will be covered witha geotextile to isolate personnel and equipment from the overburden soil of the pit being investigated.Common barriers may be used to delineate both radiological and nonradiological work-zone postings,depending on the nature and extent of contamination. If common barriers are used, they will bedelineated and posted according to both sets of requirements (29 CFR 1910.120 and 10 CFR 835) usingappropriate colored rope and postings.

Work zones will include:

• EZ

• Contamiriation reduction zone (CRZ), including a contamination reduction corridor (CRC).(the CRC may not be posted but is the primary pathway from the CRZ to the EZ)

• SZ.

Figure 7-1 illustrates the appropriate zones that will be established for each OU 7-13/14 task site(i.e., Pits 4 and 10; or 6 if investigated). This figure represents the general configuration of anOU 7-13/14 work zone and is not meant to provide an exact layout or configuration of all equipment orzone sizes. Several factors may result in changing cause zone configurations, size, and location. Theseinclude: the pit (i.e., 4, 10, or 6) being investigated, evolution of project tasks, site monitoring data, andchanging wind direction. Additionally, entrances and egress points may change based on these samefactors. Changes in zone configuration and size will be the decision of the HSO in conjunction with theIH, RE, RCT, and FTL (as appropriate).

The LMITCO Radiological Control Manual, MPC-187, "Posting Radiological Control Areas"shall be used for posting and controlling access to radiologically controlled areas at the OU 7-13/14subsurface investigation project site. RADCON personnel at the OU 7-13/14 subsurface investigationproject site will establish radiologically controlled areas. Figure 7-2 illustrates a generalizedconfiguration for additional radiologically controlled areas within the EZ that will be established duringcoring and instrument installation tasks.

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EZEntranc

Exit

TANRMACargo Container

(or CSA)

GeneralizedPit Boundaries

EZ

mCRC:

• Personnel Exit •

CRCEntrance &

Equipment Exit

SZ

Drill ControlPanel

Structure

Note: Entire project site is locatedwithin the RWMC SDA Radiologicalbutler zone areas (RBA) undergroundradioactive material area.

RAD Trailerwith PCMs

FieldTrailers

not to scale

LegendCRC - Contamination Reduction CorridorCRZ - Contarnination Reduction ZoneCSA - CERCLA Storage AreaEZ - Exclusion ZonePCM - Personal Contamination MonitorRBA - Radiological Buffer AreaRMA - Radioactive Material AreaSZ - Support ZoneTAA - Temporary Accumulation Area

Figure 7-1. General work zones for the OU 7-13/14 subsurface investigation project site.

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RAM(as required)

RA Boundary

TAA/RMACargo

Container(or CSA)

l 0 l

Waste and PPE

A

SonicDri

Airline Exit ContainersConnection onlyDrop Box

1SP 1

<• ca"•-• 0 SP 2cctieC

0 013

I- - - -

EntranceOnly

•••

CAM or airmonitoringinlet hose

n

CAM or airmonitoringinlet hose

CRC/SZ line(see Figure 7-1)

RAD Trailerwith PCM

EZ

CA Entry only required forcoring activities not required forprobing activities.

Note: Entire project site islocated within the RWMCSDA Radiological buffer zoneareas (RBA) undergroundradioactive material area.

not to scale

Legend

CA - Contamination AreaCAM - Continuous Air MonitorCRC - Contamination Reduction ZoneCSA - CERCLA Storage AreaEZ - Exclusion ZonePCM - Personal Contamination

Monitor (survey station)

RA -RAM -RMASP-1 -SP-2 -SZTM -

Radiation Ar eaRad ati on Ar ea Mori tor

- Rad oacli ve Material AreaStep Off PadStep Off Pad 2

- Suppor t ZoneTempor ary Accum dation Ar ea

Figure 7-2. A generalized radiological control area configuration for the OU 7-13/14 project task sites.

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These will include:

• Radiological buffer area (RBA) (which is the entire SDA)

• Radiation area

• High Radiation Area (if required due to dose rate from logging source)

• Contamination area (CA) with transition tent areas

• Radioactive material area(s) (RMA)

• Underground Radioactive Material Area

• Radiological Control trailer (CRC/SZ line) with a personal contamination monitor (PCM).

7.1 Exclusion Zone

The EZ will be large enough to encompass the primary task area (e.g., drilling, logging, surfacegeophysics, etc.) and to allow equipment and personnel to move about freely and conduct necessaryequipment and material handling tasks. The minimum number of personnel required to safely perform theOU 7-13/14 subsurface investigation project tasks will be allowed into the EZ. Since the drill rig andlogging tripod assembly will be moving between probehole locations, the EZ will initially encompass anarea large enough to prevent nonfield team personnel in the support zone from being exposed to potentialsafety and health hazards.

The EZ is a controlled access zone at all times. An entry and exit point will be established at theperiphery of the EZ/CRC to regulate the flow of personnel and equipment. The EZ boundary will bedelineated with rope or printed hazard ribbon and posted with signs. Factors that will be considered whenestablishing the EZ boundary include: tasks being conducted, air monitoring data, radiologicalcontamination data, radiation fields, equipment in use, the physical area necessary to conduct siteoperations, and the potential for contaminants to be blown from the area. The boundary may be expandedor contracted, as this information becomes available.

Radiologically controlled areas will be established within the OU 7-13/14 subsurface investigationproject EZ during coring and instrument installation tasks to restrict the movement of personnel,equipment, and bagged core samples in order to prevent the potential spread of contamination. Theseareas will include a CA (immediately around the corehole installation and drilling/sampling activities),transition tent for exiting the CA (Figure 7-2). This transition tent may be posted as a radiologicalcontamination RBA at the discretion of RADCON.

There will be designated entry and exit points for the CA. The contaminated and potentiallycontaminated PPE will be containerized in the CA until fully characterized. All items (including PPE,equipment, debris, etc.) generated should be considered potential CERCLA mixed waste until furthercharacterization is completed per MCP-444, "Characterization Requirements for Solid and HazardousWaste." The disposition of investigation derived waste generated by the installation of probeholes isdescribed by Becker et al. 1999. The field sampling plan cun•ently under development will address IDWissues associated with the core hole drilling and sampling.

No equipinent will be released from the CA until a comprehensive radiological survey has beencompleted (hand-held instruments, swipes, etc.) in accordance with LMITCO MCP-139, "Radiological

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Surveys," and the equipment has met the radionuclide-specific unrestricted release criteria listed in DOEOrder 5400.5, Section II-5(c), and listed on Figure IV-1 (5400.5), or has been appropriately contained andlabeled.

All personnel who enter the EZ will wear the appropriate level of PPE for the degree and type ofhazards present as listed in Section 9. When Level B activities are taking place (Table 9-2), standbypersonnel will be stationed just outside the CA to respond to events inside the CA. These responders willdon a portion of the same Level B protective clothing, as the worker inside the CA, and have theremaining required respiratory protection and protective clothing ensemble in the immediate area. Thenumber of standby personnel will be determined on a task-by-task basis by the project HSO.

7.2 Contamination Reduction Zone and Corridor

The OU 7-13/14 subsurface investigation project's CRZ and CRC are transition areas surroundingthe EZ, and are located between the EZ and SZ (Figure 7-1). The CRZ and CRC will serve to buffer andfurther reduce the probability of the SZ becoming contaminated. The CRC will encompass an area largeenough to allow for equipment and personnel to travel through. All project personnel and equipment(except for the drill rig) entering and exiting the EZ will transition through the CRC. Physical transfer ofcontaminating substances on personnel, equipment, or in the air will be minimized through restrictingtraffic to these controlled areas. The CRZ and CRC may serve as staging areas for equipment andtemporary rest areas for personnel. Because of the potential for contamination (migration from airbornecontamination in the EZ), PPE and sample packaging and preparation equipment will be stored in the SZ.

As stated in the EZ section, all equipment and materials will be surveyed by RADCON personneland must meet the free release criteria before being released out of the CA or has been appropriatelycontained and labeled. If radiological or mixed contamination (nonradiological/radiological) is found,work will stop until a new RWP or ALARA Task is written, then radiological decontaminationtechniques will initially be used (as described in Section 10.2.2). One of the radiological decontaminationgoals is not to generate any free liquid. By using dry decontamination techniques (HEPA vacuum,adhesive tape, etc.) and avoiding wet methods, shielding problems (alpha contamination shielded bywater) will be minimized. If necessary wet methods will be used.

A nonradiological decontamination pad may be established if it is believed that residualnonradiological contamination is present on equipment following release from the CA. The OU 7-13/14subsurface investigation project IH will be responsible for nonradiological contamination issues anddetermining the most appropriate decontamination methods, as described in Section 10.2.2. A designatedportion of the CRC or other area will be established for the nonradiological decontamination ofequipment (if required). All decontamination supplies (nonradiological decontamination solution, Terwipes, etc.) and used nonradiological PPE and debris waste containers may be located in the CRC.

NOTE: The presence of radiological contamination, along with visual observations and IH direct readinginstruments (Table 8-6), will serve as the primary indicator for nonradiological contamination. Since theradiological instrumentation to be used typically yields detection limits much lower than traditional 11-1direct reading instruments for the waste expected to be encountered (data from previous SDAinvestigations have shown high radiological contamination levels in the RFP waste), it is not believed thatnonradiological contamination will be found at elevated concentrations without detectable radiologicalcontamination. Therefore, direct reading radiation/contamination instruments were serve as the primaryindicator of nonradiological contaminants.

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7.3 Support Zone

The SZ will be considered a radiological and nonradiological "clean" area. The location of the SZwill be in a prevailing upwind direction to the EZ (where possible) and readily accessible to the nearestroad. The SZ is a controlled area outside the CRZ. This area will be delineated using construction fenceor equivalent material to prevent nonproject personnel from entering the area and/or inadvertentlyentering a more restrictive work zone (e.g., CRZ or EZ). Support facilities (project management andRADCON trailers), project command center, vehicle parking, additional emergency equipment, extraPPE, and stored monitoring and sampling equipment may be located in the SZ. Visitors who do not hadappropriate training to enter other project areas will be restricted to this zone.

OU 7-13/14 subsurface investigation project site work zones and radiologically controlled areaswill be maintained during off-hours and weekends by ensuring they are in good condition prior to exitingthe project site for the day. These zones and areas will remain intact until all site tasks have beencompleted and equipment and supplies have been decontaminated and removed from the project site. TheCE, HSO, and RCT will ensure that site zones are posted and intact when leaving the site, and will beresponsible for breaking down the zones when site activities have been completed.

NOTE: Only RADCON personnel can post and remove radiological postings and raise and lowerradiological barriers. This will be accomplished in accordance with LMITCO Radiological ControlManual and MCP-187, "Posting Radiological Control Areas."

7.4 Designated Eating and Smoking Area

Ingestion of hazardous substances is likely when workers do not practice good personal hygienehabits. It is important to wash hands, face, and other exposed skin thoroughly after completion of workand before smoking, eating, drinking, and chewing gum or tobacco. No smoking, chewing, eating,applying lip balm, etc. or drinking is allowed within the OU 7-13/14 project site work zones. Allpersonnel who enter into the CA MUST complete a whole body survey as directed by the RWP. Prior toexiting the CRC into the SZ, all personnel will use the PCM station or equivalent survey method asdetermined by RADCON. As a minimum, all personnel should wash their hands prior to usingdesignated eating or smoking areas.

The designated eating areas for the OU 7-13/14 task-site personnel will be the RWMC designatedeating areas outside the SDA or outside the RWMC (e.g., CFA cafeteria).

Personnel will not be permitted to smoke in any of the OU 7-13/14 project site work zones (EZ,CRZ, CRC, or SZ). Only approved RWMC facility smoking areas or smoking areas located outside theRWMC will be used by project personnel. All smoking polices will be complied with includingdisposing of smoking materials in the proper receptacle.

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8. HAZARD ASSESSMENT AND MITIGATION

The overall objectives of this hazards assessment and mitigation section are to provide guidance onthe following:

• Evaluation of existing OU 7-13/14 (i.e., Pits 4, 10, and 6) buried waste contents whereintrusive activities will occur to determine the radiological, chemical, biological exposurepotential to OU 7-13/14 persoimel by all routes of entry (Pit 6 is included as the project maydecide to investigate this pit also)

• Evaluation of all OU 7-13/14 subsurface investigation project tasks to determine the extentthat existing radiological, chemical, and physical hazards may potentially impact task-sitepersonnel

• Establishment of the necessary monitoring and sampling required to continuously evaluateexposure and contamination levels and determine adequate action levels to mitigate potentialexposures and provide specific actions to be followed if action levels are reached

• Provide mitigating measures through the use of engineering controls, isolation methods forTRU mixed waste contamination from personnel, work practices to limit personnelexposure, administrative controls, and appropriate respiratory protection and protectiveclothing to protect task-site personnel from hazards.

8.1 OU 7-13/14 Site Activities Hazards

Personnel may be exposed to safety hazards, chemical, radiological, and physical agents whileworking at the OU 7-13/14 subsurface investigation project site. Buried waste in Pits 4, 10, and 6;historical detection of chemical and radiological soil contamination; and the radiation fields fromexposing buried waste from these pits (and potential "shine from adjacent waste pits, trenches or opencoreholes) all contribute to the potential hazards. Additionally, the use of the drill rig and loggingequipment in the investigated pit's EZ will present direct physical hazards to workers. The magnitude ofthese hazards to personnel entering the work zones is dependent on both the chemical/radiological natureof the contaminants encountered and the tasks being performed. Engineering controls (e.g., DSE) will beimplemented (whenever possible) along with adequate work practices, real-time monitoring ofcontaminants, and site-specific hazard training to further mitigate potential exposures and hazards.

The greatest exposure and hazard potential will occur when buried waste material is brought to thesurface inside the cores and as residue in the drill string and other equipment surfaces are handled insidethe DSE (sampling and instrument installation). It is assumed that all cardboard and wood boxes andapproximately 70% of all metal drums are breached and no longer provide an adequate layer of wasteconfinement based on past studies in the SDA and flooding that has occurred (McKinley and McKinney1978).

Pits 4 and 10 were selected because available information indicates they probably contain thecontaminants identified as risk drivers (Becker et al. 1998a). Pit 6 was selected as an alternative pit toinvestigate for the same reasoning. Based on soil gas survey data, the east end of Pit 4 has the highestorganic vapor concentrations. Pit 10 corresponds to one of the areas with high soil gas concentrations andreceived waste shipments containing uranium, plutonium, and americium. The exact number andplacement of probeholes and subsequently coreholes will be addressed in the field SAPs for theseactivities.

8-1

Table 8-1 summarizes each primary task, associated hazards and mitigation. Table 8-2 lists thedominant radiological contaminants that will Iikely be encountered during the project tasks, and Table 8-3lists the dominant nonradiological contaminants that present higher health hazards based on potentialquantity of material present.

Table 8-4 presents an evaluation of these radiological and nonradiological contaminants withrespect to potential routes of exposure and symptoms of overexposure. Additionally, the exposurepotential by all routes is stated based on quantity of material present, toxicity, distribution of containers inthe pit, known migration from containers, and likely matrix to be encountered during coring/samplingtasks (highest potential exposure task). Engineering and administrative controls, worker personalprotective clothing strategies, personnel monitoring, and restricted access to potential CAs will focus onthose contaminants that have been determined to present a "moderate to "high" exposure potential(Table 8-4). Several of the nonradiological contaminants listed (e.g., asbestos, cadmium) have extremelylow TLVs based on airborne exposure to these inorganic substances in their pure form. Due to the natureof the matrix that they exist in (sludge or moist soil), the mixing action that occurred during flooding andsubsidence, and the manner that they will be brought to the surface (compacted core samples inside innercore barrels) the release potential from these contaminants is considered low.

Pits 4 and 10 (and Pit 6, if investigated) subsurface investigation activities involve knownradiological hazards. Due to these hazards, it has been determined that a RWP, according to theRadiological Control Manual, MCP-7, "Radiological Work Pennit7 will be required for all Pit 4 and 10(and Pit 6, if investigated) activities. RADCON will use existing Engineering Design Files (EDFs) inaccordance with LMITCO Radiological Control Manual, MCP-6, "Engineering Design File and useMCP-352, "Conducting Airborne Hazard AnalysiC to evaluate potential airborne radiological exposures.

SWPs, RWPs, and Job Safety Analysis will be used in conjunction with this HASP to addresshazardous and radiological conditions at the project site. These permits will augment this HASP andfurther detail specialized protective equipment and dosimetry requirements. The industrial hygiene andradiological monitoring are outlined in Subsections 8.4.1 and 8.4.2, respectively.

8.2 Routes of Exposure

Exposure pathways for hazardous materials and radionuclides are directly related to the nature ofproject tasks planned for Pits 4 and 10 (and Pit 6, if investigated)—principally the intrusivedrilling/coring, sampling, and instrument installation activities. Engineering controls (DSE with HEPAfiltration), continuous monitoring, training, and work controls will mitigate potential contact and uptakeof these hazards; however, the potential for exposure exists. Exposure pathways include:

• Inhalation of radiologically contaminated organic compounds and fugitive dusts duringintrusive activities and core handling tasks. This contamination form may have traceamounts of inorganic compounds, and be contaminated with radionuclides resulting inpotential lung deposition

• Skin absorption and contact with radiologically contaminated organic and inorganiccompounds during drilling/sampling tasks that can be absorbed through

8-2

Table 8-1. Pits 4, 6, and 10 activities, associated hazards and Mitigation.

Activity or Task Associated Hazards or Hazardous Agent Hazard Mitigation

Mobilization and SitePreparation

(sonic drill rig and all supportequipment)

Soil Gas Surveys and SurfaceGeophysical Mapping

• Radiological contamination—subsurface soils

• Radiation exposure near Pits 4, 10, or 6

• Chemical/inorganic contaminants—subsurface soils

• Equipment movement/vehicle traffic--trailer(s)/drillrig/logging truck pinch points, and stnick-bypotential

• Lifting/backstrain—laying out geotextile, stagingdrilling materials

• Subsidence of soil from heavy equipment—on ornear Pits 4, 10, or 6.

• Heat/Cold Stress

• Radiological contamination—subsurface soils

• Radiation exposure--near Pits 4, 10, or 6/shinefrom adjacent waste pits or trenches

• Chemical/inorganic contaminants—subsurface soils

• Equipment movement/vehicle traffic—pinch pointsand struck-by potential

• Lifting/backstrain staging materials, lifting carts


• Only near surface intrusion, RCT surveys, RWP,dosimety, direct reading instruments

• Controlled areas, qualified operators, JSAs, SWP,TPRs

• Pipe racks, proper lifting techniques, two-personlifts

• Lifting plan, JSA, SWP, TPR, qualified HEOCoordination through RWMC shift desk prior towork

• IH monitoring, work-rest cycles (as required)

•

•

•

•

•

Only near surface intrusion, RCT surveys, RWP,dosimetry, direct reading instruments

Controlled areas, qualified operators, JSAs, SWP,TPRs

Coordination through RWMC shift desk prior towork

Proper lifting techniques, two-person lifts (asrequired)

IH monitoring, work-rest cycles (as required)

8-3



Probehole Installation andDownhole Logging

Coring, Sampling, andInstrument Installation

(Pits 4 and 10 soil/wastematerial. Pit 6, an altemate pit,

may be included at the discretion

of the OU 7-13/14 subsurfaceinvestigation project.)

Radiological contaminants—subsurface soil/waste ondrill string and logging equipment

Radiation exposure— logging source, Pits 4, 10, or 6buried waste residues contact handling/adjacent pit

shine

Chemical/inorganic contaminants—subsurfacesoil/waste, and potentially drill string and loggingequipment

Equipment movement/vehicle traffic—Crane, drill rig,pinch points and struck-by potential

Lifting/backstrain—drill string/case handhng/tripodassembly setup

Hazardous noise levels—open drill rig engine panel.

Heat/cold stress

Radiological Contaminants subsurface soil/wastecontact, drill string handling

Radiation exposure —Pits 4, 10, or 6 buried waste andresidues contact handling/shine from adjacent waste pits

or trenches

Chemical/inorganic contaminants—subsurfacesoil/waste, drill string, core surfaces

Organic vapors in corehole/DSE—VOCs

Equipment movement—Crane and drill rig movement

Lifting/backstrain—drill string/case handling

Hazardous noise levels—open drill rig engine panel

8-4

•

•

•

•

•

•

•

•

•

•

Only near surface intrusion, RCT surveys,dosimetry, subcontractor logging procedures

Controlled areas, qualified operators, JSAs, SWP,TPRs, PLN

Pipe racks, proper lifting techniques, two or threeperson lifts (three with logging tripod)

Lifting plan, JSA, SWP, TPR, qualified HEO andlogging engineer, and coordination through RWMCshift desk prior to work

Noise surveys and hearing protection (as required)

111 monitoring, work-rest cycles (as required)

Only near surface intrusion, RCT surveys,dosimetry, direct reading instruments

Controlled areas, qualified operators, JSAs, SWP,TPRs, PLN

Pipe racks, proper lifting techniques, two-personlifts

Lifting plan, JSA, SWP, TPR, qualified HEOCoordination through RWMC shift desk prior towork

Noise surveys and hearing protection (as required)




Equipment Decontamination • Radiological contaminants—wasteresidue/decontamination aerosols/particulatescontact, drill assembly handling

• Radiation exposure—waste residues contacthandling/shine from adjacent waste pits or trenches

• Chemical/inorganic contaminants—wasteresidue/decontamination aerosols/particulatesassembly

• Equipment movement/vehicle traffic—drill rig

• Lifting/backstrain—drill parts handling

(as required)

• Slip/trip/fall wet surfaces


• Only near surface intrusion, RCT surveys, RWP,dosimetry, direct reading instruments

• Controlled areas (indoors for large scale decon)

• Direct reading instruments

• Proper lifting techniques, two-person lifts (asrequired)

• Coordination through RWMC shift desk prior towork


8-5

Table 8-2. Dominant radiological contaminants of concern at the Pits 4,6, and 10 project site.°

Estimated Estimated EstimatedActivity in Correspondi Activity in Corresponding Activity in Corresponding

Pit 4 ng Mass Pit 6 Mass Pit 10 MassRadionuclide (Ci) (g) (Ci) (8) (Ci) (g)

Am-241 2.2E+04 6.39E+03 3.66E+03 1.06E+03 1.33E+04 3.86E+03

Np-237 1.31E-01 1.86E+02 1.38E-02 1.96E+01 1.76E-01 2.49E+02

Pu-238 4.33E+02 2.51E+01 4.74E+01 2.59E+00 1.75E+02 1.02E+01

Pu-239 9.51E+03 1.52E+05 1.58E+03 2.53E+04 5.69E+03 9.10E+04

Pu-240 2.19E+03 9.46E+03 3.53E+02 1.55E+03 1.27E+03 5.59E+03

Pu-241 5.72E+04 5.72E+02 9.53E+03 9.53E+01 3.49E+04 3.49E+02

U-234 3.18E-00 5.14E+02 1.31E-00 2.12E+04 6.17E-00 9.97E+02

U-235 4.99E-01 2.33E+05 7.32E-02 3.42E+04 4.44E-01 2.07E+05

U-236 1.63E-01 2.52E+03 4.26E-02 6.58E+02 2.08E-01 3.21E+03

U-238 6.47E-00 1.94E+07 2.94E-00 8.83E+06 8.44E-00 2.53E+07

a. Bruce Becker, personnel correspondence 1998.

b. Nature of the waste when it was buried, radioactive decay, or mixing of container contents is not taken into account.

8-6

Table 8-3. Dominant nonradiological contaminants of concern at the Pits 4, 6, and 10 project site.0

Chemical or CompoundEstimated Qty (kg)(in entire Pit 4)

Estimated Qty (kg)(in entire Pit 6)


Acetone 7 2 5

Aluminum Nitrate 16,700 6,990 13,900Nonahydrate

Ammonia 247 0 0

Asbestos 15 6 13

Benzine 1 0 0

Beryllium 406 4 g 1,270

2-Butanone 2 1 3

Butyl Alcohol 14 2 7

Cadmium 163 2 234

Carbon Tetrachloride 14,000 14,900 24,100

Ethyl Alcohol 2 1 2

Formaldehyde 34 0 0

Hydrofluoric Acid 654 273 542

Lead 50,700 13,100 49,000

Mercury Nitrate 71 29 58Monohydrate

Methyl Alcohol 32 5 15

Methylene Chloride 2,110 349 974

Methyl Isobutyl Ketone 776 324 644

Nitric Acid 4,250 1,740 3,460

Potassium Chloride 764 2,060 4,620

Potassium Nitrate 17,200 46,300 104,000

Potassium and Sodium 50 162 363Dichromate (as Cr)

Potassium Phosphate 382 1,030 2,310

Potassium Sulfate 764 2,060 4,620

Silver 0 0 0.4

Sodium Chloride 1,530 4,120 9,250

Sodium Nitrate 34,600 92,800 208,000

Sodium Phosphate 764 2,060 4,620

Sodium Sulfate 1,530 4,120 9,250

8-7


Chemical or CompoundEstimated Qty (kg)(in entire Pit 4)



Sulfuric Acid 14 4 8

Terphenyl 118 0 0

Tetrachloroethylene 3,030 3,340 5,370

Toluene 32 0 0

Tributyl Phosphate 87 36 72

1,1,1-Trichloroethane 12,500 12,300 20,200

1,1,2-Trichloro-1,2,2- 1,320 218 610Trifluoroethane

Trichloroethylene 11,800 13,000 20,900

Trimethylolpropane- 39 0 0Triester

Uranyl Nitrate 20 8 16

Xylene 135 12 33

Zirconium 4,130 5,710 689

Zirconium Alloys 415 173 504

a. Bruce Becker correspondence 1998.

b. Nature of the waste when it was buried, decomposition of organic materiel, or mixing of container contents is not taken intoaccount.

