11%0 DOE/EA-0858. Public P,r,cAlt,7, D-,:rn-t,181-it of li,,neuzy U. S. lOpzrevofris Oflica 14014)
ENVIRONMENTAL ASSESSMENT FOR
DECONTAMINATION AND SELECTIVE DEMOLITION OF AUXILIARY REACTOR AREAS II AND III
AT THE IDAHO NATIONAL ENGINEERING LABORATORY
September 1993
U. S. Department of Energy Idaho Operations Office Idaho Falls, Idaho Department of Energy Idaho Field Office 785 DOE Place Idaho Falls, Idaho 83401-1562 December 6, 1993
See Addressee List
SUBJECT: Environmental Assessment for Decontamination and Selective Demolition of Auxiliary Reactor Areas II and III at the Idaho National Engineering Laboratory (OID-OEA-RH-93-86)
Enclosed is a copy of the Environmental Assessment and Finding of no Significant Impact for Decontamination and Selective Demolition of Auxiliary Reactor Areas II and III at the Idaho National Engineering Laboratory. Please include this as part of your collection of INEL documents. The public may receive individual copies by contacting:
Director Office of External Affairs U. S. Department of Energy 785 DOE Place, MS 1214 Idaho Falls, Idaho 83401 1-800-708-2680
Please contact me at (208) 526-7300 with any questions.
Sincerely,
A. ing, Director Office of External Affa
Enclosure Addressees 2
ADDRESSEES:
Public Reading Room INEL Twin Falls Office INEL Technical Library 233 2nd Street North, Suite B 1776 Science Center Drive Twin Falls, Idaho 83301 Idaho Falls, Idaho 83415 INEL Boise Office Idaho Falls Public Library 816 West Bannock, Suite 306 457 Broadway Boise, Idaho 83706 Idaho Falls, Idaho 83402
Pocatello Public Library 812 E. Clark Pocatello, Idaho 83201
Twin Falls Public Library 434 2nd Street East Twin Falls, Idaho 83301
University of Idaho Library University of Idaho Campus Government Document Department Rayburn Street Moscow, Idaho 83403
Boise Public Library. 715 South Capitol Blvd. Boise, Idaho 83706
Shoshone-Bannock Library Human Resources Center Bannock and Pima Fort Hall, Idaho 83203
Moscow Environmental Restoration Information Office 530 South Ashbury, Suite 2 Moscow, Idaho 83843
INEL Pocatello Office 1651 Al Ricken Drive Pocatello, Idaho 83201 FINDING OF NO SIGNIFICANT IMPACT FOR THE
DECONTAMINATION AND SELECTIVE DEMOLITION OF AUXILIARY REACTOR
AREAS II AND III AT THE IDAHO NATIONAL ENGINEERING LABORATORY
AGENCY: Department of Energy
ACTION: Finding of No Significant Impact
SUMMARY: The Department of Energy (DOE) has prepared an environmental assessment (EA), DOE/EA-0858, for the proposed action of decontaminating, demolishing, and disposing of radiologically contaminated buildings, structures, utilities, and other miscellaneous items at Auxiliary Reactor
Areas (ARA) II and III at the Idaho National Engineering Laboratory (INEL).
The proposed action would reduce the risk of radioactive exposure and eliminate the need for and cost of further surveillance and maintenance at
ARA II and III.
Based on the analyses in the EA, DOE has determined that the proposed action is not a major Federal action significantly affecting the quality of the human environment, within the meaning of the National Environmental Policy Act
(NEPA). Therefore, the preparation of an environmental impact statement (EIS) is not required and DOE is issuing this finding of no significant impact.
1 COPIES OF THE EA ARE AVAILABLE FROM: Mr. Dennis S. Hurtt, Director Office of External Affairs Idaho Operations Office U. S. Department of Energy 785 DOE Place Idaho Falls, ID 83402-1118 (202) 526-8101
FOR FURTHER INFORMATION ON THE NEPA PROCESS CONTACT:
Ms. Carol Borgstrom, Director Office of NEPA Oversight (EH-25) U. S. Department of Energy 1000 Independence Avenue, S.W. Washington, DC 20585 (202) 586-4600 or leave a message at (800) 472-2756
PROPOSED ACTION: The proposed action consists of the following:
1. Decontamination, demolition, and disposal of ARA II, including removal of all the buildings, structures, concrete foundations and supports, utilities, aboveground and belowground tanks, and associated piping from ARA II. All asbestos-containing material would be removed prior to demolition of the buildings. The site would be recontoured and reseeded.
