U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Haystack Navajo Radioactive Structures Site - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IX
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Subject:
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POLREP #6
Progress
Haystack Navajo Radioactive Structures Site
Haystack, NM
Latitude: 35.3553091 Longitude: -107.9475609
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To:
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Vivian Craig, N.N. EPA
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From:
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Randy Nattis, Federal On Scene Coordinator
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Date:
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7/20/2013
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Reporting Period:
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7.08.2013 - 7.21.2013
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1. Introduction
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1.1 Background
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Site Number: |
09WW |
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Contract Number: |
EP-S5-08-02 |
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D.O. Number: |
0096 |
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Action Memo Date: |
9/15/2011 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
Entire site |
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Mobilization Date: |
5/5/2013 |
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Start Date: |
5/6/2013 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
NNN000909132 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Removal Action
1.1.2 Site Description
The Site consists of 12 structures and 8 exterior areas containing areas of elevated Uranium contamination soils or materials on residential properties known as Allotments. Allotments are reservation land the federal government distributed to individual Indians, generally in 40-, 80-, and 160-arce parcels. Typically, the allotment includes residential structures, Navajo ceremonial buildings, called Hogans, and frequently an outer storage building. The Hogan and storage buildings are usually located in close proximity (within 200 feet) of the residential structures. Exterior surveys include approximately ½ an acre surrounding each primary structure; however, in some cases where the structures are closer together the survey areas may consist of less than ½ an acre apiece.
In February, June, July and August of 2011, U.S. EPA, in partnership with Navajo Nation EPA (NNEPA), investigated 58 residential properties containing 171 structures in the Haystack and Church Rock Chapter areas. U.S. EPA assistance was requested by Navajo Nation to conduct these investigations based on results of the initial screenings conducted by NNEPA in these same areas in 2009 and 2010. The U.S. EPA investigation identified 12 structures and 8 yards; all located within the Haystack and Church Rock Chapter areas, requiring response action. All of the structures are occupied and used for residential purposes.
1.1.2.1 Location
The Site is located within the Navajo Nation Indian Reservation in New Mexico. The Site is situated within the Navajo Nation Chapters known as Haystack and Church Rock.
1.1.2.2 Description of Threat
Current Site conditions pose ongoing releases and the threat of future releases of hazardous substances, namely: Uranium and its progeny (i.e. Radium-226 and Radon) and ionizing gamma and alpha radiation associated with those progeny. The likelihood of direct human exposure, via ingestion and/or inhalation of hazardous substances, and the threat of future releases and migration of those substances, pose an imminent and substantial endangerment to public health, welfare and the environment based on the factors set forth in the NCP, 40 CFR 300.415(b)(2).
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
In February and throughout the summer of 2011, U.S. EPA conducted radiation assessments of 58 residential properties and all of the structures associated with each residential property, which amounted to a total of 171 structures. Most of the subject residential properties had been identified during previous screenings as potential concerns. These earlier screenings were conducted separately by NNEPA in order to streamline U.S. EPA’s assessment activities.
Past and present investigations were requested based on anecdotal evidence that residents transported contaminated mine materials to their residential properties for use in structure construction. Many of these residents worked in nearby uranium mines and reportedly carried contaminated construction materials home from the mine.
In addition, some of the residential properties are situated down gradient from abandoned uranium mines (both reclaimed and un-reclaimed). Therefore, some of the contamination in residential soils may be the result of contaminant transport forces (i.e., contaminant migration due to wind and runoff).
U.S. EPA conducted the radiological assessments of these 171 structures in partnership with NNEPA. In each structure, U.S. EPA measured total gamma radiation and gamma radiation dose rate. NNEPA measured total radon in select rooms in structures where there were current residents. Outside of each structure on the residential property yard, U.S. EPA measured total gamma radiation using a GPA integrated radiation ratemeter. The equipment logged the GPS location for each reading, collecting thousands of mapped data points per residential property.
Inside each structure and in every room, U.S. EPA conducted gross gamma scanning surveys of structure floors and walls with a ratemeter and a Ludlum Model 44-20 (a 3” by 3” unshielded sodium iodide scintillator). In those same locations U.S. EPA conducted an area gross gamma dose rate measurement with a Reuter-Stokes RSS-131 Pressurized Ionization Chamber (PIC). Finally, radon measurements were collected using Rad Elec model radon detection equipment. Results from all instruments at all locations were tabulated for use in removal decision-making in consultation with NNEPA
Daily background PIC and ratemeter measurements were also included in these tables. These background measurements were collected at a field calibration site visually determined to be uncontaminated by the assessment team. The average background measurements were used to determine daily instrument investigation levels (ILs)(Average background plus 3 times the standard deviation). Areas exceeding ILs for any of the instruments were flagged and photographed by the assessment tram during each residential property and structure investigation.
