2 4H (TR 61')l IDAI'A I6.IM OI.5S5. 16.01.01 5S6 IDAI'A In.Ul.U.S.OOS (4(1 CI-R 264.55.1) IDAI'A 16.01.05.00X (40 (TR 264.554) ('lii'inicul-specifh- None idcmilicil l.t>catioii-.\pecific Nniic uk-nnlicd Sue (icnt-ral inspcciiiHi requirements I'tTMinnel .securily Idaho (iiijiiivc dust enmsion.s Si»rm water di.scliarge.s during construction NliSIIAI'S lor Radionuclides from DOE (•aciliiies. linnssion Monitoring and l-mission Compliance Rules for Control of Air Pollution in Idaho IDAI'A 16.01.05 oaX|40C-H<264.3IO,l,,(5,| Rnn-on and run-off control, Temporary units Remediation waste staging piles Applicable, or Relevant and Appropriate (R&A), CM-'I IK* , Comments Applicable Applicable Applicable Applicable Applicable Applicable Applicable Applicable Applicable Applicable Applies only K RCRA umt.s are created as pan of interim action. Applies only ,1'RCRA uniis are created as part ol interim action. Applies only .f RCRA units are created as part ol interim action. Applies during con.siruehon of remedies and observation wells; will be met through engineering controls Applies during construction ofremed.es- u ill be met though engineering control*. Applies during construci.on of remedies- uill be met (hough engineering controls. Applies during construction of remedies- \s ill be met though engineering controls. Run-on to and run-off from KfRA ha/ardous soils, if present. »,|| he controlled during the interim action period. Applies, 10 the soil stockpiles derived from grading and sealing the Tank (•arm or from construction of the diversion channels Applies to the soil stockpiles derived from grading and sealing the Tank l-'ami or from construction of the diversion channels
-------
Table 12-1. (continued).
            AJtcMialiu- AKAK.s citation
 TKC\

 I>OIOnta -4.15.I


 l><>!  Oidci 5-101)5
                 De.scription
Radioactive waste management perlbnnance
ohjcttives to protect workers.

lixpnsures In public will be ALARA
    Applicable, or
    Relevant and
 Appropriate (R&A),
      or TBC
TBC
                                                                                    C'onuiients
                      SubMunlivc design and construction
                      requirements will be met to protect workers.
                      Substantive design and construction
                      requirements will be met to keep public
                      exposures AI.ARA

-------
        Storm Water Discharges during Construction Rules re
   discharges into waters of the United States. These rules will
   controls on construction activities.
 12.2.1.2  Chemical-Specific.  No chemical-specific ARARs were identified for this alternative.

 12.2.1.3  Location-Specific. No location-specific ARARs were identified for this alternative







12.2.2   Soils Under Buildings and Structures Selected Remedy: Alternative 2-
        Institutional Controls with Containment                «"«ma«ve *
     nuer Buuu.nes or stmcn.r-  Ah '"* *"* l°cation-sPcclflc A«ARs for the selected remedv for the
     ^^crCvSbd:;,Alternativc 2-is *ummariMd in Tawe i2-2- A di—«««

                 :.  Site security, inspections, and personnel training will be required durin- the
                period 
-------
 Table 124  «S*i.«
             Alieriiaiixe AKAKs ciliiiMiii
  """" ^ "
                                              - —   		Description
                                                       Applicable, or
                                                       Relevant and
                                                    Appropriate (R&A).
                                                   	orTBC

                                                                                 	  t omments
  IDAI'A  l60|.05.ooX|40CM<26-l.l4(a).(b),(c)|


  IDAI'A  1601  050UX  MOCR< 26-l.l5|a),(c)|


  IDAI'A l60I.OSOOX|40CH<264.l6(a)(l),(c)


  IDAI'A 16 01.0|.650,  16 01.01.(,51



 IDAI'A 16111.01.5X5. 16.01 0|.5X(,
 •4111
           <).\
IDAI'A k..(l|.()5.()(IS(-)OC-| R 264.55.1)


IDAI'A lo.OI.()5.0(JX<40(TR 264.554)


IDAI'A 16 01 .(l.S.OOK (40 tTR 26-1 «J7)
  Sue security


  (ienerul inspection requirements

  I'ersonnel training


 " Idaho fugitive dust emissions



  Rules Ibr Control ,,f Air Pollution in Idaho
 NliSIIAPS Ibr Radionuclides from DOK
 l-acihties, l-imission Monitoring and Kmission
 i ompliance
 Storm water discharges during construction

 Temporary units


 Remediation waste staging piles


(ieneral groundwater monitoring requirements


Surveying and recordkeeping
  Applicable


  Applicable


  Applicable


  Applicable



  Applicable


 Applicable





 Applicable


 Applicable


 Applicable


 Applicable


R&A
   Applies ifihe soils are capped in place with
   an engineered barrier

   Applies jfihe soils are capped in place with
   an engineered barrier

   Applies ifibe stills are capped in place uith
   an engineered barrier

   Applies during construction; will be met
  during barrier's 1000-year eshmated design
  life.         •

  Will be met during construction by
  administrative and engineering contiols

  Airborne releases will be mimmi/ed by
  overlying building and/or structure, by-
  administrative and engineering controls
  during construction, and subsequently by Hie
  barrier.

  Will be met during construction through
 administrative and engineering controls

 Applies Ibr soils or liquids (i.e.. purge water)
 that are excavated and managed on-siie

 Applies Ibr soils that are excavated and
 managed  on-site

 Substantive requirements will be met to
 detect future releases from the Group ' sites
 which are left  in place.

 Applies if the soils are capped with an
engineered barrier; substantive' requirements
will be met.

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Table 12-2.  (continued)
            AllciiumeAUARs citatum              _            _ jjescrmjKin

 ll)\l'\ If. (II (IS IHIS |4IH l-K2o4.1|()(a)l-5|        I mullill elosuic requirements
 IDAI'A Id ill l)5ii(i,S|4ll('H<
l.iiniJIill post-closure requirements
 IDAI'A Id 01.1)5 (Hid (4i> C| |< 2l,2 11)
ll.i/ardous waste determination
l.iii'iitiiiii-'i/iivijic

None iilcill 1 1'ieil
                                                    Applicable, ur
                                                     Relevant and
                                                  Appropriate (K& A).
                                                       or'llK'   __
                                                 Applicable
                                                                                                   Applicable
                                                                                                   Applicable
                                .2(1 through 24)    Ha/ardous waste characteristics identification   '    Applicable
                                                                        Applies if the MII|> :ire capped wnb .m
                                                                        engineered burner: siib.sianiixe requirenienis
                                                                        will be met

                                                                        Applies if the soils are capped with an
                                                                        engineered harrier; substantive requirements
                                                                        will he met.  40 n-R 264.'>7 will he used 1.1
                                                                        meet the requirements of 40CI-R
                                                                       Applies to soils that are excavated ami that
                                                                       may require prelreatment to meet ICDI-
                                                                       waste acceptance criteria; applies to soils
                                                                       where a ha/ardous waste determination bus
                                                                       not been made.

                                                                       Applies for ha/ardous \\aslc contaminated
                                                                       soils thai are excavated and disposed oil-site
I )( )l ( )rdei 4.
-------
                                                       DOE

                               ^
              in the Temporary Units may be subject to LDRs                        '  °'S "















 f 2.2.2.2   Location-Specific. No location-specific ARARs were identified for this alternative
                                         monitored i
                                                            4A-Remova. and On-Site
Ot(Kr SceToTAIte^r"* aT'™'"' andlocatio«-sP^'^ ARARs tor the selected remedv for
.utner Jsurtace Soils, Alternative 4A. is summarized in Table 12-3.  A discussion of the ARAR, 'mH



                                 ^ *"
                              Sites
                        measures, and health and .afetv plans implemented or planned fo
                                           I2-I5

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IJ
Table 12-3. Compliance \vilh ARARsfor Group 3   Other Surface Soils Selected Remedy.

                                                                                       Applicable, or Relevant and
                                               	     . J2i-5rii']!i!!i	Appropriate (R&AJ. prjjtc
                   M.    .    . i, M,
                  AltenuhveAKAKsautmn
           Group .1  Oihvr Surface Soils: AUcriuiliu1 -lA-.Reii{o»;il and OIIMU- Disposal
 ID.M'A  Idtil III dMi. |() III III 65)


 IDAI'A  Id.ilLOl 5SS

 ID.M'A  Idlll III SNd

 4(1 Cl l<  dl '12

 4(1 Cl U  <>l 'H

 4UC| |<  122 2(.
Idaho fugitive dust emissions                  Applicable


Rules for the control of air pollution in Idaho    Applicable


NI-SIIAI's for Kadiomiclidcs from !)()!:         Applicable
l-acilities, l-inission Monitoring and (-mission
Compliance

Slorm water discharges during construction      Applicable


I la/ardous waste deiemiinalion                applicable
          IDAI'A Hi (H.li.S.dOS (40 CI.K2d4.55.il       leinporary mills


          IDAI'A Id.(il.o5.ons (4(1 ('!•!< 2M.554)       Remediation waste staging piles
          IDAI'A  l()dl 05.011 (40CM<2dSC
          IDAI'A ld.0l.l)5.0ll (40CI-K2dS.4y)
          ('liemii-al-specific

          IDAI'A l()OK)5.(l()5(4(ICI;R2dl.2lt
          ilmwgh 24)
              l K 7dl 50(a|(5)
                                          I and disposal rcsinciions
                                          Alternative l.DR treatment siandards for
                                          contaminated soils
                                            Applicable


                                            Applicable



                                            Applicable



                                            Applicable
                                          1 la/ardous waste characteristics identification   Applicable
                                         I'CH disposal requirement*!

                                         I'CH ivmciliaiion waste
                                                                                               Applicable

                                                                                               Applicable
                                                                                                                                              ('oininenis
                                                                                                                             Will be met during construction through
                                                                                                                             adiniinstraii\e and engineering contrnls.

                                                                                                                             Will be met using administrative and enginecnim
                                                                                                                             controls


                                                                                                                             Will be mel using administrative and eiigmccimi>
                                                                                                                             controls
 Will he mel during e.\cu\aiion and disposal
 through engineering controls.

 Applies if (he soils disposed outside of the WA( i
 3 AOC; applies to soils where a lia/ardous waste
 deteninnalion has not been made

 Applies to temporary (-  I year) storage or '
 treatmenl units

 I'.xcavated st>ils can be temporarily staged prior
 to disposal in the ICDI- without trigi-enim I DR->
 orMTRs

 Applies only to soils from sites CI'I'-'P C|'|»-97
 fPIMW. and CIM'-'W in Mills thai hax c"        '
 placement

 Applies only to soils from sites CIT-92 CI'l'-';7
t'PP-98. and CI'P-99 or soils that have triggered
placement.
                                                                        Applies if the soils are excavated and
                                                                        consolidated to facilitate (heir management and
                                                                        for soils that are treated or placed in a long-term
                                                                        storage unit

                                                                        Applies to I'CB-comammaled soils and debus.

                                                                        Applies to I'CH-comaminaied soils and dehris

-------
 ^?bi
 able 12-3: (cominueJ).


       ..AJkTnaU\eA||.- ,„
                                                                                                                 project workers.

