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GIS-Based Modeling of Contaminated Soil Volumes at Multiple Sites in the Formerly Utilized Sites Remedial Action Program - 20149

The remediation of hazardous, toxic, and radioactive waste (HTRW) sites produces cost-related risks associated with the estimation of contaminated soil or debris volumes. Historical risk-management techniques include cost contingencies to cover volume uncertainties that affect project budgeting and decision-making. The Buffalo District teamed with project partners to lessen volume uncertainty and reduce project risks at multiple HTRW sites managed under the Formerly Utilized Sites Remedial Action Program (FUSRAP). Historical remedial investigations under FUSRAP commonly identified the presence of radiological material in site media, the associated human health risk, and then areas of remediation. To manage remedial execution and reduce risk, pre-design or remediation-phase sampling essentially 'chased' contamination, which was not conducive to efficient predictive budgeting derived from Feasibility Study (FS) cost analyses. The Buffalo District first optimized their approach to better understand volume uncertainty by utilizing the Argonne National Laboratory's Bayesian Approaches for Adaptive Spatial Sampling (BAASS) software [1]. BAASS processed soft data (e.g., gamma walk-over data) and spatial sampling data to estimate the lateral extent of contaminated soil irrespective of depth (i.e., gross contamination extent) and define areas of contaminant uncertainty. The software performed a binary transformation of contaminant concentrations at all sampling points based upon remedial action goals or a sum of ratios approach (i.e., clean, impacted, or range of impacts in soil). The model produced two-dimensional (horizontal) contaminant probability contours and statistical uncertainty in the sampling coverage and resulting contaminant extents. This method was translated vertically by partitioning the sampling data into depth brackets that produced a stacked representation of contaminant extents and uncertainty in the subsurface (i.e., similar to construction lifts). The results commonly led to a better understanding of project uncertainty and the need for sampling strategies that produce high-confidence soil volumes, which control costs. The BAASS-based delineations were eventually replaced by Empirical Bayesian Kriging (EBK) methods available in ArcGIS Spatial or 3D Analysts [2]. The EBK method calculates contaminant probability zones derived from user-controlled semivariograms of the spatial datasets. The resulting probability zones (e.g., 50% or 80% of contaminant probability) represent the two-dimensional surface delineation of the overall horizontal remedial area, similarly to BAASS. However, unlike BAASS, the vertical sampling data within these probability zones became vertical control points to contour a subterranean surface that connects subsurface points to the land-surface delineations of contamination. The resulting representation of horizontal and vertical impacts within an enclosed envelop (volume) of soil included uncertainty distributions that are used to plan uncertainty-reduction sampling. These data-driven and math-based models of three-dimensional sampling results produced well-bounded remedial volumes for project planning and better uncertainty predictions during project budgeting. The EBK method was applied to several FUSRAP sites managed by the Buffalo District and compared to less rigorously modeled sites previously remediated by the District. The comparison of modeled to actual remediated volumes provide a basis for validating the volume-estimation method. This comparison is important to ensure modeled volumes match physical boundaries of site remediation. FUSRAP sites with denser investigative sampling and lesser volume uncertainty proved useful in remedial planning and contracting. The Buffalo District noted that historical sites with sparser sampling arrays had greater disparity between estimated volumes and final remedial volumes. The benefit achieved over the cost of detailed soil sampling appears positive for FUSRAP projects, especially where impacts vary widely and appear unbounded by investigation-phase sampling. The subsequent Empirical Bayesian Kriging of contamination coupled with vertical contouring for soil estimations reduces uncertainty in soil volumes or indicates where sampling is required to reduce uncertainty, which together optimize remedial planning and budgeting. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Software for Transformative Remedial Action Scheme Tool (TRAST)

The transformative remedial action scheme tool (TRAST) can be applied to improve and validate the power system remedial action scheme (RAS), and further improve the performance of power system operation and control. This tool provides a full suite of advanced functionalities, which are given as follows: 1. Advanced statistical data analysis; 2. OPF-based automated power flow case generation; 3. Customized dynamic simulation in HPC/cloud platform; 4. Machine learning based RAS coefficient prediction; 5. A reliable RAS validation strategy in multiple commercial platforms.

