Through our Worldwide Environmental Remediation Services (WERS) contract with USACE-Huntsville, KEMRON was contracted by USACE-Alaska to perform excavation, packaging, transportation and disposal of approximately 37,000 tons of PCB-contaminated soil from the White Alice Radio Relay Station (RRS) in Port Heiden, AK. The work was performed for the benefit of US Air Force, who is responsible for the environmental cleanup of the White Alice RRS.
Since work at the remote area of Alaska is performed only during the warm summer months of May through September, KEMRON and Jacobs, our team subcontractor, coordinated closely with the native village officials and the local construction subcontractor, Aniakchak Contractors LLC. Close coordination with the community is maintained to ensure adequate housing and meals for field workers and availability of the limited labor pool and heavy equipment at Port Heiden during the limited field season. Additionally, KEMRON manages the many logistics involved in cost-effectively transporting equipment and personnel to Port Heiden and removing the waste from Port Heiden given the remote location and short field season.
The project scope includes delineation of known areas of PCB soil contamination, excavation and containerizing these non-TSCA and TSCA regulated soils for transport to Seattle and disposal in Subtitle D and TSCA landfills as required. Confirmation sampling of the excavation areas and analysis at an off-site laboratory is performed to confirm compliance with the 1 ppm PCB cleanup objective.
Planning documents prepared for this project include a Work Plan, Sampling and Analysis Plan (SAP)/Quality Assurance Project Plan (QAPP), Accident Prevention Plan (APP)/Site Safety and Health Plan (SSHP), and a Waste Management Plan (WMP). The preparation of the planning documents, including a Soil Transport Memorandum documenting the regulatory requirements and procedures for the soil barge transport, were expedited and approved by ADEC within six weeks to allow for transport of the first barges of PCB contaminated soil within three months of contract award.
Horizontal and vertical delineation of the PCB contaminated soil is performed using a 15-foot by 15-foot grid system established with RTK GPS. The grids established control for proper sampling, in accordance with 40 CFR 761.61(a)(6) and Subpart O, and controlled removal to minimize over excavation of the soil. Because the cost of removing and disposing of PCB contaminated soils form remote areas, KEMRON diligently manages the depths of excavation to meet the 1 ppm cleanup objective. All sampling and excavation equipment are properly decontaminated between areas and the decontamination process is verified with QC wipe samples submitted for laboratory analysis.
Excavated soils are placed in 10 cubic yard supersacks suspended in a loading frame. Each supersack has a unique identifying number and weights and non-TSCA or TSCA information is recorded for each at the time of generation. Once the supersack is filled approximately 80 percent, the supersacks are sealed and lifted to a flatbed truck for transport to the staging area. The staging area is maintained with a heavy duty HDPE bottom liner and is tarped daily with a HDPE top cover that is weighted to protect from the strong winds and rain common to this part of Alaska.
As there is no road access to Port Heiden, KEMRON schedules barges for the transport of the non-TSCA and TSCA soils to permitted landfill in the lower United States once a sufficient tonnage is ready for shipment. No dock is available at Port Heiden for the barges, so KEMRON constructed a ramp at the shoreline for access to and loading of the barges. KEMRON and its transportation subcontractor, ELM, use a small lightering barge at high tide to navigate the shallow waters present at the landing at Port Heiden. The supersacks of contaminated soil are loaded with the lifting frames to the lightering barge, which then transports them to a larger barge in deeper water. Several trips by the lightering barge are required and all loading work is performed as allowed by tidal and weather constraints. Once both the lightering and large barge have full loads, the PCB contaminated soil is transported to Seattle for offloading to rail for non-TSCA and trucks for TSCA soil. The soils are then transported to the permitted landfills for proper disposal.
Reporting for the project includes daily QC Reports, Weekly Reports describing the field operations, Monthly Project Management Status Report and Annual reports. The Annual Summary Reports provide a summary of the activities performed during the field season, analytical data from the soil delineation and confirmation sampling, and copies of the waste manifests, weight tickets and disposal certifications.
Safety Light Corporation (SLC), formerly known as US Radium Corporation, manufactured self-illuminated watches and instrument dials, smoke detectors, neutron sources, exit signs, and other merchandise containing radioactive materials, as well as military applications regulated under the Nuclear Regulatory Commission. Radioactive material included radium-226, strontium-90, cesium-137, polonium-210, carbon-14, krypton-85, and tritium. The site was divided into three OUs. KEMRON is responsible for OU-1 (on-site buildings and debris) and OU-3 (landfills, contaminated soils, sediment and surface water). Additional sites on OU-3 were identified that warranted removal actions to include the West Lagoon, East Lagoon, West Dump and East Dump. USEPA issued an Action Memorandum to address these areas and assigned KEMRON a TO implement the following activities: assessment, excavation, removal and disposal of discrete, buried high-activity, radiologically-contaminated items, soil and miscellaneous items; grading and capping with an engineered cover to prevent off-site migration of soils during a flooding event; secure adjacent areas of exposed soil with geo-fabric, stone and topsoil or an engineered cap to prevent off-site migration of soils during a flood event and arrange for post removal site controls including long-term maintenance of the cap.