                                                                                                                 W.II he n,e, by administrative and engineering
                                                                                                                 umtmls dunng excavation ofcon.a.nina.ed s.^
                                                                                                                  nd construction, operat.on. and closure of,| e
 IDAI'A I(..OI OI.5Sf>

 -)IICI-K(»I >)1

 •40 ( 'I Kdl.'M

 •»«C1-|<  122.26
                                       Kules for the control ofair pollut.on in Idaho    ApPlicah,e
                                       NliSllAI'srorRadiomicl.desirom
                                                                                                                    W"ll be met during construct.,),, imuBh
                                                                                                                    admm.strative and eng.neermg controls
                                                                                                                    bone, us.ngad.nin.stratne and eng.neer.ng
                                                                                                                     c me, us-ngadnunisu^ive and engineering
H'AI'A 16.01.05.008 [40CI-R
2W 15(a),(c)|

IDAI'A  16.01.05.008 (40 CI-K
 Stomt w


 Nile .security


(ieneral inspection requirements

IVrsonnel training
                                                                                  Applicable


                                                                                  Applicable


                                                                                  Applicable
                                                                       Will be me, during excavutu,,, and disposal
                                                                       ihrough engineering controls.

                                                                       Applies to either soils capped,,, place or
                                                                       uiasolidated in the IC'IJF.

                                                                      Applies l« cither M,ils capped, n place or
                                                                      consolidated in the R 'Dr.

                                                                      Applies toei.her soils capped,,, place or
                                                                      consolidated in ihelCDK

-------
Table 12-3.  (continued}.

         A llci n.iliv c AR AR>_i iliJtiiHi"    _
  IDAI'A Ift ill H5IH1S (40 CJ-K 2M 92)
  IDAI'A l(i.tll OS IXIK (411CI-R 2M 93)
  IDAI'A Id (II OS (ins (-10 (•|-I(2H-4,«J5)
  IDAI'A Id  III 05 I HIS (40 CI-R 2M.97)
  IDAI'A U.  Ill U5mS(4()ri-R2G4.9K)
  IDAI'A Id  III (15 (MIX (-1(1 CI-R 264.114)

  IDAI'A Idlll 05.00K|40n-R264JOI)

  IDAI'A Id 01 05 OOS |4() CI-K 2(i4..1()|)(a>
 and | h)
  IDAI'A Idlll O.YOOK
 |40( ll<2d4.UO|a)|l)(2)|l)(4>(5)|
 IDAI'A  Id 01 05.00S
 |40( IK 2d4..\lO(h)(|)|4)(5)(d)|
 IDAI'A  ldOI.05.00X|40C|-R2||
 IDAI'A ld1.7«>(a)and(h)

IDAI'A lh.OI.()5.oi)X(40CI;R2(i4.1*)2)

IDAI'A ld.in.05.OOK (4(1 C'l-R 264.d()l |

IDAI'A  Id.OI 05.00K«4()C|-R2(i4.
Suhparl I)
IDAI'A  Id 01.05 OOS (40 C'lR _'d4,
Siihp.ul  1)1))
                 Description^
  Applicable, or Relevant and
  Appropriate (R&A). or TIK'
  (irtiuiuluaicr ptolcction Mandard
  I ta/urdoiis consiiiticnis
  I'Mtltl lll'c»fll|lllilllVtf
  (icncral groiindvvalcr nioiiilonng rcquirernunis
  Detecnoii inoniloring program
  Di.spii.sal and dcconiaininaOon ofcqinpniunl.
  .slmcuirc.s, and .soils
  I.andHII do-sign and operating requirements

  Surveying and rceordkceping

  l.andllll cloMire rcqtiircincni.s

 I andfill poM-closure rci)inri;iiicnls

 Landlill locaiion standards

 l.iiiull'ill action leakage rate
  I emporary units

 Remediation  waste .staging piles

 I't'H landfill design requirements

 I't'H container and moveable equipment
 deeonlainmation reqiiiremenis
 Design and inslallation of new tank systems or
 components
 Miscellaneous units environmental
 performance standards
 Use and management of containers

i'omainnicn! buildings
  Applicable
  Applicable
  Applicable
  Applicable
  Applicable
  Applicable

  Applicable

  Applicable

 Applicable

 Applicable

 Applicable

 Applicable
 Applicable

 Applicable

 Applicable

 Applicable

 Applicable

 Applicable

Applicable

Applicable
    _   	   ('onimeiiN
  Substarmve pans of regulations uill he met
  Siibsiantive part.s of regulations will be met
  SubMaiitivc pans of regulations will he mel
  SubMantivc pans of regulations will be mel
  Substantive pans of regulations will be met
  All equipment will he decontaminated before
  leaving the K'DK
  IU)F will be designed to meet minimum
  technology requirements or equivalent
  Substantive requirements will he mel

 Substantive requirements will be met

 Substantive requirements will be met

 Substantive requirements will he met

 Substantive requirements \M|| he met
 Applies for soils or liquids that are managed on-
 site
 Applies for soils that are excavated and managed
 on-site
 Applicable for 1'CH-conlaniinaled soils;
 Substantive requirements will he met
 Applicable for PC'U-contaminated soils;
 Substantive requirements will he met
 Applies to the SSST.

 Applies to the SSST.

Applies to the SSST.

Applies to the SSST.

-------
Table 12-3. (continued).
         Alternative ARARs citation

 IDAI'A Idol 115 (HIS (40 CI-R 2(>4 1052
 Illlullgll HH.2)

 IDAI'A l(> 1)1  Cl |< 2()4,
 Suhpaii I  )

 IDAI'A 16 K|.i)5. (IDS (4(1 CM< 2n4.
 Sulip.iil < j)
 IDAI'A Ifi.()l.()5.il(l5 (40CI-R 261.20
 Ihiiiuj-h 24)
2S I'SC.llKH
I ><>!• Order 4.15.1
DOI.Onlcr 5400.5
                Description
 Air emissions standards liir equipment leaks


 Air emission standards lor tanks, surface
 impoundments, and containers

 Surface impoundment design and operating
 requirements

 Corrective action management units (CAMUs)

 lla/ardous waste accumulation time


 Releases from solid waste management units


Closure and post-closure
 Applicable, or Relevant and
 Appropriate (R&A), or TBC
 Applicable
                                                                                           Comments
Applicable


Applicable


Applicable

Applicable


Applicable


Applicable
lla/ardous waste characteristics identification    Applicable
                                          National Artlieological and Historical
                                          Preservation Act
                                          Native American Graves Protection and
                                          Repatriation Act
                                          Radioactive waste management performance
                                          objectives to protect workers
                                            Applicable



                                            Applicable




                                            TBC
                                          Exposures to the public will be kept ALARA     TBC
 Applies to the SSST.


 Applies to the SSST and evaporation pond.


 Applies to the SSS I and evaporation pond.


 Applies to the evaporation pond.
 Applies to the SSST.
Applies lo closure and post-closure of ICDI-
Complex.

Applies to closure and posl-closute of l( 'Dl-
Complex.
                                                                         Applies to soils received from outside the W .\( i
                                                                         3 AW
                             Will be met during siting new
                             excavations/construction in previously
                             undisturbed areas
                             Will be met during suing new
                             excavations/construction in previously
                             undisturbed areas
                                                                        Substantive requirements will be met in
                                                                        designing, constructing, and operating the ICDI-
                                                                        to protect workers

                                                                        Will be met by administrative and engineering
                                                                        controls during excavation of contaminated soils,
                                                                        and construction and operation of the ICI)I;; and
                                                                        by the capping system after closure.

-------
 Table 12-3.  (coniinucd).
         Allenutne AUAKs citation
                                              Applicable, or Relevant and
                                              Appropriate (R&A). or T»r
  Group .V -Other Surface.Soils: Alteryuju; 4A-ICDF OiUTationsfgr Non-INTE C Sails and Dehri^
  IDAI'A K. III (IS l)| | H"flK2oS)
 IDAI'A If. Ill IIS (i| | (4(inK2fiX.4»)
 IDAI'A IdOl l).S.(ll).S<40ri-|< 261)

 IDAI'A K)li| nSnoiiHOCHt 2(>2 II)
 4ll ( IK 7(.| 5l)|:i
 4(1 C| K "(.I S
 40U-K 7(,| S
 4IICI |< 7(.l .S
 4IICI-K 7(.l .S
 i.i>rutiiin-<,pefijh
 None
 IK(\
 Dill . Onk-i 4.VS I
I M)l-().iier 5400.5
 I .ami disjhisal restrictions
                                                                                        Applicable
 Aliemalivc Kind di-.pi.sal rcMnclioas Irealmcni   Applicahk-
 standards I'm oimaiiimaicd .soil
 Identillcaiioii and listing ofha/ardous waste     Applicable
 lla/urdous waste ilclcriniinilion

 I'CM disposal re<.|iiireinenis
 I'CH renicdiaiion waste
 I'CIJ radioai'iixe waste
I'orous surliices
Disposal rct|iiiretnenis for I'CH.s
 Applicable


 Applicable
 Applicable
 Applicable
 Applicable
Applicable
                                           Radioactixe waste management perfonnance     'I BC
                                           objectives to protect workers
                                          l-.xpostires to the public will be kept ALARA    TBC
     l be met lor oil \VAd .1 wastes by irealmi:
 reiiiediaiion wastes lioin outside the \VA(i ,\"
 A<)(' to be disposed of in the ICW as required
 Will he mel by ireatinj; reiiiediaiion wastes from
 outside Hie WAti .1 AOC1 disposed of in the
 R '1)1' as required.

 Siibstann\e rcquirenienis will be met  for soils
 received from outside the OU .\. I .\ A( K'.
 Will be met lor off WA( i .\ maienals prior to
 excavation by eliaraeten/.ing wastes-from outsulc
 the WA( i 3 AOC'
 Applies to I'CH-comammaled soils and debus.
 Applies to I'CH-i-oniaiiiinated soils and debus
Applies to I'CH-conlaminated soils and debus.
Applies to IVH-conUiminalcd soils and debris.
Applies to l'( •H-coiilammaled soils and debris.
                                                                         Suhsiantixe requirements will be met for
                                                                         excavation, handling, and transport of off-ADC
                                                                         radionuclide contaminated soils to the K 'Dl- u>
                                                                         protect workers
                                                                         Will be met by administrative and engineering
                                                                         controls during excavation of contaminated soils
                                                                         and construction and operation of the IC'DI-- and
                                                                                            i after closure.

-------
                                                                       *•*« ** «*-
                                                                                         -
  Compliance with NESHAPs will rcouire a,r mS',r       g   ,  COM™"°''. operations and closure.




  upon the results of the modeling                 Regulatory nonfkation levels will be partially based
                                   ce« to                H







 States would be met bv administrative^! , COntaminatlon|that discharges into waters of the United

 during remedial design. admimStratlVe and ^'^nng controls on construction activities, to be defined
Contaminated Soil (IDAPA 1 6 01 05 01   4&FR ^1^ .^^DR Treatment Standards for
ICDF because WAG 3 is conside red ^one s n^AO^ I   ^ ^ ^ WI" be P'aced direct]y in ^




                                        for disp°sal ai the K«      ^
                                                    -        indudes
16.01.05,008 rSub                        °'~>1X'cew'*.th"llteIa"««
           (40 CFR 264 553 and 40 CFR  M «j  T               uirements o    APA



-------
        An area v\ ithm the INTEC fence will be designated as the remediation waste storaue. treatment area
  lor OL 3-13 remediation wastes. This area will be utilized under the substantive requirements ofJDAP \
  16.01,(b.008 (40 CFR 264.553), Temporary Units, and IDAPA 16.01.05.008 (40 CFR 264 554)
  remediation uaste staging piles. These regulations apply specifically to remediation wastes. Varies
  treated or temporarily stored in TUs or in remediation waste staging piles are not subject to LDRs as Ion-
  as they are managed within the area of contamination.                                             r

        Specific sections of RCRA Standards for Owners and Operators of Hazardous Waste TSDFs applv
  ui the  ICDF (Table 12-3).  Substantive portions of general facility standards (IDAPA  16 01 05 008
  |40 CI-R 264 Subpart BJ) including IDAPA 16.01.05.008 [40 CFR 264.14 (Sue Security)] w.H applv and
  v\ui be met during the institutional control period by maintaining all  required controls on entry includin-
  lences and signs.                                                                   '         "

       Specific sections of IDAPA  16.01.05.008 [40 CFR 264 Subpart F (Releases From Solid  Waste
  Management Units)] cited m Table  12-3 apply to the ICDF. including uroundwater protection standard,
  hazardous constituents, point of compliance, general groundwater monitoring requirements and detection
  momtonng program. These will be met by developing and implementinu a  facility monitoring plan
  >pccihc lor the ICDF during remedial design.                        "       '          fa F

       Specific sections oflDAPA 16.01.05.008 [40 CFR 264 Subpart N < Landfills)] and IDAPA
  16.01.05.005 [40 CFR 261.75 (b)] cited m Table 12-3 apply to the design, construction, operation, closure
 ^M-,,^,    SUrC °'thC ICDR Not a" of these sectlons xvil] aPP'-v If the 1CDF ^ used exclusively for a
 C tKCLA  ons.te action, in particular those containing exclusively administrative requirements  moludm»
 record keeping.  All substantive requirements stated in the referenced sections will be met and the
 methodology tor compliance will be described in detail during remedial design for the ICDF.