Fan, Xiaoyuan↗

Part IV: Remedial Action

This part of the book focuses on the remedial action where the remedy is selected and approved with associated regulatory documentation, detailed designs are prepared, and construction and/or implementation of the remedy is completed. The application may include remediation of environmental media (e.g., subsurface sediments or surface water sources), waste processing, and/or deactivation and decommissioning of historical facilities. Once a preferred remedy is implemented, the final steps include long-term stewardship and site closure (discussed in Part V). Refer to Section 3.2 of Chapter 1, Remediation Strategy for Complex Waste Sites, for context on how these steps fit into the broader remediation process.

Johnson, Christian D.↗

Transformative remedial action scheme tool (TRAST)

Techniques and apparatuses are described that enable transformative Remedial Action Scheme (RAS) analyses and methodologies for a bulk electric power system, including methods of designing, reviewing, revising, testing, implementing, verifying, or validating a RAS. An improved RAS improves operation of the power system, including performance, reliability, control, and asset utilization. The example methodologies discussed—also referred to as a transformative Remedial Action Scheme tool (TRAST)—provide an end-to-end solution for adaptively setting RAS parameters based on realistic and near real-time operation conditions to improve power grid reliability and grid asset utilization, by leveraging utility data analysis and employing dynamic simulations and machine learning to significantly simplify and shorten the entire RAS process.

Fan, Xiaoyuan↗

Life-Cycle Baseline Customization for the Formerly Utilized Sites Remedial Action Program - 20304

One of the responsibilities of the federal government is to estimate sound and defensible life-cycle baseline costs for use in federal budget estimates and to meet federal financial reporting requirements. To accomplish this, the US Department of Energy (DOE) Office of Legacy Management (LM) and the US Army Corps of Engineers (USACE) have partnered together to ensure that the liabilities documented in each Formerly Utilized Sites Remedial Action Program (FUSRAP) site's life-cycle baseline are specifically tailored. FUSRAP was created in the mid-1970's to clean up radiological contamination resulting from the early development of nuclear weapons. DOE was responsible for FUSRAP until October 1997, when Congress transferred the administration and execution of FUSRAP site cleanups to USACE. By 1997, DOE had completed the cleanup of 25 of the 46 sites that were active within the program and had begun cleanup at 13 additional sites. USACE was assigned responsibility for the cleanup of the 21 remaining FUSRAP sites, and at 8 additional sites that had since been referred for cleanup. The LM mission for the FUSRAP sites is to perform long-term surveillance and maintenance (LTS and M). Currently, LM provides long-term stewardship for 34 completed FUSRAP sites. Another 20 sites are under active remediation by USACE. Within the last 5 years, USACE has completed the cleanup at five FUSRAP sites and the LTS and M responsibility has been transferred to LM. By 2029, USACE will compete remediation at eight additional sites and LTS and M for those sites will transfer to LM. Because responsibilities for the FUSRAP sites transfer between USACE and LM upon completion of remedial actions, both agencies maintain life-cycle baselines for different stages of the project and both must have a strong understanding of the needs and requirements for each site. This understanding ensures that the life-cycle baselines form a complete and accurate picture of what is required for the site and for the FUSRAP program. LM focuses on several things when customizing the life-cycle baseline estimates for the FUSRAP sites, including (1) Understanding the unique requirements for each site. By reviewing site-specific documents prepared by USACE, such as Feasibility Studies and Records of Decision, and partnering with USACE to gain additional insight about site conditions and requirements for stewardship, as well as potential risks, LM can better develop the life-cycle baselines. (2) Developing site-specific labor breakdowns. This ensures the required labor mix is baselined for specific activities by comparing the labor mix required to perform activities at (a) other LM-managed FUSRAP sites and (b) non-FUSRAP LM sites and (c) by USACE at active FUSRAP sites. (3) Taking a tiered approach to life-cycle baseline planning. Estimates for sites transferring to LM in the near term (5 years) are more definitive than for sites transferring in the out-year period. Remedial actions at the near-term sites are at or near completion, providing LM a strong understanding of the LTS and M requirements and remaining liabilities. This in turn allows for site-specific customization of the baseline. (4) Using a robust risk management approach to ensure that liabilities specific to each site are identified, evaluated by probability and severity, and documented in relation to the impact to cost or schedule. To ensure the most accuracy within all the baselines, the FUSRAP life-cycle baselines are updated as needed to support program, project, and contract management needs. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Deep Learning-Based Adaptive Remedial Action Scheme with Security Margin for Renewable-Dominated Power Grids

