Department of the Air Force; Decommissioning Plan for Site WR-111 of Hill AFB, UT

957 Pages·2015·28.09 MB·English

DEPARTMENT OF THE AIR FORCE
HEADQUARTERS UNITED STATES AIR FORCE
WASHINGTON DC
18 December 2014
MEMORANDUM FOR NRC REGION IV
ATTN: Dr. Robert Evans
FROM: AFMSA/SG3PB
SUBJECT: Decomissioning Plan (DP) for Site WR-111ofHill AFB, UT, Radioactive Material Permit#
UT-000517-00/03 AFP
Per your request, we have redacted portions of the subject DP to be released for the public via the
Federal Register. Attached are the following documents:
1) Redacted copy of the DP with red ink (CD titled Atch 1). This document is for your records.
2) A CD with redacted files (Atch 2) from the Project Manager ofthe Site WR 111. These
documents may be released to the public.
3) A copy of the letter (Atch 3) from Ms. Sponaugle, the Project Manager ofWR-111 ofEA
Engineering, Science and Technology Inc., for your information.
4) A list of the redacted files from the CD title Atch 1 for quick reference.
Please only publish the clean copy (Atch 2) contents to the public in the federal register.
If you have any questions, please contact me at 703-681-6871 or E-Mail at
[email protected].
IBLJC
:i""i;(,n;;dlate Release
~-~-;~al Release
N:>N-PUBLIC
a0 A.3 Sen,:;it;'lf' SC'~"urity Relat.d Ramachandra K. Bhat, Ph.D., CHP
[J OAt.h7 e~rr: _I it _I _In_ . al Senior Health Physicist
USAF Radioisotope Committee Secretariat
~ate:~
.!
AF Medical Support Agency
Office of the Surgeon General
Attachemnts:
1. Red ink copy CD-Site WR-111-Not to be released to the public
2. Clean copy CD- Site WR-111-To be released to the public RECEIVED
3. Memo from Ms. Sponaugle dated 3 Dec 14
4. List of the Redacted files by EA Engineering
n1=r 1 1 2014
DNMS
L:\Permits\Hill AFB UT\04000517\C020141218
225 Schilling Circle, Suite 400
Hunt Valley, MD 21031
Telephone: [phone]
Fax: [phone]
EA Engineering, Science, and Technology, Inc. www.eaest.com
3 December 2014
MEMORANDUM
TO: Kyle Gorder, P.E., Project Manager, Air Force Civil Engineering Center, Hill IST, Hill Air
Force Base (AFB), Utah
!<'ROM: Amy Sponaugle, P.E., Project Manager, EA Engineering, Science and Technology, Inc.
(EA)
SUBJECT: Public Release of Project Information- Site WR111, Magnesium-Thorium Disposal
Trench Site at Little Mountain Test Almex, Hill Air Force Base; Hill AFB Performance
Based Remediation (PBR) Contract No. F A8903-09-D-8560, Task Order 0006
EA has reviewed the documents on the enclosed CD titled "Final Redacted Documents for Site WR111,
Hill Air Force Base, Utah" and has redacted information in those documents per our Memorandum to
Kyle Gorder (Project Manager, Air Force Civil Engineering Center, Hill IST, Hill AFI3) dated 17
November 2014. The documents on this CD may be released to the public.
As requested, EA has also enclosed a CD titled "Red Highlighted Documents for Site WRlll, Hill Air
Force Base, Utah" that shows the information (in red highlight) that was ultimately redacted. The
documents on this CD should not be released to the public.
If you have any questions or require additional information, please do not hesitate to contact me at 410-
329-5103 or email at asponaugle(ii.\eaest.com.
Amy Sponaugle
Site WR111 Project Manager
EA Engineering, Science, and Technology, Inc.
Enclosures:
I - CD titled "Final Redacted Documents for Site WRill, Hill Air force Base, Utah", dated 3 December 2014
2- CD titled "Red Highlighted Documents for' Site WR Ill, Hill Air Force Base, Utah", dated 3 December 2014
cc: S. Staigerwald (EA Senior Project Mamtger)
J. Lazzcri (EA Program Manng~r)
A. Bndour
Seth Smith
file
Attachment 3
List of the Redacted files by EA Engineering from the Atch 1 CD.
for the Site WR 111 of Hill AFB
Introduction: On 3 Nov 14, the Radioisotope Committee Secretariat (RICS) received redacted copy of the
documents of the site WR Ill to be released for the public in federal register from Dr. Evans ofNRC
Region IV. Then RICS forwarded the documents to Mr. Gorder, the Hill AFB Installation Remediation
Project Manager who forwarded the documents to the contractors and sub-contractors for review. Mr.
Gorder received the redacted copy with red ink and a clean copy from the Project Manager of the Site
WR Ill of EA Engineering, Science, and Technology, INC. In general, some names, addresses,
telephone numbers, NRC license numbers etc. have been removed from the documents. We have given
below the list of the files to be redacted (highlighted with red ink)by the EA Engineering from the Atch 1
CD for the Site WR Ill of Hill AFB.
File Title: Documents to be released by NRC for public comment Part 1 of2-
a. APOI4-Radiation Safety Procedure for classifying radioactive Waste (Page 227)
b. OP-00 !-Operation Procedure for Radiological Survey (Page 237)
c. OP-002- Operating Procedure for Radioactive Air sample and Analysis (Page 254)
d. OP-005-0perating Procedure for Volumetric and Material Sampling within Radiological
Control Areas (Page 270).
e. OP-008-Radiation Safety Procedure for Chain of Custody (Page 283).
f. OP-0 18:0perating Procedure for Decontamination of Radioactivity from equipment and
Tools (Page 289).
g. OP-020- Operating Procedure for Operation of Operation of Contamination Survey Meters
(Page 300).
h. OP-021- Operating Procedure for Alpha-Bata counting Instrumentation (Page 307).
1. OP-061-0perating Procedure for Sample Labelling. (Page 319).
J. OP- 062 Operating Procedure for Sample Handling and Packaging and Shipping (Page 323).
k. OP-187- Operating Procedure for Records Management (Page 329).
I. OP-312- Operating Procedure for Wipe Sampling Procedure (Page 335).
m. OP-351 -Operating Procedure for Surface Soil Sampling (Page 342).
n. OP-359- Operating Procedure for Field Activity Documentation (Page 352).
o. OP-360 Operating Procedure for Sample Numbering (Page 364).
p. OP-387- Operating Procedure for Gamma Walkover Survey (Page 370).
Attachment 4
L/Permit/Hiii/040-00517/Correspondence to and from NRC/C020141212
DEPARTMENT OF THE AIR FORCE
HEADQUARTERS UNITED STATES AIR FORCE
WASHINGTON DC