      The equipment decontamination section of IDAPA 16.01.05.008 [40 CFR 264 Subpart G (Closure
 ?/ m^tS??nlaPpIieS l° Cl°SUre and P°st-closure'Of 'he 'CDF.  Additionally, Sections IDAPA
 16.01.05.008 [40 CFR 264.3I0(a)( 1)(2)(3)(4)(5) and 40 CFR 264.310(b)(l )(4)(5)(6) from Subpart N|
 apply to tmal closure ot  the landfill.  The specific performance standards cited will be met and the
 methodology lor compliance will be described in detail durinu remedial design for the ICDF  The
 IDAPA 16.01 05.008 [40 CFR 264.309(a) and (b)J requirements for survey™ and record kecpm- also
 apply, All  substantive requirements stated m the referenced sections will be  met, and the methodolo-n
 lor compliance will be described in detail during remedial design for the ICDF.

 12.2.3.2   Chemical-Specific. RCRA  hazardous u astc characteristics identification is required to
 MCIhtate handling and management  of hazardous waste contaminated soils.  PCBs waste regulations will
 *ippl> to all PCB-contammated soils received from both within and outside of the WAG 3 AOC  The
 ^uhMantivc requirements of the PCBs regulations will be met during soil excavation and disposal  The
 K DI- w.H be  designed and constructed to satisfy the PCB landfill requirements. Equipment used to
 handle PC B-contammated soils will  be decontaminated to satisfy the substantive PCB equipment
decontamination requirements.  .

 12.2.3.3   Location-Specific. Location-specific ARAKs for this alternative relate pnmarily u> ncv,
e\ca\ation. construction, or operations activities, including tho^e required for the ICDF in previous
undiMurhcd areas. All of these ARARs u ill be met through the suing  process for new facilities. The
Hil-KJjnme requirements of the RCRA location standards  | IDAPA 16.01.05.008 (40 CFR ">64 I8(a) and
•hii| will he met. Archeology I and Native American cultural rcM.urces will be protected by perfomv —
.Hi acuities in accordance uith the National Archeological and  Historical Preservation  Act "and the    '""
Native American (.raves Protection and Repatriation Act. No endaniiered species are known to he
piv-ent a: the propn^d ICDF Study Area.

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         The smng exaluation study discussed ,„ Secnon 11 evaluated the proposed Studv Area for the

    V(,.i?^
       i i\ u i. -fi; v, i R. _^ . _j» |p aouiUon to other criteria  Tlic K DF- nr tn i'»1 *
I-oca .on-spec.lic requ.rements for discharges d.verted from the Percoiat.on Ponds will be met'bv the
: dee ^i discharge .al.emanve Regulator- compl.ancc u.ll be descnbed in the percoiat.on pond
«-.ji-cme::t
                .
«-p.ji-cme::t permit .ippncation>.

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         Table 12.4.  <
i j
i j
                                                                                                            ___

                                                                                                   Applicable. or Relevant and
          IDM'A 11,01 "Minx (-1(1 r|.'R 264.14)
         I \cculivc Older I I'
 Kiveisiind Ihiihuis Act


 IDM'A 37(1.1.0')

 IDM'A Id.iU IIS|IIISH(K'I-K2(>4.II4)


 IDAI'A Ktui.ul (,Sii.  K.oj.ni (,5|


H'AI'A  I (Ul I  (II.5,S5.  Idol (i| S«(,
        IDAI'A .17.(M.(I7.(U(I
                                                           Silc
                                                                                        Applicable
                                                  Subs.an.ive requ.remen.s of 4n.yif,heH,g ,,,, R,cr channel ,s
 Appl.es lo perched wate
 Appl.ie.sio drilling, sampling, or treat,,,,-,,.
 cciuipmcnl that coiiiacis perched W8,icr

 Will be met throuj-h administrative and
 engineering controls during con.sirucimn

 Will he met through admmi.strutive and
 engineering controls during coiiMmcimn

 Will be met •through admim.strative and
 engineering amirols dunng construct,,,,,


Applicable only if the Big Lost River.s
determined lo be a continuously flowinu
water body; relevant and appropnaie ,f The
Hig Lost River is determined to be an
intermittent river

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I J
l'j
Table 12-4. (coniiiuied).
            Alternative 'A RAJ
-------
       o     ,?               S 435' ' and 54°°-5 provide *uidance on radiological human health and
   hel    r  Potion recrements. on cleanup and management of residual radioactive material  and
  the release of property.  Rad.at.on exposures to the public, workers, and the environment will be kept
  adm1n^r-rqU1H    '"      ^^ ^ Perrormance °^^ » ''» ^ met through monitoring  and
  adrrumxranve and engmeenng controls to minimize exposures to contaminated perched water.

  12.2.5   Snake River Plain Aquifer Interim Action Selected Remedy: Alternative 2B-
           lnst.tut,onal  Controls with Monitoring and Contingent Remediation
  Snake MS^^''^^'' *"* Iocation-sPecific ARARs for the selected remedy for the
  sr^'jr.s TB^                • AItemative 2- is summarized in Tabie • 2-5  * d™ *
  12.2.5.1   Action Specific.  IDAPA Rules for Control of Air Pollution in Idaho apply to releases or
  em.ss.ons ot tox.c and/or carcinogenic constituents to the atmosphere, which mav occur during so '
  excavation, movement and consolidation, or during groundwater treatment system operation
  Engineering and administrative controls would be used to maintain emissions from soils below allowable
  levels. Any groundwater treatment system would be designed and operated to meet emissions Imlus

       State of Idaho Fugitive Dust Emission rules would apply to any activities generating fugitive dust
 These rules require that all reasonable precautions be taken to prevent the generafion of fugidve dust from
 unprotected surfaces, as well as during active operations.                             g


               E,m'tSi0nS Standard_S f°r Hazardous Air Po"«ams for radionuclide emissions from DOE
                    ,? 'I?*™** **""* radionuclides may be suspended with fugitive dust duTing soil
    uFp  CO,nS°hdatl0n-  Jhe radiatio" d0^ to the public will be estimated and included in the
 annual INEEL calculations and reports. If radionuclides associated with fugitive dust releases exceed
                 , Di%ha.l»e.D.u™8 Cons<™tion ™™ requ.ring control of contamination that
              waters of the Ln.ted States would be met by administrative and engineering controls on
construction activities, to be defined during remedial design.                engineering controls on

      If contingent groundwater remediation is implemented, the treated uroundwater will either be

                                    iV6r WJth d°VVnStream rCCharge °>the SRPA or P'a-d '" a
        will annlv de   rt             e *«er discharge requirements and wastewater land appiication
                '11  "  °"                                                         ill be


CFR v/nm,         Standards for Miscellaneous Units (IDAPA  16.01. 05.00X [40
CFR  6
                          ,                                                 ..   .
                      y apply to any system used to treat extracted SRPA water if continent
r^n!atl°n 'f 'mplemenf '  Standards wi» be niet by designing, constructing, operating and closing the
system .so as to prevent releases to so,!, groundwater. surface vsater or air that would result in adverse^
effects on human health and the environment.  The remedial design report will identify specific measures
to control releases. The treatment svstem uill also need to address all COCs which are present in the
                                            12-26

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I J
I
IJ

             Alternate cAKARs olalion
  IDAI'A I7(i.t.iwo25
  IDAI'A 16.111 (I500X<40CI-R264.II4)

  IDAI'A KM 1 1 01.5X5,  Id OI.ol.5H6
  IDAI'A K.lll.lll (,SO.  KMH.oi.65l
 411 (  IK 6 1. V2, 6 !.<).»

 4ii (1 R 125

 UK 1K20. .. \ppendi\H. | al>|L- 2
 40 CI K  122.26
 IDAI'A 16 0105.00X1 40 (I'R 264.601)

 IDAI'A I6.0I.07JOO

 IDAI'A 16.01.02.400

 IDAI'A 16.01.02.401
IDAI'A 16.0 1. 05006 (40 (TK 262.11)
   Applicable, or
   Relevant and
Appropriate (R£A),
      01 TBC
                                                                                                   	
                                                                                                (rn    em Rem —--
                                                                                                       	-•
                                                                                                                                      _Conmienis
                                                           Idaho Well Construction Standards
                                                           Disposal or decontamination of equipment,
                                                           structures, and soils
                                                           Rules for the Control of Air Pollution in Idaho
                                                           Idaho l-'ugiiive Dust l-missions
                                                           NI-SIIAI's for Radlonuclides from DOt f-acililies,
                                                           I'-mission Monitoring and Emission Compliance
                                                           NI'DI-.S
 Applicable
 Applicable

Applicable
Applicable
Applicable
                                                          Annual limits for liflluem Concentrations           Apphcable
                                                          Storm Water Discharges During Construction       Applicable
                                                          Treatment Standards for Miscellaneous Units        Applicable

                                                          Wastewater land application permit requ.rements     applicable

                                                          Rules governing point source discharge             Applicable

                                                          Point source waste-water treatment requirements      Applicable
                                                Hazardous waste determination
                                                                                                Applicable
                     Applies to SRI'A monitoring.
                     Applies to drilling, sampling, and treatment
                     equipment that contacts SRPA groundwater.
                     Will be met by treatment system.
                     Will be met for contaminated dull cuttings
                     Will be met using engineering and
                     administrative controls.
                     Applies if contingent remediation is
                     implemented and treated groundwater is
                     discharged to the Big | ,Ost River
                     Applies il'treated water is discharged.
                    Substantive requirements will he mei.
                    Specific requirements will be clarified and
                    met in 10% design.
                    Applies if treated waste water is discharged
                    to a percolation pond; substantive
                    requirements will be met.
                    Applies to treated waste water is discharged
                    to the Big Lost  River.
                    Applies if treated wastewater is discharged to
                    Ihe Big Lost River.
                                                                                                                      Applicable to groundwater that will be stored
                                                                                                                      long term or treated

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Table 12-5. (continued).
           Altcin.nive ARAKscitation

IDAI'A K. ol II 2iHiu)H.
                                                                                                                      Ibis AKAR will he met in the reMoraiion
                                                                                                                     limelrame (2095) m the SRI'A contaniinaiu
                                                                                                                     plume outside dl the current INTI:(' !,eciiril>
                                                                                                                     fence. Any recharge lo the .SRI'A will he
                                                                                                                     limited lo concentrations M> that this ARAR
                                                                                                                     will be met in 20V.S
                                                                    Substantive lequirements will he IIIL-I lo
                                                                    proiecl workers.