2. Decontamination, demolition, and disposal of contaminated ARA III structures, including removal of the ventilation stacks, foundations, tanks and associated piping, contaminated material from the reactor building and the water pumphouse, and removal of all asbestos.
The proposed action does not include removal of the reactors; the reactors from ARA II and ARA III were removed and disposed of in 1961 and 1965, respectively.
2 ENVIRONMENTAL IMPACTS: The State Historic Preservation Officer (SHPO) has informed DOE that the ARA II and III facilities have been determined to be eligible for the National Register of Historic Places. The SHPO further informed DOE that the proposed action would have an adverse effect on these historic facilities and that appropriate mitigation would be historical documentation of the facilities. In accordance with section 106 of the National Historic Preservation Act, historical documentation will be prepared in consultation with the SHPO and the Advisory Council on Historic
Preservation. The section 106 consultation process would be completed and concurrence obtained from the SHPO prior to commencement of the proposed action.
. . There are no wetlands in the vicinity of ARA II and III and therefore no impacts to wetlands would occur. There are no prime farmland or wild and scenic rivers in the vicinity of ARA II and III, and therefore these resources would not be affected. Because all decontamination and demolition activities would occur at remote and isolated sites, it is not anticipated that noise abatement would be required during the proposed activities. The proposed action would not affect any threatened, endangered, or candidate species or other environmentally sensitive resources.
All of the proposed activities would take place within ARA II and III facility boundaries and all soil disturbance would occur in previously disturbed areas.
Some radioactive particles could be re-suspended by soil disturbance at
ARA II, where radioactive particulates were released to the environment as a
result of an accident in 1961. The resuspension of radioactive particles
3 would be inhibited by applying water or soil fixatives. The potential for emissions generated would be further minimized by high efficiency particulate
air filtered containment in buildings or other confined areas according to INEL decontamination and health and safety plan specifications such that no emissions of atmospheric pollutants are anticipated during routine conduct of the proposed action.
All wastes generated by the proposed action (56 m3 (2,000 ft3) of solid waste;
2,000 m3 (70,000 ft3) of low-level radioactive waste; 3800 L (1000 gallons) of mixed waste; and 14 m3 (500 ft3) of asbestos waste) would be disposed of,
treated at existing INEL facilities, or stored. No expansion of INEL treatment, storage or disposal facilities would be required. An Asbestos
Removal Notification would be provided to the Environmental Protection Agency
as required by the Clean Air Act.
The proposed project would not materially increase radionuclide emissions from the INEL, nor would activities at other INEL facilities contribute to or increase radionuclide exposure to workers at these sites. A health physicist would be present at the work site during all work periods to monitor exposure of personnel to radiation and to ensure that contaminated materials are not inadvertently transported off-site by workers. Personnel exposure to
radiation would be kept as low as reasonably achievable and would not be
allowed to exceed administrative limits.
Accidents that could occur during this proposed action would be of the
industrial type, such as those associated with the operation of heavy
4 equipment or with demolition and falling debris. These types of accidents would not result in increased emissions of contaminants into the environment, but could result in worker injury. Otherwise, the maximum reasonably foreseeable accident scenario would be a fire involving the residual radioactivity. The maximum radiological dose that could result from a potential fire during decontamination and demolition activities at ARA II and
III is estimated to be 1.0 X 10-4 rem for onsite workers and 1.4 X 10-5 rem for the public. The estimated cancer death risk corresponding to these doses is 4.0 X 10-8 for a worker and 7.0 X 10-9 for a member of the public. This risk is small enough that no deaths among the exposed population would be expected as a result of the accident.
ALTERNATIVES CONSIDERED: The No Action alternative is the only alternative to the Proposed Action. No reasonable alternatives to the proposed action were identified. For example, an alternative involving decontamination and demolition of all ARA-III structures is unreasonable, because there is no need to decontaminate and demolish structures that are not contaminated and could be used for other purposes. Alternatives involving in-place disposal, such as entombment, are unreasonable and were not evaluated because they would not meet DOE's need to reduce the risk of radioactive exposure and the cost of surveillance and maintenance.