The Remedial Action Scheme (RAS) is designed to take corrective actions after detecting predetermined conditions to maintain system transient stability in large interconnected power grids. However, since RAS is usually designed based on a few selected typical operating conditions, it is not optimal in operating conditions that are not considered in the offline design, especially under frequently and dramatically varying operating conditions due to the increasing integration of intermittent renewables. The deep learning-based RAS is proposed to enhance the adaptivity of RAS to varying operating conditions. During the training, a customized loss function is developed to penalize the negative loss and suggest corrective actions with a security margin to avoid triggering under-frequency and over-frequency relays. Simulation results of the reduced United States Western Interconnection system model demonstrate that the proposed deep learning–based RAS can provide optimal corrective actions for unseen operating conditions while maintaining a sufficient security margin.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Opportunities to Implement Solutions to Achieve Remedial Action Objectives in Consideration of Stakeholder Interests - 20365

A case study in the implementation of a soils excavation and removal project conducted at a Formerly Utilized Sites Remedial Action Program (FUSRAP) Maywood Superfund Site (FMSS) vicinity property; an active commercial business, in a densely populated area, with significant operational, technical and, logistical constraints that were expected to limit areas that could be remediated. The United States Army Corps of Engineers-led (USACE) team successfully navigated complex overlapping stakeholder interests to achieve a more efficient and complete removal of contaminated soils and debris while minimizing unnecessary excess costs to the Government. This paper centers on FUSRAP activities at the FMSS vicinity property located at 149-151 Maywood Avenue, Maywood, Bergen County, New Jersey. For most of its FUSRAP history, this ∼109,000 square meter (27-acre) property housed a now-demolished ∼26,000 square meter (6.5-acre) warehouse operated by Sears Logistics Services, a unit of the Sears Roebuck Company (Figure 2). Sears ended its property lease and vacated the warehouse in December 2016. Given that long history and for the purposes of this paper, the property will be referred to as the 'Sears property' or simply 'the property.' The Sears property is approximately 109,000 square meters (27-acres) and is currently zoned for commercial use. The property is bound to the north and northwest by 100 West Hunter Avenue (the Stepan Company), to the northeast by 205 Maywood Avenue, to the east by Maywood Avenue, to the south by 23 West Howcroft Road, and to the west by businesses on NJ Route 17 and the NJ Route 17 roadway. Until December 2016, the property housed a warehouse and distribution center operated by Sears Logistical Services. On-site structures were demolished by the property owner in 2017. The warehouse covered the north section of the property along the Stepan Company property line. A railroad spur from the adjacent property now known as the Maywood Interim Storage Site (MISS) ended at the northeast corner of the warehouse. Wetlands were located east of the warehouse; the rest of the property was covered with paved parking lots and grassed areas. During remediation at the property, opportunities frequently arose where the project team was able to coordinate effectively with stakeholders to sequence remediation activities to facilitate removal of otherwise inaccessible soils and identify opportunities for materials reuse when supported by residual radiological and chemical levels. Some specific opportunities include: - remediating individual truck loading dock bays to maintain tenant operations; - working along a busy highway and in a utility corridor containing a 30-inch high pressure gas main; - remediating Lodi Brook and associated wetlands requiring bypass pumping and other diversionary structures to maintain local community stormwater drainage; - protecting during remediation and supporting access to facilitate tenant/owner maintenance of critical fire protection and water supply system service lines buried in contaminated soils and necessary for safe warehouse operations; and - coordinating with stakeholders to ensure non-radiological contaminants of concern for the site (unaffiliated with FUSRAP) were addressed by the responsible party in a manner that maximized benefit to all parties while supporting an efficient overall site remediation program. Once the property was vacant and the warehouse structure and radiologically non-impacted above-grade structures were demolished, the project identified an opportunity to significantly reduce the volume of waste associated with the foundation of the former warehouse, a foundation suspected of being partially constructed in radiologically contaminated soils. The project developed and implemented supplemental radiological verification survey and sampling strategies based on radiological cross-contamination risk potential with process flow-charts and screening-level based decision points; a program that classified saw-cut sections of concrete based on observed residual surface radioactivity conditions using a combination of gamma sensitive sodium-iodide scans and beta sensitive Geiger-Muller direct measurements. The proposed approach was reviewed with stakeholders with feedback, including consideration of applicable State of New Jersey Site Remediation Program criteria and guidance before implementation. Once classified, additional sampling was performed at frequencies driven by screening. The sampling methods, stockpile sampling frequencies, criteria and, approach to data evaluation were developed in consideration of existing site cleanup standards, regional background ranges, State of New Jersey radiological remediation program guidance, and specific stakeholder input With the property remediation and survey efforts nearly completed, it is relevant to examine retrospectively the objectives, assumptions and limitations in the remedial design (i.e., what was planned) versus what was able to be accomplished through effective teaming. Benefits to other environmental remediation site programs include better understanding of how to work effectively with stakeholders to achieve win-win outcomes, and approaches to site remediation, waste minimization and materials reuse that were successful in their overall outcomes. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