                                                                    Substantive AI.AKA requirements will he
                                                                    MUM jo£i_oiect the public.

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                                                           with ih
  12.2.5.2
  Ifini ii inn/ \       .-',-,  ""'  The Sroundwater quality standards promulgated under IDAPA
  .6.0... ,.200,a> are ann,,,^ . ^ specific contaminants cited in Table ,2-58 Computer modeling
                             lants will meet the prmmHu.-at*>r ^ini^,, o»««j—1_ u. -.^^^
            <:OC\action le^'e|(s) 3^ exceeded in selected monitoring wells as described in

concenatons  innf                  Contains l'^ hazardous waste at detectable






f 2.2.5.3   Locatfon-spec/ffc. No locauon-spedflc ARARs are identified for the selected alternative








     The DOE Order 5400.5 requirement that the treatment technology be selected based on in

                                        ^
       D,Uspodsa?S °ylinderS Sel6Cted R6medy:  Altemative ^-Removal, Treatment and

                   °         n

                                         12-29

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  Table 12-6.  ( Chance uiihARAfe for Gnjup 6
                        AKAKs en. ..... n
                           -------   -
          K, in ii| (,sn.
  IIUI'X l(,li| o|  sx.s.
                             | 5x6
  IDAI'X Kill) IIS(H|X(4()C|.|<


  •JIICI |< tun 440
                  I  t4(»CI-K2h,S)
IMAI'A U.OI.o.S.oi | (401'1-R 20S.4'))
IDAI'A  16.0 1. OS .OOK (4(ICM< 2
IDAI'A U..O|.()5.oo(S(40C|-K 264.554)

                                                                 .,
                                                        „       IjescripUiin
                                                                              ~
                                             Applicable. orRcle\ ;mt and
                                               Appropriate (R&A I. or
                                             	UK'
                                                  Rules lor comrol of a.r pulluiion in Idaho     Applicable


                                                  S.orn, walcr discharges d,,n.,B cons.rueuon    Appheuhle
                                                 ,l;1/ardol)s tt:l

 l-and disposal


 Alicniaiive LDR treatment standards for
 contaminated soil

Temporary units


Remediation waste staging piles
                                                icable


                                           Applicable
 Applicable





 Applicable


 Applicable


Applicable


Applicable
   Will I* met during excavat.on and disposal
   "sing dust suppresMon

   Will he met dining treatment of tank
   contents

   Will be me. through engmeemig controls
   'luring e.u-a\atmn and construction

   Applies to eumpmeni used to treat o, h.mdle
  lia/ardous materials in the cylmdcis

  Applies only a. ollsite disposal of the
  cylinder contents

  Applies fiirlia/ardous ^aslccomammalcd
  Mills that are excavated and managed on-si.e

  Applicable to empty containers and
  compressed gas cylinders

 .Substantive requirements will be met for
 treatment, storage, disposal and
 iransporta.mn of RCRA ha/ardoas cylmder
 contents or hazardous waste contammatcd


 Applies only to the treatment and disposal of
 Hazardous waste contaminated soils

 Applies only to the treatment and disposal of
 ha/ardous waste contaminated soils

 Applies to the Morage and treatment of
 na/ardous remediation media

Applies to the stagmg of |,a/a,dous
remediation soils/debris

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Table 12-6. (continued).




            Alleiii-ilixe AKAKs iMUilion

 IDAI'A If, ill iiS(Mix(4((C|.|<2(,4Subpari Xi


 IDM'A K.nl iiSiitiX(4»C|-R2(v4.SubpuilJ)


 IDAI'A l<>S(i()X(40CI-K2(>4SubpaimB)


 IDAI'A K.DI ()XOIIX(40CH<2()4 lOXOthioiiuh
 Hl.XJ)

 IDAI'A K. ill O.yllltNHOCI |< 264..MI))

 ('lu-mical-\perifli-

 IDAI'A K. Ill'IISoo.S (40 U K 2f)l)
                                                                                            Applicable, or Relevant am)
                                                                                               Appropnale(R&A), or
                                                                                                       TIU1
                                                  Miscellaneous units                         Applicable


                                                  Tank N>'slcm-s                              Applicable


                                                  Air emission standards for equipment leaks    Applicable


                                                  Air emission standards for tanks, surface       Applicable
                                                  impoundments, and containers
                                                 l.andlllls
                                                 Ideniilk-aiion oflla/ardous Waste
                                                                                           Applicable
                                                                                           Applicable
 Applies to hazardous wastes that are stored.
 treated or disposed.

 Applies to ha/ardous wastes thai are slored,
 treated or disposed.

 Applies 10 ha/ardous wastes that are stored,
 treated or disposed.

 Applies to ha/ardous wastes that are stored,
treated or disposed.

Applies only if cylinders are capped in place.
                                                                                                                       Applies of soils containing ha/ardous waste
                                                                                                                       area encountered
None nlciililiod
nt< \

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  \\£ Dl -choral  n,^r    dah° FUg"Ve °USt EmiSSi°n "W'a'ions. and regulations for Storm
  \\ ater Du.charge, Durmg Construction apply and substantive prov isions will be met as described
  prevously. Substantive Portions of Rules for Control of Air Pollution in Idaho will be met by
  charactenzmg the tank contents, and designing and using treatment systems that will not result in releases
  to the atmosphere exceeding allowable levels.                                              reieai.es
               H         •     bU,n'ed gaS CyHnderS are not thou^ht to be hazardous, if hazardous
          , are d.scovered m the cylmders these will be removed from the cylinder and treated to meet
  hazardous waste treatment requ.rements. However, a hazardous waste residue remaining in an emn'v
                             ^
 cylinders ,s at atmosphenc pressure, and therefore termed empty. Hazardous waste residuesTe^ntv aas
 cylmders are not cons.dered hazardous waste and can be disposed accordingly.                 P * g
 rnn,,nuf                    Tesiduals Ksuh'^ fro™ treatment of the compressed gas cvlinder
 be ann£nh.neC?!fa'y KW     ^^"^  The use and management of hazardous waste containers will
 be applicable. The substantive requ.rements of these regulations will be met as specified.
 the LDRShwmda°nnivVVaThS f£ P1**"1.1"11 the comP^d gas cylinders have leaked to the underlying soils,
 iithha r      P5 •    r   ?   requirements tor hazardous waste contaminated soils will be met by
 either a Contamed ,n pohcv dec.sion or by treating the contaminated soils to meet LDRs.
      The Agencies may elect to pursue a contingent remedy of capping in place pursuant to the
     e0".Tthr:^
and removal of the cylmders prevent implementation of the selected remedy.
40 CFR^On LR0CI"A,PrOC!IdUrMSK0r P'Ting and ImP'ementinS Offtite Response Actions under
1^   h  K     PP y< u          met f°r °ff"Site Shipment and disposal of a"y S°W or hazardou
wastes by shipping any hazardous wastes or hazardous waste treatment residuals derived fromThe
                       itie c  emiitted fociiit
                     SpieC/ffc' If a hazardous waste is determined to have been released to the soils

        T I5,*   ^ l° ,hTdOU; WaStC Characte-li« Wentif.ca.ion in IDAPA 1 6.0 1 .05.00^40 CFR
         he H                                           ICDR S°ils that are determined to be
         be dehsted using a no-longer contained in determination and disposed in the ICDF.

12.2.6.3   Location Specific.  None identified.


      nt . . j^n Radioactive waste management procedures will be used to protect workers
      Order 43?. I ) and to keep exposures to the public ALARA (DOE Order 5400.5).

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  was JuLd?;^                     PrheV'°USly Cl°Sed and aba"d°-<> in ,976, and. therefore,

                           ^^^^
 in the SSST will be subject to LDR   L       '   , T        Y ,  SySt£m comPonents *« are treated
 Criteria will also be subject to LDRs'.   q           * afe ^^ to- meet the ICDF Waste Acceptance


 and disp^d^                                      \° b^ ^ardous and are removed, treated,
 under 40 CFR 300.440 apply Tht c ™ ^cffll TforT Tr 'mplementing Offsite R<*P°™ Actions

t2.2.7.3  Location-Specific. There are no location specific ARARs

                                          12-33

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 Table 12-7. J-omplinnce with ARARsJor Group 7 . SFii-20 Hoi Waste Tank System Selected Remedy.^
            Allt''	IVC •>L{:AJ<\^'-''!'.'!1.     „_	,  	Description	
           M-K-20 lint \\aslv_Taiik SjMvni:  Altcrnaihe 4—Kynuiiaj. Treatment, and On-S
  IDAI'A Id OKI I  650. I (i.O I.OI.051

  -KM  IKdl ')2. (.1 "1

  IDAI'A K, III 01 5x5. Id 01.II1.5X6

  IDAI'A Id III 0500X|40S.4'J)
 Idaho l-ugiiive Dtisi 1-missions

 NI-.SIIAI's for Radionuclidcs from IX)L"
 l-acilities
 Rules for the Control of Air Pollution in
 Idaho
 Secondary containment and detection of
 releases
 Temporary units

 Remediation waste staging piles

 Miscellaneous units

 Land disposal restrictions
Alternative LOR Treatment Standards for
Contaminated Soil
IDAI'A I (,.oi .05.005 (4(11 'IK 261.20 through 24)     I la/ardous waste characteristics
                                                identification

IDAI'Ald.OI.OS.OOd, 40CI.-R262.il)              I b/ardous waste de.em.ma.ion
40 (TK 61 Subpait M, (, 1. 145, 61.150; d 1. 15b        Asbestos regulations
                                                                                          Applicable, or Relevam and
                                                                                            Appropriate (R&A). or
                                                                                                   •JUC
  Applicable

  Applicable

  Applicable

 Applicable

 Applicable

 Applicable

 Relevam and Appropriate

 Applicable
 Applicable


 Applicable

Applicable
Applicable
                                                                                                                      	   (junnients
                                                                                                                    Will be met using engineering controls
                                                                                                                    during tank waste and system removal
                                                                                                                    Will be met using engineering controls
                                                                                                                    during tank waste and system removal
                                                                                                                    Will be met using engineering contioK
                                                                                                                    during tank waste .ind system removal
                                                                                                                    Applies il'ha/ardoiK wastes are pumped or
                                                                                                                    transferred to a treatment system.
                                                                                                                    Applies to any lank components or soiK that
                                                                                                                    aie excavated
                                                                                                                    Applies to any tank components or soils thai
                                                                                                                    are excavated
                                                                                                                    Applies to liquids or sludges lli.il aie
                                                                                                                   removed from the tank
                                                                                                                   If placement is triggered, l.DRs uill apply.
                                                                                                                   If placement is triggered, l.DRs vull apply.
                                                                                                                   Applies only to lia/urdous liquids or sludges
                                                                                                                   ni the lank or underlying soils thai may have
                                                                                                                   been impacted by a release
                                                                                                                   Substantive requirements will be met
None identified

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Table 12-7. (continual).
            Alternative AKAks citatio
 Applicable, or Relevant and
   Appropriate (R&A), or
	     TUC
 l«)l- Ordci s-iou s
                                                  Radioactive waste management              -| |j(-
                                                  perlormaiRc objectives lo protect workers
                                                 I'xpo.suros lo ihe public will be kepi
                                                 AI.AUA
TUC
                            Substuniivc rcijiiirenieiils will be mel by
                            administrative ;,,u| engineering controls
                            during excavation, removal, treatment and
                            disposal of the lank system and contents

                            Will be met In administrative and
                            engineering controls during excavation,
                            removal, treatment and disposal of the tank
               	5i'sle_rn jnul_ci.iiilems.