8-8

Table 8-4. Evaluation of radiological and nonradiological contaminants at the Pits 4, 6, and 10 project site.

Pit 4, 6, & 10 Materialor Chemical (CAS #,Vapor Density & Exposure Limit' Routes ofIonization Energy (PEL/TLV) Exposureb

Metals and Inorganic Compounds

Aluminum NitrateNonahydrate(7784-27-2)

Ammonia(7664-41-7)VD-0.61E-10.18 eV

Asbestos(12001-29-5)VD—NA

Beryllium(7440-41-7)VD—NA

TLV-TWA-2 mg(Al)/m3

TWA-17 mg/m3STEL-24 mg/m3

TLV-0.2 fiber/ccPEL-0.2 fiber/cc(29 CFR 1910.1101)

TLV-0.002 mg/m3Ceiling-0.005 mg/m3

Ih, Ig, S

Ih, Ig, Con

Ih, Ig, Con

Ih, Ig, Con

Symptoms of OverExposure' (Acuteand Chronic)

Severe eye irritation,irritating to mucusmembranes and upperrespiratory front, upperand skin irritation

Irritation to skin, eyes,and respiratory tract.Toxic by inhalation.

Irritation of eyes andskin, chronic asbestosis,restricted pulmonaryfunction

Respiratory, eyes,dermis, chest pain(chronic-berylliosis)

TargetOrgans/System

Behavioral(somnolence),skin andappendages(hair)

Eyes/Respiratory No—NIOSHtract No—ACGIH

Eyes/Respiratory Al—ACGIHtract Yes—NTP

Yes—IARCYes—OSHA

Eyes/Respiratory Yes—NTPtract, skin Yes—IARC

No—OSHA

Carcinogen?(source)l

Exposure Potential'(all routes without regard

to PPE)

No Moderate Potential

Distributed in pits and mayhave migrated from drums.

• 16,700 kg in Pit 4)

(P, 6,900 kg in Pit 6)

(Pz. 13,900 kg in Pit 10)

Low PotentialDistributed in Pit 4 and mayhave migrated from drums.

(g--. 247 kg in Pit 4)

(P.- 0 kg in Pit 6)

(-P. 0 kg in Pit 10)

Low PotentialSource from pipe insulationand ACBM. Airbome releasefraction would be nominal tolow due to matrix (coresample)

(= 15 kg in Pit 4)

(gg 6 kg in Pit 6)(P.: 13 kg in Pit 10)

Moderate-High PotentialDistributed indnims containing 740 series'sludge from RFP.(ge. 406 kg in Pit 4)(P-. 4 kg in Pit 6)(g-- 1,270 kg in Pit 10).


Pit 4, 6, & 10 Materialor Chemical (CAS #,Vapor Density &Ionization Energy

Cadmium(7440-43-9)VD—NA

Hydrofluoric Acid(7664-39-3)VD-0.71E-15.98 eV

Lead(7439-92-1)

o VD—NA

Mercury NitrateMonohydrate(7783-34-8)

Exposure Limit'(PEL/TLV)

TLV-0.01 mg/m3*TLV-0.002 mg/m3**PEL-0.005 mg/m3(29 CFR 1910.1027)

* - inhalable fraction** - respirable fraction

TWA-3 ppm(2.5 mg/m3)

TWA-PEL-3 ppm(2.5 mg/m3)

TLV-0.05 mg/m3PEL-0.05 mg/m3(29 CFR 1910.1025)

Routes ofExposureb

lh, Ig

lh, Ig, S,Con


Respiratory, nervoussystem, irritation ofmucous membranes,dryness of mouth,headache

Irritation eyes, skin,nose, throat; pulmonaryedema; eye, skin bums;rhinitis; bronchitis;bone changes

lh, Ig, Con Lassitude, weight loss,anemia, nausea,vomiting, paralysis,constipation

TLV-TWA-0.025 S, Ihmg(Hg)/m3

Extremely destructiveto mucus membrane,upper respiratory tract,eyes and skin. Bumingsensation, coughing,wheezing, laryngitis,short breath, headache,nausea, vomiting.

TargetOrgans/System

Kidneys/respiratory tract,blood, prostate

Eyes, skin,respiratorysystem, bones

GI tract, centralnervous system,kidneys, blood,gingival tissue

Skin, kidneys,G.I. systemnerves, blood


to PPE)

Low PotentialNumerous trace sources addedduring several shipments.(a.- 163 kg in Pit 4)(z 2 kg in Pit 6)

(z 234 kg in Pit 10)

High PotentialDistributed in the pits and mayhave migrated from drums.(z 654 kg Pit 4)(z: 273 kg Pit 6)(z 542 kg Pit 10)

No Moderate Potential Sourcesinclude shielding, aprons,gloves, and uncementedsludge.

(z 50,700 kg Pit 4)

(z 13,100 kg Pit 6)

(z. 49,000 kg Pit 10)

No Low PotentialDistributed in the pits and mayhave migrated from drums.

(z. 71 kg Pit 4)(z. 29 kg Pit 6)(z 58 kg Pit 10)

Carcinogen?(source)d

Yes—NTPYes—IARCA2—ACGIHYes—OSHA

No—NIOSH

No—ACGIH

00



Nitric Acid(7697-37-2)VD-2 to 31E-11.95 eV

Potassium chloride(7447-40-7)VD-NA

Potassium dichromate(7778-50-9)VD-10

Potassium nitrate(7757-79-1)VD — 3


ACGIH

TWA-2 ppm(5 mg/m3)STEL-4 ppm(10 mg/m3)

OSHA

PEL-TWA-2 ppm(5 mg/m3)

None established

TLV-0.05 mg/md** Chromate

None established

Routes ofExposureb

Ih, Ig, Con

Symptoms of OverExposure(Acuteand Chronic)

Irritation eyes, skin,mucous membrane;delayed pulmonaryedema, pneumonitis,bronchitis; dentalerosion

lh, Ig, Con Eyes, irritation ofmucous membranes

Ih, Ig, Con Respiratory, eyes,dermis, skin irritation,discoloration, mucousmembrane ulcerating,perforated septum

Ih, Ig, Con Respiratory irritation,(Ig—GI pain, nauseaand vomiting)

TargetOrgans/System

Eyes, skin,respiratorysystem, teeth

None identified,primarily alocalized irritant

Skin




to PPE)

No High PotentialDistributed in the pits and mayhave migrated from the drums.

(ft 4,250 kg Pit 4)(ft 1,740 kg Pit 6)(ft 3,460 kg Pit 10)

No Moderate PotentialDistributed in thedrums containing 740 series'sludge from RFP.(ft 764 kg Pit 4)(ft. 2,060 kg Pit 6)(ft 4,620 kg Pit 10)

Yes—NPT Moderate PotentialYes—IARC Drums containing 740 series'No—Z List evaporator salt distributed inNo—OSHA the pit. High pH matrix

increases K2Cr207 potential.(ft 22 kg Pit 4)(ft 59 kg Pit 6)(ft 32 kg Pit 10)

No Moderate-High PotentialDistributed in thedrums containing 740 series'sludge from RFP(ft 17,200 kg Pit 4)(ft 46,300 kg Pit 6)(ft 104,000 kg Pit 10)



Potassium phosphate(7778-77-0)VD-NA

Potassium sulfate(7778-80-5)VD-NA

Silver(7440-22-4)VD-NA

Sodium chloride(7647-14-5)VP-NA

Symptoms of Over Exposure Potential'

Exposure Limita Routes of Exposure' (Acute Target Carcinogen? (all routes without regard

(PEL/TLV) Exposureb and Chronic) Organs/System (source)d to PPE)

None established Ih, Ig, Con Eyes, minor skinirritation


No Moderate PotentialDistributed in thedrums containing 740 series'sludge from RFP.

None cstablished

TLV-0.01 mg/m3

None established

lh, Ig

Ih, Ig, Con

None identified

Respiratory, blue-grayeyes, skinirritation andulceration, GIdistention

Ih, Ig, Con Eyes, irritation ofmucous membranes

None identified No

Nasal septum,skin, eyes


(Az 382 kg Pit 4)

(it, 1,030 kg Pit 6)

(t, 2,310 kg Pit 10)

Low-Mod PotentialDistributed in thedrums containing 740 series'sludge from RFP.0: 764 kg Pit 4)(P.: 2,060 kg Pit 6)(2-- 4,620 kg Pit 10)

No Low PotentialOnly trace amount in Pit 10,distributed during severalshipments.(az 0.4 kg in Pit 10)Moderate PotentialDistributed in thedrums containing 740 series'sludge from RFP.(t', 1,530 kg Pit 4)(t: 4,120 kg Pit 6)

(g-- 9,250 kg Pit 10)

No



Sodium dichromate(10588-01-9)VD-10

Sodium nitrate(7631-99-4)VD-2.9

Sodium phosphate(7558-79-4)VD-4.9

Sodium sulfate(7757-82-6)VD-NA

Symptoms of OverExposure Limie Routes of Exposure' (Acute Target(PEL/TLV) Exposureb and Chronic) Organs/System

TLV-0.05 rng/m3** Chromate

Ih, Ig, Con Respiratory, eyes, skinirritation or ulcerating

Kidneys, liver

None established

None established

None established

Ih, Ig, Con Respiratory, eyes,dermis, (Ih/Ig maycause cyanosis)

lh, Ig, Con Respiratory, eyes,dermis

lh, Ig, Con Respiratory, eyes,dermis



to PPE)

Yes—NPT* Moderate PotentialYes—IARC* Drums containing 740 series'Yes—Z List* evaporator salt distributed inYes- OSHA* the pit. High pH matrix*Cluomium increases Na2Cr207 potential.

(z 38 kg Pit 4)(r-: 103 kg Pit 6)(-4, 231 kg Pit 10)

None identified, No High Potential Distributed inprimarily a the drums containing 740localized irritant series' sludge from RFP.

(gz 34,600 kg Pit 4)

(al 92,800 kg Pit 6)(Az 208,000 kg Pit 10)

None identified, No Moderate Potentialprimarily a Distributed in thelocalized irritant drums containing 740 series'

sludge from RFP.(= 764 kg Pit 4)

2,060 kg Pit 6)(z 4,620 kg Pit 10)

None identified, No Low Potentialprimarily a Distributed in thelocalized irritant drums containing 740 series'

sludge from RFP.

(it., 1,530 kg Pit 4)

4,120 kg Pit 6)(A-- 9,250 kg Pit 10)



Sulfuric Acid(7664-93-9)VD-3.4IE-

Uranium—insolublecompounds, as U(7440-61-1) (metal)VD-NAIE

Uranium—solublecompounds, as U(none)VD-IE-


ACGIII

TWA-1 mg/m3STEL-3 mg/m3

OSHA

PEL-TWA-1 mg/m3

TWA-0.2 mg/m3STEL 0.06 mg/m3

OSIIA

PEL-TWA0.25 mg/m3

TWA-0.05 mg/m3

Symptoms of OverRoutes of Exposure' (AcuteExposureb and Chronic)

Ih, Ig, Con Irritation eyes, skin,nose, throat; pulmonaryedema, bronchitis;emphysema;conjunctivitis; stomatis;dental erosion;tracheobronchitis; eye,skin bums; dermatitis

IH, IG, Dermatitis; kidneyCon damage; blood changes;

(Potential occupationalcarcinogen); in animals;lung, lymph nodedamage.

Ih Ig, Con Dermatitis; kidneydamage; blood changes;Potential occupationalcarcinogen); in animals;lung, lymph nodedamage.

TargetOrgans/System

Eyes, skin,respiratorysystem, teeth

Skin, kidneys,bone marrow,lymphaticsystem, lungcancer

Skin, kidneys,bone marrow,lymphaticsystem, lungcancer

Carcinogen?(source)j


to PPE)

No Low PotentialDistributed in thedrums containing 740 series'sludge from RFP.

(- 14 kg Pit 4)4 kg Pit 6)

(m 8 kg Pit 10)

YES—NIOSH(Potential)

YES—NIOSH(Potential)

Moderate-High PotentialDistributed in the pits. Most isin solid non-soluble form,from metals, filters, trash saltcakes, and scrap. U-238 is theuranium isotope of mostconcem. (See Table 8-2 forU-234, 236). For U-238:(c-- 1.94E+04 kg Pit 4)(t- 8.83E+03 kg Pit 6)

(-4 2.53E+04 kg Pit 10)

Low-Mod PotentialMost is in solid non-solubleform, from metals, filters,trash salt cakes, and scrap. Asmall percent of the U-235could be soluble. Total U-235:

(A= 233 kg Pit 4)34 kg Pit 6)

(t: 207 kg Pit 10)

in


Pit 4, 6, & 10 Materialor Chemical (CAS #,Vapor Density & Exposure Limit.Ionization Energy (PEL/TLV)

Uranyl Nitrate(13520-83-7)

Zirconium/Zr-compounds(7440-67-7)VD-NA

Organic Compounds

Acetone(67-64-1)VD-2IE-9.7 eV

Benzine(VM + P Naptha)(8032-32-4)

PEL-0.05 mg (U)/m3

TLV-5 mg/m3Ceiling-10 mg/m3

TLV-500 ppmSTEL-750 ppmCeiling-1782 ppm

Routes ofExposureb

Ig, lh, S

Ih, Con

Symptoms of OverExposure` (Acuteand Chronic)

Irritation to eyes, mucusmembrane, and upperrespiratory tract. Maybe fatal if swallowed.

Respiratory, irritationof skin and mucousmembranes, lunggranulomas

lh, Ig, Con Nervous system,respiratory, derrnis,headache, Contact witheyes may causepermanent damage

ACGIH S, Ih, Ig,

TLV-1370 mg/m3 Con

(300 ppm)

NIOSH

REL 10H TWA-350 mg/m3

CL-1800 mg/m315 min.

Wheezing, laryngitis,shortness of breath,headache, nausea, andvomiting, coughing,burning sensations

TargetOrgans/System

Liver, kidneys,lungs, brain

Respiratorysystem, skin

Respiratorysystem, skin

Central nervoussystem, skin,lungs


Yes—Cailf.Proposition 65

Exposure Potential`(all routes without regard

to PPE)

Low PotentialDistributed in pits and mayhave migrated from drums.20 kg Pit 4)

(4.1 8 kg Pit 6)frd 16 kg Pit 10)

No Low -Mod PotentialSource is from scrap metal,.(z 4,545 kg Pit 4)

(z 5,883 kg Pit 6)(g,- 1,193 kg Pit 10)

No

ACGIHAnimalcarcinogen

Low PotentialAbsorbed on rags in waste innumerous shipments.(rd 7 kg Pit 4)es 2 kg Pit 6)(m 5 kg Pit 10)

Low Potential

Absorbed on rags in waste innumerous shipments.(--.11 kg Pit 4)(ft 2 kg Pit 6)(a 5 kg Pit 10)

a



2-Butanone(78-93-3)VD-2.5IE-9.54 eV

Butyl Alcohol(71-36-3)VD-2.55IE-10.4 eV

Carbon tetrachloride(56-23-5)VD-5.3IE-11.5 eV

Diesel fuel(8008-20-6)VD->1

Ethyl Alcohol(64-17-5)VD-1E-10.47 eV


TWA 200 ppm(590 mg/m3)STEL-300 ppm(885 mg/m3)

OSHA

PEL TWA-200 ppm(590 mg/ m3)

STEL C-50 ppm*Ceiling-152 ppm*(Ceiling for both)**n-Butanol

TLV 5 ppmSTEL-10 ppmCeiling-63 ppm

Not established

ACGIH

TLV-TWA-1000 ppm(1880 mg/m3)

OSHA

PEL-TWA-1000 ppm(1900 mg/m3)

Routes ofExposureb

Ih, Ig, Con

Ih, Ig, S,Con

lh, Ig, S,Con

Ih, Ig, S,Con

Ih, Ig, S,Con


Irritation of eyes, skin,nose; headache;dizziness; vomiting;dermatitis

Nervous system,respiratory, dermis,headache, shortness ofbreath

Nervous system, eyes,respiratory, Irritation ofeyes/skin, centralnervous systemdepression, headache

TargetOrgans/System

Eyes, skin,respiratorysystem, lungs,central nervoussystem

Respiratorysystem, eyes,skin

Central nervoussystem, eyes,liver, lungs,kidneys

Nervous system, eyes, Skinrespiratory, dermis,headache, skin irritation

Irritation eyes, skin,nose; headache,drowsiness, fatigue,narcosis; cough; liverdamage; anemia;reproductive,teratogenic effects

Eyes, skin,respiratorysystem, centralnervous system,liver, blood,reproductivesystem


No-NIOSHNo-ACGIH


to PPE)

Low PotentialAdsorbed on rags in waste innumerous shipments.es 2 kg Pit 4)(n 1 kg Pit 6)(m 3 kg Pit 10)

No Low PotentialSource from uncementedsludge.

14 kg Pit 4)(*= 2 kg Pit 6)(re 7 kg Pit 10

High PotentialWidely distributed in pits andprobably has migrated fromdrums.

14,000 kg Pit 4)(re 14,900 kg Pit 6)(z 24,100 kg Pit 10)

No Moderate PotentialWill be used to refuelequipment.

A2—ACGIHYes—NTPYes—IARCNo—OSHA

No-ACGIH Low PotentialAdsorbed on rags in waste innumerous shipments.(rt 2 kg Pit 4)

1 kg Pit 6)(Az 2 kg Pit 10)



Formaldehyde(50-00-0)VD-1.071E-10.88 eV

Methyl alcohol(67-56-1)VD-1.111E-10.8 eV

Methylene chloride(75-09-2)VD-2.9IE-11.3 eV

Methyl IsobutylKetone(563-80-4)VD-1E-9.32 eV


ACGIH

TLV-0.37 mg/m3(0.3 ppm)

OSHA (29 CFR1910.1048)

PEL-TWA —0.75 ppmSTEL-2 ppm


TLV-50 ppm

TWA-200 ppm(705 mg/m3)PEL—None

Routes ofExposureb

lh, Ig, S,Con

Ih, Ig, S,Con

Ih, Ig, Con

lh, 1g, Con


Irritation eyes, nose,throat, respiratorysystem; lacrimation(discharge of tears);cough; bronchitisspasm, dermatitis

Nervous system, eyes,respiratory, centralnervous systemdepression, (Contactwith eyes may causetemporary cornealdamage.)

Headache, dizziness,skin irritation

Irritation eyes, skin,mucous membrane,respiratory system;cough

TargetOrgans/System

Eyes, skin,respiratorysystem, cancer,kidneys, liver,heartNasal cancer

Eyes, skin,central nervoussystem


Exposure Potentiar(all routes without regard

to PPE)

Skin, centralnervous system,eyes, cardiovas-cular system

Eyes, skin,respiratorysystem

Yes-NIOSH

Yes-ACGIH

Yes-OSHA

Low PotentialAdsorbed on rags in waste innumerous shipments.(os 34 kg Pit 4)es 0 kg Pit 6)(w 0 kg Pit 10)

No Low PotentialSource from uncementedsludge.es 32 kg Pit 4)(a 5 kg Pit 6)(= 15 kg Pit 10)

No Moderate-High PotentialDistributed throughout thepits.es 2,110 kg Pit 4)(m 349 kg Pit 6)(a 974 kg Pit 10)

No Moderate PotentialDistributed throughout thepits.es 776 kg Pit 4)(z 324 kg Pit 6)

644 kg Pit 10)

00



Terphenyl (o-, m-, p-)(84-15-1, 92-06-8,92-94-4)VD-NAIE- 7.78-8.01 eV

Tetrachloroethylene(127-18-4)VD-5.8IE-9.3 eV

Toluene(108-88-3)VD-3.14IE- 8.82 eV


ACGIH

Ceiling-0.5 ppm(5 mg/m3)

OSHA

Ceiling-1 ppm(9 mg/m3)


ACGIH

WA= 50 ppm(188 mg/m3)

NIOSHTWA-100 ppm(375 mg/m3)STEL-150 ppm(560 mg/m3)Ceiling-200 ppm(10 min)

OSHA

PEL-TWA-200 ppmCeiling-300 ppm and500 ppm (10 min peakduring 8-hr shift)

Routes ofExposureb

Ih, Ig, Con

lh, Ig, Con

lh, S, Ig,Con


Irritation eyes, skin,mucous membrane;thermal skin bums;headache; sore throat;in animals: liver,kidney damage

Nervous system,respiratory, headache,loss of consciousness,dermis

Irritation eyes, nose;fatigue, weakness,confusion, euphoria,dizziness, headache;dilated pupils,lacrimation (dischargeof tears); nervousness,muscle fatigue,insomnia; paresthesia;dermatitis; liver, kidneydamage

TargetOrgans/System

Eyes, skin,respiratorysystem, liver,kidneys

Liver, kidneys,eyes, upperrespiratory,central nervoussystem

Eyes, skin,respiratorysystem, centralnervous system,liver, kidneys,bladder, blood

Carcinogen?(source)°


to PPE)

No Moderate PotentialDistributed in Pit 4.

118 kg Pit 4)(po 0 kg Pit 6)0 kg Pit 10)

No High PotentialWidely distributed in pits andmay have migrated fromdrums.(Ps 3,030 kg in Pit 4)

3,340 kg Pit 6)5,370 kg Pit 10)

No Low PotentialAdsorbed on rags in waste innumerous shipments.(2: 32 kg Pit 4)(Rd 0 kg Pit 6)(z 0 kg Pit 10)



Tributyl Phosphate(126-73-8)VD-NA1E-

1,1,1-Trichloroethane(71-55-6)VD-4.6IE-11.1 eV

Trichloroethylene(79-01-6)VD-4.53IE-9.5 eV

1,1,2-Trichloro-1,2,2-Trifluoroethane(76-13-1)VD-6.51E-11.99 eV

Trimethylolpropane-Triester (Triacrylate)(15625-89-5)


NIOSHTWA-0.2 ppm(2.2 mg/m3)

OSHA

PEL-TWA--0.4 ppm(5 mg/m3)



TWA-1000 ppm(7,600 mg/m3)STEL-1250 ppm(9,500 mg/m3)

Non listed.

Routes ofExposureb

lh, Ig, SCon

Ih, lg, S,Con


Irritation eyes, skin,respiratory system,headache; nausea

Nervous system,dermis, respiratory,eyes, central nervoussystem depression,headache

Ih, Ig, Con Nervous system,headache, respiratory,eyes, pulmonary edema

Ih, Ig, Con Irritation skin, throat,drowsiness, dermatitis;central nervous systemdepressant/depression;in animals; cardiacarrhythmia, narcosis

Ih, S, Ig Irritation to eyes, mucusmembrane and upperrespiratory tract. Causesskin irritation.

TargetOrgans/System

Eyes, skin,respiratorysystem, centralnervous system,blood

Central nervoussystem, skin,eyes,cardiovascularsystem

Respiratory,heart, liver,kidneys, centralnervous system

Skin, heart,central nervoussystemcardiovascularsystem

Mucus mem-branes, upperrespiratorytract, skin.



to PPE)

No Low PotentialAdsorbed on rags in waste innumerous shipments.(m 87 kg Pit 4)(ms 36 kg Pit 6)(= 72 kg Pit 10)

No High PotentialWidely distributed in pits andmay have migrated fromdnuns.(4i 12,500 kg Pit 4)(Ps 12,300 kg Pit 6)

20,200 kg Pit 10)

No High PotentialWidely distributed in pits andmay have migrated fromdrums.(sz 11,800 kg Pit 4)(Pt 13,000 kg Pit 6)(1=, 20,900 kg Pit 10)

No Moderate PotentialDistributed in pits and mayhave migrated from drums.

1,320 kg Pit 4)(74 218 kg Pit 6)(z 610 kg Pit 10)

Not listed Low potentialDistributed in Pit 4 and mayhave migrated from drums.(m 135 kg Pit 4)(z 12 kg Pit 6)fr.; 33 kg Pit 10)


Pit 4, 6, & 10 Materialor Chemical (CAS #,Vapor Density & Exposure Limit'

Ionization Energy (PEL/TLV)

Xylene(95-47-6)VD-5.2IE-8.6 eV

TLV--100 ppmSTEL-150 ppmCeiling-651 ppm

Radionuclides—Pu-238, Pu-239, Pu-240, Pu-241,

et aL 19981)

RadiologicalContaminant

Radionuclides(whole body exposure)

Radionuclides(fixed and removablesurface contamination)

1NEEL 1.5 rem/yrproject ALARA doselimit-per RWP orALARA Task

Posting of CAs perINEEL RCM, Table 2--4, and § 835.603.f

Posting of radiationareas per INEEL RCM,Table 2-3

Posting of CAs perINEEL RCM,Table 2-4, § 835.404.c,and § 835.603.f

Routes ofExposureb

Ih, Ig, S,Con


Nervous system,respiratory, dermis,eyes, headache,drowsiness

TargetOrgans/System

Central nervoussystem, eyes,skin, GI tract,blood, liver,kidneys


Exposure Potential`(all routes without regard

to PPE)

No Low potentialSource from uncementedsludge.(go 135 kg Pit 4)

12 kg Pit 6)(= 33 kg Pit 10)

Am-241, Np-237, U-238, U-236, U-235, and U-234 (dominant radioisotopes, 99.9% of radioactivity [Becker

WholeBody

Ig, Con

Electronic dosimetrywill be used to alertworkers to increasedgamma radiation fields.Albedo dosimetry andNRD instruments willbe used to monitor forneutron radiation.

Alarming personnelcontamination monitorsand hand-heldinstruments(see Table 8-6)

Blood forming Yescells, GI tract,and rapidlydividing cells

GI tract,ionization ofinternal tissue

Yes

Expected Levels

Mod-High PotentialLow doses from repeatedhandling of cores. Coresample contact readings rnayexceed 200 mR/hr.

Logging source installationand removal from tool.

(High Radiation Area may beestablished during loggingtasks)

Mod-High PotentialContact with contaminatedsurfaces. Fixed andremovable contaminationlevels may exceed 100 timesTable 2-2 values for specificradionuclides.