The current status of inelastic and capture Gamma-ray production evaluations in translated ENDF-VIII.0 GNDS files and recommended remediation actions

This report provides the status of discrete nuclear levels and inelastic gamma-ray production for neutron induced reactions in current ENDF-VIII.0 evaluations for the isotopes in the GRIN project. Different categories of issues are identified after a comparison with information from “adopted” ENSDF files. Improvement strategies are given and recommendations are described. We have included a similar, but more limited, analysis for thermal capture data where EGAF and ENSDF thermal libraries are considered. In addition, we provide a validation plan to employ different transport code simulations.

73 NUCLEAR PHYSICS AND RADIATION PHYSICS↗

Independent Review of Groundwater Remediation Strategy for Hexavalent Chromium and RDX Groundwater Plumes at Los Alamos National Laboratory (Rev. 1)

Site operations at the Los Alamos National Laboratory (LANL) resulted in the release of oxidized chromium, Cr(VI), into Sandia Canyon from cooling tower effluent from 1956 until 1972. The chromium traveled with the surface water approximately 3 miles downstream before migrating below ground surface. Chromium concentrations exceed 50 μg/L in the upper portion of the aquifer. Another LANL groundwater plume of concern is associated with RDX (Royal Demolition Explosives, 1,3,5-trinitro-1,3,5-triazine). Between 1951 and 1996, RDX was released to the mesa-top facilities' process water outfall, adjacent and underlying soils, and alluvial sediments, along with surface water in Cañon de Valle. Between 2000 and 2010, two remedial actions were deployed, removing much of the near-surface RDX, however, recharge due to precipitation has transported RDX into the perched-intermediate zone and into the regional aquifer. The report documents an independent technical review by scientists from the Department of Energy (DOE) Network of National Laboratories for Environmental Management and Stewardship (NNLEMS) to provide recommendations for potential near term actions to address and optimize remediation for both the Cr(VI) and RDX plumes. The proposed near-term remedial actions include design of pump and treat systems for Cr(VI) and monitoring and study for natural attenuation for RDX. The review assesses existing data, conceptual and numerical modeling, and it recommends a technical integration process to support identifying and implementing strategic, effective and efficient remedies. The DOE Environmental Management Los Alamos Field Office (EM-LA) and their cleanup contractor Newport News Nuclear-BWTX, LLC Los Alamos (N3B) provided the information required for the review. Interviews were also conducted with regulators to obtain the full spectrum of technical, regulatory and scientific perspectives. The independent review team was impressed by the capabilities, experiences, innovativeness, and insightfulness of the technical representatives from both the regulator, the New Mexico Environment Department (NMED) and N3B. Incorporation of vadose zone flow pathways in the conceptual site model (CSM) and configuring the numerical modeling for the site was generally state-of-the-practice (or better). This could be considered state-of-the-art by addressing uncertainties related to spatial extent of hydraulic windows. The reviews from the regulators were thorough and often provided useful concepts for consideration and future/study resolutions. The overarching consensus recommendation of independent review team is that the LANL groundwater plumes should be addressed in context of the emerging "management of complex sites" paradigm.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