The SLC buildings were in serious structural disrepair. KEMRON conducted repairs to structural damage of the buildings and general repairs on the roof and access points of the buildings prior to decontamination activities. Extensive pre-demolition planning was performed including the preparation of the radiation work permit (RWP) for working in high contamination areas involving tritium and other radioisotopes. KEMRON conducted repairs to structural damage of the buildings and general repairs on the roof and access points of the buildings in order to safely enter, assess and decontaminate all structures. Additionally, the previous contractor stored a variety of incompatible radioactive materials in the same containers. KEMRON segregated the incompatible materials in secure containers, arranged for and completed transportation and disposal.
KEMRON transferred files from various buildings to a central location for EPA. The files were then surveyed to see if any showed contamination due to radioactivity by START and PADEP.
Following decontamination and removal of all files, KEMRON demolished all building structures that included: an aboveground metal silo; 8×8 building; solid waste building; utility building; liquid waste building; multi-metals building; carpenter shop; butler building; elevated water tower; main building; tritium building; machine shop; and water tank. All utilities were de-energized, capped and removed. KEMRON was able to safely segregate a wide array of radioactive materials into proper storage containers prior to shipment offsite for disposal. Once all buildings and structures were decontaminated, KEMRON worked with US Ecology, Idaho, the disposal site, to obtain a permit exemption from the NRC allowing T&D of radioactive building materials and debris to the disposal site at a significantly reduced cost (70% reduction in disposal costs).
KEMRON and the assigned START contractor conducted an assessment of the higher activity radioactive material and discrete isotopic sources. A comprehensive air monitoring and data management program was established with all data compiled and submitted to appropriate regulatory agencies. Team member, Perma-Fix, supported KEMRON in the waste characterization and radiation monitoring activity throughout the task order. KEMRON conducted a removal effort along the perimeter of the West Dump area, consolidated the contaminated soils back into the disposal area footprint and installed an engineered cap consisting of geofabric, stone and top soil. Six out buildings within OU-1 were surveyed and emptied of their contents. Over 100 yards of material classified as Bulk Survey for Free Release (BSFR), 25 yards of Low Level Radioactive Waste (LLRW), 1 drum containing a radium needle, one drum containing cesium contaminated debris, 3,705 pounds of contaminated 2-R containers, 4,320 pounds of contaminated lead shielding, and 88 pounds of depleted uranium were identified, sampled, repackaged, removed and transported offsite for disposal.
KEMRON completed two source removal projects at the Well 12A Superfund Site in Tacoma, WA, a former oil recycling facility where off-site migration of chlorinated solvent-contaminated groundwater impacted Tacoma’s drinking water well.
During the first phase, KEMRON was tasked to excavate approximately 500 cy of filtercake and soil estimated to contain greater than 10,000 ug/kg CVOCs. Although a small UST was thought to be present at the site, the geophysical surveys identified a buried rail tank car filled with pea gravel and product. KEMRON sampled and tested the product and the pea gravel from the tank car and both were found to be hazardous for lead and chlorinated solvents. After shearing the top of the tank, KEMRON excavated approximately 40 cy of hazardous pea garvel to two rolloff boxes for transport to a permitted RCRA landfill. Approximately 1,700 gallons of product and 5,000 gallons of contaminated rinsewater were pumped to a tanker truck and disposed at an offisite hazardous waste disposal facility. The steel tank was cut and transported offsite for recycling. As part of our green remediation best management practices, KEMRON recycled a total of 8.0 tons of steel and 1.4 tons of concerete under this phase of work.
Soil waste characterization samples collected from the excavation footprint indicated that a approximately 800 cy of soil in the north area was contaminated with chlorinated solvents at levels exceeding the RCRA Subpart CC threshold of 500 ppm VOCs, requiring incineration at an additional cost to the Government. KEMRON quickly developed an ISCO approach for the north area soil to reduce the concentrations to below 500 ppm so that the waste could be transported and disposed at a hazardous waste landfill as planned. USACE approved the cost-effective alternative. KEMRON excavated and direct-loaded to the Subtitle C landfill approximately 700 cy of soil in the south area that did not require treatment. The contaminated soil/filtercake in the north area was then treated with persulfate in six-inch lifts at a dosage of between 2-10% by weight, depending on degree of contamination. Lime was applied as an activator. After each 6-inch lift was thoroughly dry-mixed with the excavator, KEMRON spread the lift in the south area excavation and applied water to facilitate the reaction. The process was repeated until all of the soil in the north area was treated. KEMRON monitored the effectiveness of the treatment with field test kits and after approximately two months, analytical testing confirmed the treatment goals had been met. An excavator direct-loaded the treated soil/filtercake to trucks, which hauled the waste to the Subtitle C landfill. During treatment and excavation, perimeter air monitoring was performed and surfactant sprayed on the excavation surface to mitigate release of noxious organic vapors in this active commercial area.