1,J



Exposure Limir Routes of(PEL/TLV) Exposureb


TargetOrgans/System



to PPE)

Radionuclides(airborneradioactivity)

10% of DAC forspecific radionuclideselected (10 CFR 835)

Posting of airborneradioactivity areas perINEEL RCM,Table 2-4 and §835.603.d

lh, Ig, Con Alarming continuousair monitors, portableair samplers, andsurface swipe counting(See Table 8-6)

Respiratory Yessystem, GItract, ionizationof internaltissue

a. ACGIH 1997 TLV Booklet and OSIIA 29 CFR 1910 substance specific standards, and MSI)S Net INEL.

b. (lh) inhalation; (Ig) ingestion; (S) skin absorption; (Con) contact hazard.

c. (nervous system) dizziness/nausea/lightheadedness; (dermis) rashes/itching/redness; (respiratory) respiratory effects; (eyes) tearing/irritation;

d. If yes, idcntify agency and appropriate designation (ACGIII Al or A2; NIOSH; OSI IA; IAR('; NIP).

e. Estimates (t) of specific compounds from Tables 8-2 and 8-3.

VD—vapor density (Air = I ) CNS—ccntral nervous system CVS —cardiovascular system DAC—derived air concentrationGI—gastrointestinal PEL—permissible exposure limit TLV—threshold limit value REM—roentgen equivalent manRCM—radiological control manual DAC— derived air concentmtion IE—ionization energy eV —electron volts

Material Safety Data Sheets for these chemicals are available at the OU 7-13/14 project trailer.

Low PotentialIsolated core retrieval system.Potential if HEPA systemfails.Airbome levels exceeding10% of specified DAC valuepossible in localized area ifconfinement breached.

unprotected skin or corrosion resulfing in chemical burns, uptake through skin absorption,and/or skin contamination

• Ingestion of radiologically contaminated organic and inorganic compounds adsorbed to dustparticles or waste residues adhering to drill or sampling equipment leading to potentialuptake of contaminants through the GI tract that result in GI irritation, intemal tissueirradiation, and/or deposition to target organs

• Injection, while handling radiologically contaminated organic and inorganic materials, bybreaking of the skin or migration through an existing wound, resulting in localized irritation,contamination, uptake of soluble contaminants, and deposition of insoluble contaminants.

8.3 Environmental and Personnel Monitoring

The potential for exposure to radiological and nonradiological hazards exists during many of thetasks that will take place at the OU 7-13/14 subsurface investigation project site and affects all personnelwho work in the CA and EZ Refinement of work controls zones (Section 7), engineering andadministrative controls, worker training, and the use of protective equipment will mitigate most of thesehazards to a large degree. However, given the variability in waste distribution and content, monitoringwith direct reading instruments will be conducted to provide RADCON and IH personnel with real-timedata to assess the effectiveness of these controls.

The greatest exposure potential from Pit 4, 10 (or 6 if investigated) buried waste contaminants willbe to the project personnel conducting sample core, casing removal tasks (drill helpers), and instrumentinstallation. These personnel will repeatedly enter the area immediately around the DSE and directlyhandle core samples inside the DSE and when removed through the material transfer port. The IH andRADCON personnel will focus on these activities and monitor with direct reading instrumentation,swipes, and full and partial period air sampling (as deemed appropriate). Other workers and areas of theproject site will also be monitored to verify the integrity of DSE and core sample packages, ensurecontamination has not migrated from radiologically contaminated material or waste containers, and todetermine the effectiveness of decontamination practices (if required).

Personnel working at the OU 7-13/14 subsurface investigation project site may be exposed tohazardous materials or hazardous physical agents as already described. Safety hazards and other physicalhazards will be monitored and controlled as outlined in Subsection 8.5. The specific hazardous agentexposures that will be monitored are listed on Table 8-5.

8.3.1 Industrial Hygiene Monitoring

Several of the substances listed in Table 8-4 have an American Conference of GovernmentIndustrial Hygienists (ACGIH)-TLV "skie notation indicating that a potential significant contribution tothe overall exposure may be by the cutaneous route. This includes the mucous membranes and the eyes,either by contact with vapors or, of probable greater significance if permeation or damage to PPE occurs,by direct skin contact with the substance. Therefore, use of layered protective clothing and monitoring ofcontaminated drill string and core sample material handling techniques will be of critical importance.

The spread of contamination during drilling section and core sample handling tasks parallel theseconcerns, and monitoring for surface radiological contamination will provide an additional indicator ofnonradiological hazards (given the widespread distribution of TRU nuclides in Pits 4 and 10 (and 6).Isolation of known or potentially contaminated surfaces (i.e., all materials entering the inner DSE area)

8-22

Table 8-5. Pits 4, 6, and 10 radiological and nonradiological hazards to be monitored.°

Task or Activity Radiological and Nonradiological Hazards to be Monitored

All tasks

Mobilization, Site Preparation,Soil Gas Surveys, andGeophysical Mappingd

Probehole Installation &Downhole Logging

Core Sampling, InstrumentInstallation, and Corepacking/shippingContainerizing the core samples indrums for shipment tosubsampling facility andmonitoring of drums when sealed

Decontamination (as required)

Hazards noise (heavy equipment/steam cleaner, if used), CO (ifgenerators used), and heat and cold stress

Radiological contamination (alpha, beta, gamma)Airborne radioactivity (alpha, beta, gamma)Radiation fields (gamma and neutron)Hazards noise levels (heavy equipment)

Radiological contamination (alpha, beta, gamma)Airbome radioactivity (alpha, beta, gamma)Radiation fields (gamma and neutron)VOCsb.̀Carbon monoxide (if generator used for supplemental power)Hazards noise levels (heavy equipment)

Radiological contamination (alpha, beta, gamma)Airbome radioactivity (alpha, beta, gamma)Radiation fields (gamma and neutron)Radioactivity (establish TRU content and Ci/g for shipment)VOCs (xylene, acetone, butyl alcohol, methyl alcohol)bChlorinated organic volatile compounds (carbon tetrachloride,1,1,1-trichloroethane, trichloroethylene, methylene chloridetetTachloroethylene)

Radiological contamination (alpha, beta, gamma)Airborne radioactivity (alpha, beta, gamma)Radiation fields (ganmm and neutron)VOCs (xylene, acetone, butyl alcohol, methyl alcohol)bChlorinated organic volatile compounds (carbon tetrachloride, 111-trichloroethane, trichloroethylene, methylene chloridetetrachloroethylene)Carbon monoxide (if generator used to power steam cleaner)Hazards noise levels (steam cleaner, if required for nonradiologicaldecontamination only )

a. Monitoring and sampling will be conducted as deemed appropriate by project ILI and RADCON personnel based on specific tasks and siteconditions.

b. All VOCs will be monitored with direct reading photoionizstion instrumentation (lamp eV per IH) to provide a single value for comparisonto the VOC listed on Table 8-7 (PPE Level C or D only).

c. All chlorinated VOCs will be evaluated with a PID (11.7 eV lamp) initially, then detector tubes if levels are suspected to exceed the actionlimit established for carbon tetrachloride listed on Table 8-7 (PPE Level C or D).

d. These tasks or activities will also be performed on Pit 6, if the project decides to investigate Pit 6.

8-23

with sleeving or bags will serve as the primary defense whenever possible. In many cases, contaminationof outer surfaces will be visually observable, and avoidance of waste residual on the drill string sectionsand core samples will be emphasized. Various direct reading instruments and other semi-quantitativedetection tests (detector tubes) will be used at the discretion of the IH to determine the presence ofnonradiological and other physical agents. The frequency and type of sampling and monitoring will bedetermined by changing site conditions, direct reading instrument results, observation, and professionaljudgement. Instruments and sampling methods listed in Table 8-6 will be used by the project IH asdeemed appropriate.

All full and partial period airbome contaminant sampling will be conducted using applicableNIOSH or OSHA methods and in conformance to the LMITCO Safety and Health Manual. Riskassessments for task-site personnel will be conducted according to the LMITCO Safety and HealthManual, MCP-153, "Industrial Hygiene Exposure Assessment."

8.3.1.1 Industrial Hygiene lnstrument and Equipment Calibration. All monitoringinstruments will be maintained and calibrated in accordance with the manufacturer's recommendations,existing IH protocol, and in conformance to the LMITCO Safety and Health Manual. Direct readinginstruments will be calibrated, at a minimum, prior to daily use and more frequently as determined by theproject IH. Calibration information, sampling and monitoring data, results from direct-readinginstruments, and field observations will be recorded per Subsection 3.1.

8.3.2 Radiological Monitoring

The radiological inventory of Pits 4, 10 and 6 includes nuclides that emit alpha, beta, gamma, andneutron forms of ionizing radiation. During OU 7-13/14 subsurface investigation project tasks, thepotential exists for exposure to both external (penetrating ionizing radiation [gamma, neutron, andhigh-energy beta]) and internal radiation (inhalable, ingestible, or absorbed radioactive contaminants). Aswith the nonradiological contaminants discussed above, the greatest potential for both external andinternal radiation exposure will be experienced by individuals who will be in direct contact with the wastematerial or in the proximity of core samples and contaminated material (Subsection 8.4).

Based on the unique and distinctive hazards presented by both external and internal radiationsources, they will be evaluated, controlled, and monitored individually (although the detection of anyradionuclides will serve to alert for the presence of both). For purposes of this monitoring section, theywill be discussed separately and distinguished by their effects as radiation (external) and contamination(internal). Radiological monitoring at the OU 7-13/14 subsurface investigation project site will includearea, airborne, equipment, and personnel monitoring. Monitoring will be performed in accordance withthe LMITCO Radiological Control Manual, MCP-139, "Radiological Survey?' and MCP-357,"Job-Specific Air Sampling/Monitoring," and LMITCO Radiological Control Manual, MCP-425,"Surveys of Materials for Unrestricted Release and Control of Movement of Contaminated Material."

8.3.2.1 Radiation Monitoring. Sources for extemal radiation hazards include elevatedbackground levels from buried waste at Pits 4 and 10 (and Pit 6 if investigated), potential "shine fromadjacent SDA pits, exposure from waste material brought to the surface (cores, residue on drill string,direct exposure from open coreholes, etc.), and the handling of radioactive sources (calibration, logging,packaging cores). Since external radiation sources exist throughout the OU 7-13/14 subsurfaceinvestigation area, a variety of area and personnel monitoring methods will be used. These may includethe use of direct reading radiation detectors (ion chambers, Geiger-Mueller [GM], neutron, etc.), TLD,albedo and electronic dosimetry, passive HPGe gamma detection devices (core sample nonintrusiveanalysis), and possibly the use of alarming remote area monitors (RAMs). This data will be used byRADCON personnel to evaluate the effectiveness of engineering controls, ensure radiological area

8-24

00

Table 8-6. Equipment to be used for monitoring radiological and nonradiological hazards

Chemical or Radiological Hazard to be Monitored orSampled Equipment and Monitoring/Sampling Method

VOCs (listed on Table 8-5)Aromatic VOCs (listed on Table 8-5)Chlorinated VOCs (listed on Table 8-5)

VOCs and chlorinated VOCs (screening)

Chlorinated VOCs (above action limit)

Explosive atmosphere (LEL/02) and CO

Radiological contamination (alpha)

Radiological contamination (beta/gamma)

Radiological contamination (general counting)

Personal contamination monitors

Radiation (gamma and neutron) fields andGeiger-Mueller (GM) instruments

Hazardous noise levels (>85 dBA, >140 impact)

Heat/cold stress

Personal sampling pumps with appropriatemedia

VOCs—NIOSH 1300, 1400, 2000Aromatic VOCs—NIOSH 1501Chlorinated VOCs—NIOSH 1003

HNU-101 PIDs or equivalent (10.6 or 11.7 eV lamps per IH)

Dredger, or equivalent detector tubes (carbon tetrachloride) — for Level D or C PPE only

MSA-36I or equivalent, with CO cell

Count-rate—Bicron/NE Electra (DP-6 or AP-5 probe) or equivalentStationary—Eberline RM-25 (HP-380AB or HP-380A probe) or equivalentCAM ALPHA 6-A-1 (in-line and radial sample heads, pump, RS-485) or equivalent (as required)Grab Sampler—SAIC H-810 or equivalent

Count-rate—Bicron NE/Electra (DP-6, BP-17 probes) or equivalentStationary—Eberline RM-25 (HP-360AB probe) or equivalentCAM (beta)—AMS-4 (in-line and radial head, pump RS-485) or equivalent (as required)Grab Sampler--SAIC H-810 or equivalent

LB-5100/NFS-RPS Counting System or equivalentAlpha/Beta Scalars Protean equivalent

Eberline PCM-2 or PCM-1C or equivalent

Ion Chamber—Eberline RO-20 with RO-7 (2, 200 & 20K probes) or equivalentGM Dose Rate—Ludlum 2241 (HP-270 probe) or equivalentNeutron—Eberline E-600 with NRD or equivalentElectronic dosimetry—SAIC PD-3I with reader and RCMIS station or equivalent

ANSI Type S2A sound level meter and/or ANSI S1.25-1991 dosimeter(A-weighted scale for TWA dosimetry, C-weighted for impact dominant sound environments)

Heat Stress—WBGT, body wt, fluid intake Cold Stress—ambient air temp, wind chill charts

a. Air sampling will be conducted as deemed appropriate by project IH and RADCON personnel based on initial direct reading instrument data, swipes, and other site factors(homogeneity of coring material, radiological contamination/fields, extemal waste residue, etc.).

boundaries are adequate, alert project personnel to potential high radiation sources, and ensure theeffectiveness of decontamination methods and procedures.

8.3.2.2 Contamination Monitoring. The greatest potential for radioactive contamination will befrom the TRU contributing alpha emitters. All tasks involving waste handling or waste contacted surfaceswill be considered sources for radiological contamination. Alpha contamination is of particular concerndue to its mobility, the difficulty in detection, and therefore, ease of cross-contamination. Due to thepresence of beta-gamma emitting radionuclides, beta-gamma radioactive contamination is also a concem.Contamination monitoring for alpha and beta-gamma radioactive contamination will be accomplishedusing extensive direct survey and swipe collection techniques. Low background alpha-beta counters,located at the OU 7-13/14 subsurface investigation project sites, will be used to quantify contaminationlevels. This data will be used by RADCON personnel to evaluate the effectiveness of engineeringcontrols, ensure radiological area boundaries are adequate, alert project personnel of contaminatedequipment or areas, and ensure the effectiveness of personnel and equipment decontamination procedures(if implemented).

Of particular concem is the potential for airborne radioactivity in the proximity of the DSE. Thedrill string and inner cores will be in direct contact with contaminated waste and could potentially providea source for the generation of airborne radioactivity. The need for airborne radioactivity sampling will beevaluated per MCP-352, "Conducting Airborne Hazard Analysis" and performed in accordance withMCP-357, "Job-Specific Air Sampling/Monitoring." Air monitor inlets will be located at key potentialrelease points (e.g., DSE and transition tent area) to determine if airborne radioactivity is present. Theentire (aboveground) portion of the drill string will be contained by the DSE. During drilling operationsthis enclosure will be under continuous negative pressure with a HEPA vacuum system to ensure anyleakage in the enclosure is inward. A modified glove bag enclosure will surround the area where samplecore sections will be removed and new drill sections added, providing a ban•ier between the source ofcontamination and workers during the insertion/removal of items. Additionally, the nature of the sonicdrilling process, as it advances downward, tends to form a stable matrix to "fix" contaminants andminimize upward migration along the outer surface of the casing.

Even though double confinement will be used to isolate the sample cores, all sampling and drillingpersonnel will be required to don, at a minimum, Level C protective clothing and respirator protectionprior to entering any of these CAs during active core sampling, removal tasks, and instrument installationtasks. While working inside CAs and any time contamination is found, personnel will change outergloves frequently to prevent its spread. If protective clothing becomes contaminated, individuals will bedirected to the transition tent area for decontamination (dry methods) or directed to remove thecontaminated garment and change into a new one (Section 10, discusses specific decontaminationprocedures). If protective clothing is punctured or torn by a contaminated object, then the clothing will beremoved and the "break point" surveyed by RADCON personnel to determine if contamination wasintroduced to the underlying garments or skin. When activities are completed inside CAs, all personnelwill complete a whole body survey (beta/gamma) (alpha) and proceed directly to the PCM-2 for anadditional automated survey.

8.3.2.3 Radiological instrument and Equipment Calibration. RADCON personnel will useradiation and contamination detectors and counters listed on Table 8-6 to provide radiological informationto OU 7-13/14 project personnel. Daily operational and performance checks will performed on allportable survey instruments to ensure they are within the specified baseline calibration limits.Accountable radioactive sources (including any logging source[s]) will be maintained in accordance withMCP-137, "Radioactive Source Accountability and Control." All radiological survey and monitoringequipment will be maintained and calibrated in accordance with the manufacturer's recommendations,

8-26

existing RADCON protocol, and in conformance to the LMITCO Radiological Control Manual, MCP-93, "Health Physics Instrumentation," and in accordance with 10 CFR 835.703(d).

8.3.2.4 External Dosimetry. Radiological dosimetry will be required for personnel working onthe OU 7-13/14 subsurface investigation project site (Pits 4 and 10, and Pit 6 if investigated). Coresampling tasks will require personnel to handle bagged core samples of waste material and associatedsecondary waste streams that present a potential external radiation hazard. In addition, RWMCrequirements state that individuals leaving the administrative control area into the TSA or SDA must weara personal dosimetry (TLD). Based on these requirements and exposure potentials at Pits 4 and 10 (andPit 6 if investigated), all personnel who enter the project area will be required to wear per5onal dosimetry.Dosimetry for personnel entering the EZ will consist of a basic TLD and an electronic dosimeter (directreading dosimeter). TLDs will be worn "face our (beta window exposed) and have an albedo dosimeter(neutron dose from logging source) attached to the bottom. Specific dosimetry requirements will bestated in the task RWPs or ALARA tasks. The Radiological Control and Information ManagementSystems (RCIMS) will be used at the project work site to track extemal radiation exposures to projectpersonnel. Individuals are responsible for ensuring all required personal information is provided toRADCON personnel for entry into RCIMS and logging in each day.

Unless otherwise directed by the RWP, personnel dosimetry devices shall be worn on the front ofthe body between the shoulders and the waist. When circumstances are such that other parts of the bodymay receive significantly greater doses, the RWP may instruct personnel to wear the dosimeter in a morerepresentative position or may specify additional supplemental dosimetry.

8.3.2.5 Internal Monitoring. Internal radiation sources (removable and airborne contamination) atthe project site include the buried waste materials from Pits 4 and 10 (and Pit 6 if investigated), residue ondrill string, sample core outer surfaces, and potentially airborne radioactivity from sampling, corehandling, and decontamination tasks (if required). The purpose of intemal dose monitoring is todemonstrate the effectiveness of contamination control practices and to document the nature and extent ofany internal uptakes that may occur. Baseline, event based, and project-termination internal monitoringwill be used to indirectly measure any deposited radioactive material in the body for field team memberswith the highest potential for intemal uptake (samplers, driller helpers, etc.). Other field team memberswho may not directly handle contaminated materials will receive baseline and project-termination wholebody counts.

To indirectly measure the amount of radioactive material present inside the body, whether fromnaturally occurring or inadvertent uptakes, whole body counters and bioassay samples will be used. Fromthese measurements, an intemal dose may be calculated. The estimated internal dose shall be based onbioassay data rather than air concentration values unless bioassay data are unavailable. If such data arenot available, it will be based on representative air concentration values in accordance with 10 CFR835.209(c). Intemal dose evaluation programs shall be adequate to demonstrate compliance withTable 2-1 of 10 CFR 835(d). OU 7-13/14 subsurface investigation project personnel are responsible forsubmitting alI required bioassay samples upon request.

8.3.3 RADCON Engineer/IH Exposure Assessments

To prevent and mitigate potential personnel exposure to radiological, nonradiological, and physicalhazards at the project site, action levels (ALs) have been established for contaminants that have beenevaluated and determined to present a moderate to high exposure potential (listed on Table 8-4). TheseALs, and associated responses, are listed on Table 8-7. If ALs are reached, personnel will take theappropriate measures as listed. For upgrading PPE, the threshold (i.e., protection factor) for the particular

8-27

Table 8-7. Action levels and associated responses for OU 7-13/14 subsurface investigation project hazards.

Contaminant/Agent Monitored Action Level (AL) Response Taken if AL Exceeded

Organic Vapors (11.7 eV lamp) <5 ppm in workers' breathing zone

(Applies only if not in Level C 5-10 ppm sustained for 1 minute in

or B respiratory protection) workers' breathing zone

(Applies only if not in Level Cor B respiratory protection)

Explosive Vapors (LEL)b

Hazardous Noise Levels

Radiation Field

Monitor near source for elevated levels, adjust DSE as needed, ensure personnel are

on upwind side of source, continue to monitor.

Continue working, pull CCL4 detector tube sample.If < 5 ppm, continue working, periodic monitoring (minimum every 5 minutes).If >5 ppm, leave area until vapor dissipates then continuous monitoring or donminimum of Level C respiratory protection' and continue working.

10-25 ppm in workers' breathing zone If episodic—leave area until dissipates, perform continuous monitoring or donminimum Level C respiratory protection and continue working.If sustained—don minimum Level C respiratory protection°.

25-50 ppm in workers' breathing zone Evacuate area and don minimum Level C respirator protectiona, continue periodicmonitoring (minute every 5 minutes).

> 50 ppm in work area Evacuate area consult FTL whether to abandon corehole, if not, don Level Brespirator protection, continue periodic monitoring (minimum every 5 minutes).

<1 % LEL in corehole or casing Periodic monitoring (during each drilling event).

1-5% LEL in corehole or casing Continuous monitoring, if >5% LEL, stop drilling and check DSE and HEPA systemfor integrity.

5-9% LEL in corehole or casing Stop advancement, use available local exhaust system to evacuate corehole airspace, continuously monitor, check system integrity, proceed slowly.

>9% LEL in corehole or casing Stop advancement and all other activities in immediate area, use local exhaustsystem (DSE attached HEPA vacuum) to evacuate corehole air space. If levels donot drop, abandon corehole location.

<85 dBA

85-114 dBA

a. >115 dBA b. >140 dBA

<5 mrem/Hr

5-100 mrem/hr @ 30 cm §835.603.b)

>100 mrem - 500 Rad @ 100 cm(§835.603.b)

No action.

Hearing protection required to attenuate to below 85 dBA (based device NRR).

a. Isolate source, evaluate NRR for singledevice, double protection as needed.

No action, no posting required.

Post as "Radiation Area"—Required items: RW I or II training, RWP, personaldosimetry.

Post as "High Radiation Aree—Required items: RW II, RWP, alarming personaldosimetry, dose rate meter, temporary shielding (as required).

b. Control entry, isolate source, onlyapproved double protection wom.

00


Contaminant/Agent Monitored Action Level (AL) Response Taken if AL Exceeded

Radiological Contamination

Airborne Radioactivity

Exceed RAM alanning set point, ifrequired (fast ringing bell, flashing redlight)

1-100 times RCM Table 2-2 values(§835.603.d)

> 100 times RCM Table 2-2 values(§835.603.d)

Concentrations (µCi/cc) > 10% of andDAC value (§835.603.d)

Exceed CAM alarming set point, ifrequired (fast ringing bell, flashing redlight)

Any failure of the DSE, other primary engineering control, orconfinement system, or emergency event at the OU 7-13/14 subsurfaceinvestigation project site or RWMC (sirens, fire, explosion, release, etc)

a.

b.

c.

NRR

RW

dBA

RCM

DAC

Evacuate area inunediately, muster at CRZ and await instruction from RADCON.

Post as "Contamination Area", Required items: RW II training, personal dosimetry,RWP, don PPE, bioassay submittal (as required).

Post as "High Contamination Area"—Required items: RW II training, personaldosimetry, RWP (with prejob briefing), don PPE, bioassay submittal (as required).

Post as "Airbome Radioactivity Area"—Required items: RW II training, personaldosimetry, RWP (with prejob briefing), don PPE, bioassay submittal (as required).

If not in Level B respiratory protection-evacuate upwind to CRZ, await RADCON.

If in Level B respiratory protection-leave immediate area to upwind location,maintain air line connection and await RADCON instructions.

Evacuate the CA.

Use emergency shut-off on drill rig.

Proceed to an upwind position or assembly area as directed by CE.

Level C respiratory protection will consist of a full-face respirator equipped with a combination multichemical-HEPA cartridge (i.e. MSA GMC-H) as prescribed by the project IH. See Section 9,Personal Protective Equipment for additional Level C requirements.

LEL concentrations will be measured indirectly by monitoring the exhaust stream of the HEPA vacuum.

Section 11, for the OU 7-13/14 subsurface investigation project site (Pits 4 and 10; Pit 6 if investigated) details specific events and appropriate emergency responses. Any release should beconsidered an emergency event and require at least an evacuation of the OU 7-13/14 subsurface investigation project area.

Noise reduction rating

Radiological Worker

decibel A-weighted

Radiological Control Manual

derived air concentration.

level being worn must be exceeded or another type of contaminant introduced to justify PPE modification(i.e., Level B ensemble offers the highest level of respiratory protection deemed appropriate for thisproject, so no further upgrade would be appropriate).

8.4 Physical Hazards Evaluation, Control, and Monitoring

The physical hazards present at the OU 7-13/14 subsurface investigation project task sites (Pits 4and 10; Pit 6 if investigated) and the methods that will be used to monitor and control them are describedin this section. It is critical that all personnel are aware and understand the nature of the tasks that will beconducted, the equipment to be used, and the controls in place to eliminate or mitigate potential safetyhazards.

8.4.1 Temperature Extremes

Project activities will be conducted during months where there is a potential that both heat and coldstress factors could affect task-site personnel based on ambient air temperatures and layered PPE.