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                               12.3  Cost Effectiveness


  Ih^,f      I2"h8 summarizes the Comparison of costs of the Of 3-I3 remedial alternatives. In al! cases
  he altemat.ve that most cost-effectively protects human health and the environment, and meets ARARs

   ehc±^r "eSnTrr ""^ ** f °°' EaCh remed'a! aC"°n Sdected is Cos< effect, ve in tha'
  me cobts uere determined to be proport.onal to the overall effectiveness of the remedy  The Agencies

  ±£3 AR ARea TIT™"''31 ^^ ^^ PK>teCtS hU™ ^ ™d the -vironment a d
  eachle ^groupfng          COmPanSOn °' Cost-effect'^s bet^n alternatives is described below for


  12.3.1   Tank Farm Soils Interim Action (Group 1)


                3   is ' increase fror" Alternative 1 (Existing Institutional
Controls), w,,h the lowest overall cost, to Alternative 4B (Excavation, Ex Situ Treatment, and Off-Site
	 	 — - — • ••^"•••"-'•1 <->i <-u.-u:> ui uiiciiiuuves lOrWALij
Site,GrouDinu
Tank Farm Soils Interim
Action
Soils Under Buildings and
Structures
Other Surface Soils
Perched Water
Snake River Plain Aquifer
Interim Action
Buried Gas Cylinders
SFE-20 Tank
a MI*M..,re.,,.mihonMMi,,,'
Alternative 1
S3.4M

S6.4M
S6.8M
S7.3M
SI3.9M
S6.4M
S6.4M
Alternative 2
S10.0M

S9.2M
SI 5. DM
S20.0.M
S14.SM(2Ar
S1.8M
SS 7\I
Alternative 3
SI5.IM

S8.3M
S37.5M
S259.2M
S39.8M(2B)
SS.2M
SS.5M
Alternative 4 A


NA
S84.9.V1
NA
S7S7.9M<3)
NA
S4.6\!(4)



NA
S244.6M
NA
NA
NA
NA
      !> I.T :MC 'ficcicdal(cnuii\c aa-

-------
         D,sposal), w,th the h.ghest cost of the five alternatives evaluated. However as the cost of each
   alternate mcreases from Alternative 1 through Alternative 4B, so does the level of o^rotec^
   and long-term effectless. Alternative 1, while the least expensive, provides the lowest level of
   protect™ after the msntutional control period is over, and is least effective in the long-tent   Alternative
   4B prov.des the greatest level of protection and long-term effectiveness by removing fhe cTntamSed
   maten.1 from the sue, treatmg it, and permanently disposing of it off-Site  Additionally  the oS
   mob.l«y and volume of the contaminated soils will be reduced by this alternative. Simila rlv Al erna'tive
  4A (Excavat-on and On-S.te Disposal) provides a significant level of protection and effec veness bv

   ac it Sereth°nftaminated St' " T !°Cati0n and C°maining «-j" an e"g'neered and mon orei
  fac.hty. Neuher the tox.aty nor the volume of the contaminated soil is reduced by this alternative
  however. Companng Alternative 4A  to 4B for ail criteria but cost indicates that Altemat £ TA   'sliriitlv
  T, t ma 1 4VB cTmn  f ^temativer4B-  However' 
-------
     12.4  Utilization Of Permanent Solution And Alternative Treatment
                     Technology To The Maximum Extent Practicable

        The selected remedies in this ROD represent the maximum extent to which permanent solutions
  and alternative treatment technologies can be used in a practicable manner at OU 3-13  Of those
  alternatives that are protective of human health and the environment and comply with ARARs the
  selected remedy provides the best balance of trade-offs in terms of the five balancing criteria, while also
  considering the statutory preference for treatment as a principal element and considering State and
  community acceptance.

       The Tank Farm Soils Interim Action, Alternative 3, is not a permanent solution and does not use
  alternative treatment technologies. Because current information regarding the nature and extent of
  contamination at the Tank Farm is inadequate to support selection of a final remedy, a separate RI/FS for
  ™, ,?< S^ 'S underway- The Tank Farm is n°w referenced as a separate operable unit, OU 3-14  The
  OU 3-I4 RI/FS will further investigate contamination at the Tank Farm and develop alternatives for a
  hnal remedy. Use of a permanent solution or alternative treatment technologies will be considered in the
  development of alternatives in the Tank Farm RI/FS.

       The selected remedy for the Soils under Buildings and Structures, Alternative 2,  is a permanent
 solution but does not use alternative treatment technologies. Since the contaminated soils will remain
 isolated onsite for up to 1,000 years, the selected remedy will result in a permanent solution for the
 release sites. The sites will be covered with natural earthen materials to isolate the contaminated soils and
 prevent exposure to humans or the environment.  The barrier system will be designed to prevent future
 exposure for up to 1,000 years, which will allow natural radioactive decay to reduce contaminant
 concentrations over t,me to levels that are not a risk to human health or the environment. The barrier
 design will also minimize contaminant migration by inhibiting water infiltration. Long-term isolation
 will provide an effective permanent solution for these sites. Although treatment technologies exist for the
 nonradionuchde COCs, arsenic,  mercury-, and chromium, the primary COCs at these sites are
 radionuchdes. Effective treatment technologies for radionuclides are currently unavailable  The
 treatment technologies evaluated were determined not to be practicable because they were ineffective
 difficult to implement, or very costly.  Therefore, the use of alternative treatment technologies also cannot
 be met except through natural radioactive decay over time.

      The selected remedy for the Other Surface Soils. Alternative 4A. provides a permanent solution
 because the contaminated soils will be permanently removed and contained at the 1CDF  Contaminated
 soils present at the release sues will be excavated to a minimum depth of 10 feet below ground and
 disposed in an engineered facility designed for long-term isolation and protection. Although treatment
 technologies ex.st for the nonradionuclide COCs. mercury. lead, and chromium, present at some of these
 sites, the primary COCs at these sites are radionuclides. The treatment technologies evaluated were
 determined not to be practicable because they were ineffective, difficult to implement, or verv costlv
 Therefore, the use of alternative treatment technologies will not be met.                   '     '

      The selected remedy for the Perched Water. Alternative 2. provides a permanent solution but does
 not use alternative treatment technologies.  Alternative 2 is comprised of existing and additional
 institutional controls to restrict perched water use and implementation of initial phased remedies to
control water infiltration and perched water releases to the SRPA.  The proposed initial phased remedies
.ire permanent actions that control sources supplying water to the perched zone. These actions are
designed to reduce leaching and transport of >oil contaminant;, to perched water, to reduce the volume of
water in the perched /one. and to minimise the potential for penciled water releases to the SRPA The low
vield ol the perched /one limits implementation of active remediation. The inability to implement active
                                             I2-3S

-------
   remediation because of -perched zone characteristics eliminates the need for alternative treatment

   technologies5'          ' thiS remedy *''" "Ot meet the Statutory req"'>ement for alternative treatment


        The Snake River Plain Aquifer Interim Action, Alternative 2B, is not a permanent solution and
   does not use alternative treatment technologies unless active remediation is implemented  The SRPA

   ™TNTFer   ^ INTE? SeCUdty fenCC JS a fina' aCtion' SRPA S^ndwaicr actions inside the
   current INTEC secunty fence. ,f needed, will be addressed in OU 3-14.  Ifgroundwater remediation is
   implemented, treatab.lity studies will be implemented to evaluate and selecT appropriate treatment
   technologies. Alternative treatment technologies will be considered in the treatability studies  Active
   groundwater remed.ation would provide a permanent solution by removing groundwater from the zone of
  nSlTrS T°n- BeCa"STeI5"rrent '"formation regarding the nature and extent of contamination
  a set^R , F^h  ,  TIT [  EC SeCUmy fenCe IS  inadCqUate f° SUPP°rt selection of a final r^edy,
  fn !de he curTenMNTFr   ^     F™" %?*** *'" * imPlemented' F<"^ evaluation of the SRPA
  ms.de the current INTEC secunty fence will be deferred to OU 3-14. The OU 3-14 RI/FS will further
  investigate contamination in the SRPA inside the current INTEC security fence and develop alternatives
  tor a final remedy.  Use of a permanent solution or alternative treatment technologies will be further
  considered in the development of alternatives in the OU 3-14 RI/FS.
  ™H „ Jhf Se,'eCted T^ f°r th£ BUn"ed °aS C>"inders- Alternative 2, provides a permanent solution
  and uses treatment technologies, where necessary, as the principal remedy.  Alternative 2 consists of the

  recvH     fl ^""T"! "T11 °f *' ^ Cy'''nderS' treatment °f the tank COntents' ^ necessary, and
  recycling of the gas cylinders. Excavation will be conducted to minimize the potential for any gas
  releases to the env.ronment. The gases in the cylinders will be vented to the atmosphere if they are

        °                                "                                    meth°ds wi" be
       The selected remedy for the SFE-20 Hot Waste Tank System, Alternative 4, provides a permanent
 solufon and uses treatment technologies, where necessary, as the principal remedy  Alternative \ TwT
 permanently remove the tank and associated structures for disposal on-Site. The tank liquid will be
 removed and treated at the PEW Evaporator.  The tank sludge will be removed and treated ex-s.u using a
 "ther d^oosed^lf ' ^^ ^ T^"3"'5 in 
-------


         ,                          to r   ce voiume
 ,ong.term

12.6  Five-Year Review

         12-40

-------
               13.  DOCUMENTATION OF SIGNIFICANT CHANGES
    T
   mad, ,„ ,he ROD fta, are different than presemed in ,he Proposed Plan. Al.hougMhe            "
                            are induded in ** xa™ ^ ROD <
                                    13.1   New Sites
        Four new sites have been identified in this ROD using the FFA/CO new site inclusion process
                     * beI°W' " We" " thC °U 3-13 rdeaSe She      each ™ *» ^en placed in for
  13.1.1   CPP-96— Tank Farm Interstitial Soils
       Release site CPP-96 is a new Group I site that consolidates all of the previously defined Tank
       tM r6 ^^ 3nd thC JrerV'ening Tank Fami imerStitial Soils 
-------
•ed
   Site C PP-37a. a former seepage pit receiving runoff from the Tank Farm will be add-c^v
   ""?" GTP 3' °ther Surfactf Soils-  A P^sumptive remedy of excavate and d.spo^c ai the
   1C Dl- will be implemented. 1 his sue was discussed m the Proposed Plan as part of  "sues u
   oe transferred toother programs."

  Site CPP-37b (former construction landfill inside the fence) will be addressed as a Group 1
  soils site. This site was discussed m the Proposed Plan as pan of "sites to be transferred to"
  other programs."

  Site CPP-66 Fly Ash Pit was discussed in the Proposed Plan as part of "sites to he
  transferred to other programs."  Tins sue has been moved to OU 10-04 for further exaluiti.ir
  of ecological risk.

  Sues CPP-61. -81. and -82 previously identified as "No Further Action" (CPP-61) and "No
  Action ' (CPP-81 and 82) sites in the Proposed Plan, have been determine to require
  additional information to make a decision. These site are transferred to OU 3-14 for further
  evaluation.


                       13.3   Other Changes

 The Agencies reviewed the site characterization data for Site CPP-41 and decided that the
 site should be split into two sites that will be designated CPP-4la and CPP-4lb The
 Agencies have decided in this ROD that Site CPP"-4la has insufficient data to make a "No
 Further Action" decision. Site CPP-4U will be included in this ROD as a Group •> site The
 Agencies have decided that the risks posed by Site CPP-41 b are less than 1 x 10'4 or an
 HI <1 and that this site requires "No Action".