12 September 2014

MEMORANDUM FOR NRC REGION IV
ATTN: Ms. Cook

FROM: AFMSA/SG3PB,

SUBJECT: Waiver for Environmental Assesment (EA): Site WR-111 at Hill AFB UT

The subject site WR111 is located in the far southeast corner of the Little Mountain Test Annex, Hill
AFB, UT. The Chief Environmental Quality Branch, 75th Civil Engineering group of Hill AFB,
completed “EA of Proposed Emergency Power Unit Overhaul Complex at Little Mountain Test Annex
Utah” dated 14 March 2014 (Atch 1A and 1B) to provide safe facilities in which emergency power units
would be overhauled for the F-16 fighter aircraft. We request your office make a decision declaring that
Hill AFB WR111 project is categorically excluded from further analysis of EA, and that there is no
adverse impacts on cultural resources nor is there an impact on the sites of religious and cultural
significances of American tribes, in accordance with the 22 August 2014 memo of Mr. Linford, the Hill
AFB Environmental Attorney (Atch 2). The following responses address the questions listed in the 15
August 2014 email from Mr. Whitten.

Question: 1. We understand that Little Mountain Test Annex is federal property. In that context we
need to confirm whether there are any Native American or local governmental agencies that have an
interest in the Little Mountain Test Annex. This information is needed for possible consultations with
these various groups, if any.

At a minimum, the NRC Region IV plans to consult with the State of Utah, but any other group that
has a claim in the property needs to be added to the list of consultations.

Radioisotope Committee Secretariat’s (RICS’) Reply: The Hill AFB Environmental Office
recently completed an EA on a similar action at the Little Mountain Facility and determined that action
would have no adverse impact on cultural resources (See Appendix A page 54 of Atch 1A). Of the
twenty tribes contacted, only two responded (See Appendix B on page 63 of the Atch 1A for the Navajo
Nation and Atch 1B for the Hope Tribe) and concurred with Hill AFB’s determination. Nevertheless, the
Air Force will ask these tribes to confirm that no sites of religious and cultural significance are within the
perimeter of the Little Mountain Test Annex and will inform the NRC of any responses. Hill AFB has
consulted with the State of Utah’s Division of Radiation Control regarding this project and believes that
continued coordination is appropriate.

Question 2: AF does not give detailed decommissioning instructions for soil remediation (Section 5.1
of the DP). Will this information will be included in the contractor's work plan or equivalent document?
Please provide a copy of this work plan?

RICS’ Reply: The “Remedial Design/ Action Work Plan” dated August 2014 is given in Atch 3. The
Section 4 of Atch 3 (Removal Action Elements, beginning pdf page 29) and more specifically
Section 4.3 (Excavation and Handling of Contaminated Material, beginning pdf page 37).