8.4.1.1 Heat Stress. Outside temperatures are expected to be variable during the probing anddrilling/coring phase of the project, and personnel will be required to wear protective clothing thatprevents the body from cooling. High ambient air temperatures can result in increased body temperature,heat fatigue, heat exhaustion, or heat stroke that can lead to symptoms ranging from physical discomfort,unconsciousness, to death. Personnel must inform the FTL, CE, or HSO when experiencing any signsand/or symptoms of heat stress or observing a fellow employee ("buddy") experiencing them. LMITCOSafety and Health Manual, MCP-2704, "Heat and Cold Stress" and Table 8-8 of this section furtherdescribe heat stress hazards.

Monitoring for heat stress conditions shall be performed according to the LMITCO Safety andHealth Manual, MCP-2704, "Heat and Cold Stress." Depending on the ambient weather conditions,work conditions, type of PPE wom, and the physical response of work operations personnel, the IH/RCTshall inform the FTL of necessary adjustments to the work/rest cycle. Additionally, physiologicalmonitoring may be conducted to determine if personnel are replenishing liquids fast enough. A supply ofcool drinking water will be provided in designated eating areas and consumed only in these areas.Workers may periodically be interviewed by the IH, RCT or HSO to ensure that the controls are effectiveand that excessive heat exposure is not occurring. Workers will be encouraged to monitor their bodysigns and to take breaks if symptoms of heat stress occur. The signs of heat stress are listed on Table 8-8.

Individuals showing any heat exhaustion symptoms listed in Table 8-8 will (1) stop work, (2) exitwork area, (3) be decontaminated (as appropriate), (4) remove protective clothing, (5)move to shelteredarea to rest, (6) be provided cool drinking water, and (7) be monitored by a Medic or CPR/First Aidtrained employee.

Personnel exhibiting signs and/or symptoms of heat stroke will be immediately transported to thenearest medical facility for medical attention. Section 11 details additional emergency situations andassociated responses.

NOTE: Heat exhaustion and heat stroke are extremely serious conditions that can result in death andshould be treated as such. Transport individual immediately to the nearest medical facility.

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Table 8-8. Heat stress signs and symptoms.

Heat-RelatedIllness Signs and Symptoms Emergency Care

Heat Rash Red skin rash and reducedsweating

Heat Cramps Severe muscle cramps,exhaustion, sometimeswith dizziness or periodsof faintness

Heat Rapid, shallow breathing;Exhaustion weak pulse; cold, clammy

skin; heavy perspiration; total body weakness;dizziness that sometimesleads to unconsciousness

Heat Stroke Deep, then shallow,breathing; rapid, strongpulse, then rapid, weakpulse; dry, hot skin;dilated pupils; loss ofconsciousness (possiblecoma); seizures ormuscular twitching

Keep the skin clean; change all clothing daily;cover affected areas with powder containingcornstarch or with plain comstarch.

Move the patient to a nearby cool place; give thepatient half-strength electrolytic fluids; if crampspersist, or if more serious signs develop, seekmedical attention.

Move the patient to a nearby cool place; keep thepatient at rest; give the patient half-strengthelectrolytic fluids; treat for shock; seek medicalattention.

DO NOT TRY TO ADMINISTER FLUIDS TOAN UNCONSCIOUS PATIENT

Cool the patient rapidly. Treat for shock. If cold-packs or ice bags are available, wrap them andplace one bag or pack under each armpit, behindeach knee, one in the groin, one on each wrist andankle, and one on each side of the neck. Seekmedical attention as rapidly as possible. Monitorthe patient's vital signs constantly.

DO NOT ADMINISTER FLUIDS OF ANYKIND

8.4.1.2 Low Temperatures. Exposure to low temperatures will likely be a factor during the timeof OU 7-13/14 subsurface investigation project activities and can be at other times of year if theconditions are right. Relatively cool ambient temperatures and wet or windy conditions increase thepotential for cold injury to personnel. The project IH and HSO will be responsible for obtainingmeteorological information to determine if additional cold stress administrative controls are required.The LMITCO Safety and Health Manual, MCP-2704, "Heat and Cold Stress" discusses the hazards andmonitoring of cold stress. Table 8-9 provides the cold stress work/warm-up schedule. Project personnelwill also be cautioned regarding cold stress factors associated with rapid cooling once impermeable PPElayers are removed causing the potential for freezing of accumulated moisture on PPE outer and iimersurfaces (under extremely cold conditions). Table 9-2 requirements must be followed for the outer layerof protection based on radiological and nonradiological hazards. The following are provided as generalmeasures for inner clothing layers to prevent cold stress:

• Workers should wear layered warm clothing (heavy socks, hooded garments, etc.) when theair temperature is from 40 to 45°F (4 to 7°C)

• When the air temperature is from 30 to 40°F (-1 to +4°C), depending upon worker comfort,clothing for wannth, in additional to chemical protective clothing, shall be wom. This mayinclude:

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Table 8-1. Cold stress work/warm-up schedule.

AirTemp

°F (approx.)

No Noticeable Wind 5 mph Wind 10 mph Wind 15 mph Wind 20 mph Wind

MaxWork No. ofPeriod Breaks





-15° to —19° Normal 1breaks

Normal 1breaks

75 min 2 55 min 3 40 min 4

-20° to -24° Normal 1breaks

75 min 2 55 min 3 40 min 4 30 min 5

-25° to -29° 75 min 2 55 min 3 40 min 4 30 min 5 Nonemergencywork should cease

-30° to -34° 55 min 3 40 min 4 30 min 5 Nonemergencywork should

-35° to -39° 40 min 4 30 min 5 Nonemergencywork should cease

cease

-40° to -44° 30 min 5 Nonemergencywork should cease

-45° and below Nonemergencywork should cease

Insulated suits, such as whole-body thermal underwear

Wool or polypropylene socks to keep moisture off the feet if there is a potential forwork activity that could cause sweating

Insulated glove liners when air temperatures are extremely low (less than 5 to 10°F[-12 to -15°C]), gloves with reflective surfaces, which reflect body heat back to thehand, should be used)

Insulated boots, head cover such as hard hat liners

• At air temperatures below 30°F (1.7°C), the following work practices should be followed:

If the clothing of a worker might become wet on a job site, use an impermeable outerlayer.

If a worker's underclothing becomes wet, change into dry clothing immediately;however, if the clothing becomes wet from sweating, the worker may finish the taskthat caused the sweating before changing into dry clothing.

Provide workers a warm area (65°F [18.3°C] or above) to change from work clothinginto street clothing.

Provide workers a warm break area (60°F [15.6°C] or above). A vehicle may be used.

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If appropriate, space heaters may be provided in the work area to warm the hands,feet, etc.

Provide hot liquids in the break area (outside project controlled zones); the intake ofcaffeine should be limited because of diuretic and circulatory system effects.

Utilize the buddy system at all times; any personnel observed with severe shiveringshall leave the cold area immediately.

- Workers should layer their clothing (i.e., thinner, lighter clothing layered underheavier clothing).

To prevent heat stress, workers should dress appropriately for performing strenuousactivities.

Workers handling liquids that evaporate easily (gasoline, diesel fuel, etc.) shall takespecial precautions to avoid soaking clothing or gloves with the liquids because of theadded danger of cold injury due to evaporative cooling.

Minimize the need for workers to sit still or stand for long periods of time.

Additional cold weather hazards exist from working on snow- or ice-covered surfaces. Slip, falland material handling hazards are increased under these conditions. Every effort must be made to ensurewalking surfaces are kept clear of ice. The CE or HSO should be notified immediately if slip or fallhazards are noted at the OU 7-13/14 subsurface investigation project site.

8.4.2 Noise

Personnel working at the task site may be exposed to noise levels that exceed 85 decibelA-weighted (dBA) near heavy equipment or at the open panel to the drill rig motor. The effects of highsound levels (noise) may include the following:

• Personnel being startled, distracted, or fatigued

• Physical damage to the ear, pain, and temporary or permanent hearing loss

• Interference with communication that would wam of danger.

Noise measurements (using instruments listed on Table 8-6) will be performed by the IH per theLMITCO Safety and Health Manual, MCP-2719, "Hearing Conservation Program," to detennine ifpersonnel assigned to the jobs identified are above allowable noise exposure levels. A TLV of 85 dBA(time-weighted average) will be applied to personnel exposed to noise levels over no more than an 8-hourday. This level is based on a 16-hour "recovery" period in a low noise environment. If personnel arerequired to work longer than 8 hours in a hazardous noise environment, then the TLV will be adjusted to alower value. The project IH must be consulted regarding modifications to the 85 dBA 8-hour TLV value.

Personnel whose noise exposure routinely meets or exceeds the allowable noise level will beenrolled in the INEEL OMP or subcontractor Hearing Conservation Program. Personnel working on jobsthat have noise exposures greater than 85 dBA will be required to wear hearing protection until noise

. levels have been evaluated, and will continue to wear the hearing protection specified by the IH untildirected otherwise.

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8.4.3 Fire, Explosion, and Reactive Materials Hazards

Fire, explosion, and reactive materials hazards at the task site include potential explosiveatmospheres in the corehole or casings, combustible materials near ignition sources (hot motor or exhaustsystem), transfer and storage of flammable or combustible liquids in the SZ, and chemical reaction(reduction, oxidation, exothermic, etc.) from incompatible waste materials. Portable fire extinguishers,with a minimum rating of 10A/60BC shall be strategically located at the project site to combat Class ABCfires. They will be located in all active work areas, on or near site equipment that have exhaust heatsources, and all equipment capable of generating ignition or has the potential to spark. Additionally, sandand shovels will be provided in strategic locations inside the CA in the unlikely event of a core samplefire involving metal material. OU 7-13/14 project personnel will receive fire extinguisher training as partof this HASP training, as listed on Table 4-1. Project personnel will not attempt to suppress fires thathave evolved beyond the incipient (initial) stage.

8.4.3.1 OU 7-13/14 Project Equipment Fire Hazards. Combustible or ignitable materials incontact with or near exhaust manifolds, catalytic converters, or other ignition sources could result in afire. The project FPE will identify these sources as equipment is brought on the project site. Theaccumulation of combustible materials will be strictly controlled at the project site. Disposal ofcombustible materials shall be assessed at the end of each shift. Class A combustibles such as, trash,cardboard, rags, wood, and plastic will be properly disposed of in metal receptacles in the SZ and inappropriate waste containers within the CRC, CRZ, and EZ. Weed control measures will be implementedas necessary to keep vegetation cleared around project ignition sources and structures.

Diesel fuel may be used at the task site for generators and decontamination equipment (steamcleaner, if required) will be safely stored, handled, and used. Only FM/UL-approved flammable liquidcontainers, labeled with the content, will be used to store fuel. All fuel containers will be stored at least15 m (50 ft) from any facilities [trailer(s)] and ignition sources, or stored inside an approved flammablestorage cabinet. Additional requirements are provided in LMITCO Safety and Health Manual, MCP-584,"Flammable/Combustible Liquids Storage and Handling." Portable motorized equipment such asgenerators, light plants, etc., will be shut off and allowed to cool down in accordance with themanufacturer's operating instructions prior to refueling to minimize the potential for a fuel fire.Refueling tasks will only be conducted by qualified fuel handling personnel.

8.4.3.2 Corehole Airspace ignition Sources. Although the coreholes will be cased and no airwill be introduced during advancement or core sampling, the potential still exists for organic vapors tobuild up in a corehole during core sampling and instrument installation tasks. The source of these vaporsis from volatile organic hydrocarbons in the SDA pit soils. Engineering controls (DSE—local exhaustventilation) will surround the drill string providing a continuous supply of airflow to prevent vapors fromreaching an explosive level. Additionally, monitoring of DSE exhaust stream during coring and samplingtasks will be conducted with a multi-gas/02 meter by measuring the airstream (downstream of the HEPAfiltered DSE). If the measured airstream approaches 10% of the lower explosive limit (LEL), thenadvancement will stop and the airspace allowed evacuated with the DSE HEPA vacuum until levels dropbelow 10%.

8.4.3.3 Waste Reactivity and Fire Potential. The waste material in Pits 4, 10, and 6 containnumerous chemical compounds and materials that, if combined or commingled in their pure form, couldcause a chemical reaction that results in the release of liberated gases, reaction intermediates, andpotentially thermal energy. This anticipated potential occurrence is based on conditions at Pits 4 and 10(and Pit 6 if investigated).

8-34

Nitrate salts present in these pits are anticipated to be of similar concem as those addressed in Pit 9.RFP Series 745 potassium and sodium nitrate salts have been noted in Pit 9 as being of particular concemduring intrusive activities already performed at Pit 9. These nitrate salts were process wastes combined ina mixture described as 60% sodium nitrate, 30% potassium nitrate, and 10% miscellaneous during thefilling of drums (745 Series sludges). The miscellaneous mass consisted of organic waste (alcohols,organic acids, and ethylenediaminetetracetic acid [EDTA]) and used items (rags, paper, and gloves) (Pit-9ROD 1993).

It is extremely unlikely that vapors in the corehole or at the core casing-waste interface wouldsustain a fire if an ignition occurred (Prendergrast 1998). Fire protection measures have been developedas a contingency for delivering water to extinguish subsurface fires during core sampling. Corehole firesuppression consists of a quick connect valve attached directly to the DSE to deliver water down insidethe corehole casing. Also, fire extinguishers will be located near the drill rig to be used to extinguish anyresidue ignition sources at the surface. Any surface fire that may occur will only be fought in theincipient state (small fire extinguishable and hand-held extinguishers). If a surface fire cannot beextinguished safely with a hand-held extinguisher, then the area will be placed in a safe shut-down modeand the project site evacuated in accordance with the procedures provided in Section 11.

8.4.3.4 Preliminary Results of Cold Test Sonic Drilling for Simulated Pit 9 Wastes.Preliminary results of cold test sonic drilling for the OU 7-10 SIA Project are also applicable to theOU 7-13/14 subsurface investigation project at Pits 4 and 10 (and Pit 6 if investigated). A sonic drillingtest was conducted at the RSI (sonic drill rig vender) facility, Woodland, California from July 6 to 9,1998. The purpose of this cold test was to demonstrate the safety of sonic drilling methods inrepresentative Pit 9 waste and "worst case waste scenarios. Accordingly, two waste cylinders wereprepared with unique waste to determine the following data objectives:

1. Determine if a noncoated drill bit will spark if it were to encounter a solid carbon steel objectwhile advancing with rotation through Pit 9

2. Measure the temperature in simulated waste containers and the substrate while advancing thesonic drill bit through this waste using a series of thermocouplings

3. Verify no exothermic reaction occurs during core drilling through nitrate salt/oil/organicmixture.

The RSI sonic drill rig was used to core through the waste contained in the test cylinders with thefollowing results:

I. No sparks were observed or measured when the noncoated drill bit was advanced using acombination of sonic and rotational (up to 60 rpm) methods into a 3/4-in. piece of carbonsteel.

2. The maximum temperature increase measured in the waste, two 1-in. thick polyethylenesheets, concrete, and substrate (soil) was 63°F.

3. The nitrate/oil and nitrate/wood chips mixtures showed no trace of heat effect for the sonicdrilling. Additionally, the nitrate mixtures were subject to direct flame from a propane torchand did not bum even after prolonged exposure. The organic material burned as long as itwas in direct contact with the flame, but did not sustain burning when the flame wasremoved.

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Based on the results from these cold tests under "worst case conditions, the probability of areaction from coring though the Pit 9 waste material is considered minimal. A complete review of theCalifornia cold test is described in Stage I Pit 9 Sonic Drilling Safety and the Combustibility Test Report.

8.4.4 Biological Hazards

The OU 7-13/14 subsurface investigation project at the SDA is located in an area that provideshabitat for various rodents, insects, and reptiles. Based on biological studies done at the INEEL, deermice have been known to carry the hantavirus. The virus is present in the nesting and fecal matter of deermice. A potential exists foi project personnel to disturb nesting or fecal matter during the course ofmobilization and intrusive activities. If such materials are disturbed, they can become airbome and createa potential inhalation pathway for the virus. Also, contact and improper removal of these materials mayprovide additional inhalation exposure risks.

If suspect rodent nesting or excrement material is encountered, the CE, IH, or HSO will be notifiedimmediately and no attempt shall be made to remove or clean the area. Following an evaluation of thearea, an SWP will be written for disinfecting and removing it from the project task area in accordancewith MCP-2750, "Preventing Hantavirus Infectioe. The IH will provide the necessary guidance forprotective equipment, mixing, and application of the disinfecting solution (bleach solution) and properdisposal method of the waste. Typical PPE for disinfecting and removing a large nesting area mayinclude full facepiece respirator with a HEPA filter cartridge, Tyvek coveralls, outer booties, and two pairof gloves (latex inner-nitrile outer). Generally, all seams and mating/overlapping PPE ensemble pieceswill be taped.

Snakes, insects, and spiders may also be encountered at the project site. Common areas to avoidinclude material stacking/staging areas, under existing structures (trailers, buildings, etc.), under boxes,and other areas that provide shelter for snakes. Protective clothing will prevent insects from directcontact with personnel; however, repellant (DEET or equivalent) may be required during Level Dactivities. Areas where standing water has accumulated provide breeding grounds for mosquitoes andshould be avoided. In cases where large areas of standing water are encountered, it may be necessary topump the areas dry or add a small concentration of nonhazardous surfactant to the water to break thesurface tension (mosquito hatching phases). Consult with the project and RWMC environmentalcoordinator before adding surfactant to standing water areas.

8.4.5 Conflned Spaces

Work in confined spaces may subject personnel to risks involving engulfment, entrapment, oxygendeficiency, and toxic or explosive atmospheres. There are no confined spaces present at the OU 7-13/14subsurface investigation project task site.

If a suspected confined space is discovered and not properly posted, it will be treated as a permitrequired confined space until a determination is made by an assigned safety/IH professional. Entrancesshall be posted with the required danger or caution sign per the LMITCO Safety and Health Manual,MCP-2749, "Confined Spaces?' A confined space entry permit is required before an employee can entera confined space per the LMITCO Safety and Health Manual, MCP-2749.

e. Pendergast, W.f., Stage I Pit 9 Sonic Drilling Safety, Lockheed Martin Technologies Company, EDF-ER-038, INEEL/INT-98-00510, Revision 5, February 1998.

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8.4.6 Safety Hazards

Industrial safety hazards pose a significant, if not the most likely, threat to personnel whileperforming tasks at the OU 7-13/14 subsurface investigation project site. Section 6 provided general safe-work practices that must be followed at all times. This section describes specific industrial safety hazardsand procedures to be followed to eliminate or minimize potential hazards to project personnel.

8.4.6.1 Handling Heavy Objects. During probing and drilling operations, handling andmaneuvering of probe, drilling cases, bits, full core sections, and various other pieces of equipment mayresult in employee injury. Manual material handling will be minimized through task design and use ofmechanical and/or hydraulic lifts whenever possible.

If it becomes necessary to abandon coreholes, personnel will be required to handle bags ofBentonite or sand to perform mixing operations. Bags can weigh over 36 kg (80 lb) and present a seriousback strain hazard. Persormel shall not lift objects over 50 lbs without mechanical assistance or the helpof another person, and will be trained in the proper methods in accordance with the LMITCO Safety andHealth Manual, MCP-2716, "Personal Protective Equipment." In addition, the CE or HSO willperiodically review the basics of safe lifting in the daily POD safety briefings.

8.4.6.2 Powered Equipment and Tools. It is not anticipated that steam cleaning equipment willbe used other than if deemed necessary by the RCT. At the OU 7-13/14 subsurface investigation projectsite, radiological release surveys will determine what equipment can leave the CA. All power equipmentand tools will be properly maintained and used according to the manufacturer's specifications by qualifiedindividuals. The LMITCO Safety and Health Manual, MCP-2735, "Hand and Portable Power Tools" willbe followed for all work performed with powered equipment including powered steam cleaners.

8.4.6.3 Heavy Equipment and Moving Machinery. The hazards associated with the operationof heavy equipment include injury to persormel, equipment damage, and/or property damage. All heavyequipment will be operated in the manner in which it was intended and according to manufacturer'sinstructions. Only authorized personnel will be allowed in the vicinity of operating heavy equipment andshould maintain visual communication with the operator. Work-site personnel shall comply withLMITCO Safety and Health Manual, MCP-2745, "Heavy Industrial Vehicles," MCP-2743, "MotorVehicle Safety," and MCP-2744, "Powered Industrial Trucks."

Task-site personnel working around or near the drill rig, logging truck, and other movingmachinery shall comply with the appropriate LMITCO Safety and Health Manual MCPs andDOE-STD-1090-96, DOE Hoisting & Rigging Standard. Additional safe practices will include:

• All heavy equipment will have backup alarms

• Walking directly in back of or to the side of heavy equipment without the operator'sknowledge will be prohibited; all precautions will have been taken prior to moving heavyequipment

• While operating heavy equipment in the work area, the equipment operator shall maintaincommunication with a designated person responsible for providing direct voice contact orapproved standard hand signals; in addition, all site personnel in the immediate work areashall be made aware of the equipment operations

• All equipment shall be kept out of traffic lanes and accessways. Equipment shall be storedso as not to endanger personnel at any time.

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• All project personnel will maintain a safe distance from any of the rotational drillingcomponents while operating.

8.4.6.4 Hoisting and Rigging of Sonic Drill Rig. The sonic drill rig will require hoisting andrigging tasks to be performed for loading and unloading from trailers and as part of the probehole(TPR-179) and corehole procedures. An approved lifting plan and job safety analysis (JSA) is in placefor these activities. It identifies the engineered lifting points, center of gravity, drill rig gross weight,crane load charts, and rigging requirements. All hoisting and rigging of the sonic drill rig will beperfonned in accordance with PRD-160, Hoisting and Rigging and DOE-STD-1090-96 as applicable forOU 7-13/14 operations.

8.4.6.5 Electrical Hazards/Energized Systems. Electrical equipment and tools as well asunderground lines may pose shock or electrocution hazards to personnel. Safety-related work practicesshall be employed to prevent electric shock or other injuries resulting from direct or indirect electricalcontact. If work on energized systems is necessary, these practices will conform with the requirements inthe LMITCO Safety and Health Manual, MCP-273I, "Electrical Safety," LMITCO Operations Manual,MCP-1059, "Lockout and Tagout, " facility supplemental MCPs, and Parts I — III of NFPA 70E. Inaddition, all electrical work will be reviewed and completed under the appropriate work controls (i.e.,HASP, SWPs, work orders).

Before beginning drilling or excavating operations, underground utility clearances will be obtainedby contacting Telecommunications (526-1688 or 526-2512). Subsurface investigation clearance will beobtained in accordance with LMITCO Facilities and Maintenance Manual, MCP-151, "SubsurfaceInvestigations." The requirements for advanced 48-hour notice will be met.

8.4.6.6 Personal Protective Equipment. Wearing PPE will reduce a worker's ability to movefreely, see clearly, and hear directions and noise that might indicate a hazard. Also, PPE can increase therisk of heat stress. Work activities at the task site will be modified as necessary to ensure that personnelare able to work safely in the required PPE. Work-site personnel shall comply with LMITCO Safety andHealth Manual, MCP-2716, "Personal Protective Equipment" and Radiological Control Manual,MCP-432, "Radiological Personal Protective Equipment." Pit 4 and 10 (and Pit 6 if investigated) projectPPE levels for each task are described in Section 9 and listed in Table 9-1 of that section.

8.4.6.7 Decontamination. Decontamination procedures for personnel and equipment are detailedin Section 10. Due the unique nature of contamination (TRU mixed waste), the Section 10 procedureswill serve as the primary DECON method for all personnel and equipment that enter the EZ andradiologically controlled areas at the OU 7-13/14 subsurface investigation project site (i.e., Pits 4 and 10;and Pit 6 if investigated). The appropriate LMITCO MCPs provide additional requirements for chemicaland radiological decontamination requirements.

Decontamination procedures (Section 10) and applicable MCPs must be followed and theappropriate level of PPE worn during DECON activities. Project RADCON and IH personnel will followLMITCO Radiological Control Procedure, MCP-148, "Personnel Decontaminatioe and Safety andHealth Manual—I4B MCPs and general IH practices; for sampling activities the appropriate OU 7-13/14Probe Installation Plan or Field Sampling Plan for Coreholes will be followed.

Note: If decontatnination of equipment is required, the appropriate location for decontamination will beevaluated by the HSO in consultation with RWMC RADCON personnel based on the nature of thecontamination, extent of decontamination required, and a new RWP or ALARA task written .

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8.4.7 Inclement Weather Conditions

The inclement or adverse weather conditions that may pose a threat to persons or property at thetask site (for example, sustained strong winds 25 mph or greater) electrical storms, heavy precipitation, orextreme heat or cold) will be evaluated by the FTL with input from the HSO, IH, safety engineer, RCT,and other personnel, as appropriate. Stop work and mitigation measures will be determined andcommunicated to field personnel. During all activities, OU 7-13/14 subsurface investigation projectRADCON and IH personnel will determine if wind or other weather conditions pose unacceptablehazards to personnel or the environment.

8.4.8 Cryogenics

Logging tool detectors require cooling with liquid nitrogen (LN2). LN2 will be supplied to thelogging tool using standard gas fittings and a feed line for each tool. A LN2 storage cylinder(approximately 160 liters) will be filled as required by an INEEL commercial compressed gas venderunder using existing RWMC work controls. LN2 tool feed line connections to this storage cylinder willbe made by the logging subcontractor. All LN2 tasks will be conducted and protective equipment worn inaccordance with MCP-2736, "Cryogenic Systems7 and as listed on applicable JSA.

