Example 6: Using Inactive Waste Site (IWS) Information to Support Hazard Categorization

DOE-STD-1120-2005/Vol. 2

concurrently spill their contents, along with inventory of 5 waste drums located onsite (0.744 Ci total), in

order to exceed the revised HC3 TQ. This is not plausible.

A simple Hazard Analysis Document was submitted to DOE for approval and the facility was

downgraded below Hazard Category 3.

Example 6: Using Inactive Waste Site (IWS) Information to Support Hazard Categorization

The Department of Energy Environmental Management (EM) program office is responsible for a large

number of inactive waste sites. The DOE EM program office provided guidance for categorizing these

inactive waste sites in the September, 2002 Memorandum, Hazard Categorization of EM Inactive Waste

Sites as Less Than Category 3, Jessie Hill Roberson to Distribution, September 17, 2002. Analyses that

identified key assumptions and considerations that provided the basis for the downgraded categorization

of these sites were included in the guidance. The categorization (below Category 3) remains valid as long

as the key assumptions and considerations remain valid.

Remediation of the inactive waste sites may result in one or more of the key assumptions becoming

invalid. It still might be beneficial to use the IWS assumptions and conditions that remain valid to assist

in performing a final hazard categorization for the environmental restoration (ER) activity. The

categorization of the ER activity would summarize the valid IWS assumptions showing how they remain

applicable under the ER activity allowing the majority of the effort to focus on the one or two conditions

that do not meet the IWS guidance.

An example of this is an IWS designated below grade liquid disposal site that is identified as a RCRA

cleanup site or subject to a CERCLA Record of Decision (ROD) as a site requiring remediation. The

decision in the ROD requires that contaminants to be immobilized in place. The contractor elected to

perform the immobilization by grouting the infiltration media (crushed rock) and waste using permeation

grouting techniques (low pressure flowable grout). The technique will require the installation of

injection piping to deliver the grout above, below, and throughout the waste matrix (clearly an intrusive

activity).

The hazard analysis document described the site and techniques to be used to accomplish the

immobilization. The description specified that there are no above ground structures, no below grade

structures with human access or services, no tanks, and the process did not add explosives or reactive

chemicals capable of generating sufficient energy to cause a significant release. The description also

B-8