 The Proposed Plan indicated that "No Action" or "No Further Action" be taken at 51 sues
 After further review of the "No Action" and "No Further Action" decisions the Agencies
 have decided in this ROD that 11 of these sues have insufficient data to support either "No
 Action or "No Further Action." These 1 1 sues will he managed as follows:

       Sites CPP-16. -24. and -30 will be included within the new Group  1 - Tank Farm
       Interstitial Soils consolidation site CPP-96.

      Sites CPP-41 a. -60. -68. and -86 will be included within Group 2 -  Soils  Under
       Buildings or Structures.

      Site CPP-85 has been closed in place a> part of the W(T closure. The \V( T un-
      closed under an approved 11\V\-IA closure plan. The WCF will be included wiih ihe
      Group 2 Soils Under  Buildings and Structures sues in the CERCLA 5-year re\ icus.

      Sites CPP-61. -SI. and -S2 will be transferred to OU 3-14 for further evaluation.

A.s pan of the Agencies review of the "No Action" and "No Further Action" site decision-,
the Agencies have decided that 34 of the release sues evaluated under OU  1-13 meet the
RAOs established under this ROD and require "No Action."  Ten sites were previously
designated as "No Aetio:," sues under the.H-'A TO. The Agencies have also decided [hat ^
ol the release sues have existing or potential contaminant sources but do not ha\c an

-------
     .h    o-' ."''" bC ""P1""5""-'11 M ™ """im action under OU 3-13  The decis.on
  lor the SRPA ou,s,de ,he current INTEC secunty fence is a final action under his ROD

  undVr'ou 3™ *' '°r 'he SRPA 'nS'de "" CUrrem INTEC
                               frora prev'ous 1NTEC s"e mv's"sa"ons »•"' 1>c "h-J »

  Site CPP-67 Percolation Ponds

       The Proposed Plan discussed the need to close the -existing percolation ponds to
       ehmmate recharge to the perched water zones (Group 4). "ihe Proposed^ did not
       .peaty the locanon ot the replacement percolation ponds.  The location of the
       ^placement percolation ponds is selected under this ROD and is shown on
       Hgure Mo.  A wastexvater land appl.cat.on permit xvil! be  subm.tted lor the
       replacement percolation ponds on or before 2001, and the existing ponds will s,on

       (w[ Apf :nane;t  y Decriber 3 K 20°3'  inhe nw ^^ ^LPP^LZirm«
       (\V LA  Kannot be m p ace to support th,s date, then the ponds will be replaced under

                      y> "     CERCLA ER r°                      and
 The Agenc.es have determined that lining the Big Lost River may be a necessary second sten
 to reduce recharge to the perched water. Therefore, relocation of the river "sTolnuer be m?

 StS^                 — - - — ±S^.
 aSs a "^Fun^Mn"',0,111 "'> was V*™"** '"cl^ed in the Proposed Han

      ^         '                                    '
       PP                                  RL'BRA-  Hott'ever- "ndcr the

             ''"'"'"
 F -   CO un,    r   ''"'"'"   n  ?A land d'SP°Sal Umt (LDU> d"'^ation.  Under the
        '      retainmy an LDU designation w,ll be remediated under CERCLA  As a
The WCF has been closed under an approved mvMA closure plan and a post-closure

                             ^
 v   addresite «                                  mngS an   tructur" SIt"
Ml address the substantive requirements of IDAPA 16.01.05.008 (40 CFR 264 310)
Additionally these requirements uill be incorporated into the post-ROD motoring plan for
                             °a  rCUim
          the
                                    Jecision criteria, the Agencies have

it ire-is i,, -ho u     UT M!m" lhC K'I)|; U> °C !hc CPP'67 Percolation Ponds and

            or. :nc -pec:lie K'DI; cell locations \\ill be determined through the

-------
 completion ofa comprehensive geotechmca! evaluation of the ent.re Studv Area w|,,,-h Jr-n'
 be reviewed and approved by the Agencies.                          ' '

 OU 3-13 RD.RA and OL< 3-14 monitoring well construet.on and samplme wastes .-cnen-.v
 prior to the construct,™ of the ICDF and SSST w,|| he temporanlv (not to exceed fen
 managed and treated u-,,h,n the WAG 3 AOC ,n remed,a,,on waste staring-piles and
 S rro'v"?-I" ac|e°?anctf WIth the substantive requirements oflDAPA 16.01.05 OOS
 anktre and  h     , t <"FR2M.S54). Treatment will be accomplished usm, mobile
 tankage and physical chemical treatment and will comply with the substantive requirements
 ol IDAPA  16.01 05.00S (40 CFR 264 Subparts J, BB, and CC). The final d spoTonT
 these wastes w,ll be m the ICDF.  The anticipated wastes include soil drill cutting
 monitoring well purge water, personnel protective equipment, and decontamination wastes.

 This ROD recognizes that the INTEC facility ,s an operatina facility. As such  periodic
 maintenance and upgrade activities will be conducted during the  implementation of the
 remedial  actions under this ROD.  Prior to conducting any sue disturbance activities the
 Agencies will be not.hed of the extent of any disturbance and provided a plan for acencv
S?^ H   !?   r'V^ fcessary coTective actions that will be performed to ensure that
the remedies identified ,n th.s ROD remain operat.onal and functional. A formal svstem for
not ncation and approval of disturbances to OU 3-13 sites w,II be developed during remed.al
                                \:-4

-------
                  14.  RESPONSIVENESS SUMMARY
^^^

     ^^^
            '       "   reV'eW °f "* Pr°°Se
                      o
place between Oc.ober 23 and December "IWgwhi'ch, H"H  reV'eW °f "* Pr°P°Sed Plan took

                                                                                1

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                                   15.  REFERENCES

 Anderson, S. R.. 1 99 1 . Stratigraphy of the Unsaturated Zone and Uppermost Part of the Snake River
      Plain Aquifer at the Idaho Chemical Processing Plant and Test Reactor Area. Idaho National
      Engineering Laboratory, Idaho. USGS Water-Resources Investigations Report
      9I-4010-IDO-22095.                                     "        P


 Bartholomay, R. C. efal..  1 997, Hydrologic Conditions and Distribution of Selected Radiochemical and
      Chemical Constituents in Water. SRPA. INEL. Idaho.  1992 through 1995. U S Geological Survey
      Water-Resources Investigations Report 97-4086, April.

 Bartlett, R. J. and J. M. Kimble, 1976, "A Behavior in Chromium in Soils:  II. Hexavalent Forms "
      Journal of Environmental Quality, 5( 1 ):383B386.

 Berenbrock and Kjelstrom, 1998, Preliminary Water-Surface Elevations and Boundary of the 100-Year
      Peak Flow in the Big Lost River at the Idaho National Engineering and Environmental Laboraton-
      Idaho. L. S. Geological Survey Water-Resources Investigations Report, 98-4065, 1 3 pp.

Berenbrock and Kjelstrom, 1998, Preliminary Water-Surface Elevations and Boundary of the 100-Year
      Peak
                                                                                     -
                in the Big Los, River at the Idaho National Engineering and Environmental Laboraton-
      Idaho, \j. b. Geological Survey Water-Resources Investigations Report, 98-4065, 13 pp.

 DOE, 1 987, Resource Conservation and Recovery Act. "Consent Order and Compliance Agreement"
      U.S. Department of Energy, U.S. Environmental Protection Agency, and U.S. Geological Survey
      August.                                                                               .


 DOE, 1 998, Idaho National Engineering and Environmental Laboratory, Comprehensive Facilitv Land
      Use Plan, U.S. Department of Energy.


 DOE, EPA. and IDHW, 1994a, Track 2 Decision Statement for Operable Unit 3-07 Track 2 Summary
      Report. No Further Action Determination for Sites CPP- 1 6.  CPP-20. CPP-24 CPP-">5  CPP-30
      and CPP-32E. Document Number 5809.

 DOE. EPA, and IDHW. 1 994b. Track 2 Decision Statement for OU 3-08. Track 2 Summarv Report Sites
      CPP-l5andCPP-29, Document Number 5810.                                '       '

 DOE- ID, 1991 , Federal Facility Agreement and Consent Order for the Idaho National Engineering
      Laboratory. U.S. Department of Energy Idaho Operations Office, U.S. Environmental Protection
      Agency Region 10, State of Idaho Department of Health and Welfare.

 DOE-ID. 1 994. Track 2 Sites: Guidance for Assessing Low Probability Hazards Sites at the Idaho
      \at,onal Engineering Laboraton: DOE ID-10389. Revision 6. January.

DOE-ID, 1 995a. Long-Term Land Use Future Scenarios for the Idaho National Engineering Laboraton-
      DOE ID- 1 0440. current revision.

DOE-ID. 1995b. lodinc-1 -29 Contamination: \ature. Extent, and  Treatment Technologies  Bechtel
      Hanlord. Inc.. Richland. WA. DOE RL-95-89. Revision 0. February. 76 pp.
                                            15-1

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                                                            <>U3-,3 a, t*f
                                      L'S- Department of En«*y Idaho Onions Office,



                           ~
      Office. U.S. Env.ronmen.al Protection Agency. Idaho Department of Health and Welfare October
         ::^^
             - C°mt"'ehe"sh's Fac""y <-""" "« H™. U.S. Depanmcm of Energy idaho Operations
 EPA. 1988. C«Ci.J Compliance ,„>;, O,;,CT. /.„,„ ,,fa,,,ra/ OSWER Direcdve 9234 ,.„,
 EPA-
EPA. 1995. EPA s Integrated Risk Information System (Internet address
     imp: \vww.epa.govvngispgm3/iris. index.html.
  A' FR Vo'u>     UCS  navanarS, P"" HaZard°US WaStt C°mbuslion Facilities" F
    ri\  01 o_. - o. L .b. En\ ironmenta! Protection Agency. May 2. 1 997. p242 12
Colder A^cwies 1 990. Kfpan ,;,. ,hc ,liallo a,cmtc(l/ p,,^,  „  D
    ^o^^r^r^         arej IOT Ec&° idah°- '«--^

-------
   INEL  199 1, Qosm> Plan for Land Disposal Unit CPP-48. Excess Chemical French Drain  Idaho
        Nanonal Engmeenng LaboratOIy, Department of Energy Idaho Operations Office June

   LITCO, 1994, Track 2 Draft Final Scoping Summarv Report OU 3-10 Sites CPP-4^ CPP 44  CPP ^
       ana CPP-56. 1NEL-96M97, Lockheed Martin Idaho Technology CornSy/Rev^on 2.'      *


  UTC Un'itTn7^ 7 °"**MI DO"''G''°'' ^^' IMMogicaUy Contaminated Soils. Operable


  LITCO. 1 995a.  Engineering Evaluation Cost Analysis (EE/CA)for Operable Unit (OU) 10-06
  LITCO. 1 995b -Final Preliminary Scoping Track 2 Summary Report for Operable Unit (OU) 3 09
       Lockheed Idaho Technologies Company, INEL-95/0094, Revision 4 February
  1 995c, Waste Area Group 3 Comprehensive Remedial investiga
WorkPlan, Lockheed Martin Idaho Techno.ogies Company
                                                               tion
 LMITCO 1 997a, HWMA Closure Plan for the Waste Calcining Facility at the Idaho National
      Entering and Environmental Laboratory. INEEL-96,? 1 89, Re'Sfn 2^une,^ 997
                                                                          Administrat.on,

                 t' F ^"^^PP^'^. Risks, and Protection, Nuclear Energy Agency
                 for Economic Cooperation and Development.

