Kip Huston
U.S. Army Corps of Engineers

The Formerly Utilized Sites Remedial Action Program (FUSRAP) is a U.S. Army Corps of Engineers (USACE) program to clean up or otherwise control sites where residual low-level radioactive contamination remains at sites formerly used for uranium processing, extrusion, and machining; thorium processing; and radioactive materials storage as a part of our early nuclear energy and defense programs. Sites are managed through six USACE districts (Baltimore, Buffalo, New England, New York, Philadelphia, and St. Louis). The mission and objectives of FUSRAP support the overall USACE Hazardous, Toxic, and Radioactive Waste (HTRW) cleanup mission—namely, to protect human health and the environment by remediating sites and facilities in a responsible, cost-effective manner that optimizes opportunities for land and facility reuse. Since the early 1980s, the program has grown from 21 sites in 10 states to 46 sites in 14 states, with 25 sites completed at the end of FY 1997. This review outlines the historical background of FUSRAP, remedial action progress to date, and an accelerated path forward to program completion.

The Formerly Utilized Sites Remedial Action Program (FUSRAP) was initiated in 1974 by the Atomic Energy Commission (AEC) under authorities granted by the Atomic Energy Act of 1954, as amended. FUSRAP was managed by the U.S. Department of Energy (DOE) from 1981 to 1997. On October 13, 1997, management of FUSRAP was transferred to the U.S. Army Corps of Engineers (USACE) under the Energy and Water Development Appropriations Act of 1998.

The mission and objectives of FUSRAP support the overall Hazardous, Toxic, and Radioactive Waste (HTRW) cleanup mission of USACE. FUSRAP’s mission is to identify, evaluate, and clean up or control sites where residual radioactivity exceeding current guidelines remains from Manhattan Engineer District (MED)/AEC contract activities and other sites assigned by Congress. Program objectives are to

• Identify and evaluate sites where authority and need for response action exist
• Clean up or control the sites to ensure protection of public health and the environment
• Dispose of or stabilize radioactive material in a way that is safe for the public and the environment
• Perform work in compliance with applicable federal, state, and local environmental laws, regulations, and land use requirements
• Certify the sites for appropriate future use

FUSRAP currently includes 46 sites in 14 states (Fig. 1). Sites where remedial action is ongoing are managed through six USACE districts (Baltimore, Buffalo, New York, New England, Philadelphia, and St. Louis Districts). At the end of FY 1997, radiological cleanup had been completed at 25 sites, and 13 other sites had been partially remediated. More than 200 vicinity properties have also been remediated. This paper reviews the origin and history of the program, summarizes FUSRAP remedial action progress to date, identifies FUSRAP cost and schedule reduction initiatives, and outlines an accelerated path forward to program completion.

During the 1940s, 1950s, and 1960s, many federal and commercial sites in the United States were used to process and store uranium and thorium ores or for other work supporting the atomic energy program. Most FUSRAP sites were involved in work for MED during World War II or in nuclear activities for AEC. Congress has also added several other sites where industrial contamination is similar to the material from MED/AEC operations.

Established in 1942 under the jurisdiction of the Army as the lead agency in development of nuclear energy, MED was responsible for process development, engineering design, materials procurement, and site selection for the nuclear energy program. MED responsibilities were transferred to AEC in 1946. At that time, more than 10 prime contractors and several hundred subcontractors were involved in nuclear production and research operations.

Contracted work was conducted at national laboratories, universities such as the University of Chicago and the University of California at Berkeley, and industrial chemical processing facilities such as Linde Air Products Division of Union Carbide in Tonawanda, NY; Mallinckrodt, Inc., in St. Louis [known as the St. Louis Downtown Site (SLDS)]; and E.I. du Pont de Nemours & Company (DuPont & Company) in Deepwater, NJ. Facilities such as the Middlesex Sampling Plant (MSP) in Middlesex, NJ, were used for sampling, shipment, and storage of ores prior to processing. Contractors also used offsite storage locations and landfills for storage and disposal of process residues and other radioactive wastes. Examples include the St. Louis Airport Site (storage of residues from Mallinckrodt operations); Ashland 1 in Tonawanda, NY (storage of residues from operations at the Linde facility); and the Middlesex Municipal Landfill (disposal of construction wastes from activities at MSP). A number of smaller commercial sites were used in uranium metal machining and fabrication under subcontracts issued by prime contractors.