8.5 Other Task Site Hazards

Task-site personnel should continually look for potential hazards and immediately inform the CEor HSO of the hazards so that action can be taken to correct the condition. The CE, HSO, RCT, and FTLwill be at the project site and visually inspect the site to ensure that barriers and signs are beingmaintained, unsafe conditions are con•ected, and debris is not accumulating on the site. Periodic safetyinspections will be performed by the SE, HSO or CE in accordance with MCP-3449, "Safety and HealthInspectionC using an OU 7-13/14-specific checklist. Additionally, targeted and/or required self-assessments may be performed during OU 7-13/14 operations in accordance with MCP-8, "Self-Assessments Process for Continuous Improvement." All inspections and assessments will be noted in theFTL logbook. Health and safety professionals present at the task site may, at any time, recommendchanges in work habits to the FTL or CE. However, all changes that may affect the OU 7-13/14 projectwritten work control documents (HASP, JSAs, RWPs, SWPs), must have concurrence from theappropriate project technical discipline representative on site and a Document Action Request (DAR)prepared as required.

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9. PERSONAL PROTECTIVE EQUIPMENT

The OU 7-13/14 subsurface investigation project site (Pits 4 and 10; and Pit 6 if investigated) posessignificant potential hazards to personnel from the nature of the buried waste material (TRU mixed waste)from coring operations and from industrial safety hazards (moving equipment and vehicles). Anyoneentering the CRZ and EZ must be protected against these potential hazards. The purpose of PPE is toshield or isolate personnel from chemical, radiological, physical, or biological hazards that cannot beeliminated though engineering or other controls and may be encountered at the project site. It isimportant to realize that no PPE ensemble can protect against all hazards under all conditions and thatwork practices and adequate training will also provide a greater level of protection to workers.

Selection of the proper PPE to protect OU 7-13/14 subsurface investigation project site personnel isbased on:

• Pits 4 and 10 (and Pit 6 if investigated) project tasks to be conducted (mobilization,drilling/coring, sampling, etc.)

• Known or suspected radiological and nonradiological materials and agents expected to befound at the task site

• Potential contaminant routes of entry

• Physical form and chemical characteristics of contaminants

• Acute and chronic effects from exposure to contaminants

• Local and systemic toxicity of contaminants

• Anticipated exposure levels (surface and airborne)

• The Hazard Analysis (Section 8) evaluation of this HASP.

Anti-contamination (Anti-C) requirements are dictated by RWP in conformance with LMITCORadiological Control Manual, MCP-432, "Personal Protective Equipment."

PPE is generally divided into two broad categories: (1) respiratory protective equipment and(2) personal protective clothing. Both of these categories are incorporated into the standard four levels ofprotection (Levels A, B, C, and D), based on the potential severity of the OU 7-13/14 subsurfaceinvestigation project hazards. Table 9-1 provides guidance in the selection process for respiratory andprotective clothing. Pits 4 and 10 (and Pit 6 if investigated) project site-specific hazards andcontaminants will be evaluated in determining the most appropriate PPE level and modifications.

9.1 Respiratory Protection

Several of the radiological and nonradiological contaminants of the buried waste material coresamples to be obtained from Pits 4 and 10 (and Pit 6 if investigated) present a significant potentialrespiratory hazard if released in an airbome respirable form. Table 8-4 and Section 8 presented thecontaminants and exposure potential based on the tasks to be completed, amount and form of hazardousconstituents, engineering controls that will be implemented, and containerized nature of core retrieved

9-1

Table 9-1. Respiratory and protective clothing selection.

Respiratory PPE Selection'

Hazard Level of Protection

Not immediately dangerous tolife or health (IDLH) or oxygendeficient atmospheric conditions.Gaseous, vapor, particulateand/or aerosolchemicals/radionuclides.

IDLII or oxygen deficientatmospheric conditions.Gaseous, vapor, particulateand/or aerosolchemicals/radionuclides.

Level C—full-facepieceLevel B—full-facepiece supplied air respirator or airhood

HEPA/chemical combination cartridge or airhood for concentrationsup to the protection factor of an air-purifying fiill-facepiece respiratorand within the assigned DAC value

Level B—full-facepiece, supplied air respirator with an escape-onlySCBAa orLevel A—self contained breathing apparatus

HEPA/chemical combination cartridge for concentrations up to theprotection factor of an air-purifying full-facepiece respirator andwithin the assigned DACa value

a. A multichemical/HEPA combination cartridge to be selected by IH and RADCON personnel based on specific task hazards.

Protective Clothing Selection

Low atmospheric contaminant levels that are present under stable conditions. No anticipatedimmersion, splashes, or potential for unexpected contact with chemical or radiologicalcontaminants.

Moderate atmospheric contaminants under relatively stable conditions, liquid splashes orother direct contact that do not have corrosive characteristics or can be absorbed by exposedskin. Low radiological contamination and airborne radioactivity levels.'

Moderate to high atmospheric contaminants under unstable conditions, potential for contactwith wet, contaminated surfaces/material that can saturate or permeate Level C protectiveclothing. Moderate radiological contamination and airborne radioactivity levels.'

High and unknown atmospheric contaminants, potential for contact with substances that posea high hazard potential to the skin, high potential for splash, immersion or exposure tounexpected vapors, gases, aerosols, or dusts that may present an IDLH situation/readilyabsorbed through the skin. High radiological contamination and airborne radioactivity levels.'

a. Derived air concentration (DAC) based on specific radionuclides.

b. SCBA = self-contained breathing apparatus.

c. Contamination levds and airbome radioactivity as defined by 10 CFR 835.603.d.

Level D

Level C

Level B

Level A

material. This evaluation concluded that the primary potential respiratory hazards will be from airborneradioactivity and organic vapors. Therefore, the type of respiratory protection required for this project isbased on these primary potential respiratory hazards.

The level and type of respiratory protection are task-specific and relate directly to the airbornehazards for each given task or activity. Task-based respiratory protection and protective clothing requiredare listed on Table 9-2. Required levels of respiratory protection will vary based on specific tasks.

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Personnel will not exceed the assigned protection factors (APFs) of the respiratory devices listed onTable 9-3.

The potential for encountering nonradiological and airbome radioactivity during core handling andsampling tasks presents the single worst case exposure scenario for uptake of contaminants during thecourse of this project. Airhoods or Level B, Type C supplied air respirators ([SARs], MSHA/NIOSH30 CFR 11), will be required for core sampling and instrument installation tasks (DSE material transfers).Breathing air cylinders (if used) shall be marked to identify the material contained in accordance with theAmerican National Standards Institute (ANSI) Z48.1-1954 and Federal Specification BB-A-1034a-1968.Breathing air cylinders shall be hydrostatically tested within the past two years.

The SARs or airhoods will be operated in a continuous flow mode so any leakage due to amomentary break in any seal or sealing surface is outward. Air lines will be kept as short as possible witha maximum length as stated in the manufacturer's operating instructions. In no case will air Iine hosesexceed 91 m (300 ft). Air for the airhoods or SARs will be supplied from an onsite breathing aircompressor with air line coupling station. The number of stations will be limited to the capacity of thecompressor system to maintain the recommended airflow to each facepiece or airhood. Airline couplingswill be Schraeder quick-disconnect (or equivalent, as long as they are integrated throughout the air linesystem and incompatible with other gas system couplings) or as required by the manufacturer.

The compressor supplying the air shall be equipped with the necessary safety and standby devices.The compressor shall be constructed and situated at the project site to avoid entry of contaminants into theair system and suitable air line air-purifying sorbent beds and filters installed to further assure thatdelivered breathing air quality meets the requirements for Grade "D" breathing air (Compressed GasAssociation Commodity Specification G-7.1-1996 and ANSI Z86.1-1993). A receiver of sufficientcapacity to enable the respirator wearers to escape in the event of compressor failure (if escape bottles arenot worn), and alarms to indicate compressor failure and overheating shall be installed in the system. Ifan oil-lubricated compressor is used, it shall have a high-temperature or carbon monoxide alarm, or both.If only a high-temperature alarm is used, the air from the compressor shall be frequently tested by theproject IH for carbon monoxide and other Grade "D" air criteria, as required.

All personnel required to wear tight fitting respirators shall complete training and be fit-testedbefore being assigned a respirator per the training and documentation requirements in Section 4 of thisHASP. Requirements for respirator use, emergency use, storage, cleaning, and maintenance, as stated inthe LMITCO Safety and Health Manual, MCP-2726, "Respiratory Protection." shall be followed.

9.2 Personal Protective Equipment Levels

This subsection provides detail and explanation of the four levels of PPE. Modifications to theselevels shall be made under the direction of the HSO in consultation with the project IH and RADCONpersonnel, as appropriate. Such modifications are routinely employed during HAZWOPER site activitiesto maximize efficiency and to meet site-specific needs without compromising personnel safety and health.Due to the TRU mixed waste contamination that will be encountered at the project site, special attentionwill be given to both respiratory and protective clothing modifications to meet specific task requirements.The HSO, IH, and RADCON will determine what modifications are appropriate to the PPE levels listedon Table 9-2.

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Table 9-2. OU 7-13/14 subsurface investigation project task-based PPE requirements and modifications.

Task or Assignment Level of PPE Modifications and Comments

• Mobilization and SitePreparation,

• Probehole installation

• Downhole logging

• Drill Rig Movementinside EZ

Level D (primary) A11 non-DSE tasks will be conducted in Level D PPE with somemodification for hand and head protection as warranted.

Modified Level D(contingency only)

Upgrading to modified Level D (protective clothing) ifcontamination is detected above RWP limits during probeholeinstallation or completion activities.

Level C(contingency only)

If atmospheric contaminants increase to concentrations aboveaction limit, Level C air-purifying respiratory protection(chemical/radiological) will be wom in conjunction withchemical protective clothing (Tyvek coveralls or equivalent).

• Core Sampling

• Instrument Installation

• DSE Repair orReplacement'

Level B (primary) All tasks in Level B, double anti-C (outer layer may be coatedTyvek or Saranex-23C if contact with waste residue cannot beeliminated), all seams taped, airline respiratoiy protection(airhoods), and other requirements per the task/area RWP.

Level C (downgradecontingency)

If atmospheric contaminants below action levels for Level Brespiratory protection (chemical/radiological) and no airbomeradioactivity, downgrading to Level C air-purifying respiratorswith HEPA/chemical combination cartridges may be allowed.

RCT Surveys and SwipeCollection inside activeCA b

Level B (initially) All tasks in Level B, double anti-C (outer layer may be coatedTyvek or Saranex-23C if contact with waste residue cannot beeliminated), all seams taped, airline respiratory protection(airhoods), and other requirements per the task/area RWP.

All surveys followingcorehole completion androutine surveys

Level C (downgradecontingency)

If atmospheric contaminants below action levels for Level Brespiratory protection (chemical/radiological) and no airbomeradioactivity, downgrading to Level C air-purifying respiratorswith HEPA/chemical combination cartridges may be allowed.

Confirmation surveys innonactive areas of CA

Modified Level D orLevel D

Based on routine survey results during CA operations and RWP.

Sample Core Assay andShipment Preparation

Level D (initially)

Modified Level D(contingency)

Handling free-released double-contained (bagged or sleeved)core samples (placing in shipping containers), modifications pertask/area RWP and SWP if required.

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Task or Assignment Level of PPE Modifications and Comments

• General EZ ActivitiesOutside CA

• Demobilization ofEquipment

Level D (Primary)

Modified Level D(contingency only)

The general area outside designated CA will be consideredradiologically clean and no PPE beyond Level D will berequired. However, as specific activities are conducted(removing trailer anchors, geocomposite sections, etc.), somemodifications may be required as deemed appropriate by theHSO and RCTs.

Decontamination

• Inside CA Level B (Primary)

All decontamination will be conducted in Level B, double anti-C (outer layer may be coated Tyvek or Saranex-23C if contactwith waste residue cannot be eliminated), all seams taped,airline respiratory protection (airhoods), and other requirementsper the task/area RWP.

Level C(contingency)

Decontamination of nonradiological surface contamination maybe conducted in Level C PPE if airborne concentrations arewithin the specified action limits.

• Inside EZ Level C (Primary) Decontamination of nonradiological surface contamination maybe conducted in Level C PPE if airbome concentrations arewithin the specified action limits.

Modified D(contingency)

Modified D allowable if respiratory hazards eliminated orminimized as demonstrated through monitoring.

• Outside EZ Modified Level D General decontamination of uncontaminated surfaces (generalwashing) in the SZ or other designated area will be conducted inmodified Level D if a high-pressure sprayer or steam cleaner isused to prevent splashing and spraying hazards (face shield,apron, rubber boots) will be wom.

a. The DSE will not be replaced between sample locations unless it is determined that gross contamination has occurred that couldaffect the integrity of the outer confinement.

b. Radiological surveys and swipes will be collected prior to dismantlement of the CA. If contamination is found, work will bestopped a new RWP written, and decontamination effort will be conducted to remove the source. If the contamination isdetermined to be fixed, then the contaminated material or area will be removed or contained, as appropriate.

CA = Contamination Area (10 CFR 835)CRZ = Contamination reduction zone (29 CFR 1910.120)DSE = Drill string enclosureEZ = Exclusion zone (29 CFR 1910.120)RBA = Radiological buffer area (10 CFR 835).

NOTE: Personnel must inspect all PPE before donning and entry into any work zone. Items found to bedefective or that become unserviceable during use will be doffed and disposed in accordance with postedprocedures and placed into the appropriate waste stream. PPE inspection guidance is provided inSection 9.4.

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Table 9-3. Assigned respiratory protection factors.'

Type of Respirator

Respiratory Inlet Covering(full facepiece)

Chemical APF Radiological APF

Air-purifying Chemical Agents

100

Radionuclides50b,c

Atmosphere Supplying Chemical Agents

100

1,000

1,000

Radionuclides

50'

1,000'

2,000`

Air line and SCBA (demand mode)

Airhood (continuous flow mode-6 CFM to hoodminimum)

Air line (pressure demand and continuous flowmode)

SCBA (pressure demand, open/closed c rcuit) Chemical AgentsSee belowd

Radionuclides

10,000

a. ANSI Z88.2-1980.

b. Particulates only. When HEPA filters are used in atmospheres not containing radioactive gas.

c. LMITCO MCP-432.

d. Although positive pressure respirators are currently regarded as providing the highest level ofsimulated workplace studies concluded that an users may not achieve protection factors of 10,000definitive APF could not be listed for positive pressure SCBAs. For emergency planning purposesconcentrations can be established, an APF of no higher than 10,000 should be used.

respiratory protection, recentBased on this limited data, awhere hazardous

9.2.1 Level D Personal Protective Equipment

Level D PPE will only be selected as a work uniform and not on a site with respiratory or skinabsorption hazards requiring whole body protection. It provides no protection against airborne chemicalhazards, but rather is used for protection against nuisance contamination and physical hazards. Level DPPE will only be allowed in areas that have been characterized or are known to have never beencontaminated. At the OU 7-13/14 subsurface investigation project site, Level D PPE is only allowedduring mobilization tasks, tasks where it has been determined Als will not be exceeded inside the EZ andSZ activities. Level D PPE ensemble may be modified to provide protection from skin and physicalhazards, but not respiratory protection.

Basic Level D PPE consists of the following:

• Coveralls or work clothes (as determined by the IH, RCT)

• Hard hat (as required by safety engineer and type of work being performed)

• Eye protection, safety glasses with side shields as a minimum (see LMITCO Safety andHealth Manual, MCP-2716, "Personal Protective EquipmenC)

• Safety footwear (steel or protective toe and shank, as determined by the safety engineer)

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Optional Level D Modifications consist of the following:

• Chemical or radiological protective clothing (Tyvek, Saranex, etc.) as prescribed in task-specific RWP or SWP

• Chemically resistant hand and foot protection (inner/outer gloves, boot liners, etc.)

• Radiological modesty garments under outer protective clothing

• Any specialized protective equipment (hearing protection, cryogenic gloves, face shields,welding goggles, aprons, etc.).

9.2.2 Level C Personal Protective Equipment

Level C PPE shall be worn when the task site chemical and/or radiological contaminants have beenwell characterized indicating that personnel are protected from airborne exposures by wearingair-purifying respirators (APRs) with the appropriate cartridges, no oxygen-deficient environments exist(<19.5% at sea level), and that there are no conditions that pose immediate danger to life or health(IDLH).

Basic Level C PPE shall include Level D ensemble with the following respiratory and whole bodyprotection upgrades:

• Full-facepiece APR equipped with a NIOSH approved HEPA/chemical combinationcartridge (IH to specify chemical combination cartridge)

• Chemical-resistant coveralls (Tyvek QC®, Tychem 7500®, Saranex-23-PTM, etc.) asprescribed in task-specific RWP or SWP (IH to specify material)

• Chemical-resistant outer shoe/boot cover (IH or RCT to specify material)

• Inner chemical-resistant nitrile rubber gloves with cotton liners (as determined by the IHand/or RCT)

• Outer chemical-resistant Viton or polyvinyl alcohol (PVA) gloves (as determined by the 11-1)

Optional Level C Modifications consist of the following:


• Any specialized protective equipment (hearing protection, welding lens, aprons, etc.).

9.2.3 Level B Personal Protective Equipment

Level B PPE shall be wom when personnel cannot be adequately protected with air-purifyingrespirators because there are high levels of contaminants present, the appropriate respirator cartridges orcombination is not available, a significant hazard exists for skin exposure, or IDLH/oxygen-deficientconditions exist. If IDLH conditions do not exist, then an escape air-purifying cartridge may besubstituted for the escape bottle.

9-7

Level B PPE includes Level C ensemble with the following respiratory and whole body protectionupgrades:

• An airhood operating at a minimum pressure of 6 CFM or a full-facepiece SAR with a 10-minute escape bottle, a self-contained breathing apparatus (SCBA) or an escape air-purifyingcombination HEPA/chemical cartridge (SAR hose length no more manufacturer'sspecification and under no circumstances greater than 91 m [300 ft])

• Chemical-resistant coveralls or encapsulating suit (Tyvek QC®, Tychem 7500®, Saranex23-CTM or equivalent)

• Any other chemical or radiological PPE prescribed in task-specific RWP or SWP

• Chemical-resistant butyl or one-time-use natural latex outer boots (as determined by the IHand/or RCT)


• Outer chemical-resistant Viton or PVA gloves (as determined by the IH).

Optional Level B Modifications consist of the following:

• Radiological modesty garments


NOTE: All seams must be taped and secured to prevent skin contact from hazardous substances ina soil, liquid, mist, and aerosolized form.

9.2.4 Level A Personal Protective Equipment

The use of Level A PPE ensemble (fully encapsulating suits) is not anticipated for this project.Level A ensemble must be further evaluated to determine if the safety basis for subsurface investigationactivities at Pits 4 and 10 (Pit 6 if investigated) are still valid or if additional safety analysisdocumentation is required. Prior to selecting Level A PPE, the assigned IH and/or RCT must ensure thatsite characterization to identifying known and potential chemical and radiological hazards is completed(to the extent possible).

Level A PPE has the maximum respiratory, skin, and eye protection and is suitable for use insituations where the levels of contaminants are known to be very high and dangerous, where levels arecompletely unknown, or where an IDLH condition could develop.

Level A PPE includes Level B ensemble with the following respiratory and whole body protectionupgrades-

• Open circuit SCBA or a full-facepiece SAR with a 15-minute escape-only SCBA bottleoperated in a continuous-flow mode (SAR hose length of less than 91 m [300 ft])

• Fully encapsulating, chemical-resistant suit (Barricade®, Tychem 10000TM, or equivalent)

9-8

• Chemical-resistant butyl or one-time-use natural latex outer boots (as determined by the IHand/or RCT)


• Outer chemical-resistant Viton or PVA gloves (as determined by the IH).

• Optional Level B Modifications



9.3 Protective Clothing Upgrading and Downgrading

The OU 7-13/14 subsurface investigation project HSO, in consultation with the project IH andRADCON personnel, will be responsible for determining when to upgrade or downgrade PPErequirements. Upgrading or downgrading PPE requirements based on current conditions is a normaloccurrence. Action levels, listed on Table 8-7 in Section 8, provide the basis for determining suchdecisions.

The following are reasons for upgrading or downgrading.

• Upgrading Criteria (work will stop immediately if PPE upgrading is required)

Unstable or unpredictable site radiological and/or nonradiological hazards

Contaminants that are difficult to monitor or detect

Known or suspected presence of skin absorption hazards

Temporary loss or failure of any engineering controls

Identified source or potential source of respiratory hazard(s)

Change in the task procedure that may result in an increased contact withcontaminants or meeting any of the criteria listed above.

• Downgrading Criteria

New monitoring data information that shows the contaminant levels to be lower thanestablished action limits

Implementation of new engineering or administrative controls that eliminate orsignificantly mitigate hazards

9-9

Elimination of potential skin absorption or contact hazards

Change in site conditions that results in removal of physical hazards orreduces/isolates them to a controlled area

Completion or change in tasks that results in the elimination of key hazards thatrequire higher levels of PPE.

Table 9-2 lists each task or assignment and the corresponding level of PPE, as well as anyadditional or special items necessary for personal protection at the task site.

9.4 Inspection of PPE

All PPE ensemble components must be inspected prior to use and when in use within theOU 7-13/14 project work zones of Pits 4 and 10 (Pit 6 if investigated). Self-inspection and the use of thebuddy system, once PPE is donned, will serve as the principal forms of inspection. If at any time PPEshould become damaged or degradation/permeation is suspected, an individual will inform others of theproblem and proceed directly to the work zone exit point to doff and replace the unserviceable equipment.Additionally, all PPE that becomes contaminated or presents a potential source for the spread of suchcontamination will be required to be decontaminated in the transition tent area or replaced. Table 9-4provides an inspection checklist for common PPE items.

Table 9-4. PPE inspection checklist.

PPE Item Inspection

Gloves

Respirators (full-facepieceair-purifying and supplied airrespirators with escape-onlySCBA bottles or escapecartridges)

Before use:

Pressurize gloves to check for pinholes, blow in the glove, then rolluntil air is trapped and inspect. No air should escape.

Before use:

Air line matches the air line respirator to be used (black hose)

Inspect air line hose connections (sections of hose) to ensure all arethreaded or permanent metal-to metal connections (no quickdisconnect pieces)

Check condition of the facepiece, head straps, valves, connectinglines, fittings, all connections for tightness.

Check cartridge to ensure proper type/combination for atmospherichazards to be encountered, inspect threads and O-rings for pliability,deterioration, and distortion.

Check for proper setting and operation of regulators and valves,check all hose connections back to the breathing air compressor,check the pressure to the air line station and on individual air lineconnections to ensure pressure is within required range (inaccordance with the manufacturer's specification).

Before entry into Level B area:

Ensure air compressor is providing a minimum of 110 psi when alIpersonnel have air lines hooked up to compressor manifold.

9-10


PPE Item Inspection

Airhoods

Level D, C, and B Clothing

Level A Encapsulating Suit

Before use:

Airline matches the airhood to be used (red hose)

Airhood is within 3-year shelf life (for PVC components)

Visually inspect all seams and surfaces for tears, cracks, etc.(specialattention to area where hood attaches to shoulder shroud)

Pressurize airhood to check for pinholes or defective seams (no airshould leak out when choking clear hood piece).

Before entry into CA:

Inspect all airline connections for tight fit (pull connections 3 times).

Ensure air compressor is providing a minimum of 110 psi (— 6 cfmper airhood) when all personnel have air lines hooked up tocompressor manifold.

Before use:

Visually inspect for imperfect seams, nonuniform coatings, tears, etc.Hold PPE up to the light and inspect for pinholes, deterioration,stiffness, and cracks.

While wearing in the work zone:

Look for evidence of chemical attack, such as discoloration,swelling, softening and material degradation. Inspect for tears,punctures, and zipper or seam damage. Check all taped areas toensure they are still intact.

Before Use:

(not anticipated to be worn) Same item as with other protective clothing, with the addition ofchecking the operation of the pressure relief valve, inspect fitting ofwrists, ankles and neck. Inspect face shield for cracks, fogginess,scratches, and crazing.

While wearing in the work zone:

Same as other protective clothing.

9-11

10. DECONTAMINATION PROCEDURES

Buried waste material that will be core sampled from Pits 4 and 10 (and Pit 6 if investigated)contains numerous radiological and nonradiological contaminants that could deposit on drill stringsections, outer core surfaces, interior surfaces of confinement material, HEPA vacuum intemal surfaces,and debris and waste containers. The release or cross-contamination (equipment-to-equipment orequipment-to-personnel) of contaminants would result in an extensive decontamination effort. Everyeffort will be made to prevent contamination of personnel and equipment through the use of engineeringcontrols, isolation of source materials, continuous site monitoring and surveying, personnel training, andby following all contaminated material handling requirements and procedures.

10.1 Contamination Control and Prevention

Everything that enters the established CAs could become contaminated. Contamination controland prevention procedures will be implemented throughout this project to minimize personnel contactwith contaminated surfaces. The contaminated drill string will be contained within a HEPA-filterednegatively pressurized DSE. At the OU 7-13/14 subsurface investigation project site, the followingcontamination control and prevention measures will be employed:

• Identifying potential sources of contamination and designing confinement, isolation, andengineering controls to eliminate or mitigate any potential for contact or release ofcontaminants

• Minimizing the personnel, equipment, and materials that enter the CA

• If contamination is found on outer surfaces (outside the DSE or glovebag confinement),immediate decontamination procedures will be implemented to prevent the spread ofcontamination (see Subsection 10.2.2)

• Covering or sleeving all sections and pieces of the drill rig adjacent to the DSE (wherepossible) to prevent deposition of airborne contaminants on outer and accessible surfaces if afailure were to occur

• Constructing a temporary surface layer (geomembrane) on top of the pit's overburden forPits 4 and 10 (Pit 6 if it is investigated). This additional layer will provide a better surface toconduct required radiological surveying/swiping, reduce contaminant migration, and hastendecontamination if contamination is noted on the geocomposite surface

• Using remote drill operational controls to reduce the number of personnel in the immediatearea (within 15 m [50 ft]) of the confinement structure (DSE) and active portion of the drillrig

• Using only established control entry and exit points from the CA to minimize the potentialfor cross-contamination and expedite contamination control surveys

• Wearing disposable outer garments and using disposable equipment (where possible).