Under the No Action alternative, no structures would be decontaminated or demolished at ARA II and III. Surveillance and maintenance of the facilities would continue and radiologically contaminated surfaces would be subjected to
natural weathering and decay. Health and safety risks and maintenance costs
5 would likely increase as the condition of the unoccupied radioactively contaminated structures declined over time.
DETERMINATION: The proposed action to decontaminate and demolish ARA II and
III at the INEL does not constitute a major Federal action significantly affecting the quality of the human environment within the meaning of NEPA.
This finding is based on the analyses in the EA. Therefore, the preparation of an EIS is not required for this proposed action.
Issued at Washington, D.C. on .zrCr' , 1993.
Peter N. Brush Acting Assistant Secretary Environment, Safety and Health 1
6 DOE/EA-0858
ENVIRONMENTAL ASSESSMENT FOR
DECONTAMINATION AND SELECTIVE DEMOLITION OF AUXILIARY REACTOR AREAS II AND III
AT THE IDAHO NATIONAL ENGINEERING LABORATORY
September 1993
U. S. Department of Energy Idaho Operations Office Idaho Falls, Idaho DOE/EA-0858
1. PURPOSE AND NEED FOR AGENCY ACTION AND DESCRIPTION OF THE PROPOSED ACTION
The Department of Energy Idaho Operations Office (DOE-ID) needs to take action to meet the objectives of removing contaminated facilities from the list of surplus facilities; reduce the risk of radioactive exposure; and eliminate the need for and cost of further surveillance and maintenance of Auxiliary Reactor Areas (ARA) -II and -III at the Idaho National Engineering Laboratory (INEL). The DOE-ID proposes to decontaminate, demolish, and dispose of radiologically contaminated buildings, structures, utilities, and other miscellaneous items at ARA -II and -III at the INEL. The ARA -II and - III facilities are contaminated facilities managed by the DOE-ID Surplus Facilities Program in accordance with DOE Order 5280.2A, "Decommissioning of Radioactively Contaminated Facilities." A surplus facility is any site or facility that has no identified or planned programmatic use and is contaminated with radioactivity at levels that require controlled access.
ARA-II was the site of the Stationary Low-Power Reactor (SL-1) where a nuclear excursion and steam explosion occurred in 1961 that resulted in three deaths. Following the accident the SL-1 reactor building was disassembled and buried 1/2 mile East of the ARA-II facility boundary and the reactor itself was buried at the Radioactive Waste Management Complex (RWMC). Remaining support buildings at ARA-II were grossly decontaminated and converted to other uses such as laboratories and welding shops and were used until the facility was abandoned in 1986. Most of the contamination at the ARA-II is fixed low-level contamination and is prevalent in the soil and building walls, insulation, floors, and floor drains. The highest level of contamination is found in the power extrapolation building (ARA-615)(Figure 1).
The ARA-III facility was constructed for development and experimental testing of an Army gas- cooled reactor. Test programs were conducted at ARA-III until 1965 when the reactor was removed and buried at the RWMC and the reactor pit was grossly decontaminated. The facility was then used as a component and instrumentation laboratory for testing and evaluating items used in nuclear reactor experiments. Use of the facility was discontinued in the 1980's. The ARA-III area (Figure 2) is contaminated *th low levels of radioactivity with the largest source of residual radioactive material in the waste storage tanks, ARA-735, and ARA-736. DOE/EA-0858
Figure 1. Plot Plan of ARA-II
Deep well Raw water pumphouse storage tank x I x Substation 601 701 x
Power extrapolation 615 Storage building 614 738
Weld c.3 shop D Chlorination •••• El building x i...., 1 :««« Z920213 4 2 DOE/EA-0858 Figure 2. Plot plan of ARA-III X X---A -1 Earth berm 735 Abandoned loundation / 11111161 36 714 O Concrete pad Fire hydrant Earth berm and hose house 711 ----NI 713 715 ....._1 II ffillthilliiillillig 608 j I c'llquilied petroleum gas tank 4 732 Fire hydrant E sand hose housern 622 r 0 dl 607 Distribution II Liquified petroleum a • J 609 box gas tank 610 (100 gallon) 0 Sewer 740 manhole Fire hydrant and hose house 621 739 (.1 Distribution box - 3K X X-- X 3 DOE/EA-0858 The proposed decontamination and demolition of ARA-II would include removal of all the buildings, structures, concrete foundations and supports, utilities, aboveground and belowground tanksand associated piping (Figure 1). All asbestos-containing material would be removed prior to demolition of the buildings. The site would be recontoured and reseeded. The proposed decontamination