As a result of these activities, materials, equipment, buildings, and soil became contaminated, primarily with naturally occurring radionuclides. When sites were no longer required for nuclear programs, they were decontaminated and released for use without radiological restrictions or stabilized in accordance with survey methods and guidelines then in existence. Radiological criteria governing release of sites for unrestricted use changed between the 1950s and the 1970s and are still undergoing development.

In 1974, AEC initiated a survey program to identify and reevaluate formerly used nuclear program sites to determine whether additional decontamination was required. This survey program was the primordial FUSRAP. In 1975, AEC was replaced by the Energy Research and Development Administration (ERDA), which assumed AEC’s programmatic responsibilities, including the activities of the survey program. The Department of Energy Organization Act of 1977 transferred responsibilities of ERDA to DOE. DOE formalized the program, developed a generic plan for identifying and surveying sites, and managed FUSRAP until October 1997, when Congress transferred the program to USACE.

Under the organizational strategy developed by DOE in the early 1980s, responsibilities for FUSRAP activities were assigned to DOE Headquarters and DOE Oak Ridge Operations. DOE contracted engineering firms from the private sector to manage and perform FUSRAP activities. Principal FUSRAP contractors have included Bechtel National, Inc. (project management contractor since 1981) and Science Applications International Corporation (environmental studies contractor since 1991). Technical support contractors providing designation and verification support have included several government laboratories and institutions (Argonne National Laboratory, Oak Ridge National Laboratory, Oak Ridge Associated Universities/Oak Ridge Institute for Science and Education).

Since FUSRAP began, surveys and/or records reviews have been conducted for more than 400 sites. The program currently includes 46 sites in 14 states. Major remedial action progress has been accomplished by DOE since 1981, including removal of thousands of cubic meters of radioactive material from residential and commercial properties and shipment for disposal or storage at government-controlled and monitored storage sites. The majority of smaller sites formerly used in uranium processing, extrusion, and machining have also been remediated.

By the end of FY 1997, DOE had completed radiological cleanup at 25 FUSRAP sites in 12 states, partially remediated 13 additional sites, and cleaned up more than 200 vicinity properties. Figure 2 summarizes site completion progress by calendar year. Cleanup activities at completed sites are summarized in Table I. Cleanup progress at sites where remedial action is ongoing is discussed further in other presentations at this conference session.

FUSRAP tailors the cleanup approach at each site to most expeditiously and cost-effectively address stakeholder concerns; meet site-specific technical and logistic challenges; and achieve compliance with cleanup criteria that ensure protectiveness of human health and the environment. FUSRAP cost and schedule reduction initiatives implemented by DOE are discussed briefly below.

Project efficiency initiatives. Management initiatives to enhance project efficiency have included a 33% reduction in contractor staff during FY 1997; relocation of project teams to the sites to enable them to work more closely and efficiently with subcontractors in the field and allow closer contact with stakeholders; and performance-based and fixed-price contracting strategies to increase cleanup work done per project dollar.

Interim actions. Interim removal actions to expedite site remediation have been an integral part of the site cleanup strategy at large sites in the New York, Buffalo, and St. Louis Districts (1,2,3,4,5,6,7,8,9,10). Examples include pile removal at Maywood and Wayne; decontamination/dismantlement of buildings at Colonie, SLDS, Linde, and Ventron; and cleanup of vicinity properties in Maywood and St. Louis.

Partnering. Cost savings have been realized at several industrial sites through partnerships with the site owner in site restoration. For example, FUSRAP has teamed successfully with Mallinckrodt at SLDS and with Morton International at Ventron in building remediation, decontaminating several buildings at these sites in preparation for dismantlement by the owner (8,10).