Note: Any radiological contatnination detected above those levels listed in the "Limiting Conditions ThatVoid the RWP" Section of the RWP will immediately result in a stop work action and void the RWP. Anydecontamination required will be performed under a separate RWP or ALARA task.

10-1

10.2 Personnel and Equipment Decontamination

Decontamination procedures for personnel and equipment are necessary to control contaminationand protect personnel. Both chemical and radiological contamination will be decontaminated fromsurfaces at the exit from the CA and other work zone transition boundaries (CRZ for nonradiologicalnonhazardous materials, as appropriate). Due to the nature of the contamination source material at theOU 7-1 3/14 subsurface investigation project site (TRU mixed waste) and limitations of direct readingorganic vapor instrumentation, radiological contamination will serve as the best proxy for detecting bothradiological and nonradiological surface contamination. Industrial hygiene instrumentation will also beused to detect off-gassing of VOCs from surface contamination, along with other qualitative methods(e.g., pH paper as appropriate).

All radiological and mixed hazardous substance decontamination tasks will be performed inLevel B PPE ensemble initially. All radiological decontamination operations for equipment and areasshall be performed in accordance with Chapter 4 of the LMITCO Radiological Control Manual.Nonradiological decontamination will be evaluated on a case-by-case basis by the HSO and project IH todetermine the most appropriate PPE (Level C protective clothing will initially be selected until sitemonitoring can demonstrate downgrading is wan•anted). Nonradiological contamination is not expectedto be present without some detectable radiological contaminants, given the nature of the waste materialsdisposed in the SDA over the years. Specific personnel and equipment decontamination methods areprovided below.

10.2.1 Personnel Decontamination

Engineering controls, in conjunction with project contamination prevention and control practicesand proper protective clothing donning and doffing procedures, will serve as the primary means toeliminate the need for personnel decontamination. Procedures for donning and doffing protectiveclothing will be posted at all established radiological contamination area entrances and exits. All PPEitems will be inspected prior to being donned; Table 9-4 in Section 9 describes how to inspect PPE items.After donning protective clothing, your buddy, the CE, HSO, and/or RCT will check to verify properdonning technique. Personnel are at greatest risk of contamination when removing core samples andcasing from the DSE, during corehole abandonment, and from improper doffing of contaminatedprotective equipment when exiting a CA (during a confinement failure scenario only). Core samples willbe removed from the DSE through the lower port directly into a confinement enclosure (sleeving), thendouble-bagged with a second layer.

Gross contamination of surfaces also increases the probability of personnel contact and cross-contamination. If cross contamination is found on any PPE surfaces (gloves, booties, outer protectiveclothing), they will be immediately decontaminated or doffed in accordance with the posted instructions.Contamination deposited on the surface of PPE, if allowed to remain there, can potentially permeate thePPE material. Most surface contamination can be detected and removed by accepted decontaminationpractices. A contaminant that has permeated PPE material can be difficult to detect and remove.TyveknA, coated TyveknA, or Saranex-23C® will be worn at the project site to minimize permeation ofsurface contaminants. However, even with these fabrics, if a contaminant is allowed to remain for anyextended period on the surface of PPE, it is more likely to degrade or permeate the material. Thefollowing are the major factors that impact the extent of permeation:

• Contact Time—The longer a contaminant is in contact with PPE material, the greater theprobability or extent of permeation. For this reason, minimizing contact time is one of themost important objectives of the decontamination procedure.

1 0-2

• Concentration—As the concentrations of a contaminant increases, the potential forpermeation of protective clothing increases.

• Temperature—An increase in temperature generally increases the permeation rate ofcontaminants.

• Chemical and Physical Characteristics—Permeation rates depend on themolecular/particulate size of the contaminant and the pore size of the protective material.Also, chemical characteristics (e.g., polarity, vapor pressure, pH) of both the contaminantand the protective clothing will determine permeability. As a general rule, gases, vapors andlow-viscosity liquids tend to permeate more readily than high-viscosity liquids or solids.

PPE selection will provide for the layered barriers required to prevent permeation and minimizeexternal surface contamination. The options for the outermost protective clothing layer (Tyvek QCTM,Saranex-23C®, etc.) will depend on the likelihood for deposition of contaminants and the specific tasks,as listed on Table 9-2.

If contamination is detected on outer PPE layers, careful removal of these outer PPE layerswill generally eliminate over 99% of contamination. This will be the primary decontamination methodat the OU 7-13/14 subsurface investigation project site if protective clothing is contaminated. Removal ofcontaminated PPE using standard radiological doffing techniques (rolling outer surfaces inward whilebeing removed) provides the most effective method for containing and isolating the contaminants andgreatly reduces the potential for exposure to other personnel who would be put at risk of cross-contamination from other decontamination methods (washing, brushing, etc.). Contamination on theupper areas of the protective clothing poses a greater risk to workers because volatile or radiologicalsubstances may become airbome closer to the breathing zone and create an inhalation hazard for both forthe individual and others in the immediate vicinity. Any excessive motion or ballistic movements(ripping off tape, snapping gloves or booties) will greatly increase the chance of generating airbornecontamination. A wipe down with maslins may be required prior to doffing anti-Cs. This will be basedon surveys and work activities in conjunction with RADCON support personnel onsite.

Removal of respiratory protective devices will be the most critical element of the doffing procedureto prevent potential uptake through inhalation of contaminants. This is a demonstrated skill that has beenperformed as part of passing the DOE Core Radiological Worker H practical exam qualification.However, it is recognized that this project will entail a transition tent decontamination sequence that manyof the project personnel have not experienced; therefore, some supplemental training on the properdonning and doffing sequence (Section 10.3) will be provided by RADCON personnel. Written doffinginstructions will be posted at the exit boundary to each tent transition area and the contamination RBA (ifestablished) for personnel to follow. All doffing steps must be followed in the order listed. RADCONpersonnel will also be at the project site to assist personnel who have questions regarding the doffingprocedure.

Since any persomiel contamination event would likely involve a TRU mixed waste residue,decontamination of personnel shall follow the general procedures of the LMITCO Radiological ControlManual, Chapter 5, and MCP-148, "Personnel Decontamination," with some modifications fornonradiological constituents based on recommendations from the project 111. The primary difference instandard radiological and chemical decontamination is the use of water or other decontaminationsolutions with the chemical decontamination. Due to the TRU (alpha) components of the waste residue,the use of such solutions will be kept to a minimum. All decontamination tasks will be conducted underthe direct supervision of LMITCO RADCON (radiological engineer or RCT) and LMITCO IH personnel.

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Dry capture-type decontamination methods will be used whenever possible to decontaminate smallareas of surface contamination. These include the use of a HEPA vacuum, adhesive tape, or similartechnique. Contaminated surfaces will then be resurveyed to confirm the contamination was removed.The next progressive approach for removal of surface contamination will include the use of a spray bottlefilled with amended water (amended with 1-2% nonphosphate detergent and 2-5 % sodium bicarbonate)to make an aqueous solution) mist the contaminated surface, followed by a wiping with a Teriwipemtowel (or equivalent). Decontamination methods may be altered by RCT or IH. Confirmation surveyswill be conducted following these decontamination techniques. Personnel and personal propertydecontamination procedures that may be used include tape, vacuuming (vacuum equipped with a HEPAfilter), spray and wipe techniques, or other approved techniques. One of the primary objectives will be toavoid creating any free liquids. All waste generated from decontamination will be handled, stored, andmanaged in accordance with Section 10.4.

10.2.2 Decontamination in Medical Emergencies

An injured or ill person will immediately be evaluated by first-aid trained personnel at theOU 7-13/14 subsurface investigation project task site. If the person's condition is serious, then the CEwill contact the Warning Communications Center (WCC) to summon emergency services (FireDepartment and CFA Medical). In addition, the RWMC shift supervisor and others will be contacted, asstated in Section 11.

Medical care for serious injury or illness will not be delayed for decontamination. In such cases,gross contamination may be prevented by removing the injured person's outer protective clothing (ifpossible) and covering other contaminated areas with a bag, glove, etc. If contaminated PPE cannot beremoved without causing further injury (except for the respirator which must be removed), the individualwill be wrapped in plastic, blankets, or available material to help prevent contaminating the inside of theambulance, medical equipment, and medical personnel. The IH and/or RCT (depending on the type ofcontamination) shall accompany the employee to the medical facility to provide information anddecontamination assistance to medical personnel. Contaminated PPE will then be removed at the CFAmedical facility and carefully handled to prevent the spread of contamination. The LMITCORadiological Control Manual, Chapter 5 and MCP-148, "Personnel Decontamination," containsinformation on proper handling of radiologically contaminated wounds.

Based on the potential for TRU mixed waste at Pit 4 and 10 (and Pit 6 if investigated) task sites,chemical contamination only is unlikely. However, the same decontamination procedure for injuredpersonnel with radiological contamination will be followed for chemically contaminated personnel. Thisincludes removing the outer layer of protective clothing and evaluating the individual for other surfacecontamination. If the remaining contamination appears to be corrosive, the affected area will be wipedwith a dampened Teriwipend saturated with the premixed amended water solution (described in Section10.2.1). This solution will bind particulate radiological contamination and chemically buffer acidic orbasic substances. This process may need to be repeated. The affected areas will then be covered duringtransport to the medical facility.

10.2.3 Equipment Decontamination

The DSE and other confinement engineering and isolation controls have been designed to preventcontamination from migrating from drill rig components that come into direct contact with the buriedwaste. The exterior surfaces of the drill rig, support equipment inside the CA, and radiological/IHinstrumentation (other than detection surfaces) will be contained or sleeved (wherever possible) to isolatethem from potential deposition of particulate or other surface contamination. The drill string andsampling wire line/winch assembly will be contained within the DSE under negative pressure. These

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engineering controls will serve to isolate the drill string and eliminate or mitigate many of the potentialcontamination pathways to prevent equipment contamination and greatly reduce the need fordecontamination. Project IH and RADCON personnel will conduct surveys and collect swipesthroughout the core sampling and abandonment tasks in accordance with the technical procedures toevaluate engineering controls, material handling methods, and confmement integrity. Contaminationcontrol methods will not protect the inner surfaces of the drill string and DSE from becomingcontaminated. A potential for cross-contamination exists from anything that comes into contact withthese surfaces, and if this occurs, equipment decontamination will be conducted. This decontaminationwill be conducted immediately following detection of levels exceeding unrestricted release criteria toprevent the spread of contamination.

Both real-time instrumentation and visual observation will be used to detect contamination withinand beyond the immediate drilling area. Equipment and personnel decontamination will use bothinstrumentation and visual methods for contamination detection and to minimize the potential spread andairborne generation of contamination. Where radiological and IH concerns do not prohibit their use,LMITCO Environmental Manual Technical Procedures, TPR-51, "Decontamination of Heavy Equipmentin the Fiele and TPR-52, "Decontamination of Sampling Equipment in the Fiele will be followed.RADCON and IH personnel will evaluate any contaminated equipment to determine the most appropriatedecontamination method based on the nature of the contaminated item, degree of contamination, level ofeffort to decontaminate the item, and importance in decontaminating versus disposing of such items. Insome cases, the level of effort and potential for spreading contamination from conductingdecontamination tasks far outweigh the benefit from engaging in extensive decontamination efforts toreturn an item to service. A cost-ALARA versus benefit evaluation will be done on items that haveextensive contamination or are relatively inexpensive. Low-cost consumable items will be discarded ifinitial decontamination efforts fail or extensive decontamination is required that is not in accordance withALARA principles.

For nonradiological decontamination of free released equipment, a decontamination pad may beestablished in the CRC. If it is deemed necessary and appropriate by the OU 7-13/14 subsurfaceinvestigation project IH, then a wet wiping with the aforementioned amended water solution orpotentially steam cleaning of this equipment prior to leaving the CRC may be conducted. If steamcleaning is performed, a drainage system that allows for a single collection point will be established.Decontamination waste water will be collected using a submergible pump and containerized/characterizedin accordance with the LMITCO Environmental Management Procedures Manual.

10.2.3.1 Small Area Surface Contamination. Dry capture-type decontamination methods will beused whenever possible to decontaminate small areas of surface contamination. These include the use ofa HEPA vacuum, adhesive tape, or similar technique. Contaminated surfaces will then be resurveyed toconfirm the contamination was removed. The next progressive step for removal of this type ofcontamination will include the use of a spray bottle filled with amended water (described above) to mistthe contaminated surface followed by a wiping with a Teriwipem towel (or equivalent). Methods such asmaslins or wet wipes may also be used. The contaminated area will be surveyed and swipes collected toevaluate the effectiveness of these methods. If no removable contamination is detectable but surveys (IHand RADCON) continue to indicate the presence of contamination, then the contamination will bedeemed fixed. The level of fixed contamination will be compared against unrestricted release levels. Ifabove the established release for the specific isotope(s) of concern, then the item will be contained byenclosing it in a bag or similar means to isolate it from contact with other surfaces. Disposal/reuseoptions will then be evaluated.

10.2.3.2 Large Area Surface Contamination. It is not anticipated that large areadecontamination will be required with the use of project engineering controls, isolation methods, and

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contamination control practices. However, since the buried waste material to be core sampled from Pits 4and 10 (and Pit 6 if investigated) may be a TRU mixed waste, contingencies must be available fordecontamination of large surface areas. (Section 11 lists emergency events and appropriate responses thatwill be followed if the primary engineering controls fail or are compromised.) The same principles usedfor small area decontamination will hold true for large surface area contamination. Each situation will beevaluated to determine the most appropriate action. For items that continue to be needed, an ALARAreview will be required to weigh the cost of the item against the potential exposure and dose to personnelfrom conducting extensive decontamination.

The immediate action when large area contamination is detected will be to determine the source ofthe contamination and seal or contain it. Next, the extent and nature of the contamination (radiological,nonradiological, fixed, removable, alpha, beta/gamma, etc.) must be determined. This will provide theinformation necessary to develop the most appropriate decontamination (or disposal) strategy.Confinement of the item with surface contamination will be the first priority unless it can be readilydecontaminated using a HEPA vacuum and the environmental conditions will allow such an activitywithout potentially generating an airborne hazard. Confinement will generally consist of wrapping theitem in a heavy layer of plastic sheeting and taping all seams to prevent air leaks. The thickness and typeof sheeting used will depend on the item to be contained and several layers may be needed. Any sharpcomers or points will need to be padded so the sheeting will not tear. Once the item is wrapped, theconfinement airspace may be evacuated with a HEPA vacuum to prevent a release due to accidentalpuncture. Each contamination event will present unique hazards and will be evaluated by the OU 7-13/14subsurface investigation project's RADCON, IH, HSO, and other health and safety professionals at thePit 4 and 10 project site (and Pit 6 if investigated). An extensive release that results in contaminationbeing detected outside the contamination area will require a project site evacuation and formalreentry/recovery in accordance with the requirements described in Section 11.1.2 and 11.7 respectively.

10.3 Doffing PPE and Decontamination

Pits 4 and 10 (and Pit 6 if investigated) present a TRU mixed waste environment with the potentialfor both radiological and nonradiological contamination of equipment, tools, and PPE. Based onhistorical records for the SDA, it is not expected that nonradiological contamination on surfaces will beencountered without the presence of detectable radiological contamination. As stated above, bothradiological and IH monitoring will be conducted throughout all OU 7-13/14 subsurface investigationproject activities to identify both types of contaminants and potential deficiencies in designed engineeringcontrols and confinement enclosures. The PPE doffing and decontamination method described below isbased on surface contamination from a mixed waste source being present on PPE.

The proposed decontamination strategy takes into account the most restrictive radiologicalpractices (removable alpha contamination) and allowances for chemical components that may be present.Some preliminary surface decontamination of protective clothing may be required if it is grosslycontaminated and the potential for the generation of airborne radioactivity or organic vapor emissionsexists. This will involve assistance from other personnel inside the contamination area and at the doffingstation as described below. The ultimate goal of all decontamination methods is to isolate the source ofcontamination effectively and efficiently through removal of the contaminated protective clothing andconfinement in a sealed bag or waste container.

The exact sequence and specific techniques that follow are provided as the initial method at thePits 4 and 10 (and Pit 6 if investigated) project sites. If site conditions change or at the discretion of theproject radiological engineer, modifications to this procedure are appropriate. However, the HSO and IHmust also evaluate any modification. Both radiological and nonradiological (chemical) hazards will beevaluated.

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10.3.1 Level B and C PPE Decontamination (CA Transition Tent)

When Level B or C PPE are worn, a two-area transition tent will be used at the OU 7-10 task site.The purpose of this tent is to provide an access way in and exit out of the CA that will provide additionalconfinement of potential contaminants during PPE doffing and equipment transfers. This tent will be setup between the CA and the CRZ (see Figure 10-1). This tent will be within the Pit 4, 10 (and 6 ifinvestigated) EZ. Any gross contamination identified (visually and during normal monitoring) will becovered with tape and plastic or decontaminated (HEPA vacuum, spray/wipe or combination of both)prior to entering the transition tent to minimize the spread of contamination.

10.3.1.1 Contamination Area. Initial decontamination through removing the outer set of protectiveclothing (anti-Cs of appropriate material), along with supplemental dosimetry, following the postedsequence. Doffing of the outer set of protective clothing will occur at the exit to the CA. Prior toentering the transition tent, personnel will leave all tools and equipment inside the CA (bagged asrequired) and remove the outer most layer of clothing (third layer), gloves and shoe covers (scuffs) andplace them in the provided receptacles. Personnel will then proceed to the first transition tent area (TA-1)with their respiratory protection (airhood) still on and the airline connected.

10.3.1.2 Tent Area 1. TA-1 is designed to support personnel exiting the CA and serve as aradiologically controlled area to complete the doffing sequences. Personnel will remove the inner layer ofprotective clothing and disconnect/remove airhoods in TA-1. Airline hose connections will then besealed by covering the ends with a latex glove and tape, and placing it in a RADCON survey box locatedinside TA-1. While inside TA-1 (with only the inner gloves and booties on) personnel will remove theremaining PPE items and step across the line into TA-2 (one foot at a time as posted).

An air-monitoring inlet will be located inside the TA-1 area to monitor for airborne radioactivityand to ensure that respiratory protection can safely be removed.

10.3.1.3 Tent Area 2. The TA-2 serves as the final tent area and all PPE will be removed as personnelcross over into TA-2. All personnel will then be required to complete a whole body survey with a hand-held radiation detection instrument (as listed in Section 8, Table 8-6 of this HASP) while in TA-2. Thesequence for this survey is detailed in Section 10.3.2 of this HASP. Personnel will then proceed directlyto the personnel contamination monitor (located at the EZ boundary).

10.3.1.4 Radiological Buffer Area. The RBA (entire SDA) serves as the radiologically controlledarea around the entire OU 7-13/14 project site CA that provides a secondary boundary to minimize thepotential spread of contamination. Additional contamination CAs may be established as deemedappropriate by RADCON.

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RAM(as required)

RA

Boundary

TAA/RMA

Cargo

Container

(or CSA)

Sonic

Drill Rig

Waste and PPE

Airline Exit Containers

Connection only

Drop Box

2< —•co

LJJcC M

c2S

Entrance

Only

SP 1

SP 2

CAM or air

monitoring

inlet hose

CAM o air

monito ing

inlet hose

CRC/SZ line

\ (see Figure 7-1)

RAD Trailer

with PCM

EZ

*CA Entry only required forcoring actMties not required forprobing activities.

Note: Entire project site islocated within the RWMCSDA Radiological buffer zoneareas (RBA) undergroundradioactive material area.

not to scale

Legend

CA - Contamination AreaCAM - Continuous Air MonitorCRC - Contamination Reduction ZoneCSA - CERCLA Storage AreaEZ - Exclusion ZonePCM - Personal Contamination

Monitor (survey station)

RA -RAM -RMASP-1 -SP-2 -SZTAA -

Radiation Ar eaRadiation Ar ea Moni tor

- Rad oacti ve Material AreaStep Off Pad 1Step Off Pad 2- Suppor t ZoneTem por ary Accum dation Ar ea

Figure 10-1. A generalized radiological control area configuration for the OU 7-13/14 project task sites.

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10.3.2 Personnel Radiological Contamination Monitoring

All personnel inside the TA-2 will conduct a whole body radiological contamination surveyimmediately following the doffing procedure listed above. RADCON personnel may perfonn this surveyor a self-survey may be required. The RADCON personnel will determine the specific model and type ofmonitoring instruments based on the type and level of contamination. The following are guidelines forconducting a personal contamination survey using hand-held instruments.

Survey instructions will be posted inside TA-2 and will include the following:

• Verify that the instrument is in service, set to the proper scale, and the audio output can beheard during frisking

• Hold probe less than 1/2 in. from surface being surveyed for beta and gamma contamination,approximately 'A in. for alpha contamination (without touching surface)

• Move probe slowly over surface, approximately 2 in. per second for beta-gamma probe and1 in. per second for alpha probe

• If the count increases during frisking, pause 5 to 10 seconds over the area to provideadequate time for instrument response

• If the count rate increases to a value greater than 100 cpm above background with abeta-gamma instrument or any detectable contamination with an alpha detectioninstrument, remain in TA-2 and notify (or have someone notify) RADCON personnel

• Whole body survey should take approximately 2 to 3 minutes to complete, remember to friskhands before picking up probe and perform the survey in the following order:

Head (pause at mouth and nose for approximately 5 seconds) ensuring the entirerespirator facepiece sealing surface area of face is surveyed

Neck and shoulders

- Arms (pause at each elbow)

Chest and abdomen

Back, hips, and seat of pants

Legs (pause at each knee)

Shoe tops

Shoe bottoms (pause at sole and heel)

Personnel and supplemental dosimeters

Return probe to holder, facing up.

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• Following personal contamination suivey, immediately proceed to the PCM station locatedinside the RADCON trailer at the transition between the CRZ and the SZ for an automatedwhole body survey.

10.4 Disposal of Contaminated PPE and Equipment

10.4.1 Storage and Disposal of Contaminated Materials

A substantial volume of investigative derived waste (IDW) from Pits 4 and 10 (and Pit 6 ifinvestigated) subsurface investigation activities could be generated. Sources of this waste may include:

• Used PPE (protective clothing, gloves, booties, respirators, etc.)

• Small tools and equipment that cannot or will not be decontaminated/released

• Used core sections from the core sampling task

• Radiologically controlled area materials (step-off pads, bags, swipes, plastic sheeting)

• Geomembrane fabric (coving entire subsurface investigative area)

• Decontamination waste (wipes, bags, etc.)

• DSE and confinement materials

• Miscellaneous debris that cannot be released (inner casing liners, caps, lines, etc.).

Equipment that cannot be decontaminated will be bagged, labeled, and containerized in accordancewith: 10 CFR 835.601(a) (Radiological), RCRA and CERCLA requirements, and the DOE RadiologicalControl Manual, Chapter 4; and placed in an appropriately posted radiological and/or CERCLA storagearea at the OU 7-13/14 subsurface contamination project site (area of contamination). All IDW generatedfrom sampling and in the decontamination process (if required) must be handled and disposed of inaccordance with the LMITCO Environmental MCPs, ER Waste Certification Plans, Chapter 4 of theLMITCO Radiological Control Manual, and receiving facility waste acceptance criteria (WAC) (offsite)or INEEL Reusable Property, Recyclable Materials, and Waste Acceptance Criteria (RRWAC),DOE/ID10381, requirements.

Waste generated during the probehole activities (Becker et al. 1999) is anticipated to be; PPE andmaybe some liquid from cleaning equipment. These wastes will be handled exactly as indicated inSubsection 6.2 of the OU 7-10 SIA Project Field Sampling Plan. Waste generated during coreholesampling activities will be addressed in the Waste Management Section of the Operable Unit 7-13/14Field Sampling Plan for Coreholes in Pits 4 and 10 of dze Subsurface Disposal Area (Holdren et al.1999). This section will provide a description of how this material will be characterized, managed, anddisposed.

10.4.2 Site Sanitation and Waste Minimization

OU 7-13/14 subsurface investigation task-site personnel will use toilet facilities located inside theadministrative area of RWMC. Potable water and soap will also be available at the site for personnel towash their hands and face upon exiting the work area. It is important to note that any required

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radiological contamination surveys must be performed before washing face and hands to preventaccidental spread of contamination.

Waste materials will not be allowed to accumulate at the task site. Appropriate containers forcontaminated and noncontaminated waste will be maintained at transition tentareas, in the SZ, and atother appropriate locations at the task site. The RCT will survey waste before it is removed from the tasksite in accordance with standard SDA practices. Personnel should make every attempt to minimize wastethrough judicious use of consumable materials. All task-site personnel are expected to make goodhousekeeping a priority at the job site.

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11. EMERGENCY RESPONSE PLAN FOR THE OU 7-13/14SUBSURFACE INVESTIGATION TASK SITE

Activities during the OU 7-13/14 subsurface investigation project will be conducted in a mannerthat ensures the highest degree of protection for site personnel, the general public, and the environment.This section defines the responsibilities of project and emergency personnel and provides actions forresponding to various events during OU 7-13/14 subsurface investigation project activities, called theOU 7-13/14 project or Pits 4 and 10 (Pit 6 if investigated) throughout this section.

This section has been written to comply with the emergency response plan (ERP) requirements of29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response," subpart 1910.120(1). ThisERP addresses both OU 7-13/14 project emergency response and nonemergency response events asdefined by §1910.120(a)(3). The intent of this HASP ERP is to provide OU 7-13/14 project personnelwith event planning and response actions prior to initiating task activities.