and demolition of ARA-III would include removal of the ventilation stacks 714 and 715 (Figure 2), including the foundations; removal of tanks 708, 735, and 736 and associated piping; removal of contaminated material from the reactor building (ARA-608) and the water pumphouse (ARA-612); and removal of all asbestos. Remaining facilities at ARA-III, including the reactor building, which are not contaminated, could be released for other use after completion of the proposed action. However, because ARA-H1 is in a remote location of the INEL and the costs of complying with current codes and regulations would be prohibitive, release of the remaining facilities for other uses may not be feasible. Contaminated building materials would be sectioned (cut up) to reduce bulk, packaged and shipped to the RWMC for disposal (Figure 3). Conventional radiological decontamination methods, such as surface wiping, and scabbling, which is the mechanical or hydraulic removal of surfaces, would be used to decontaminate buildings, structures, and utilities. During scabbling, effluent air would be passed through high efficiency particulate air (HEPA) filters to minimize releases of particulate materials to the atmosphere. Asbestos removal, where necessary, would be handled by trained personnel using appropriate methods. Wastes generated by the proposed action would be handled by existing INEL programs and facilities, including the RWMC, sanitary landfill and Waste Experimental Reduction Facility (WERF), if operational. Wastes generated during decontamination activities would be minimized, and when possible, materials used in the decontamination process would be reused or recycled. Activities associated with the proposed action are anticipated to occur over a 5 to 6 year period at ARA-II and a 2 to 3 year period at ARA-III. The history and architecture of ARA-II and -III will be recorded in accordance witt. a Memorandum of Agreement among DOE-ID, the State Historic Preservation Office and Advisory Council on Historic Preservation. Appropriate consultation with the Shoshone-Bannock Tribes will also occur. 4 DOE/EA-0858 Figure 3. Location of facilities on the INEL ARA Awriliicy Reactor Area PBF Power Burst Facility AML-W Argonne National Laboratory - West PREP? Process Experimental Pilot Plant BORAX Boiling Water Reactor Experiment RWMC Radioactive Waste Management Complex CFA Central Facilities Area _ STF Security Training Facility EBR I Experimental Breeder Reactor I TAN Test Area North EB Experimental Breeder Reactor II TRA Tat Reactor Area IC?? Idaho Chemical Processing Plant TREAT Transient Reactor Test(Facility) LET Initial Engineering Test WEDF Waste Experimental Development Facility LOFT Loss-of-Fluid Test(Facility) WERE Waste Experimental Rixluctioa Facility WISP Mixed Waste Storage Facility WRRTF Water Reactor Research Test Facility NRF Naval Reactor Facility ZPPR Zero Power Physics Reactor To Salmon Arco • to Boise Idaho FalLs • TAX Pocatello.' Idaho 33 > 0 To Rexburg To Howe 7305 km' 890 mi To Arco TREAT art-W DR 62PPR US wERF '26'20 • To Idaho Falls 7,0•,,crE,R1 C/4. ?Ilt„ 0 5 10 15 I mi I 5 N‘14", To Blackfoot I I hi 1 0 8 16 24 DOE/EA-0858 2. ALTERNATIVES TO THE PROPOSED ACTION The No Action alternative is the only alternative to the Proposed Action. No reasonable alternatives to the proposed action were identified. For example, an alternative involving decontamination and demolition of all ARA III structures is unreasonable, because there is no need to decontaminate and demolish structures that are not contaminated and could be used for other purposes. Alternatives involving in-place disposal, such as entombment, are unreasonable and were not evaluated because they would not meet DOE's need to reduce the risk of radioactive exposure and the cost of surveillance and maintenance. Under the No Action alternative, no structures would be decontaminated or demolished at ARA-II or ARA-III. Surveillance and maintenance of the facilities would continue and radiologically contaminated surfaces would be subjected to natural weathering and decay. Health and safety risks and maintenance costs would likely increase as the condition of the unoccupied radioactively contaminated structures declined over time. 3. DESCRIPTION OF THE AFFECTED ENVIRONMENT INEL encompasses 890 square miles of relatively level semi-arid land; Big Sagebrush (Artemisia tridentate is the dominant vegetation type. INEL lies on the Snake River Plain at an average elevation of 5000 feet and is bordered by the Rocky Mountains to the west and north and sagebrush lands to the south and east. The basalt bedrock underlying INEL is overlain in most places with 1 to 10 feet of soil. Soils on INEL are primarily shallow