Radiological Investigation and Remediation

Mr. Graham served as Project Manager and LSP for remediation of a 6-acre portion of a 25-acre property containing building concrete slabs, soils and lake sediments impacted with low-level enriched uranium, cadmium, PCBs, and/or chlorinated volatile organic compounds (CVOCs) which resulted from several decades of uranium fuel rod production and industrial metalworking operations.

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The site was regulated under Federal RCRA, TSCA, and state and local regulations. Over 3,000 tons of these materials, plus a septic system, oil-water separator, and underground tanks and vaults, were excavated by a licensed remedial contractor and disposed of at permitted off-site facilities, under full-time supervision over a period of six months. Excavated areas were backfilled with stone or revegetated with wetland soils and plants depending upon location. To reduce future disposal costs, upland area subsoils were mixed with initially compost and eventually topsoil and then seeded. Prior to the remediation, public participation workshops and town official briefings were conducted, then site characterization occurred by radiological technicians and engineers. Once regulatory hurdles were passed, excavation drawings and bid specifications were prepared, and assistance provided to the client in bid evaluation/ contractor selection. Permits/approvals to allow the above activities to proceed included Digsafe, MADPH Radiation Control Program approval, MassDEP Solid Waste Beneficial Use Determination (BUD), Stormwater Pollution Prevention Plan and Water Quality Certification, local Conservation Commission approval, and U.S. Army Corps of Engineers dredging exemption approval.

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Certain areas of highly impacted soil was excavated under a sprung structure-type building temporarily erected for this purpose, under which contractor and staff were required to operate with Level C personal protective equipment. Exterior and site perimeter air monitoring stations were erected and real-time testing data obtained to verify that off-site emissions did not occur. The project approach reduced disposal costs by implementing the BUD for on-site placement of cleaned concrete and use of rail transport which also reduced carbon emissions. This project brought this portion of a contaminated site, part of which lay within wetland and lake buffer zones, to a status of increased value and potential re-sale within one year period of commencement.