Orr, B^R. and L. D. Cecil,  1991. Hydrologic Conditions and Distributions of Selected Chemical

          '
                                                                                   ,o
Pittman. J R  R. G. Jensen, and P. R. Fischer. "Hydrologic Conditions at INEL 1982 to 1985 " - USCS
     » atcr Resources Investigations Report 89-4008. DOE.-ID-22078, Revision 0.
                                           15-3

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  Robertson J. B  Robert Schoen. and J. T. Barraclough. i 974. The Influence of Liquid Waste Disposal on
                                                                                Open File
  Rood. S M G A. Harris  and G. J. White, 1 995, Background Dose Equivalent Rates and Surftcial Soil
       0^ ln«n P    °""r •M*?™™™™ for** ^aho National Engineering Laboratory INEL-
       y-4'025(). Revision 0, February.
  Sole Source Aquifer under Safe Water Drinking Act

  UN' EP, 1 985. Radiation-Doses. Effects, and Risks. United Nations Environmental Program.

  USGS 1998. Pnllminary Water Surface Elevation and Boundary- of the 100-Year Peak Flow in Big Lost
       Kiver at I.\EEL. U.S. Geological Survey. Water-Resources Investigations Report 98-4065.

  WINCO. 199 la. WAG 3 \'o Action Documentation Package Solid Waste Management Unit CPP-43
       Grease Pit South ofCPP-637, Westinghouse Idaho Nuclear Company, Inc.. Document No. 3575.

  WINCP' '" ' b' W*C 3 No Action Documentation Package Solid Waste Management Unit CPP-5 •>
      Putting Shed East ofCPP-631. Westinghouse Idaho Nuclear Company, Inc., Document No^STfr.

 WINCO. 1 99 Ic, WAF3No Action Documentation Package Solid Waste Management Unit CPP-70
      *pt,c Tank East ofCPP-655 and CPP-7I Seepage Pits West ofCPP-656, Westinghouse Idaho
      Nuclear Company. Inc.. Document No. 3577.

 WINCO 1 99 Id. WAG 3 No Action Documentation Package Solid Waste Management Unit CPP-72
      3578                of CPP-651. Westinghouse Idaho Nuclear Company, Inc.. Document No.


 WINCO. 1991e  WAG 3 No Action Documentation Package Solid Waste Management Unit CPP-73
      Leaching Cesspool East of CPP T-5, Westinghouse Idaho Nuclear Company, Inc., Document No.


 WINCO. 1991 f.  WAG 3 No Action Documentation Package Solid Waste Management Unit CPP-74
     Seepage Pit West of CPP-26. Westinghouse Idaho Nuclear Company, Inc., Document No. 3580.

 WINCO. 1 99 1 g  WAG 3 No Action Documentation Package Solid Waste Management Unit CPP-75
     bept.c Tank and Cesspool West of CPP-603. Westinghouse Idaho Nuclear Company Inc
     Document No. 3581.                                                   •"'

 WINCO. I991h, WAG 3 No Action Documentation Package Solid Waste Management Unit CPP-76
     Septic and  Cesspool West of CPP-659. Westinghouse Idaho Nuclear Company. Inc.. Document No.


WINCO. I99H. WAG 3 No Action Documentation Package Silid Waste Management Unit CPP-77
     beepajw Pit and Cesspool North of CPP-662. Westinuhouse Idaho Nuclear Company Inc
     Document No. 35X2.
                                          15-4

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                      ' DoedSi°n Documentation P^kage Waste Area Group 3, Operable Unit 6 Site
        Revin        ** St°rage ^^ WeSt °f CPP-62°' W"'^°use "aho Nuc'iear Compa^, Inc,
                      f DerSi°w D°C™eMation Packa&- W^ Area Group 3. Operable Unit 2. Site
                                 Westmghouse Idaho Nuclear Company, Inc., (MAH-FE-PL-304)!

  WINCO  I992a  Track I Decision Document Action Packages OU 3-01, Revision 0  1992  Westinghouse
        Idaho Nuclear Company. Inc., Document #520!                                Westmghouse

  WINC(?'l9n972b' T.r*ck I Decision Documentation Package Waste Area Group 3 Operable Unit ~> Site
       Revision"0  C°ntam'natl0n NW °^PP-642. Westinghouse Idaho Nuclear Company, Tnc
                     ' D!Cisi°" Documentati°n Package Waste Area Group 3 Operable Unit 2 S
                         Pant ^ ^ " ^ °f CPP-6°3' ^
                                                                                     ite
              ? TTk ' DeoiSIOn Documentation P^kage Waste Area Group 3 Operable Unit 2 Site
              Gas Storage Bu.Iding, Westinghouse Idaho Nuclear Company  Inc., Revision 0

                     ' DeCSi°n Documentation Package Waste Area Group 3 Operable Unit 2 Site
                                                                     Id'aho Nud^ar Company,
 WINCO, 1 9921 ; Track 1 Decision Documentation Package Waste Area Group 3, Operable Unit 2 CPP-
           on I    ^               of CPP-645, Westinghouse Idaho Nuclear Company, Inc.
WINC(?p
     Tnc  Revo

              TraCck l Dedsion Docu™entation Package Waste Area Group 3, Operable Unit 2 Site
             mm                                                                 '
      (?pp »2f TraCk n'p DedsciT Documentation Package Waste Area Group 3, Operable Unit 2 Site
      Tnc  RevSo?"          ^ ^ S°Uth °f CPP'697- Westinghouse Idaho Nuclea, Company,
                  c                                                 ,  perae  nt
      Revin ,        8C Area WeSt °f CPP-66°' WestinSh— Who Nuclei Company I nc,'

WINCO  1 992i. Track I Decision Documentation Package Waste Area Group 3, Operable Unit 2 Site
      Revi'sionl           P'" ^ °f CPP-6°6' ^'-nghouse Idaho Nuclear Company,  Inc.

WINCO  ] 992} Track I Decision Documentation Package Waste Area Group 3, Operable Unit ? Site

              eroSe"e
                                                                   N   lear Comy  nc..
WINCO. 1 992J. Track 1 Decision Documentation Packages Operable Unit 3-01. CPP-49 CPP-50 CPP
     31. and CPP-61. Westmghouse Idaho Nuclear Company. Inc.. Revision 0.
                                                                                                     1
                                          15-5

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  WINCO  1992k. Track I Decision Documentation Package Waste Area Group 3. Operable Unit •> Site
       CPP-6. Mercury- Contamination Area near CPP TB-4. Westinghouse Idaho Nuclear Company
       Inc.. Revision 0.                                                        .

  WINCO.  19921. Track I Decision Documentation Package Waste Area Group 3. Operable Unit "» Site
       CPP-64 Hexone Spill West ofCPP-660.  Westinghouse Idaho Nuclear Company, Inc.. Revfsion 1
                  T* ' Dceision Documentation Package Waste Area Group 3. Operable Unit 12 Site
           -8. Abandoned Line 1.5 in. PLA 776 West of Beech Street. Document No. 5292. Westinah'ouse
       Idaho Nuclear Company. Inc.. Revision 1 .                                      '     "

  WINCO 1993 c  Final Track 2 Summary Reporter Operable Unit 3-08 (Tank Farm Area II) Sites CPP-
       Revisio^3         '  CPP'27'  CPP'35' andCPP-36- Westinghouse Idaho Nuclear Company, Inc..


  WINCO. I993a. Track 2 Summon- Report for Operable Unit 3-07 (Tank Farm Area I) Sites CPP- 1 6
                                         CPP-32W- Westi«^ouse Idaho Nuclear Company, Inc..
 WINC£l '9?3b- Track 1 Decision Documentation Package Waste Area Group 3 Operable Unit 4 Site
      CPP-38. Transits on CPP-601/602/603/604/605/606/640/644/648, Westinghouse Idaho Nuclear
      Company, Inc.. Document Number 5303, Revision 1 , June.

 WINCO,  1993c Track I Investigation OfCPP-66. ICPP CFSGFAsh Pit - No Further Action
      Determination, Westinghouse Idaho Nuclear Company, Inc., Document Number 5688 September
      http:iVar.inel. gowar/owa/'getimnge  2?F_DQC=56XH Site
      CPP-68 Abandoned Gasoline Tank CPP-rES-UTI-652. Westinahouse Idaho Nuclear Company
      Inc.. Revision 2.

WINCO. 1 993h. Track 1 Decision Documentation Package Waste Area  Group 3 Operable Unit 4 Site
      CPP-3*. Transite on CPP-60 1.602:603. 604 605 606 640.644 648. Westinghouse Idaho Nuclear
      Company. Inc.. Document Number  5303. Revision I. June.

WINCO. 1 993i. Final Track 2 Summary Report for Operable L 'nit 3-08 i Tank Farm Area II)
      Westinghouse Idaho Nuclear Company.  Inc.. Revision 3. July.
                                           15-6

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15-7

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               Appendix A


Operable Unit 3-13 Responsiveness Summary


       Public Comments and Responses
         on the OU 3-13 Proposed Plan

-------

-------
                                          OVERVIEW


                   gineering and Environmental Ub0nT™  NEE  l T^ U"" (°U) 3'13' a' the
                           ^^^^^
   invesogacion/feasiWIity stud^ES,.^ Sn^e^es*  f 'NTEC ~""»<*««i« rental
   were chosen for the 99 „•„ ^J ,„ ^jg*           P™** — d. Selected remedies
           those risks.  During
  into the following
             l action alternatives. For these
 were eyak.ated, and preferred alternatives
 that w,|| be remediated or closed under other wh
 transferred to WAG 10 for further evaluation  One     rcPp
determmed to require additional action and wHl be part o%roun
remedial acUon  rous  tw
                                                       RI/FS to have
                                                       r?""K remedial action to reduce or
                                                                      ™«<> «<** were grouped


                                             ^

                                                                         remedlated
                                                                            aCti°"
                                                                     SlteS (CPR-38 and
                                                                      (CPP'66) that has been
                                                                             '
                                                      ac
                                                         he
                                                            J"
                                                                      "N° ACtl'°n" site' has
                                                                       f° the 46 SI'tes in the
                              con an  wl be part oroun                          '   s  ^
 remedial acUon groups, two other sites requiring a remedfa?acdn    H    ""^ f° the 46 SI'tes in the
 determined to pose an acceptable risk to human heaTtrVand he         ^transferred site, 50 sites were
 Agenc.es as "No Action" and "No FunherTctLn" 'L       env'™ment and were identified by the

A Proposed Plan that summarized the results of the R f/FS »  A
alternatives was released by the Aeencies for ni.hr          Presented the preferred remedial
                          rz
 alternatives was released by the
 review of this document took pl
 an automata 30-day extension to the commem period  CoZ'  ?
 people who attended the forma, portions oTth  fp  blic meetTn"
 19 persons or groups. An additional 30-day review oerinTfr
 by 5 persons or groups to submit written comment"  Public
 Pal.. Bo,s, and Moscow, Idaho on NovembeT.
                                                               16'  "8' The '"^ Pub.ic
                                                                       ' "8" which i
                                                                       ^ i0 °f ^
                                                                 comments were received from
                                                                ''"   WaS requested and
group was mixed.
                                                          r ments
                                                         alternatives for each remedial action
                                          A-i

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                 BACKGROUND ON COMMUNITY INVOLVEMENT

  In accordance with the Comprehensive Environmental Response. Compensation, and Liability Act
  (CERCLA). Section 113{k)(2)(B)(I-V) and 117. a series of opportunities were available for public
  information and participation in the remedial investigation and decision process for OU 3-13, WAG 3 of
  INTEC (ICPP), from 1991 to present.  For the public, the activities included receiving fact sheets that
  briefly discussed the status of the investigations to date, INEEL Reporter articles and updates, a Proposed
  Plan, and focus group interaction, along with teleconference calls, briefings, presentations and public
  meetings.                                                       "                   v

  During the week of October 18, 1998. the  U.S. Department of Energy, Idaho Operations Office (DOE-ID)
  issued a news release to more than 100 media contacts concerning the beginning of the a 30-day public
  comment period pertaining to the WAG 3  OU 3-13 Proposed Plan. This period began on October 23.
  1998; however, the comment period was automatically extended by the Agencies an additional 30 days in
 anticipation of large public interest. During the extended comment period^ a request to extend the
 comment period was received. As a result, the extended comment period ended on February 12, 1999.
 Additionally, two "update fact sheets" were distributed to approximately 700 citizens on the INEEL
 Community Relations Plan mailing list. The first "update fact sheet" was distributed in November 1997
 and the second was mailed out in September 1998. The purpose of the documents was to keep citizens
 appraised ot the development during the RI/FS and to include a schedule of the investigation and
 announce the approximate dates that the public meetings would take place. These fact sheets also offered
 technical briefings to those interested in the WAG 3 investigation. The news releases gave notice  to the
 public that WAG 3 INTEC (ICPP) supportive documents were available in the Administrative Record
 section of the INEEL Information Repositories located in the INEEL Technical Library in Idaho Falls
 Albertson Library on the campus of Boise State University, and the University of Idaho Library in
 Moscow. Copies of the Proposed Plan were mailed to about 700 members of the public on the INEEL
 Community Relations Plan mailing list for  review and comment. In addition, public meetings were held
 at Idaho Falls, Twin Falls, Boise, and Moscow, Idaho, on November 16, 17, 18, and 19. 1998,
 respectively.  Written comment forms were available at the meetings, and a court reporter was present at
 each meeting to record transcripts of the discussions and public comments.  A total of 34 citizens
 provided formal comments; of these. 10 provided verbal comments and 24 provided written comments.