loams, with some deposits of sand and gravel. The Snake River Plain Aquifer, a designated sole source aquifer, underlies INEL at depths ranging from 200 to 1000 feet. Depth to the aquifer at ARA is approximately 450 feet. INEL's biological and physical environment is extensively described in Bowman et al. (1984). The climate of the region encompassing INEL is semi-arid and is described in Clawson et al. (1989). The average weather conditions, (adapted from Clawson) at INEL's Central Facilities Area, April through October are; • average daily high temperature: 72°F • average daily low temperature: 38°F • average monthly precipitation: 0.8 inches • average wind speed (20 ft): 8.2 mph • highest hourly wind speed (20 ft): 40 mph. 6 DOE/EA-0858 Proposed action related work to be performed outside would occur April through October, indoor work would occur year round. There are no permanent residents within the boundaries of INEL, the nearest population centers are Idaho Falls (1990 population 43,929), Pocatello (46,080), Blackfoot (9,646), Arco (1,016), and Atomic City (25). 4. ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 4.1 Impacts to Biological and Cultural Resources, and Socioeconomics All proposed action related decontamination and demolition activities would take place within ARA-II and ARA-III facility boundaries. Soil disturbance would be caused by the removal of contaminated materials, including underground lines, sewage tanks and vaults at ARA-II and radioactive waste tanks at ARA-Ill, and by recontouring the surface. All soil disturbance would occur in previously disturbed areas, that is, the same areas used for building construction, installation of the lines and tanks, and burial of waste, etc. Since all decontamination and demolition activities will occur at remote and isolated sites, it is not anticipated that noise abatement would be required during the proposed activities. The nearest public recreational resource is Craters of the Moon National Monument approximately located 25 miles to the Southwest and managed by the National Park Service. Because of the distance between the site of the proposed activities and Craters of the Moon, and the fact that prevailing winds do not blow in that direction, neither the resources of the National Monument nor its visitors will be affected. There are no prime farmlands or wild and scenic rivers in the vicinity of ARA-II or ARA-Ill, and therefore these resources would not be affected. U. S. Fish and Wildlife Service (USFWS) preliminary wetlands inventory maps were used to identify the proximity of possible wetlands [Correspondence between D. D. Peters (USFWS) and 0. D. Markham (DOE-ID) dated March 12, 1991]. There are no wetlands in the vicinity of ARA-II or -III and therefore no impacts to wetlands will occur. 7 DOE/EA-0858 Since no threatened, endangered, or candidate species are known to occur at or near ARA-II or -III there would be no impact on the resources (USFWS letter to DOE-ID dated April 17, 1992). Bald Eagles, a listed endangered species, winter on INEL, but none are known to occur at or near ARA-II or -III. As a result, the proposed action would have no impact on their wintering area, prey base, or roosting sites. INEL biologists with the Radiological and Environmental Sciences Laboratory (RESL) informally consult with the USFWS on a regular basis concerning the status of listed and candidate threatened and endangered species and their habitat. This consultation involves requesting, biannually, a USFWS list of candidate, threatened and endangered species for the area in which INEL is located. The most recent species list will be reviewed prior to initiating the proposed action and a biological assessment will be prepared by RESL and the USFWS will be formally consulted if appropriate. ARA-II and -III were not surveyed for cultural resources prior to the original construction of these facilities in 1958. Any archaeological cultural resource values that may have been present have been scattered by surface clearing and construction and operations activities over the years. The Shoshone- Bannock Tribes will be consulted concerning archaeological resources. In a letter dated August 13, 1992, the Idaho State Historic Preservation Officer (SHPO) indicated that ARA-II and ARA-III are eligible for the National Register of Historic Places, see appendix. The letter states that the proposed action would have an adverse effect and that appropriate mitigation would be historical documentation of the facilities. This documentation will be prepared by DOE in consultation with SHPO and the Advisory Council on Historic Preservation in accordance with Section 106 of the National Historic Preservation Act. The Section 106 consultation process will be completed and the concurrence of the SHPO will be obtained prior to commencement of the proposed action. With the exception of the adverse effect determination of the SHPO concerning the historical significance of the ARA-II and ARA-III, the proposed action would not affect any environmentally sensitive resources. No socioeconomic impacts are anticipated as a result of the proposed acton. The required work force would be drawn from existing INEL employees and the regional labor force. Proposed action related employment would fall within INEL's normal employment fluctuation levels. 