Volume reduction, beneficial reuse, and recycling. Where appropriate, remedies incorporate treatment to reduce disposal volume, thereby reducing disposal costs. Soil sorting using a segmented gate system (SGS) at the New Brunswick Site reduced disposal volume by >40% and saved ~$1.2 million in transportation and disposal costs (11). Treatment technologies such as soil washing and sorting are also being evaluated for use in volume reduction of soils from MSP and commercial/industrial and governmental properties in Maywood. A mobile rock crusher has been used to reduce disposal volume of rubble and debris from building demolition at Colonie, SLDS, and sites in Ohio, saving approximately $5 million during 1994-1996. The clean stream from treatment can sometimes be returned to the site for beneficial reuse (e.g., as backfill) or otherwise managed onsite, with only treatment residuals requiring commercial disposal. Savings totaling ~$8.1 million in offsite disposal costs have been realized at Colonie through crushing masonry and building slab material from building demolition for beneficial reuse as backfill onsite, with concurrence of state regulators.

Cost savings of $150,000 were realized at Colonie through treatment of a barium-contaminated waste stream from dismantlement of a salt bath used for steam-washing brick at the main plant building. Treatment included stabilization of leachable barium in the brick and addition of anhydrous sodium sulfate to the barium-contaminated wastewater, thereby converting soluble barium chloride in the wastewater to insoluble barium sulfate and allowing both supernatant and precipitate to be disposed of as nonregulated solid waste. Other volume reduction technologies used successfully at Colonie were thermal desorption treatment and polymer-based stabilization of uranium raffinates, alkaline chlorination, nitric acid and reagent oxidation, air-stripping, solvent extraction, and cementation. Recycling efforts at Colonie included recycling of radioactively contaminated scrap metal by smelting into shield blocks for use in DOE research facilities and a respirator cartridge conservation program resulting in an annual savings of $103,000.

Innovative contracting strategies. Approximately $185,000 was saved at Colonie through a cooperative agreement with the Idaho National Engineering Laboratory Mixed Waste Focus Area and DOE-Idaho, under which lead debris was shipped for use in a demonstration of polymer encapsulation at the Envirocare facility in Utah. FUSRAP incurred no costs for macroencapsulation and disposal of the material other than scheduled costs of profiling the waste and shipping it to Envirocare. Other examples include a turnkey subcontract for Wayne pile removal; a Maywood pile removal/offsite treatment subcontract; and a subcontract covering decontamination/disposal of steel from Colonie, MSP, and DuPont.

Expedited cleanup protocols at sites with small, localized areas of contamination within buildings. Examples include removal actions at Seymour Specialty Wire, C.H. Schnoor, Granite City Steel, and Chapman Valve (12,13,14,15).

Characterization performance improvement initiatives. Examples include the use of streamlined characterization approaches at Ventron and Painesville; reduction of analytical costs by using a mobile wet chemistry lab in St. Louis and improved gamma spectroscopy systems in Maywood; and 3-D visualization modeling of Maywood soil concentration distribution data to clarify relationships between site contaminants and the water table.

Applying supplemental limits supported by hazard assessment where appropriate (e.g., Building 845 at DuPont; Building 14 at Linde).

"Zero Accidents" philosophy. In conjunction with the goal of completing site remediation as efficiently and cost-effectively as possible, FUSRAP is committed to performing work in a way that is safe for workers and the public. The program maintains an excellent safety record; in October 1997, FUSRAP personnel passed the two-year mark for days worked without a lost-time accident. FUSRAP’s safety and health (S&H) program addresses all aspects of safety and health, including industrial hygiene, health physics, industrial safety, training, and documentation. All site activities are controlled under a comprehensive generic S&H plan, supplemented by site-specific S&H plans, to ensure protection of workers, the public, and the environment.