L:\Permits\Hill AFB UT\04000517\CORRESPONDENCE TO AND FROM NRC\20140912
Question 3: DP does not provide environmental information, information necessary to support the
development of the Environmental Assessment (EA) and finding of no significant impact (FONSI). Does
the Air Force intend to conduct an EA to supplement the DP? If the answer is no, then Region IV may
have to conduct the EA as part of our detailed technical review.

RICS’ Reply: Under 32 CFR Part 989, Attachment 2, the Air Force may categorically exclude from
further analysis those “Actions similar to other actions which have been determined to have an
insignificant impact in a similar setting as established in an EIS or an EA resulting in a FONSI.” The Hill
AFB Environmental Office recently completed an EA on a similar action at the Little Mountain Facility
and found there would be no significant impact (Atch1A). Application of this CATEX (A2.3.11) to the
current project is documented on an AF Form 813 (Atch 4). After consulting the AF legal office, the
RICS is submitting the existing documents in order to convince the NRC that a waiver of further
environmental impact assessment (i.e., in the form of an additional EA and FONSI) for the Little
Mountain Annex trench removal project is justified as a result of the noted previous EA work at the Little
Mountain Facility. If NRC is not satisfied with the previous NEPA work accomplished under Air Force
NEPA requirements, then, Hill AFB will assist the NRC in preparing an EA and FONSI specifically for
the Little Mountain Annex WR 111 project.

If you have any questions, please contact me at 703-681-6871or E-Mail at
[email protected].

Ramachandra K. Bhat, Ph.D., CHP
Senior Health Physicist
USAF Radioisotope Committee Secretariat
AFMSA/SG3PB, 7700 Arlington Blvd Ste 5158
Falls Church VA 22042-5158

5. Attachments:
1A. Environmental Assesment of Little Mountain Test Annex
1B. Hopi Tribe
2. 22 August 2014 memo of Mr. Linford
3. Decommissioning Instructions for Soil Remediation
4. AF Form 813 and Email exchanges