8 DOE/EA-0858 4.2 Atmospheric Emissions Possible sources of atmospheric pollutant emissions would include vehicle exhaust and dust generated by concrete removal and excavation activities. Radioactive materials would not be generated but some radioactive particulates could be re-suspended by soil disturbance at ARA-II. These radioactive particulates were released to the environment at the time of the SL-1 accident and have been present at the ARA-II site since that time. Re-suspension of these particulates would be inhibited by applying water or soil fixatives and emissions would be minimized by using HEPA filtered containment in buildings or other confined areas according to INEL decontamination and health and safety plan specifications. An Asbestos Removal Notification would be provided to the Environmental Protection Agency as required by the Clean Air Act. No emissions of atmospheric pollutants are anticipated, but the State of Idaho Air Quality Bureau would be notified prior to initiating the proposed action. 4.3 Waste Generation and Disposition Approximately 56 m3 (2,000 ft3)of solid waste would be generated by the proposed action. This waste would consist of cleaning equipment and structural materials and would be disposed of at INEL's sanitary landfill or declared excess federal property and disposed of in an appropriate manner. This quantity of waste represents less than 1% of the anticipated INEL generated landfill waste for fiscal years (FY)-1991 through 1996. Approximately 1,960 m3 (70,000 ft3)of low level radioactive waste, consisting of concrete, equipment, and structures would be generated by the proposed action. The material would be packaged to meet the waste acceptance criteria of the RWMC and represents less than 2% of the material to be disposed of at the RWMC in FY-1991 through 1996. The major radionuclide contaminant in the material is "'Cesium and the estimated total curie content is 1.7 curies (Bradford et al., 1985). Mixed waste may be present at ARA-II. The mixed waste would be radioactively contaminated fuel oil (less than 30 gallons) remaining in the ARA-705 underground tank which has a 3780 L (1000 gallon) capacity. Any radioactively contaminated oil -emaining in the tank would be pumped out and burned at the INEL Waste Experimental Reduction Facility, if operational or taken to the INEL Radioactive Mixed Waste Storage Facility for storage. It is not anticipated that mixed waste would be present at any other location at ARA-II and no mixed waste is present at ARA-III. No significant 9 DOE/EA-0858 quantities of wastewater are expected to be generated from decontamination and demolition efforts since the dry method will be employed. No contamination plumes from underground storage tanks are present at ARA-II (Bradford et al., 1985) or at ARA-III (Hardy and Pickett, 1991). The absence of contamination demonstrated by these studies also indicates that there is no potential for associated contamination of the unsaturated zone or aquifer. Underground storage tanks would be removed in compliance with the requirements of Environmental Protection Agency Regulations in 40 CFR 280. Pipe and building insulation and floor tile at ARA-II is asbestos- containing material. Prior to beginning the demolition process, an Asbestos Removal Notification Form would be submitted to the Environmental Protection Agency (EPA). The removal of approximately 14 m3 (500 ft3)of asbestos waste is anticipated. Contaminated asbestos material would be wrapped, labelled, and disposed of at the RWMC. Non-contaminated asbestos would be wrapped, labelled, and disposed of at the INEL landfill at the Central Facilities Area. Contaminated soil would not be excavated and packaged for disposal due to the large volume of waste that would be generated if all the soil were excavated. Radioactive particles identified in the soil at ARA-II may be separated, collected and disposed of as low level waste. No soil washing/treatment facilities would be employed; a particle pick and direct disposal process would be used to dispose of low level waste. Wastes would be transported exclusively on INEL roads and this type of transportation is routine at INEL. The only public highway that would be involved would be U.S. 20/26, which would be crossed when transporting wastes from ARA to the RWMC. 4.4 Health and Safety Air monitoring would be conducted during asbestos removal to protect personnel. Asbestos removal workers would be specially trair -3d in asbestos removal procedures and would be equipped with appropriate personal protective equipment. Dust levels would be monitored while workers are involved in decontamination and demolition operations inside buildings. 