NOTE: The OSHA term "emergency" is not defined the same as an "emergency' as classified by DOEOrders 151.1, Change 2, "DOE Comprehensive Emergency Management System" and 232.1,"Occurrence Reporting and Processing of Operations Information." For this reason, the term "event" willbe used in this section when referring to OU 7-13/14 project HAZWOPER emergencies.

All "events" will be reported to RWMC emergency response organization (ERO) personnelthrough the RWMC shift supervisor for classification in accordance with Section 4 of the INELEmergency Plan/RCRA Contingency Plan (LMITCO 1997b).

The INEL Emergency Plan/RCR.A Contingency Plan (INEEL Emergency Plan) and ImplementingProcedures implement the DOE Orders 151.1 and 232.1 and describe the process developed to respond toand mitigate consequences of emergencies that might arise at the INEEL. Each INEEL facility has aspecific Addendum that supplies facility-specific information to the INEEL Emergency Plan. TheRWMC facility is Addendum 3 to the INEEL Emergency Plan (this Addendum will be modified toincorporate OU 7-13/14 subsurface investigation project activities prior to initiation of site tasks). AllRWMC and OU 7-13/14 project initiated emergencies, as defined by the INEEL Emergency Plan, willresult in activation of the RWMC ERO as specified in Addendum 3. Once the ERO is activated,OU 7-13/14 project personnel will follow the direction and guidance communicated by the RWMCEmergency Coordinator (EC).

For OU 7-13/14 project initiated events, the OU 7-13/14 project CE will serve as the on-scenecommander and single point of contact until relieved by an RWMC/INEEL ERO member or theOU 7-13/14 subsurface investigation project site is evacuated. The OU 7-13/14 project personnel willtake immediate response actions, in a graded approach described in Subsections 11.1.1, 11.1.2, and11.1.3, if an OU 7-13/14 project event occurs. These actions will be taken to ensure the safety of projectpersonnel, control or mitigate event consequences through safe shut-down of equipment (where feasible),and minimize the potential impact to offsite (beyond OU 7-13/14 project site) personnel. The FTL willprovide technical support to the RWMC command post during emergency events for the project.

11.1 Pre-event Planning and Drills

The objective of pre-event planning is to be prepared to safely respond to anticipated events andcontingencies prior to commencement of OU 7-13/14 project activities. Preplanning is also used toensure that the OU 7-13/14 subsurface investigation project ERP is integrated with the existing INEELEmergency Plan and RWMC Addendum 3, and that the INEEL emergency response organization is

familiar with the nature of the project. Before starting OU 7-13/14 project subsurface investigationactivities, the CE and HSO will ensure planning includes:

• Identifying the location of and route to emergency medical services (CFA-1612)

• Establishing that site communications are working properly (i.e., radios, cell phones, andlandlines [if available])

• Designating OU 7-13/14 project site emergency warning signals (onsite emergencies) andevacuation routes (for onsite and RWMC/INEEL evacuations)

• Inventorying emergency equipment and supplies (Table 11-1)

• Providing a tour to ERO representatives of the OU 7-13/14 project site and providing allinformation requested

• Communicating OU 7-13/14 project event and INEEL emergency procedures to all projectpersonnel and visitors, as part of the site-specific training.

In addition, a local emergency drill at the OU 7-13/14 project site will be conducted by the FTL toensure all personnel are familiar with the emergency actions, communications, and evacuation routes.Additional drill information is discussed in Subsection 11.1.5.

This ERP divides events into three primary categories: (1) OU 7-13/14 subsurface investigationproject site events that require notifying the RWMC shift supervisor but not a response from INEELemergency response personnel (fire department, etc.); (2) OU 7-13/14 project site events that require theresponse of INEEL emergency response personnel or the evacuation of all OU 7-13/14 project personneldue to an onsite, RWMC, or other INEEL facility alarm; and (3) events that will require immediateevacuation from the OU 7-13/14 project site.

11.1.1 OU 7-13/14 Subsurface Investigation Project Site Events (Notification Only)

These types of events will require some level of response by all OU 7-13/14 project site personnel.An event involving a fire, regardless of size, requires notification to the INEEL Fire Department as a firstresponse. In all cases, a formal notification will be made to the RWMC shift supervisor for classificationof the event. Also, notifications to LMITCO/subcontractor project and department personnel, DOERWMC facility and ER representatives, and other appropriate parties (environmental affairs, occupationalmedical program, etc.) as listed in Subsection 11.9 may be required. Examples of these types of eventsinclude but are not limited to the following:

• Personal injury on the task site requiring medical evaluation or treatment (but notambulatory)

• Personnel contamination or suspected uptake of radiological or hazardous substance

• Equipment or vehicle accident that results in damage to the vehicle and/or property

• Failure of engineering control or isolation that results in a temporary breach in the DSEconfinement structure or related component resulting in only localized contamination that iscontained within the established radiologically contamination area

11-2

• Unexpectedly high radiation dose to personnel (>ALARA goal) from core sample or othersource

• Any spill as defined by LMITCO MCP-439, "Facility Notification and Release Reporting."

NOTE: MCP-190, "Event Categorizatioe will be followed to determine the proper reportingfollowing any OU 7-13/14 project events.

11.1.2 OU 7-13/14 Subsurface investigation Project Site Events (INEEL EmergencyResponse Organization Required)

These types of events will present different response options for OU 7-13/14 project personneldepending on the nature and severity of the event. Ambulance, fire, rescue, and hazardous materials(HAZMAT) response services are available from the INEEL Fire Department/Medical Facility. Projectpersonnel will generally either:

1. Use emergency stops on all equipment (where available), evacuate the immediate task area(EZ), remain at the OU 7-13/14 project site (upwind and at a safe distance), and makeimmediate notification to the RWMC shift supervisor and to the WCC which is responsiblefor alerting the INEEL emergency service organizations (INEEL Fire Department). At theassembly area, personnel will be accounted for and reported to the RWMC EC. Or,

2. Following (1), proceed out of the SDA to the nearest assembly area (if conditions at the tasksite change, become worse, or if directed by the RWMC EC). Personnel will proceedupwind along the predetermined route (determined based on a primary and secondary route)to an established assembly area (determined by the FTL prior to initiating daily tasks andcommunicated to the operators at the POD), depending on the prevailing winds and nature ofthe evacuation. At the assembly area, personnel will be accounted for and reported to theRWMC EC.

A positive sweep of the OU 7-10 project site and trailers will be done by the [ISO and CE prior toevacuating the site. The personnel will proceed upwind along the predetermined route (determined basedon a primary and secondary route) to an established assembly area (windgap, south construction, Pit 9East or West gate), depending on the prevailing winds and nature of the evacuation (see Figure 11-1).Once at the assembly area, personnel accountability will be conducted and reported to the RWMC EC.

If it becomes necessary to evacuate the immediate EZ area, every attempt will be made to shutdown all project equipment (other than the HEPA vacuum) to prevent potential or further releases to theenvironment from exposed or breached confinement structures. This will most likely involve shuttingdown power to the drill rig and associated systems. Also, any ports to the DSE will be sealed to minimizepotential releases of contaminants as site conditions allow. Accountability of field team members andnonfield team personnel will be conducted by the CE using the OU 7-13/14 project site sign-in sheet andthe buddy system.

NOTE: If it is not determined that using available equipment emergency stops will exposepersonnel to unacceptable hazards, then everyone will immediately evacuate the task area andshutdown will consist of all power being shut down from the drill rig control panel structure.

The CE notifications will include pertinent details regarding the nature of the emergency(radiological, medical, fire, spill), number of personnel affected, and exact location of the incident. TheCE will make additional notifications listed in Subsection 11.9 as appropriate.

11-3

Examples of these types of OU 7-13/14 project events include but are not limited to the following:

• Fire that is burning beyond an incipient stage and cannot be extinguished with hand-heldextinguishers

• Large spill at the project site that cannot be immediately contained or controlled

• Small episodic airborne release beyond the radiologically controlled area resulting fromdamage to the DSE, HEPA system, or other confinement (from fire or failure)

• Serious injury to a worker or workers.

NOTE: MCP-190, "Event Categorization7 will be followed to determine the proper reportingfollowing any OU 7-13/14 project events.

NOTE: If the OU 7-13/14 project site is evacuated due to an OU 7-13/14 project event, thenrecovery and reentry procedures must be followed as directed by the RWMC/INEEL ERO inaccordance with Section 9 of the INEEL Emergency Plan and its associated implementingprocedures.

11.1.3 OU 7-13/14 Subsurface Investigation Project Site Events (OU 7-13/14 Project SiteEvacuation Required)

The evacuation order could be the result of an OU 7-13/14 project site, RWMC, or INEEL initiatedevent or emergency. Regardless of the source, all personnel will place the project site in a safe shutdownmode (as appropriate) and evacuate the project site and SDA IMMEDIATELY using the predeterminedroute to an established assembly area (communicated to the operators by the FTL at the POD), dependingon the prevailing winds and nature of the evacuation). At the assembly area, personnel will be accountedfor and reported to the RWMC EC.

If the evacuation is initiated by a OU 7-13/14 project event, then the CE will make immediatenotification to the RWMC shift supervisor and INEEL emergency services (WCC, INEEL FireDepartment, etc.) and appropriate personnel listed in Subsection 11.9. RWMC initiated or Site-wideevacuations will require all OU 7-13/14 project personnel to evacuate through the appropriate SDA gate,as specified on the speaker system or a 6 or D-Net radios. All personnel will be accounted for by the CEprior to exiting the assembly area using the daily OU 7-13/14 project site sign-in sheet and the buddysystem.

If off-site notifications are required (outside the RWMC or INEEL) they will be made by theRWMC Command Post personnel as stated in Section 5 of the INEEL Emergency Plan: Classification ofthese types of events will be made by the INEEL ERO using Section 4 of the INEEL Emergency Plan.Examples of these types of events or emergencies include but are not limited to the following:

• Uncontrollable fire at the OU 7-13/14 project site, RWMC, or other facility upwind of theOU 7-13/14 project site

• RWMC or other facility operational emergency

• Catastrophic event that results in a significant or prolonged airbome radioactivity orhazardous material release at the OU 7-13/14 project site

11-4

• Natural disasters (earthquakes, wild fire, lightning, tornado, etc.)

• Any event meeting the criteria of an emergency as defined by DOE Order 151.1.

NOTE: MCP-I90, "Event Categorization," will be followed to determine the proper reportingfollowing any OU 7-13/14 project events.

NOTE: If the OU 7-13/14 project site is evacuated due to a OU 7-13/14 project event, thenrecovery and reentry procedures must be followed as directed by the INEEL ERO in accordancewith Section 9 of the 1NEEL Emergency Plan and its associated implementing procedures.

11.1.4 Spills

The only potential for a liquid spill would be from equipment refueling tasks at the OU 7-13/14project site. If the spills are small enough to be safely contained at the task site, task site personnel willhandle spill control using spill supplies at the site and immediately report the incident to the RWMC shiftsupervisor and EC, in turn. Reporting requirements will be determined by the RWMC EC in accordancewith MCP-190, "Event Reporting?' Radiological releases (contamination) in uncontrolled areas areconsidered spills. If any release of hazardous or radioactive material occurs, task site personnel shallcomply with the following immediate spill response actions:

Untrained Initial Responder (or if the material characteristics are unknown):

• Use emergency stops to shutdown equipment (as appropriate)

• Evacuate and isolate the immediate area

• Notify and then seek help from and warn others in the area

• Notify FTL or CE and HSO.

Trained Responder (if you are trained to respond to the hazard):

• Seek help from and warn others in the area

• Stop the spill if it can be done without risk (e.g., retum the container to upright position,close valve, shut off power)

• Provide pertinent information to CE and HSO

• Place all equipment in a secure shutdown mode

Secure any release paths only in an emergency. Otherwise, make a plan, fill out paperwork,and respond. Don appropriate PPE level, and conduct RCT/ IH surveys of the area todetermine the extent of a radiological, chemical material spill.

Additional requirements, information, and response equipment for specialized spills (e.g., oil,PCBs) is provided in the RWMC Addendum 3, Appendix G, Spill Plan Control and Countermeasures(SPCC).

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11.1.5 Emergency Drills

An local emergency drill (coordinated with the RWMC ERO and LMITCO EmergencyPreparedness Department) shall be conducted prior to OU 7-13/14 project activities to evaluate field teammember response during a project event. The purpose of the drill is to familiarize personnel with theirrespective event and emergency response actions. All radio or telephone communications that are usedduring this drill shall be immediately preceded and followed with a statement that clearly identifies thesituation as a drill to prevent an actual emergency response from being initiated by the WCC. Additionaldrills may be conducted at the discretion of the CE, OU 7-13/14 project PM, or the INEEL EmergencyPreparedness Department.

Each drill or actual event at the task site will be followed by a critique and any identifieddeficiencies in the emergency plan will be con•ected. Critiques are described further in Subsection 11.8.

11.2 Emergency Recognition and Prevention

All OU 7-13/14 project personnel should be constantly alert for potential hazardous situations andsigns and symptoms of chemical and radiological exposure or releases. All OU 7-13/14 project personnelwill be trained in proper site access and egress in response to OU 7-13/14 project events and INEELemergencies as part of the OU 7-13/14 project HASP site-specific training. Visitors will also receive thistraining. Alarm identification, location and use of communication equipment, location and use of siteemergency equipment, and evacuation routes will be covered. Emergency phone numbers and evacuationroute maps will be located in the support zone (OU 7-13/14 project trailer), CRZ (posted), and in the EZ(inside the drill rig control structure). All field personnel should be familiar with the techniques forhazard recognition and assigned ALs. Specific roles and responsibilities once an event is initiated aredescribed in Subsection 11.4.

A POD meeting will be held daily before entering the EZ to discuss:

• Tasks to be performed (location, equipment, personnel, etc.)

• Radiological and chemical hazards that may be encountered, including their effects, how torecognize symptoms, monitoring to be conducted, and other physical hazards

• Event and evacuation procedures to be followed after an alert signal (OU 7-13/14 projectinternal communication), RWMC or site alarm is sounded (including primary and secondaryevacuation routes).

As subsurface investigation activities progress, new equipment and more intrusive activities willrequire additional items to be discussed during daily POD briefings. Constant air monitors (CAMs) or airmonitoring inlets and RAMs (as required) will be placed at strategic locations within the CA and EZ,respectively, to provide alarms in the event of failure of confinement or unexpected radiation fields.These systems will be calibrated and maintained in accordance with LMITCO MCP-93, "Health PhysicsInstrumentation."

11.3 Emergency Facilities and Equipment

Emergency response equipment that will be maintained at the OU 7-13/14 project task site is listedin Table 11-1 along with the persons responsible for inventorying and maintaining this equipment.Addendum 3 (RWMC) to the INEEL Emergency Plan lists emergency equipment available at theRWMC. This includes the command post (CP) located in Building WMF-637, equipment located in

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Table 11-1. Emergency response equipment to be maintained at the OU 7-13/14 subsurfaceinvestigation project site.

Equipment Name and Quantity RequiredLocation atTask Site

ResponsiblePerson

Frequency ofInspection

First-aid kit SZ HSO Monthly

Eyewash station CRZ/SZ line HSO Weekly

Hazardous materials spill kit SZ HSO Monthly

Radiological spill kit SZ RCT Monthly

Extra PPE SZ HSO Weekly

Communication equipment (operational) On site CE/FTL Daily test

SCBA (2) (Phase II only) SZ HSO Monthly/each use.

Fog horns (3) for signaling onsite alerts SZ/CRZ/EZ HSO Weekly

10A/60BC Fire Extinguisher EZ HSO Monthly/each use

Other: Wind socks (1) SZ CE Daily (condition)

Sand and shovels' (2) EZ CE Weekly/during coreremoval operationsonly

a. Sand and shovels (2) are only required during phase II operations.

Building WMF-601 (SCBAs, dosimeters, air samplers, decontamination, and first-aid equipment, etc.).In addition, Section 11 of the INEEL Emergency Plan lists all INEEL emergency facilities and equipmentavailable. The INEEL Fire Department maintains an emergency hazardous materials (HAZMAT) vanthat can be used to respond to an event or emergency at the OU 7-13/14 project site. Fire departmentpersonnel are also trained to provide immediate hazardous material spills and medical services. At leasttwo persons with current Medic/First-Aid training will be present at the OU 7-13/14 project site to renderfirst aid assistance to injured personnel. Project RADCON and IH personnel will assist with allemergency decontamination efforts.

The INEEL Fire Department has a mutual aid agreement with the Idaho Falls, Blackfoot, and ArcoFire Departments to supplement the equipment and resource of the INEEL.

As IDW is stored at the OU 7-13/14 project site in a Temporary Accumulation Area (TAA),Appendix L of the RWMC Addendum will be amended to include specific spill and response equipmentlocated at or in the TAA.

11.4 Personnel Roles, Lines of Authority, and Communication

This section provides information on the roles and responsibilities of all OU 7-13/14 projectpersonnel during project site events and INEEL emergency conditions. Additionally, both intemal and

11-7

external communication methods are detailed along with notification responsibilities during events and/oremergencies. OU 7-13/14 project personnel will take immediate actions to control or mitigate events atthe project site (as appropriate); however, once the RWMC or INEEL ERO is activated, it will serve asthe primary response organization during all emergencies. Table 11-2 lists the responsibilities of the CE,FTL, HSO, and Medic First personnel during a OU 7-13/14 project event.

The INEEL ERO is structured to fit the diversity of the INEEL and to optimize its resources. It isan umbrella structure that consists of three basic levels: (1) on-scene, based at On-Scene CP, (2) theRWMC CP (for OU 7-13/14 project emergencies), and (3) LMITCO/DOE-ID management, based at theEmergency Operations Center (EOC).

During INEEL emergencies, the Incident Command System (ICS) is used (Figure 11-1). The ICSis an emergency management system designed for use from the time an incident occurs (even at less-than-emergency category events) until the requirements for emergency management and operations no longerexist.

Table 11-2. Responsibilities during a OU 7-13/14 project event or RWMC/INEEL emergency.

Responsible Person Action Assigned

CE Contact WCC and Signal evacuation

CE or FTL Assemble Safety/IH/RCT team

CE Contact RWMC Shift Supervisor (SS) and EmergencyCoordinator (in-turn) — serve as primary area warden

HSO and Medic First trained personnel First aid to victims

HSO Contact OMP (as required)

CE Spill confinement/reportinga, (see spills above)

FTL Support the RWMC CP as technical representative

a. The Environmental Affairs spill response categorization/notification team must also be contacted immediately viapager #6400.

COMMAND

StoffFunctions

Operations Logistics Planning

11-8

Financial/Legal(E0C Level Only

GT980095

Figure 11-1. Incident Command System functions.

The structure of the ICS can be established and expanded/contracted depending on the changingconditions of the event. The system consists of procedures for controlling personnel, facilities,equipment, and comrnunications. It is intended to be staffed and operated by trained, qualified personnelfrom the responding INEEL ERO. In the event an incident requires a unified command with multipleagencies, the ICS adapts quickly to facilitate that effort, including incidents involving multiplejurisdictions.

The ICS unified command concept permits agencies/individuals with jurisdictional/functionalresponsibility to have a voice in determining overall objectives for addressing the incident and themethods used to obtain those objectives.

11.4.1 Project Personnel

Every person at the OU 7-13/14 project site has a role to play during an event or INEELemergency. During the POD safety meeting, buddies will be teamed together as detailed in Section 6.5.This forms the basis for personnel and project accountability during an evacuation. During an evacuation,each individual is expected to know the location of his or her buddy and be able to report this to the CE atthe assembly area. All personnel will be accounted for by the CE using the OU 7-13/14 project sign-insheet and the buddy system. The CE will serve as the area warden for the OU 7-13/14 project and reportpersonnel accountability to the EC following an evacuation. Additionally, all project personnel areresponsible for immediately reporting any event at the OU 7-13/14 project site to the CE or HSO.

11.4.2 Construction Engineer

The OU 7-13/14 project CE will serve as the OU 7-13/14 project on-scene commander during allproject events or INEEL emergencies until relieved by an RWMC/INEEL ERO member. If relieved bythe RWMC EC, the CE will support emergency operations at the project site or at the RWMC CP (asrequested). The CE is responsible for initiating all requests for emergency services (fire, medical, etc.)and notifying the RWMC shift supervisor/ERO of the event. An additional responsibility includespersonnel accountability if a project or INEEL site evacuation is required. All project personnel willfollow the directions given by the CE (or RWMC EC if the ERO is activated) during project events andINEEL emergencies. The CE will be in direct communication with the RWMC CP/EC and direct allproject personnel to the appropriate assembly area during an evacuation. Following an evacuation, theCE will ensure all project personnel are accounted for and make appropriate notifications to the RWMCEC, OU 7-13/14 project management, and others listed in Subsection 11.9. The CE will also serve as theOU 7-13/14 project area warden.

11.4.3 RWMC Emergency Coordinator

The CE will serve as the OU 7-13/14 project on-scene commander during project events untilrelieved by the RWMC EC, INEEL ERO personnel, or an evacuation is ordered. The RWMC EC ordesignated alternate (meeting the same training requirements) is familiar with all aspects of the INEELEmergency Plan, RWMC Addendum 3, all operations and activities at the facility, the characteristics ofthe OU 7-13/14 project waste, the location of all records within the facility, and the layout of the RWMCand OU 7-13/14 project site. The Central Facilities Area (CFA) emergency action manager (EAM) willprovide direct support logistics and limited operations support to the RWMC EC.

The RWMC EC assumes primary responsibility for responding to and coordinating all emergencysituations at the RWMC, including the SDA. The RWMC EC takes appropriate measures to ensure the

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safety of RWMC personnel and the public. Possible actions may involve evacuation of personnel fromthe OU 7-13/14 project site, the SDA, the entire RWMC or areas within the emergency planning zone(EPZ). The RWMC EC is additionally responsible for implementing emergency procedures, coordinatingprotective actions and con•ective measures, and performing offsite notifications, as required. All fieldteam members may be called upon to assist the EC in talcing emergency actions or providing informationof on site conditions and radiological/hazardous materials present.

11.4.4 Emergency Communications

It is critical that both internal and external communication systems be established for use during aOU 7-13/14 project event or emergency. Failure to immediately warn onsite personnel of event situationscould result in potential physical harm or exposure to radiological/nonradiological OU 7-13/14 projecthazards. During an event or response, crucial information must be conveyed quickly and accurately toonsite project personnel and the RWMC ERO. Information communicated regarding the OU 7-13/14project (e.g., location of injured personnel, orders to evacuate the site, and notices of blocked evacuationroutes) must be understood by all project personnel during times of confusion and while wearing PPE.

A separate set of internal emergency signals has been developed and will be discussed daily at thePOD safety meeting and rehearsed during the OU 7-13/14 project emergency drill. Additionally, clearexternal communication to request RWMC and INEEL ERO emergency services (as required) must beestablished. Extemal communication systems and procedures will be available and accessible to all sitepersonnel.

11.4.4.1 Internal Communications. An intemal communications system is used to alertOU 7-13/14 project personnel to danger, convey safety information, and maintain site control. Radiosand cellular phones will be used to communicate response messages to site personnel. Additionally, abackup system (audible fog horn blast) and hand signals are listed in Table 11-3. Take cover alarms forOU 7-13/14 project initiated events will follow the nonemergency signal below. RWMC or INEEL takecover alarms are described in Subsection 11.5.

11.4.4.2 External Communications. External communications systems will be used at theOU 7-13/14 project site to alert offsite (outside OU 7-13/14 project work zones) RWMC/INEEL EROs ofevent conditions at the project site and to receive incoming information regarding RWMC or otherINEEL initiated emergencies. D, 6, or F-Net radios and cellular phones will serve as the primary methodby which the RWMC shift supervisor/EC and INEEL ERO resources are contacted.

All project personnel must be familiar with the type and location of external communicationdevices and the proper protocol for summoning assistance. The CE will serve as the primary contact forrequesting INEEL ERO response teams (fire, medical, etc.) and notifying the RWMC Shift supervisor/ECof event conditions; however, all project personnel must be able to perform this duty.

11.4.5 Notifications

The notification process will be used to summon INEEL emergency response resources, alertRWMC ERO of OU 7-13/14 project events, and to inform project management of project incidents assoon as possible. An event at the OU 7-13/14 project site will require the CE to notify the RWMC shiftsupervisor, at a minimum, and may require INEEL emergency response resources (fire, medical, etc.). Ifrequired, direct communication to summon these resources will be used (WCC-526-1515 orWCC/Emergency channel "KID-240," or the INEEL Fire Department-777. See Table 11-4 for additionalemergency phone numbers). Hand-held radios and cellular phones, phones in government vehicles, and

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landline phones (if available) in SZ trailer(s) can all be used to contact INEEL emergency responsepersonnel.

Table 114. OU 7-13/14 project internal and backup emergency signals.

Device or Communication Signal andMethod Associated Response

WCC/emergency channel call forOU 7-13/14 project site:

Evacuation of OU 7-13/14 projectarea

Fog Homs (blasts)

Visual Signals

Emergency—personnel will use emergency stops to shutdown allequipment (where available), then evacuate immediately todesignated assembly area.

Nonemergency—personnel will place equipment in a safeshutdown mode then exit the immediate work area using normaldecontamination procedures and proceed to designated assemblyarea.

One Long Blast—Emergency evacuation, as stated above.

Two Short Blasts—Nonemergency evacuation of immediate workarea (OU 7-13/14 project EZ/CRZ) as stated above. Proceed tosupport zone trailer.

Three Long Blasts—All clear, return to CRZ/EZ.

Hand Clutching Throat—Air line problem or can't breathe (free airline or remove airhood).

Waving Hand Inward—Need assistance (must don PPE beforeentering).

Grip Buddy's Wrists and Point Toward Exit—Leave areaimmediately.

Thumbs Up—OK/1'm all right/I understand.

Thumbs Down—No/negative.