FUSRAP S&H checkpoints include operational readiness reviews; weekly safety meetings; general and site-specific training (including OSHA Hazard Communications and Hazardous Waste Operations and Emergency Response training); monitoring (including direct monitoring of personnel and the work area and perimeter monitoring when necessary); medical surveillance and bioassay programs; site and restricted work area access control; worker use of respiratory protection and personal protective equipment; and established emergency response and notification procedures. Mechanisms for feedback, oversight, and continuous improvement include external and internal assessments; an established corrective action process including root cause analysis; and a continuous improvement program.

Effective on October 13, 1997, the date the Energy and Water Development Appropriations Act of 1998 became law, DOE assigned the Bechtel and SAIC FUSRAP contracts to USACE, and USACE assigned the contracts to the Omaha District for overall program management. USACE moved quickly to assign transition teams to respond to the mandate from Congress to take over responsibility for managing the program, which includes remediation activities totaling $140 million for FY 1998. They were also assigned to evaluate current FUSRAP plans and to report to Congress within 90 days regarding how USACE would complete cleanup of the FUSRAP sites.

One USACE transition team was assigned to assess the overall management of FUSRAP by the project management contractor, Bechtel National, Inc., and the support services contractor, SAIC. A second team was assigned to evaluate remediation activities in progress at FUSRAP sites in New York, New Jersey, Missouri, and Ohio. Initial guidance given to Bechtel and SAIC was to continue to execute the current work plan until USACE completed its evaluation and formulated its execution plan. Work continued without interruption as the transition team met with the FUSRAP contractors and acquired the necessary information and understanding to develop the USACE plan for completing cleanup of FUSRAP sites.

The Omaha District maintains responsibility for overall management of the FUSRAP contract. However, the standard USACE operating philosophy is to assign responsibility for managing site remediation to the districts where the sites are located. Based on this philosophy, district assignments were as follows:

• The four FUSRAP sites in St. Louis and the Madison site in Illinois were assigned to the St. Louis District.
• The Colonie site near Albany, NY, and three sites in New Jersey (Maywood, Middlesex, and Wayne) were assigned to the New York District
• The Niagara Falls Storage Site near Buffalo, NY, five other sites in the Buffalo area, and the Luckey and Painesville sites in Ohio were assigned to the Buffalo District
• The CE site in Connecticut and the Shpack Landfill in Massachusetts were assigned to the New England District
• The DuPont site in Deepwater, NJ, near Philadelphia, was assigned to the Philadelphia District
• The W.R. Grace & Company site in Maryland was assigned to the Baltimore District.

USACE project managers in each district were assigned to take responsibility for managing Bechtel and SAIC activities at these sites.

In addition to the "execution" districts and the existing contractors, USACE uses its "Centers of Excellence" districts to provide technical support by specialists as needed. For example, the Omaha District is the USACE Center of Excellence for HTRW activities and may be called upon to provide technical expertise in risk assessment and radiological control. Availability of this additional technical resource adds significantly to the ability of FUSRAP to ensure that all options have been fully evaluated and the best option selected as technical challenges are encountered.

Early in the transition period, USACE changed the Bechtel and SAIC contracts to task order contracts. This contracting approach facilitates issuing separate task orders for work within each "execution" district and provides the flexibility to issue task orders whose completion may extend beyond the current contract end date. This flexibility will permit ongoing field remediation work to continue during the 1998 construction season without costly interruptions in ongoing field activities.

The USACE operating philosophy includes very active participation by the responsible districts at each FUSRAP site. Some of the functions previously performed by Bechtel as the management contractor are now performed by USACE. This increase in USACE activity and a shift to a decentralized execution approach resulted in some change in the level and areas of support required from FUSRAP contractors.

The current FUSRAP baseline for FY 1998 and the Draft Accelerated Cleanup Plan for the program were reviewed as a part of the transition team evaluation. The proposed cleanup criteria and remediation approach were carefully evaluated in terms of regulatory requirements, technical feasibility, commitments to stakeholders, and cost. USACE’s mandate from Congress included identifying ways to meet FUSRAP’s commitment to the public to clean up the remaining FUSRAP sites as quickly and as cost effectively as possible.