10 DOE/EA-0858 Because work associated with the proposed action would occur in a contaminated area, there is a possibility that personnel decontaminating and removing contaminated materials could be exposed to low levels of radiation. Radiation levels in areas that would be decontaminated have been characterized and range from 0.5 milli-Roentgen per hour (mR/hr) to 6.0 mR/hr [1000 milli-Roentgen are approximately equal to. one Roentgen Equivalent Man (REM)]. REM is a measurement of radiation dose absorbed by a person, and mR is a measurement of radiation exposure. A Health Physicist would be present at work site during all work periods to monitor exposure of personnel to radiation and to ensure that contaminated materials are not inadvertently transported off-site by workers. Personnel exposure to radiation would be kept as low as reasonably achievable. Administrative dose limits are 1.5 Roentgen Equivalent Man per year (rem/yr), 0.2 rem/week, and 0.05 rem/day (EG&G, 1991). Personnel exposure to radiation would be monitored and would not be allowed to exceed these limits. 4.5 Hypothetical Accidents Accidents that could occur during this action would be of the industrial type, such as those associated with the operation of heavy equipment or with demolition and falling debris etc. This type of accident would not result in increased emissions of contaminants into the environment, but could result in worker injury. A safety analysis report (1991) for ARA-I1 classified the facility as low hazard and identified the worst case accident scenario as a fire involving the residual radioactivity at the Power Extrapolation Building 615. The analysis indicated that airborne emissions from the fire would be three orders of magnitude smaller than the level necessary to cause an effective dose equivalent of 1 mrem to a hypothetical member of the public located downwind on the INEL boundary. A safety analysis report (1992) for the ARA-III has been prepared, however, the worst case accident scenario provided in the safety analysis report for ARA-II provides the most conservative estimate of effective dose equivalent and represents the greater risk of the two areas. The maximum radiological dose from a potential accident during decontamination and demolition activities at ARA II and III is estimated to be 1.02E-04 rem for onsite workers and 1.40E-05 rem for the public. Based on a dose-to-risk conversion factor of 4E-4 cancer deaths/person rem for workers and 5E-4 cancer deaths/person rem for members of the public (NRC, Preamble to Standards for Protection Against Radiation, 56 cR 23363, May 21, 1991), the cancer death risk corresponding to these doses is 7E-9 for a member of the public and 4E-8 for a worker; this risk is small enough that no deaths among the exposed population would be expected as a result of the proposed action. The dose values from a postulated accident during decontamination and demolition of the ARA-II and -III facilities do not exceed dose limits specified in 11 DOE/EA-0858 DOE Order 5481.1B, 3 rem/year effective dose equivalent for INEL on-site personnel and 1 milli- rem/hour for members of the public (Schofield, 1991). 4.6 Permits Required DOE-ID has submitted a RCRA Part A application to EPA Region X for continued operation of INEL's hazardous and mixed waste management facilities. Although EPA has not formally granted interim status, it is assumed to be in effect until the EPA provides formal notification. 