cc:
HQ AFIA/SGI (Lt Col Abell)
USAFSAM/OECM (Capt Krzyaniak)
AFCEC/CZRY (Ms. Bodour)
AFMC75 CEG/CENR (Mr. Gorder)
75 AMDS/SGPB (Mr. Kidner)
L:\Permits\Hill AFB UT\04000517\CORRESPONDENCE TO AND FROM NRC\20140912
Hill Air Force Base, Utah
Final
Environmental Assessment:
Proposed Emergency Power Unit Overhaul
Complex at Little Mountain Test Annex,
Utah
March 14, 2014
Atch 1A
Final
Environmental Assessment (EA):
Proposed Emergency Power Unit Overhaul
Complex at Little Mountain Test Annex, Utah
Contract No. FA8201-09-D-0002
Delivery Order No. 0054
Department of the Air Force
Air Force Materiel Command
Hill Air Force Base, Utah 84056
March 14, 2014
Prepared in accordance with the Department of the Air Force Environmental Impact Analysis
Process (EIAP) 32 CFR Part 989, Effective July 6, 1999, which implements the National
Environmental Policy Act (NEPA), the President's Council on Environmental Quality (CEQ)
regulations.
Printed on Recycled Paper
EXECUTIVE SUMMARY
Purpose and Need
The purpose of the proposed action is to provide safe facilities in which emergency
power units (EPUs) would be overhauled for the F-16 fighter aircraft. The F-16 EPU
overhaul operations, which are currently being conducted on Hill Air Force Base (AFB)
in a location that violates United States Air Force (USAF) explosive safety standards,
must be relocated.
Selection Criteria
The EPU overhaul complex should:
(cid:120) comply with explosive safetyrequirements,
(cid:120) establish a 300-foot buffer zone,
(cid:120) not conflict with the Hill AFB General Plan, and
(cid:120) comply with federal, state, and local environmental regulations.
Scope of Review
The issues that were identified for detailed consideration are: air quality, solid and
hazardous wastes (including liquid waste streams), biological resources, and water
quality.
Alternatives Considered in Detail
Alternative A (No Action Alternative)-Under the no action alternative, a new EPU
overhaul complex would not be constructed, and safe facilities would not be provided.
The existing facilities would operate as they currently exist.
Alternative B (Proposed Action -Construct a New EPU Overhaul Complex at Little
Mountain Test Annex [LMTA])-The proposed action would include:
(cid:120) Four buildings with structural steel frames and masonry walls, reinforced concrete
footings, foundations and floor slabs, mechanical and electrical systems, water
and fire protection systems, and communications networks. One building to
contain a boiler. Separation between buildings would be at least 300 feet. The
total footprint of structures would be 25,950 square feet.
(cid:120) Associated pavements and connections to adjacent buried utilities.
In addition to constructing a new EPU overhaul complex,Buildings 2005and2006
would be demolished on Hill AFB in support of USAF’s physical plant strategy, which
calls for reducing net facility footprint by 20 percent between 2006 and 2020 by
demolishing surplus and inefficient facilities.
Alternative C (Construct a New EPU Overhaul Complex South of the LMTA Access
Road)-The only difference between Alternative C and the proposed action would be its
location.
ES-1
Results of the Environmental Assessment
Three alternatives were considered in detail. The results of the environmental assessment
are summarized in the following table.
Summary of Predicted Environmental Effects
Issue Alternative A Alternative B Alternative C
No Action Proposed Action Construct South
of LMTA
Access Road
Air Existing degreasing Qualified asbestos abatement contractors would Same as for the
Quality operationsemit four prevent impacts to air quality. Construction proposed action.
tons per year of volatile equipment would create temporary emissions.
organic compounds, but Fugitive dust would be controlled.
would be greatly
Degreasing operationswouldemit four tons per year
reduced if dipping of volatile organic compounds, or much less if wiping
operations change to were to be implemented. Additional commuting and
wiping. delivery vehicle emissions would exist. Sub-structure
vapor barriers would protect indoor air quality.
Conformity with the Clean Air Act was demonstrated.
Solid and Regulated solid wastes If contaminated building materials, soils or pavements Same as for the
Hazardous and regulated liquids are identified, they would be properly handled during proposed action.
Waste are treated and/or the demolition and construction process. EPU
disposed in accordance overhaulactivities would generate the same types of
with applicable waste as the existing facilities.
regulations.
Biological The 20-acre vacant site Mule deer and rodents would be displaced. Same as for the
Resources would remain in its Management for loss of habitat would be proposed action.
current, somewhat accomplished by improving adjacent habitat uphill
degraded condition (north) of the proposed action.
Water Good housekeeping During construction and operations, water quality Same as for the
Quality measures and other best would be protected by implementing stormwater proposed action.
management practices management practices. Precipitation from the 95th
are being followed. percentile, 24 hour storm event would be retained on
site. Contamination ofshallow groundwater may
exist beneath portions of the proposed action. If
groundwater or saturated soils were to be contacted,
activities would be halted and Hill AFB remedial
managers would be contacted. Good housekeeping
measures and other best management practices would
be incorporated into facility design and operations.
Identification of the Preferred Alternative
Hill AFB prefers Alternative B(the proposed action).
ES-2
TABLE OF CONTENTS
1 Purpose of and Need for Action........................................................................................1
1.1 Introduction....................................................................................................................1
1.2 Proposed Action.............................................................................................................2
1.3 Need for the Action........................................................................................................2
1.4 Purpose of the Proposed Action.....................................................................................2
1.5 Relevant EISs, EAs, Laws, Regulations, Plans, and Other Documents........................2
1.6 Decisions That Must Be Made.......................................................................................4
1.7 Scope of this Environmental Analysis...........................................................................4
1.7.1 History of the Planning and Scoping Process..........................................................4
1.7.2 Issues Studied in Detail............................................................................................5
1.7.3 Issues Eliminated From Further Study....................................................................6
1.8 Applicable Permits, Licenses, and Other Coordination Requirements..........................7
2.0 Alternatives, Including the Proposed Action...................................................................9
2.1 Introduction....................................................................................................................9
2.2 Description of Alternatives............................................................................................9
2.2.1 Alternative A: No Action........................................................................................9
2.2.2 Alternative B: Proposed Action -Construct a New EPU Overhaul
Complex...................................................................................................................9
2.2.3 Alternative C: Construct a New EPU Overhaul Complex South of the
LMTA Access Road..............................................................................................12
2.2.4 Alternative D: Construct a New EPU Overhaul Complex On Hill
AFB........................................................................................................................14
2.3 Process Used to Develop the Alternatives...................................................................14
2.3.1 Alternative Selection Criteria................................................................................14
2.3.2 Alternatives Eliminated From Detailed Consideration..........................................15
2.4 Summary Comparison of the Alternatives and Predicted Achievement of
the Project Objectives..................................................................................................15
2.4.1 Summary Comparison of Project Alternatives......................................................15
2.4.2 Predicted Achievement of Project Objectives.......................................................16
2.5 Identification of the Preferred Alternative...................................................................16
3.0 Affected Environment.....................................................................................................17
3.1 Introduction..................................................................................................................17
3.2 Description of Relevant Facilities and Operations......................................................17
3.3 Description of Relevant Affected Issues......................................................................17
3.3.1 Air Quality.............................................................................................................17
3.3.2 Solid and Hazardous Wastes..................................................................................24
3.3.3 Biological Resources.............................................................................................25
3.3.4 Water Quality.........................................................................................................26
3.4 Description of Relevant Pre-Existing Environmental Factors.....................................27
3.5 Description of Areas Related to Cumulative Effects...................................................28