An Overview of In-Stu Treatability Studies at Marshall Space Flight Center, Huntsville, Alabama

Marshall Space Flight Center (MSFC) is located in Huntsville, Alabama (north-central Alabama), on approximately 1,840 acres near the center of the U.S. Army's Redstone Arsenal (RSA). MSFC is the National Aeronautics and Space Administration's (NASA's) principal propulsion development center. Its scientists, engineers, and support personnel play a major role in the National Space Transportation System by managing space shuttle mission activities, including the microgravity laboratory. In addition, MSFC will be a significant contributor to several of NASA's future programs, including the Reusable Launch Vehicle (X-33), International Space Station, and Advanced X-ray Astrophysics Facility, as well as research on a variety of space science applications. MSFC has been used to develop, test and manufacture space vehicles and components since 1960, when civilian rocketry and missile activities were transferred from RSA to MSFC. In 1994, MSFC was placed on the National Priority List for the management of hazardous waste sites, under the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). One requirement of the CERCLA program is to evaluate the nature and extent of environmental contamination resulting from identified CERCLA sites, assess the public health and environmental risks associated with the identified contamination, and identify potential remedial actions. A CERCLA remedial investigation (RI) for the groundwater system has identified at least five major plumes of chlorinated volatile organic compounds (CVOCs) in the groundwater beneath the facility. These plumes are believed to be the result of former management practices at 14 main facility locations (termed "source areas") where CVOCs were released to the subsurface. Trichloroethene (TCE) is the predominant CVOC and is common to all the plumes. Perchloroethene (PCE) also exists in two of the plumes. In addition to TCE and PCE, carbon tetrachloride and 1,1,2,2-tetrachloroethane are contained in one of the plumes. The CVOCs are believed to exist as dense non-aqueous phase liquids (DNAPLs) beneath many of the source areas.

McElroy, Bill↗

Satellite Conjunction Assessment Risk Analysis for "Dilution Region" Events: Issues and Operational Approaches

An important activity within Space Traffic Management is the detection and prevention of possible on-orbit collisions between space objects. The principal parameter for assessing collision likelihood is the probability of collision, which is widely accepted among conjunction assessment practitioners; but it possesses a known deficiency in that it can produce a false sense of safety when the orbital position uncertainties for the conjuncting objects are high. The probability of collision is said to be “diluted” in such a situation and to understate the possible risk; certain approaches have been recommended by researchers to provide (largely conservative) risk estimates and remediation methodologies in these cases. The present analysis explores two of the main proposals for quantifying and remediating possible risk in the dilution region and quantifies their operational implications. These implications with regard to imputed additional workload are considerable, especially in anticipating the conjunction event levels expected with the deployment of the USAF Space Fence radar. This effort has been undertaken as part of a larger enterprise that seeks to clarify the philosophical and statistical underpinnings of the conjunction risk assessment process. The analysis presented herein argues that a form of hypothesis testing is implicitly used in conjunction assessment risk analysis, and that there are a number of conceptual and practical reasons for constructing the associated null hypothesis to counsel against a satellite conjunction remediation action. In short, it is concluded that, for the purposes of determining whether a conjunction remediation action should be pursued, dilution-region probabilities of collision should be treated no differently from those produced under other circumstances.

Probability of collision↗

DeepGrid: Robust Deep Reinforcement Learning-based Contingency Management

Increasing uncertainty raised by the integration of renewable energy resources requires an enormous number of simulations to be carried out for the security assessment of the power grid. However, it is challenging to assess the steady-state and dynamic security indices for different system contingency events by doing an exhaustive analysis in real-time due to the computational and communication constraints. One promising solution is using data-driven techniques along with the system models to train an intelligent contingency management framework to better handle the contingencies in real-time. Nevertheless, implementing a data-driven technique to obtain the best remedial actions necessitates to account for the effect of the measurement noise on the performance of the contingency management. To tackle these challenges, we leverage a robust deep reinforcement learning (DRL) algorithm called Double Deep Q-Network (DDQN) to design a recommender system capable of prescribing optimal control actions with the help of the real-time digital simulator (RTDS). The use of RTDS system in combination with the advanced DRL algorithm allows to explore a wide variety of system contingencies in order to derive better remedial actions. The performance of the proposed algorithm is evaluated in IEEE 9-bus system under different loading conditions, and different network configurations in presence of noisy measurements.