The second phase of the project consisted of the demolition of the building overlying the source area and the implementation of ISTR, the primary source removal technology for the site. The bulding demolition required abatement of hazardous building materials (HBM) including asbestos, lead paint and PCB caulk. In accordance with the Green Remediation Plan, KEMRON abated the HBM and recycled remaining materials, including large timber beams, that did not require landfilling.
KEMRON employed electrical resistive heating (ERH) as the ISTR technology for the Well 12A site. The performance objectives for the ISTR was 90% reduction in mass of the six primary CVOCs with a mean concentration of 17.0 mg/kg within a 27,900 cy treatment volume. The subsurface system consisted of 71 electrodes, 35 multi-phase extraction (MPE) wells, 18 vapor extraction points, and 27 temperature monitoring points to a depth of up to 57 feet bgs installed both inside and outside an existing warehouse. Surface installation of the system included a 4,5000 kW power control unit, six step-down transformers, two 40 hp blowers and condensers/cooling towers, vapor/liquid separator, 18,000-gal. oil/water/DNAPL separator, two 1,000 lbs. liquid GAC vessels, three 8,000 lbs. vapor GAC vessels, and one KMn vapor polishing vessel along with a comprehensive system monitoring and control system.
After bringing in power and performing safety checks, KEMRON initated sytem start up. During operation, KEMRON conducted vapor monitoring of the treatment system daily and sampled the vapor treatment system using Tedlar bags and quick turn TO-15 analysis twice weekly. VGAC usage exceeded USACE’s estimates as a result of substantial concentrations of petroleum consituents in the vapor phase. KEMRON closely monitored the vapor treatment and replaced VGAC and KMn to ensure substantive requirements were met. Liquid management included skimming and containerizing LNAPL from the separator and water treatment sampling. After 117 days of operation the system was idled for post-treament sampling to verify the performance objectives were met. The sampling confirmed that the mean concentration of CVOCs over the treatment volume was reduced by 94.7%. Additionally, over 500,000 gallons of contaminated groundwater and condensate were treated at the site via the liquid treatment system, removing 1,790 gallons of LNAPL, and 55 gallons of DNAPL. The DNAPL was disposed as hazardous waste, however the LNAPL was used for fuel blending as another example of green remediation. All substantive air and water discharge criteria were met.
The Velsicol Chemical Corporation Hardeman County Landfill Superfund Site is located on Old Toone Road north of Highway 100 in Toone, Tennessee. The Site is a former 24-acre landfill in which about 200,000 to 300,000 drums of pesticide manufacturing waste were disposed in trenches from 1964 to 1973. These wastes contained pesticides including dieldrin, endrin, hexachlorocyclopentadiene, heptachlor, heptachlor epoxide, and volatile organic compounds (VOCs) including carbon tetrachloride and chloroform.
EPA tasked KEMRON with the construction of a soil vapor extraction (SVE) remediation system for the 3-acre Middle Disposal Area (MDA) in accordance with an April 2015 Final Remedial Design Report. The major components of this construction work includes the following:
KEMRON is also tasked with monthly monitoring and calibration on the 18 newly installed vertical extraction wells to assess effectiveness of vapor capture and balance the amount of vacuum applied to each extraction well. Routine inspection and maintenance to optimize operations. Monitoring of wireless remote monitoring system of critical system measurements such as gas flow, gas temperature and gas concentrations, vapor phase sampling and data collection to achieve a minimum 97% net reduction from baseline conditions of mean VOC soil gas concentrations with a three-year post shut-down rebound of less than 6% from baseline conditions.
- Maintenance, refurbishment, and relocation of the Southern Disposal Area (SDA) SVE Treatment System to the MDA. System included condensate recovery, 1,200 scfm utility blower, heat exchanger, granular activated carbon treatment vessels, control panel, interconnection piping, gas analyzer, wireless remote monitoring station and system instrumentation.
- Drilling and installation of nine SVE well couplets to depths of 90 feet using rotosonic drilling techniques in Level B PPE.
- Drilling and installation of three vapor monitoring probe couplets to 90 feet using rotosonic drilling techniques in Level B PPE.
- Installation of 18 precision well heads with orifice plates and to adjust vacuum pressures and measurements of critical well parameters.
- Layout and welding of over 3,000 feet High Density Polyethylene Header (HDPE) transmission pipe to connect the SVE wells to the SVE Treatment System.
- Fabrication and installation of HDPE condensate traps along transmission pipeline.
- Start-up, operation and sampling of SVE treatment system.