Based on the assessment results, U.S. EPA determined that twelve structures in the Haystack and Church Rock Chapters area required a removal action. These structures are identified as EPA Structure ID Nos: BH-02-A, BH-05-A, BH-07-A, BH-07-B, BH-19-D, BH-26-A, BH-34-A, BH-38-C, BH-42-A, BH-42-B, and CR-81-A. At nine of these structures, the indoor does levels collected with the PIC exceeded the dose action level. At the remaining three structures, the indoor dose does not exceed the action level; however, high levels of gamma radiation measured by other instruments as well as elevated interior radon levels indicate the need for removal of all or part of the structure. All twelve structures are located within the Navajo Nation.
U.S. EPA also determined that eight yards in the Haystack and Church Rock Chapter areas require a removal action. The eight yards are identified as EPA Site ID Nos: BH-16, BH-26, BH-29, BH-35, BH-40, BH-42 and CR-92. Each of these residential properties has areas containing areas of elevated Uranium contamination soils which is above the action level of two times background.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
The EPA Emergency Response Section is conducting a CERCLA removal action to mitigate the imminent and substantial threats to human health, welfare, or the environment by taking steps to prevent the release of radium-226, uranium, and the external gamma radiation. The removal action will include the following objectives to prevent direct human contact with external alpha and gamma radiation as well as uranium and its progeny radium-226 and the radon from building materials and in residential soils at up to 9 properties. Remove portions of or the entirety of 9 contaminated structures. Remove contaminated soil or material from eight residential properties. Transport and dispose excavated material at an appropriate facility. Replace excavated soils with clean fill and restore property to pre-removal conditions. Conduct confirmation scanning, sampling and analysis. Provide voluntary temporary lodging for families of affected residential properties.
2.1.2 Response Actions to Date - 7.08.2013 - 7.21.2013 - Operational Period
Property CR-81-A - Structure and Yard removal:
U.S EPA
Demolition operations:
- Foundation installation completed (EPA removal actions completed)
CHID
Construction operations:
- House framed in and roof installed
- Windows and doors installed, and exterior painted
- Electrical and plumbing completed
Property CH-92 - Yard removal:
U.S. EPA
Property BH-05-A - Structure removal:
- Foundation Pad completed
- Area for spetic tank and leach fields installed
Special note - It took 6 days to full excavate the lava rock formation in order to build the foundation pad as well as excavate the area for the septic tank and leach field.
Property BH-07-A - Structure removal
Property BH-07-D - Structure removal
Property BH-16 - Yard removal
U.S. EPA
- Soil removed - 25 ft2 / 1.85 cu yards (EPA removal actions completed)
Property BH-26 - Structure and yard removal
Property BH-29 - Yard removal
U.S. EPA
- Soil removed - 195 ft2 / 14.47 cu yards (EPA removal actions completed)
Property BH-34-A - Structure removal:
U.S. EPA
Demolition operations:
- Foundation installation completed (EPA removal actions completed)
CHID
Construction operations:
- House framed in and roof installed
Property BH-34-H
- Property in dispute, removal action unlikely
Property BH-35 - Yard removal
U.S. EPA
- Soil removed - 755 ft2 / 55.94 cu yards (EPA removal actions completed)
Property BH-36-A - Structure removal:
U.S. EPA
Demolition operations:
- Foundation installation completed (EPA removal actions completed)
CHID
Construction operations:
Property BH-38 - Yard removal
Property BH-40 - Yard removal
U.S. EPA
- Soil removed - 4,465 ft2 / 191.84 cu yards (EPA removal actions completed)
Property BH-41 - Yard removal
Property BH-42 - Structure and yard removal
U.S. ACE
Construction oversight:
Mr. James Moye and Mr. David Rodriguez will be providing construction inspections based on the following milestones:
- Foundation – This may be optional since the EPA contractor is constructing the footings and slab on grade. The inspection would evaluate excavation, reinforcing, footings, foundation walls (or slab), waterproofing, backfill and compaction, and underground plumbing & electrical (if applicable). Ideally, this USACE inspection would be performed on the foundation (prior to placing concrete) for verification of the dimensions, forms, reinforcement and any underground utilities (if applicable).
- Framing – Inspection would occur prior to insulation and sheetrock. This would include all rough framing, exterior wall and siding, exterior trim and siding, windows, and exterior doors. Ideally, USACE would also like to inspect the roof sheathing prior to roofing.
- Rough Plumbing, Mechanical & Electrical – Most municipal inspections would typically perform separate inspections on each of these. However, for this project, we can combine these as much as possible. Each on-site inspection would review construction of all three concurrently. This includes water supply and waste water lines, vent piping, the water heater, ductwork, venting and furnace installation, wiring, receptacles and electrical panel installation. We can coordinate with the contractor to verify required tests such as water line pressure and electrical conductivity and grounding requirements.