4.7 Cumulative Impacts Cumulative impacts are not anticipated from the proposed action. Due to the fixed nature of the contamination, radionuclide emissions associated with the proposed decontamination and dismantling of the ARA-II and -III facilities are not anticipated. The proposed project would not increase radionuclide emissions from the INEL nor because of the remote location of ARA II and ARA III, would activities at other INEL facilities contribute to or increase radionuclides exposure to workers at these sites. The RWMC and CFA landfills would not require expansion to accommodate any of the waste streams resulting from the proposed action. The proposed activity would not prejudice future decontamination and demolition activities at the INEL. The ARA-II and -III facilities are two of several INEL facilities scheduled for decontamination and decommissioning (D&D). The schedule for INEL facilities to be D&D'd are prioritized based on the following, 1) hazards to the public and INEL personnel; 2) recovery of strategic materials; 3) need for space or facility reuse; and 4) surveillance and maintenance costs. The decontamination and demolition of the ARA-II and III facilities would be performed consistent with the DOE-Headquarters D&D Program guidelines and DOE Order 5820.2A, Chapter V. Decontamination and dismantling the ARA-II and ARA-Ill facilities, along with the D&D of other INEL facilities would reduce the potential for future radiation exposures to the public or INEL personnel (Schofield, 1991). 5. AGENCIES CONSULTED 1. U.S. Fish and Wildlife Service, Boise Field Station 2. State Historic Preservation Officer for the State of Idaho 3. Advisory Council on Historic Preservation, Western Office 12 DOE/EA-0858 6. REFERENCES Bowman, A. L., W. F. Downs, K. S. Moor, and B. F. Russell. 1984. INEL Environmental Characterization Report. EGG-NPR-6688. Bradford, J. D., J. H. Clark, M. R. Dolenc, and G. J. White. 1985. Characterization and decision analysis for the Auxiliary Reactor Area II. PT-WM-84-010. Clawson, K. C., G. E. Start, and N. R. Ricks. 1989. Climatography of the Idaho National Engineering Laboratory, 2nd Edition, IDO-12118. U. S. Department of Commerce, National Oceanographic and Atmospheric Administration, Environmental Research Laboratory, Field Research Division. EG&G (EG&G Idaho, Inc.). Radiological Controls Manual. Chapter 2. External Radiation Exposure Control. March 1991. Hardy C.K., S.L. Pickett. 1991. Sampling and Analysis Results for the Auxiliary Reactor Area-III Facility. EGG-WM-9507. NRC, Preamble to Standards for Protection Against Radiation, 56 FR 23363, May 21, 1991. Schofield, W. D. 1992 Safety Analysis Report for the ARA-III at the INEL. WM-ERP-91-003, Rev. 2. Schofield, W.D., 1991 Safety Analysis Report for ARA-II. WM-ERP-91-006, Rev. 1. 13 DOE/EA-0858 APPENDIX IDAHO STATE HISTORICAL SOCIETY CECIL D. ANDRUS, Governor RECE1WE AUG 2 1 1992 TEICUPOCAL SUM RT 4 ? Director August 13, 1992 DIVISION 210 Main St. Boise. Idaho 83702 208-334-2682 Mr. M.B. Hinman Archaeology 210 Main St. Director, Environmental Boise, Idaho 83702 Support Division 208-334-3847 Department of Energy Idaho Field Office Education 785 DOE Place 610 N. Julia Davis Dr. Boise, Idaho 83702 Idaho Falls, Idaho 83401-1562 208-334.2120 RE: Decontamination and Decommission of ARA II and III Genealogical Library Idaho National Engineering Laboratory 450 N.4th St. Boise, Idaho 83702 208-334-2305 Thank you for requesting our reevaluation of the Historic Preservation effects that demolition may have on the ARA II and III 210 Main St. facilities located on the Idaho National Engineering Boise, Idaho 83702 Laboratory, Idaho Falls, Idaho. Demolition of these 208.334-3847, 3861 structures will be accomplished through the Decontamination Library and Archives and Decommission (D&D) program. 450 N. 4th St. Boise, Idaho 83702 Our letter of 15 November 1991 stated that 1.) ARA II 208.334-3356 and III are eligible for the National Register of Historic Places, 2.) removal of the structures is an adverse effect, Museum 610 N. Julia Davis Dr. and 3.) appropriate mitigation would be historical Boise, Idaho 83702 documentation of the facilities. We also stated that we 208-334-2120 realize these structures cannot be preserved for adaptive use or for public access. After further review, we still Old Idaho Penitentiary feel that the removal of these facilities will be an 2445 Old Penitentiary Rd. Boise, Idaho 83712 adverse effect under Section 106 of the National Historic 208-334-2844 Preservation Act (36 CFR Part 800.9.b.1). Oral History Since we do not conduct reviews under the National 210 Main St. Environmental Policy Act (NEPA), we cannot comment on Boise, Idaho 83702 208-334-3863 compliance with NEPA. Our office assists federal agencies in meeting their responsibilities required by the National Publications Historic Preservation Act. 450 N. 4th St. Boise, Idaho 83702 208.334-3428 The Idaho State Historical Society is an Equal Opportunity Employer Mr. M.B. Hinman August 13, 1992 page 2 We appreciate your cooperation. If you have any questions, feel free to contact either myself or Suzi Neitzel at 208-334-3847. Sincerely, nneth J. anson tate Hist• is Preservation Officer KJS/spn cc: Claudia Nissley, Advisory Council on Historic Preservation Clayton Marler, EG&G Idaho Brenda Ringe, EG&G Idaho Susanne Miller, EG&G Idaho Teresa Perkins, DOE Idaho Falls