Ghasemkhani, Amir↗

A comprehensive review on the loss of wellbore integrity due to cement failure and available remedial methods

With the recent abrupt fluctuations in oil pricing and the need of complying with environmental and social requirements, nowadays it is an urgent call for the oil and gas industry to produce the hydrocarbon without any loss as well as in a safe manner. Cements are placed in the annular space of casing to provide zonal isolation in between wellbore and surface during the operational life cycle of the well or even after the abandonment. But this is not what happens most of the time. Cement degrades or loses its integrity through debonding either from the casing or formation and generates cracks or fractures due to varied reasons throughout the life of the well. Multiple causes contribute to the loss of wellbore integrity – either by physical, mechanical, or chemical processes. These failures lead to sustained casing pressure (SCP) and contamination of surrounding environment. To combat this issue or to restore the well integrity, multiple remedial actions have also been either implemented in the industry or proposed based on experimental research to prevent the damage or to seal the leakage in the cement sheath. Here, this paper will provide an extensive review of the underlying reasons of cement failure and the available remedial actions to minimize the loss of well integrity issue. These information are not only useful to know about the different corrective options available for us to implement in industry but also it will provide us a knowledge base regarding how we can enhance the performance of the exiting systems to battle the cement integrity problem more efficiently.

02 PETROLEUM↗

Remedial effectiveness of a pond biomanipulation: Habitat value and concentrations of polychlorinated biphenyls in fish

The fish and plant communities in a pond contaminated with polychlorinated biphenyls (PCBs) in East Tennessee, USA, were manipulated to reduce ecological and human-health risk associated with exposure to the chemical contaminants. We evaluated the success of the remedial action using a habitat valuation approach, as well as measuring PCB concentrations in fish. Risk reduction objectives included: alter the fish community to favor fish that do not resuspend, bioaccumulate, or biomagnify PCBs; stabilize contaminated sediments to improve water quality; and stabilize shoreline soils and enhance riparian habitat. Fish targeted for removal included gizzard shad, largemouth bass, and nonnative carp. Reduced PCB concentrations in fish have characterized the new bluegill-dominated community, although a weir-overtopping event led to the need for additional removals of gizzard shad and largemouth bass. Sunfish abundance is high, as was intended. Moreover, amphibian and waterbird diversities have increased in the years following biomanipulation, possibly owing to improvements in the riparian zone and increased structural (vegetation) complexity in both the aquatic and terrestrial environment. Thus, the remedial action has improved aspects of habitat value, and PCB concentrations in sunfish have dropped below the remediation level (risk-based target value) for this pond (1 µg/g in fish fillets or 2.3 µg/g in whole body fish).

63 RADIATION, THERMAL, AND OTHER ENVIRON. POLLUTAN↗

3-D Radiological Data Acquisition, Visualization and Modeling - 20211

The U.S. Army Corps of Engineers (USACE) was tasked to investigate and remediate low activity radiological contamination from research and production of the nation's first nuclear weapons at the former DuPont Chambers Works Formerly Utilized Sites Remedial Action Program (FUSRAP) site (DuPont). The DuPont site had several buildings used for the Manhattan project that were demolished in the 1940's and 1950's apparently using heavy earthmoving equipment. Some of the contaminated rubble from the demolition appears to have been spread out by this equipment resulting in somewhat random scattering of radiologically contaminated soil and debris along with aqueous spills. Traditional investigative methods such as soil borings, test pits and 2-dimensional gamma walkovers were only partially successful in delineating the radiological contamination at the site. It was feared that even 'chasing' the contamination during remediation would miss contamination if the demolition resulted in discontinuous trails of radiologically contaminated soils. In evaluating the data generated over the interceding decades, the USACE determined that a better method to collect and process the remedial action radiological data was needed to enable the project team to optimize predictive planning and meet documentation expectations. The purpose of this paper is to provide an overview of the effort and progress to combine and organize radiological survey methods into a highly flexible sampling, modeling, and decision analysis approach that emphasizes the quality of decision-making during remediation. This innovative system blends multiple tools to develop a methodology that can extend MARRSIM [1] into the subsurface and provide tools that can be applied to other sites. (authors)

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