- Insulation & Drywall – This stage should not begin until the rough plumbing, electrical and mechanical stage inspections have passed. Ideally, USACE would like to perform a separate sheetrock nail or screw inspection prior to taping and texture. This phase of inspection includes wall insulation (not attic insulation), drywall installation, tape and texture. In some cases, the insulation contractor can provide a contractors "certification" of installation in lieu of an inspection.
- Final Inspection including Paint, Trim, Finishes and Appliances - This inspection is to verify the final completed home. This includes all finished flooring, cabinets, countertops, wall tile, mirrors, shower doors, final electrical (including fixtures), final plumbing (including fixtures), and final mechanical. At this final inspection, we would verify the functioning and performance of all the final electrical, plumbing, and mechanical systems. For final inspections, it is common for there to be a punch list of missing or incomplete items that need to be addressed. Another inspection will normally be required to verify that all punch list items have been satisfactorily completed. After passing the punch list inspection, municipalities would allow the home to be occupied.
The U.S. ACE have been on-site 7/11 and 7/18
T&D plan:
ERRS is developing a T&D plan for all generated waste, including NORM waste
*Special site note*
The U.S. Government Accountability Office (U.S. GAO) visited the site with representatives from NNEPA and U.S. EPA Region 9. A site tour was provided as well as a site summary explanation of all site activities. While visiting property BH-40, OSC Nattis explained the findings that the homes on the property exist within the boundary of the Haystack AUM site. EPA is requesting additional resources to investigate the area and to immediately address the situation.
For up to date information on the status of all removal and building activities, please visit the profile page of the OSC website www.epaosc.org/BACAHAYSTACK and scroll down to the 'Removal Status Progress Report'
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
N/A
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2.2 Planning Section
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2.2.1 Anticipated Activities
Demolition activities: BH-07-A and BH-07-D
Continued Construction of new structure at CR-81-A, BH-34-A (CHID)
Completion of foundation at BH-05-A (U.S. EPA, CHID)
Construction of new structure at BH-36-A ~ July 22nd (CHID)
Yard removal activities to start:
BH-38
BH-41
U.S. ACE to be on site during the week of 7/22 and 7/29
2.2.1.1 Planned Response Activities
EPA will demobilize the site on Aug 4th and remobilize on Aug 12th.
2.2.1.2 Next Steps
CHID to continue building CR-81-A, BH-34-A
CHID to start building BH-36-A.
U.S. ACE to continue construction inspections
2.2.2 Issues
Located backfill material (clay soils) suitable for compaction
Rocky Soils
Equipment breakdowns
Weather (wind, rain, extremely dry conditions, cold 30F, heat 100 F)
Altitude (~7000 feet)
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2.3 Logistics Section
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OSC Nattis, USACE, NNEPA, CHID, ERRS and START PMs are coordinating all logistical needs
OSC Waldon will mobilize on 7/23 and remain on site until 8/3
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
OSC Nattis is in charge of all site safety. The START contractor will support OSC Nattis and has implemented an extensive area air surveillance plan in place that involves the total particulate monitoring and sampling for dust contaminated with alpha radiation. A site map and HASP is available on the site website indentifying the exclusion zone and support zone as well as the decontamination areas. 15 minutes each morning is used to discuss radiation and worker safety.
Worker safety - All personnel will be scanned daily as they enter and leave the exclusion zone.
All equipment will be scanned as they enter and leave the exclusion zone.
2.5.2 Liaison Officer
OSC Nattis
OSC Nattis will continue to coordinate with locals, Residents, USACE, NNEPA, CHID and USEPA
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3. Participating Entities
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USEPA
NNEPA
USACE
CHID
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4. Personnel On Site
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1 EPA OSC (Nattis)
OSC Waldon with be on-site 7/23
1 NN EPA (Craig)
1 START (EnE)
7 ERRS (EQm)
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5. Definition of Terms
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CERCLA: Comprehensive Environmental Response Compensation and Liability Act of 1980
EPA: United States Environmental Protection Agency
USACE: U.S. Army Corps of Engineers
ERRS: Emergency and Rapid Removal Services contractor (EQM, Inc.)
μg/hr: Micrograms per hour
μR/hr: Microroentgen per hour
NNEPA: Navajo Nation Environmental Protection Agency
CHID: Community Housing & Infrastructure Department
OSC: On-Scene Coordinator
START: Superfund Technical Assessment and Response Team contractor (Ecology and Environment, Inc.)
TDD: Technical Direction Document
DO: Delivery Order
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6. Additional sources of information
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6.1 Internet location of additional information/report
http://staging.epar9.ene.com/navajooperationalviewer/
GIS Viewer - This will allow the user to keep track of site progress, view photos and see the areas of concerns.
6.2 Reporting Schedule
POLREPs will be reported on a weekly schedule while the Site is mobilized. The work week is to be considered Monday through Saturday, Six ten hour days, or up to 60 hours a week.
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7. Situational Reference Materials
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No information is available at this time.
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