The CE serves as the primary on-scene OU 7-13/14 project commander and performs immediatenotifications, including to the project CM. The CM will, in tum, contact the ER WAG-7 manager, EMESH&QA manager, RWMC manager/landlord, RWMC area director, ER DOE facility representative,and ER DOE WAG-7 manager. The ER WAG-7 manager will, in tum, contact the ER director, siteoperations director, and the waste operations director. All off-Site (off INEEL) notifications will be madeby the INEEL ERO.

NOTE: The EC is the point of contact at RWMC for all events and emergencies.

When notifying RWMC ERO, INEEL emergency response, or WCC personnel, all ava lableinformation on the incident should be provided. This should include:

• Informant's name, phone number, pager number

• Exact location of the event/emergency (in relation to the OU 7-13/14 project site or otherlandmarks)

• Nature of the event/emergency and special hazards (fire, medical, radiological, etc.)

• Time of occurrence and current site conditions

• Injuries or fatalities (numbers injured, type of injuries, status of injured, and if they willrequire decontamination)

• Extent of damage to area and any mitigating actions taken

• Any additional information requested.

Following notification of the RWMC EC, the event will be classified in accordance with DOEOrders 151.1, Change 2, "Comprehensive Emergency Management System" and 232.1, "Occun•enceReporting and Processing of Operations Informatiorr as outlined in Section 4 of the INEEL EmergencyPlan.

11.5 INEEL Alarms and Responses

Alarms and signals are used at the RWMC and INEEL to notify personnel of emergency conditionsthat require a specific response. Regardless of the classification, once an event is categorized as anemergency, the RWMC EC immediately notifies RWMC personnel of appropriate protective actions byactivating the voice paging system and/or alarm system. Siren-generated signals serve as the primarymeans for notifying RWMC personnel, OU 7-13/14 project personnel, and visitors in the area to takeprotective actions. The INEEL alarm systems consist of the necessary equipment to actuate alarm sirens,either manually or automatically. The alarms produce two types of signals: steady (take cover) oraltemating (evacuate). A fast ringing bell usually denotes radiation monitoring alarms. Fire alarms areoften distinctive for each facility and may vary from building to building within the RWMC.

The two primary INEEL site emergency alarms may be activated during the course of theOU 7-13/14 project activities. These include "TAKE COVER" and "EVACUATION" alarms. Thesewill be used to alert OU 7-13/14 project personnel of RWMC or Site-wide emergency situations. TheRWMC regularly conducts testing of its alarm system. The time and frequency of these tests will bedetermined and communicated to project personnel by the CE during the daily POD meeting.

11.5.1 Take Cover

Radiation or hazardous material releases, weather conditions, or other event or emergencyconditions may require that all personnel take cover indoors in the nearest building—OU 7-13/14 projecttrailer in the SZ. A take cover/shelter signal may be initiated as part of a broader response to anemergency situation and may precede an evacuation order. It may also be given by word of mouth, radio,or emergency notification system before sounding. The signal to take cover/shelter is a CONTINUOUSSIREN that can be heard throughout the RWMC area. Remember, STEADY = STAY. OU 7-13/14project personnel not in radiological areas, will proceed to the nearest trailer, building or shelter and awaitfurther instructions. Eating, drinking, or smoking is not permitted during take cover conditions.

OU 7-13/14 project RADCON, IH, and HSO personnel will assist and direct all workers in theradiological contamination area during a take cover/shelter alarm. If an evacuation alarm is soundedduring doffing procedures, follow the evacuation procedures described below.

Personnel working in radiologically controlled areas will:

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• Use emergency stops to shutdown equipment

• Immediately proceed the transition tent areas and follow posted doffing procedures

• Monitor as directed by RADCON personnel in the RBA

• Exit the EZ to the project trailer in the SZ.

11.5.2 Total Area Evacuation

A total area evacuation is the complete withdrawal of personnel from an area. If the EC or EAMinitiates a total area evacuation, follow directions given by the RWMC EC as to which SDA evacuationroute to use. The evacuation signal is an ALTERNATING SIREN that can be heard throughout theRWMC. Remember, ALTERNATE = EVACUATE. OU 7-13/14 project personnel not in radiologicalareas will proceed along the directed evacuation route to the designated assembly area.

Personnel working in radiological areas will:

• Use emergency stops to shutdown equipment (as appropriate)

• Immediately evacuate the area (do not remove protective clothing)

• Proceed along the directed evacuation route to the designated assembly area

• If abnormal radiological situations are present, then LMITCO Radiological Control Manual,MCP-124, "Response to Abnormal Radiological SituationC will be used.

NOTE: Due to the potential for cross-contamination of other areas/personnel, it is important forindividuals still wearing potentially contaminated clothing to stand downwind away from others in theassembly area and avoid unnecessary movement. RADCON personnel will direct doffing anddecontamination procedures as soon as possible.

11.6 Evacuation Routes and Procedures

Evacuation routes have been established for the SDA and OU 7-13/14 project site based on thelayout of the work zones, prevailing winds, availability of egress routes, and SDA gate locations. Routeswill be directed from the EZ through the upwind CRZ to the SZ (when possible), and from the SZ to aselected RWMC assembly area (should conditions require an RWMC or SDA evacuation). Primary andsecondary evacuation routes will be maintained by RWMC. Evacuation route maps will be located in theSZ (OU 7-13/14 project trailer), CRZ (posted), and in the EZ (inside the drill rig control structure).

Figure 11-2 shows the evacuation routes from the OU 7-13/14 project site and assembly areapickup locations. The primary and secondary evacuation routes will be evaluated daily based onmeteorological and site conditions. Figure 11-3 shows the route to the CFA medical facility (CFA-1612).

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11.7 Reentry and Recovery

11.7.1 Reentry

The reentry procedure following an evacuation of the OU 7-13/14 project site will be determinedby the source and nature of the evacuation (OU 7-13/14 project initiated or RWMC/other facility).Reentry into an originating area will be carefully planned and controlled to minimize exposing personnel

11-14

oTo CenralFachiasArea

1 - PRIMARY EVACUATION/ASSEMBLY AREA

2 - WMF 601 PARKING LOT3 - WINDGAP AREA4 - SOUTH CONSTRUCTION GATE5 - PIT 9 EAST GATE6 - PIT 9 WEST GATE

o 400 800

Scale in feel

Figure 11-2. RWMC SDA evacuation routes, take cover locations, and RWMC assembly areas.

To TAN and Rt. 33

From Rt. 20/26and RWMC

A

CFA-1611Fire Station

CFA-1612Medical —0—Facility

C

TRUE

I /

/a/

PLANT

i

M97 0133 JM82/98

Figure 11-3. Location of CFA medical facility (Building CFA-1612) from RWMC.

11-16

and equipment to radiation, hazardous materials, unstable physical conditions, or other hazards. Bothreentry and recovery are carefully plaimed and controlled to prevent initiating another event oremergency. The recovery team will develop a recovery plan that includes a plan for reentry. The primaryconsideration for reentry is rescue or corrective action.

Reentry activities may include the following:

• Perform safe shutdown duties assigned by the RWMC EC (if not conducted prior toevacuating)

• Perform operations that may mitigate the effect of the hazardous condition (cover or shieldexposed radiation sources, extinguish hot spots, seal openings, etc.)

• Search for unaccounted for personnel or ascertain that all personnel who were in the affectedarea have been evacuated (if not accounted for in the assembly area)

• Assist in evacuating injured or incapacitated personnel from the affected area

• Evaluate and report damage to equipment and facilities

• Measure and record radiation and/or hazardous material levels

• Establish new work control zones and radiologically controlled areas.

11.7.2 Recovery

During an OU 7-13/14 project event, or RWMC or INEEL emergency, actions are directed towardprotecting personnel and limiting consequences of the incident. Once initial con•ective actions have beentaken and effective control established, response efforts will shift toward recovery. Recovery is theprocess of assessing post-event/emergency conditions and developing a plan for returning to pre-event/emergency conditions when possible and following the plan to completion. The RWMC EC isresponsible for determining when an emergency situation is sufficiently stable to terminate the emergencyand enter the recovery phase.

As soon as practical after the emergency is terminated, the RWMC EC or assigned recoverymanager (appointed by the RWMC Facility Manager) will assemble all participating personnel (recoveryteam) to verify existing conditions, review the event in detail, and determine and assign correctiveactions. If necessary, the RWMC EC or recovery manager initiates or requests an investigation prior todetermining corrective actions. The recovery team will be composed of key project personnel (e.g. HSO,Ill, SE, RADCON, CE, FPE) and other technical representatives as deemed appropriate by the recoverymanager (e.g., chemical safety, explosives safety.). Investigations include personnel interviews andincident assessments that can be presented during debriefings and critiques.

11.8 Critique of Response and Follow-up

Following all emergency drills, actual events, or an INEEL emergency, a review and critique of theincident will be conducted. This will involve reviewing and revising affected aspects of this ERPaccording to new site conditions and lessons learned from the event/emergency response. Whenreviewing the emergency drill, event, or emergency infonnation, typical questions considered include:

• What caused the event or emergency?

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• Was it preventable? If so, how?

• Were procedures for prevention of the event/emergency adequate? If not, how can they beimproved?

• Were all phases of the event/emergency response adequate? How could it have beenimproved?

• How did the event/emergency affect the site profile? Were other areas affected?

• Was the public protected?

• Was the environment affected (onsite/offsite)?

11.9 Telephone/Radio Contact Reference List for OU 7-13/14Subsurface Investigation Project

Emergency contact names and numbers are listed in Table 11-4. As a minimum, this list will beposted at the OU 7-13/14 project field trailer, CRZ, and drill rig control panel inside the EZ.

Notification responsibilities for the OU 7-13/14 project are listed in Table 11-5. This list will beposted at each SZ, at the offices of those assigned notification responsibilities, and in the CE's vehicle.

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Table 11-4. OU 7-13/14 project emergency contact list.

Contact Phone Number

Warning Communications Center (WCC)

First Aid (CFA Medical Dispensary, Bldg #1612)

Occupational Medical Program (WCB Dispensary)

Fire/Security

RWMC Shift Supervisor

RWMC Emergency Coordinators (in notification sequence)(1) Kim Rogers,(2) J.R. Bishoff,(3) J.M. Wasylow,(4) Skip Cline

RWMC Area Director—Tom Clements

Project Manager (OU 7-13/14)—Doug Jorgensen

Sampling Field Team Leader/Field Geologist, LMITCO ES

Health & Safety Officer — Bruce Miller

Parsons Construction Manager—Max Lapioli

Parsons Construction Engineer—Rich Jacobson

RWMC ESH&Q Manager—Bill Mcbath

ER ESH&Q Manager—Charles Chebul

OU 7-13/14 Industrial/Construction Safety—Kelly Wooley

Industrial Hygiene—Grayson Downs

Radiological Control (RWMC Supervisor)—Randy Sayer

Radiological Control (OU 7-13/14)—Rick Horne

Fire Protection—Eric Gosswiller

Explosive Safety—Hance Clayton

Phone 6-1515, Fax-6-2567Construction-Net or WCC/Emergencychannel on hand-held Radio "KID-240"

777, 526-2356

526-1596

777

526-2767

(1) 6-7775 (p) 6071(2) 6-2766 (p) 5307(3) 6-2489 (p) 5313(4) 6-9993 (p) 6897

526-0664, pager 6095

526-7022, pager 6987

TBD

520-4644, pager 568-2043

526-6601, pager 5659

526-2596, pager 6695

526-5706, pager 7460

526-9566, pager 5689

526-2552, pager

526-0127, pager

526-6619, pager 5865

Pager: R. Horne-5898

526-8896, pager 6309

526-8197, pager 7557

11-19

Table 11-5. OU 7-13/14 project notification responsibilities.

Activity Title Phone Pager Radio

Construction Engineer

Notifies Fire Department 777 N/A KID 240

Notifies Waming Communication Center 6-1515 N/A KID 240(WCC)

Notifies In case of a spill: Environmental 6-6400 N/AAffairs Spill Team

Notifies RWMC Shift Supervisor/EC 6-2767 — N/A

Notifies ER ESH&Q Manager 6-9566 5689 N/A

Notifies OU 7-13/14 Project Manager 6-7022 6987 N/A

Notifies Parsons Construction Manager 6-6601 5659 N/A

RWMC Shift Supervisor/ — —EC

Notifies RWMC Manager/Landlord 6-7775 6071 N/A

RWMC Area Director 6-0664 6095 N/A

Notifies ER DOE Facility Representative 6-5558 6901 N/A

Notifies ER DOE WAG-7 Manager 6-7524 4457 N/A

Notifies EM ESH&QA Manager 6-8590 6519 N/A

Notifies ER WAG-7 Manager 6-7022 6987 N/A

ER WAG-7 Manager

Notifies ER Director 6-1559 N/A

Notifies Site Operations Director 6-2215 5418 N/A

Notifies Waste Operations Director 6-1677 5013 N/A

11-20

12. REFERENCES

American Conference of Governmental Industrial Hygienist, 1997 — 1998 edition, Threshold Limit ValuesBooklet.

ANL-W, December 15, 1997, ANL-W Transuranic Waste Program (TWP) Facility Implementation Plan,W0096-0481-ES, Revision I.

Barnes, C., February 1998, Evaluation of the Explosion Potential of Mtrate Salts/Organic Mixtures inOU 7-13/14, EDF-OU710-DBR-01.

Becker, B. H., T. A. Bensen, C. S. Blackmore, D. E. Bums, B.N. Burton, N.L. Hampton, R. M. Huntley,R. W. Jones, D. K. Jorgensen, S. O. Magnuson, C. Shapiro, and R. L. Van Hom, May 1996, WorkPlan for Operable Unit 7-13/14 Waste Area Group 7 Comprehensive RemedialInvestigation/Feasibility Study, INEL-95/0343, Rev. 0, Lockheed Martin Idaho TechnologiesCompany.

Becker, B. H., J. D. Burgess, K. J. Holdren, D. K. Jorgensen, S. O. Mannuson, and A. J. Sondrup, August

1998a, Interim Risk Assessment and Contaminant Screening for the Waste Area Group 7 Remedial

Investigation, DOE/ID-10569, Lockheed Martin Idaho Technologies Company.

Becker, B. H., C. B. Potelunas, and T. R. Sherwood, January 1999, Operable Unit 7-13/14 Plan for theInstallation and Logging of Probeholes in Pits 4 and 10 of the Subsurface Disposal Area, DraftRevision 0, INEEL/EXT-98-00856, Lockheed Martin Idaho Technologies Company.

Brown, A. N., Septernber 1997, Transportation Plan for the Shipment of Various Materials Containing

Transuranic Isotopes Between the Radioactive Waste Management Complex and Argonne National

Laboratory- West Using the Power Line Road, DOCUMENT #PLN-245, Revision 0.

Clayton, H., February 1998, Evaluation of the Potential for Explosions in OU 7-13/14 Waste, EDF-OU710-DBR-02.

Code of Federal Regulations, Title 10, Part 835, [EPA Implementing regulations for RCRA].

Code of Federal Regulations, Title 29, Part 1910, Occupational Safety and Health Standards for GeneralIndustry.

Code of Federal Regulations, Title 29, Part 1926, Occupational Safety and Health Standards for theConstruction Industry.

Code of Federal Regulations, Title 40, Parts 260 through 281, [EPA Implementing regulations for

RCRA].

DOE, February 1994, EM Health and Safety Plan Guidelines, DOE-EM-STD-5503-94, SAFT, U.S.Department of Energy.

DOE, September 1996, DOE Standard Hoisting and Rigging (Formerly Hoisting and Rigging Manual)„DOE-STD-1090-96, Rev. 1, U.S. Department of Energy.

12-1

DOE, October 1994, Handbook for Occupational Safety and Health During DOE Hazardous WasteActivities, U.S. Department of Energy, Office of Environmental Management, Office ofEnvironment, Safety and Health.

DOE-1D, December 4, 1991, Federal Facility Agreement and Consent Order and Action Plan, U.S.Department of Energy Idaho Field Office; U.S. Environmental Protection Agency, Region 10;Idaho Department of Health and Welfare.

DOE-ID, October 1993, Record of Decision: Declaration of Pit 9 at the Radioactive Waste ManagementComplex Subsurface Disposal Area at the Idaho National Engineering Laboratory, Idaho Falls,Idaho, U.S. Department of Energy, Idaho Operations Office, U.S. Environmental ProtectionAgency Region 10, and State of Idaho Department of Health and Welfare.

DOE-ID, 1997, Idaho National Engineering and Environmental Laboratory Reusable, RecyclableMaterials, and Waste Acceptance Criteria, DOD/ID-10381, Latest Revision, U.S. Department ofEnergy, Idaho Operations Office.

DOE-ID, August 1998, Addendum to the Work Plan for the Operable Unit 7-13/14 Waste Area Group 7Comprehensive Remedial Investigation/Feasibility Study, DOE/ID-10622, U.S. Department ofEnergy, Idaho Operations Office.

DOE-ID/EPA/IDIIW, January 1993. Smith, T. H. and D .E. Kudera, 1996, Comparison of the OU 7-13/14 project Inventory of Contaminants Against the Corresponding Portion of the Historical DataTask Inventory, and Recommended Revised Quantities, INEL-96/005.

EG&G, 1992, Results of the Soil Gas Survey and Shallow Well Screening of the Radioactive WasteManagement Complex Subsurface disposal Area, EG&G Idaho, Inc.

Hansen, J., February 1998, Procedure for Chain-of-Custody, Packaging, and Handling of RWMC SurfaceDisposal Area, OU 7-13/14, Invest gative Core Samples.

Hartley, S., February 1998a, Procedure for Drilling Investigative Boreholes in the Surface Disposal Area,OU 7-13/14, at the Radioactive Waste Management Complex.

Hartley, S., February 1998b, Procedure for Collecting Core Samples in the Surface Disposal Area, OU 7-13/14, at the Radioactive Waste Management Complex.

Holdren, K. J., S. L. Ansley, J. M. Connolly, J. D. Burgess, B. H. Becker, 1999, Operable Unit 7-13/14Field Sampling Plan for Coreholes in Pits 4 and 10 of the Subsurface Disposal Area, DOE/ID-10666 (Draft).

INEEL, February 1998a, DOE-STD-1027 Preliminary Hazard Categorization for the Stage 1 OU 7-10Contingency at the Radioactive Waste Management Complex, INEEL-EXT-98-00114.

!NEEL, February 1998b, Draft DOE-STD-1027 Preliminary Hazard Categorization for the Stage I OU 7-10 Contingency at the Radioactive Waste Management Complex, INEEL-EXT-98-00114.

King, J. J., July 1991, Methodology for Determination of a Radiological Inventory for OU 7-13/14 andCorresponding Results, ERP-BWP-64, Revision 0.

12-2

Liekhus, K. J., October 1991, Nonradiological Inventory in OU 7-13/14 at the RWMC, EG&G Idaho,Inc., Engineering Design File, ERP-BWP-65, Revision 2.

LMITCO, October 1994, Radioactive Waste Management Complex Safety Analysis Report, INEL-94/0226 Revision 2, Lockheed Martin Idaho Technologies Company.

LMITCO, September 1998, Interface Agreement Between radioactive Waste Management Complex andOperating Unit 7-10 Stated Interim Action Project, Lockheed Martin Technologies Company,Revision 0.

LMITCO, Management Control Procedures: Environmental Restoration Management ControlProcedures, current issue.

LMITCO, Manual #6: Facilities and Maintenance — Supplementals for F/U/M, Facilities, Utilities, andMaintenance, current issue.

LMITCO, Manual #8: Environmental Management, current issue.

LMITCO, Manual #9: Operations, current issue.

LMITCO, Manual #14A: Safety and Health- Occupational Safety and Fire Protection, current issue.

LMITCO, Manual #14B: Safety and Health — Occupational Health, current issue.

LMITCO, Manual #15A: Radiation Protection — INEL Radiological Control Manual, current issue.

LMITCO, Manual #15B: Radiation Protection Procedures, current issue.

LMITCO, Manual #15C: Radiological Control Procedures, current issue.

LMITCO, Manual #16: Emergency Preparedness - INEEL Emergency Plan/RCRA Contingency Plan,current issue.

LMITCO, 1997a, Quality Program Plan for the Environmental Restoration Program, Lockheed MartinIdaho Technologies Company, PLN-125 (formerly QPP-149), current issue.

LMITCO, October 1997b, INEL Emergency Plan/RCRA Contingency Plan, Lockheed Martin IdahoTechnologies Company, PLN - 114.

LMITCO, Waste Certification Plan for the Environmental Restoration Program, INEEL-96-0043, currentissue.

McKinley, K. B. and J. D. McKinney, 1978, Initial Drum Retrieval Final Report, TREE-1286.

NIOSH, October 1985, Occupational Safety and Health Guidance Manual for Hazardous Waste SiteActivities, NIOSH/OSHA/USCG/EPA, DHIIS (NIOSH) Publication No. 85-115.

NIOSH, 1996, NIOSH Pocket Guide to Chemical Hazards. NIOSH Publication Number 90-117. U.S.Govemment Printing Office, Washington, D.C.

Prawdzik, D., February 1998, Summary of Material in OU 7-13/14, EDF-OU710-DBR-03.

12-3

Smith, T. H. and D .E. Kudera, January 1996, Comparison of the OU 7-13/14 project Inventory ofContaminants Against the Corresponding Portion of the Historical Data Task Inventory, andRecommended Revised Quantities, INEL-96/005.

U.S. DOE Order 5480.8a, Contractor Occupational Medical Program, 10-19-92.

12-4

Appendix A

OU 7-13/14 Subsurface Investigation Health and Safety PlanTraining Acknowledgment

Appendix A

OU 7-13/14 Subsurface Investigation Health and Safety PlanTraining Acknowledgment

The signatures on Form 0361.02 (see following page) certify that:

• The employee has reviewed a copy of the OU 7-13/14 Subsurface Investigation HASP andquestions and concems regarding tasks and associated hazards have been answered to theemployee's satisfaction.

• The employee understands the hazards that are or may be involved in work at the subsurfaceinvestigation project site (Pits 4 and 10 at the SDA, and Pit 6 if the project decides toinvestigate it). Hazards are presented in Section 7,. Hazard Evaluation, Table 8-1 WorkActivities and Associated Hazards and Table 8-4 Radiological and NonradiologicalContaminants.

• The employee agrees to comply with all requirements as outlined in this HASP.

• The employee's training records have been verified as complete and current for theemployees assignment at the task site.

Note: When training is completed the original document will be sent to the LMITCO ER TrainingCoordinator at MS 3902.

Note: The HSO/CE ensures that the training roster is completed.

A-1

0361.02 TRAINING ATTENDANCE ROSTER Records Use Only

10/13/98 Date Rif v

Rev. 03 Quality CheckTRAIN Entry

Class Code

Page of

Course NumberER HASP 99

Revision0

Course TitleHealth & Safety Plan HAZWOPER 24 hour Supervised Field Experience Acknowledgement FormClass Title: OU 7-13/14 Subsurface Investigation Project at the SDA

Starting Date / Time

Remarks The employee's and supervisor's signature indicates that they have completed the 24 hoursupervised field experience for the OU 7-13/14 Subsurface Investigation Project at the SDA.

Instructional Org / Vendor Ending Date / Time

Training Setting: 0 Classroom• Conference

M•

CBTLive-Fire Range

III Practical ••

LabDrill

•E

Self-PacedEmergency Event

•OJT •Vendor • Walk-Through •Simulator

Student Roster Class Attendance Dates CompletionStatusS# Print Name (Last, First, MI) Signature Charge Number Phone # Org. #

,

,

...

,‘

,

Instructor's S# Instructor's Name Instructor's Signature Instructor initialeach days classattendance

-•

iv

361.0210/13/98Rev. 03

TRAINING ATTENDANCE ROSTERCONTINUATION SHEET

Page of

CourseNumberER HASP 99

Revision0

Course TitleHealth & Safety Plan HAZWOPER 24 hour Supervised Field Experience Acknowledgement FormClass Title: OU 7-13/14 Subsurface Investigation Project at the SDA

Starting Date / Time

Student Roster Class Attendance Dates CompletionStatusS# Print Name (Las , First, MI) Signature Charge Number Phone # Org. #

Instructor initial each days class attendance.

Appendix B

HAZWOPER 24 Hour SupervisedField Experience Acknowledgment Form

Appendix B

HAZWOPER 24-Hour SupervisedField Experience Acknowledgment Form

This checklist is to be completed for each HAZWOPER worker performing field tasks lastinglonger than 3 working days. The checklist is to be completed by the immediate field supervisor basedupon observations and worker refresher fraining during daily Plan of the Days meetings. For LMITCOand subcontractor personnel, the signed form (0361.02) is to be submitted to the LMITCO ER TrainingCoordinator at MS 3902 and a copy retained in the field project files.

Project: OU 7-13/14 Subsurface Investigation

❑ Knowledge of names of personnel and alternates responsible for project safety and health.

❑ Knowledge of safety, health hazards at the task site, and co-located facilities.

❑ Knowledge of personal protective equipment requirements.

❑ Knowledge of operating/maintenance procedures and safe work practices.

❑ Knowledge of hazard control.

❑ Knowledge of medical surveillance requirements, including recognition of signs andsymptoms, which may indicate overexposure to, hazards.

❑ Knowledge of decontamination procedures.

❑ Knowledge of task site and facility emergency response procedures.

❑ Knowledge of emergency signals, take cover areas, and evacuation routes.

❑ Knowledge of spill confinement and waste management/minimization procedures.

❑ Knowledge of task site access controls and posting.

❑ Knowledge of location of first aid kits, eye wash stations, fire extinguishers, and energizedsystem controls.

Please complete the Training Attendance Roster form (361.02) on the next page and return to theEO Training Coordinator to have this information placed into the TRAIN system. Retain a copy for theproject files.

Note: For LMITCO and subcontractor personnel, when training is completed the originaldocument will be sent to the LMITCO ER Training Coordinator at MS 3902.

B-1