USACE’s evaluation identified several initiatives currently being implemented that are expected to meet the challenge given by Congress to complete the work more cost effectively. Key USACE initiatives to accomplish this goal include:

• Implementing the planned DOE initiative of alternate disposal at sites where only residual amounts of radioactivity are found onsite
• Using industrial rather than residential cleanup standards at sites where projected future use clearly does not include residential development
• Using risk-based assessments to justify less conservative release levels where appropriate
• Streamlining the reporting and decision-making process to accelerate work
• Using less expensive USACE commercial disposal contracts

The anticipated outcome of implementing the USACE execution plan is more efficient and cost-effective remediation of FUSRAP sites while still ensuring compliance and protectiveness of human health and the environment for end state uses desired by the affected communities.

1. Bechtel National, Inc. (BNI), 1986. Post-Remedial Action Report for the Lodi Residential Properties, DOE/OR/20722-89, Oak Ridge, Tenn. (August).
2. BNI, 1996. Post-Remedial Action Report for the Maywood Site Vicinity Properties at 79 Avenue B, 90 Avenue C, 108 Avenue E, 112 Avenue E, and 113 Avenue E, Maywood, New Jersey, DOE/OR/21949-405, Oak Ridge, Tenn. (September).
3. U.S. Department of Energy (DOE), 1990. Certification Docket for the Remedial Action Performed at the Wayne Interim Storage Site Vicinity Properties—1985-1987, Oak Ridge, Tenn. (August).
4. DOE, 1995. Certification Docket for the Remedial Action Performed at the Wayne Site Vicinity Properties in Wayne, New Jersey, 1993, Oak Ridge, Tenn. (December).
5. DOE, 1989. Certification Docket for the Remedial Action Performed at the Colonie Interim Storage Site Vicinity Properties in Colonie and Albany, New York, in 1984 and 1985, Oak Ridge, Tenn. (July).
6. DOE, 1990. Certification Docket for the Remedial Action Performed at the Colonie Interim Storage Site Vicinity Properties in Colonie and Albany, New York—1988, Oak Ridge, Tenn. (July).
7. DOE, 1992. Certification Docket for Remedial Action Performed at the Niagara Falls Storage Site Vicinity Properties in Lewiston, New York, from 1983 through 1986, Oak Ridge, Tenn. (July).
8. BNI, 1996. Post-Remedial Action Report for Remedial Action Conducted in St. Louis, Missouri, During Calendar Year 1994, DOE/OR/21949-396, Oak Ridge, Tenn. (July).
9. BNI, 1996. Post-Remedial Action Report for Remedial Action Conducted in St. Louis, Missouri, During Calendar Year 1995, DOE/OR/21949-407, Oak Ridge, Tenn. (November).
10. BNI, 1997. Post-Remedial Action Report for Remedial Action Conducted in St. Louis, Missouri, During Calendar Year 1996, DOE/OR/21949-409, Oak Ridge, Tenn. (February).
11. BNI, 1997. Post-Remedial Action Report for the New Brunswick Site, New Brunswick, New Jersey, DOE/OR/21949-411, Oak Ridge, Tenn. (November).
12. DOE, 1995. Certification Docket for the Remedial Action Performed at the Seymour Specialty Wire Site in Seymour, Connecticut, 1992-1993, Oak Ridge, Tenn. (December).
13. DOE, 1996. Certification Docket for the Remedial Action Performed at the C.H. Schnoor Site, Springdale, Pennsylvania, in 1994, Oak Ridge, Tenn. (November).
14. DOE, 1994. Certification Docket for the Remedial Action Performed at the Granite City Site in Granite City, Illinois, June 1993, Oak Ridge, Tenn. (September).
15. BNI, 1996. Post-Remedial Action Report for the Chapman Valve Site, Indian Orchard, Massachusetts, DOE/OR/21949-408, Oak Ridge, Tenn. (November).

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