 This Responsiveness Summary has been prepared as part of the ROD. All formal verbal comments as
 given at the public meetings, and all written comments, as submitted are included in the Administrative
 Record for the ROD.  Those comments are  annotated to indicate which response in this Responsiveness
 Summary addresses each comment. The ROD presents the selected alternative for each remedial action
group along with the decisions on the "No Action" and "No Further Action" for the remaining sites. The
preferred alternatives, in the Proposed Plan, were selected in accordance with CERCLA, as amended by
the Superlund Amendments and Reauthorization  Act.  and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (the National Contingency Plan [NCP]). The
decisions presented in the ROD are based on the information contained in the Administrative Record.
Additionally, the Administrative Record is available on the Internet at http:. ar.ineUov home.html.
                                            A-ii

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                                       SUMMARY


                                                                           for *- WAO
~
                            these meninS- *
-------
                                                          - r d, .,0^ ran ,n the
 proposed soil repository for leaving contamtlts ov^er the S^PA.       "' (B°'Se
        LISTING OF COMMENTORS AND COMMENT NUMBERING
~™^                                   — ' *""
Commentors are expressing their indhTual oninln -r    C°"?mentor affiliati°n is unknown or the
index of the comments and*the paee numbe rZ he com""?"1  tiZe"" " Sh°Wn 3S the affiliation-
                         paee nume r    he com                                  -
Responsiveness Summarv. CoLenl ^eTndev^h  T"  ,aPPearS °" '* pr°vided at the end °f this
and identified as either written r^Tpublfc mS?n^ °"  t T'"315 ^'^ 3Uth°r (U for unkno-n)
for Twin Falls. TB for 'Boise and ATfor Moscov   T Si      "T 
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                                                                     1
             ir affiliati°n-and
	 Name 	
Mr. Jobe
Beatrice Brailsford
Peter Rickards
David Kipping
Margaret McDonald Steward
Pamela Allister
Pamela Allister
Steve Ramono
Chuck Broscious

Jeff Jones
Chuck Rice

Albert Taylor
Paul Randolph
Chuck Broscious

Thornton Waite
Shannon Ansley
Robin VanHom
Representative, Helen
Chenoweth
Jack Lemley
John Commander
Chris Coperfield
Margret McDonald Steward
David Hensel
Anonymous
Robert Bobo

Beatrice Brailsford
James McCarthy
Christinna '.'
; 	 	 	 	 	 — 	 _
. 	 Affiliation
Coalition 21
Snake River Alliance
Concerned Citizen
Snake River Alliance
Snake River Alliance
Snake River Alliance
Concerned Citizen
American Ecology, Inc.
Environmental Defense
Institute
Concerned Citizen
INEEL Citizens Advisory
Board
Concerned Citizen
Concerned Citizen
Environmental Defense
Institute
Concerned Citizen
Concerned Citizen
Concerned Citizen
Idaho First Congressional
District
Lemley and Associates
Coalition 21
Concerned Citizen
Snake River Alliance
Concerned Citizen
Concerned Citizen
Consultant to Shoshone-
Bannock Tribes
Snake River Alliance
Concerned Citizen
Concerned Citizen
	 — 	 . — , 	
Commentor's
	 Initials
LJ
BB
PR
DK
MMS
PA-SRA
PA
SR
CB

JJ
CAB

AT
PaR
CB-W

TW
SA
RV
HC
L
C2I
CC
MMS-W
DH
A
SBT

SRA
JM
C
Comment
Tvrw*
	 	 i y pc
TI
TI
TT
TT
TT
TB
TB
TB
TVf
1 iVl
TM
W

W
W
W

W
W
W
W
W
W
W
W
W
W
W

W
W
W
A-\

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Table 1. (continued).

            Name
 Frank Priestley

 Representative Mike Simpson,
 and Senators Larry Craig and
 Mike Crapo
 Barbara Robertson
Richard Kuehn
Unknown
Beatrice Brailslbrd
        Affiliation
                 _
 Idaho Farm Bureau
 Federation
 Idaho Congressional
 Delegation
Concerned Citizen
Concerned Citizen
Concerned Citizen
Snake River Alliance
Commentor's
   Initials
   IFBF
  MS


  BR
  RK
  U
  SRA2
Comment
  Type
   W
   VV

   vv
   W
   vv
  vv
                                        A-V!

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                             TABLE OF CONTENTS

OVERVIEW... .........
BACKGROUND ON COMMUNITY INVOLVEMENT


SUMMARY .............
         B.I.I General Comments on the RI/FS.
         B.I. 2.  Inclusion of Sites in the RI/FS

         B.I. 3.  Classification of Contaminants
        B.2. 1. Human Health Risk Assessment.
        B.2.2. Ecological Risk Assessment
        B.6.1.  Em ironmental Monitorinu .

        B.6.2.  Institutional Controls ...... "
                                                                            .IV
  LISTING OF COMMENTORS AND COMMENT NUMBERING ..............................


  SUMMARY OF COMMENTS WITH RESPONSES


 A. WAG 3CLEANUP AND PUBLIC PARTICIPATION .......................



      A.I. Overall Goals and Structure of the INEEL ER Program ........... .                  ,


            A.I.I  Results/Outcomes of the ER Program ..... . ......................                 5


      A.2.  Public Participation and Community Relations .......................


      A.3. Content and Organization of the Proposed Plan ......................


      A.4. Current and Future Activities at INTEC
                                          [[[ 14


      A.5. WAG 3 Remediation Planning and Costs....
                                               [[[ 16

B. THE CERCLA PROCESS AT WAG 3 ................................


     B.I.  The Comprehensive RI/FS ......................

   B.2.  Risk Assessment...
                         ............. ' [[[ .....26
                                               ..........                 30


   B.3. Remedial Action Objectives .......................


   B.4. Compliance with ARARs ..............


   B.5. De\elopment of Alternatives

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  C.  RELEASE SITE GROUPS AT WAG 3	               38

       C.I. Group 1: Tank Farm Soils	  38

             C.I.I. Group I Description	40
             C. 1.2. Group 1 Alternatives	40

       C.2. Group 2: Soils Under Buildings and Structures	    41

             C.2.1. Group 2 Description	43
             C.2.2. Group 2 Alternatives	      43

       C.3.  Group 3: Other Surface Soils	44

             C.3.I. Group 3 Description	    45
             C.3.2. Group 3 Alternatives	  45
             C.3.3. 1NEEL CERCLA Disposal Facility (ICDF)	1.."..1.'."."."..."".....49

                  C.3.3.1  ICDF General Comments	54
                  C.3.3.2. ICDF Siting	      55
                  C.3.3.3. ICDF Design	63
                  C.3.3.4. ICDF Waste Acceptance Criteria	65

      C.4. Group 4: Perched Water	     68

            C.4.1.  Group 4 Description	;          59
            C.4.2.  Group 4 Alternatives	         70

      C.5. Group 5: Snake River Plain Aquifer	72

            C.5.I.  Group 5 Description	73
            C.5.2.  Group 5 Alternatives	     75

      C.6. Group 6: Buried Gas Cylinders	78

            C.6.I. Group 6 Description	79
            C.6.2. Group 6 Alternatives	79

      C.7. Group 7: SFE-20 Hot  Waste Tank System	80

            C.7.1. Group 7 Description	_   80
            C.7.2. Group 7 Alternatives	80

D. OTHER ISSUES	 82

      D.I. Tank Farm	               82

      D,2, Decontamination. Decommi.>>sioning. and Dismantlement	S3

      D..V PiV)	  S4
                                            A-\ in

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      D.4. Other Disposal Facilities	,                             84




            D.4.I. Radioactive Waste Management Complex (RWMC)	  85




      D.5. Idaho High Level Waste and Facilities Disposition


            Environmental Impact Statement (Idaho HLW & FD EIS)	  85




      D.6. Unconfirmed Information at INTEC	                          86




      D.7. Mobility of Plutonium	                  86




      D.8. Nuclear Energy	                          QJ




      D.9. Research and Development	                       «7




      D. 10.  Idaho Space Port	                                               00
                                     	oo



      D.ll, INTEC Operations	               g8




INDEX OF COMMENTS	                                               00
                                      	

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A-\

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                                                                                                      1
  AlP


  ANL-W


  AOC


  ARARs

  BLR


  CAB

  CERCLA



  CFA

.  CFR


  COCs

  D&D

 DOE

 DOE-ID

 EIS

 EPA

 ER

 ESD


FFA/CO

FS


FSS

HEU

HI

HLW


HWMA
               ACRONYMS

  Agreement in Principle


  Argonne National Laboratory-West

  area of contamination


  applicable or relevant and appropriate requirements

  Big Lost River


  Citizens Advisory Board


  Comprehensive Environmental Response, Compensation, and
  Liability Act

  Central Facilities Area


  Code of Federal Regulations


  contaminants of concern


 decontamination and dismantlement

 U.S. Department of Energy


 U.S. Department of Energy, Idaho Operations Office

 Environmental Impact Statement


 U.S. Environmental Protection Agency

 Environmental Restoration


 explanation of significant differences

 Federal Facility Agreement and Consent Order

 feasibility study


 feasibility study supplement

 Highly Enriched Uranium

hazard index

high  level waste


Hazardous Waste Management Act
                                          A-\i

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   1C


   ICDF


   ICPP


   Idaho HLW& FD EIS



  ID\V


  IDWH.-DEQ

  JNEEL


  INTEC

  LDR


  LLW


  M&O


 MCLs


 MLLW


 MTRs


 NCP


 NEPA

 NPL

 NPV


 NRC


 NSI


 \\VCF

OMB

OC

PCB


RAO
   Institutional Control


   INEEL CERCLA Disposal Facility


   Idaho Chemical Processing Plant


   Idaho High Level Waste and Facilities Disposition Environmental Impact
   Statement


   investigation derived waste


  Idaho Department of Health and Welfare/Division of Environmental Quality


  Idaho National Engineering and Environmental Laboratory


  Idaho Nuclear Technology and Engineering Center


  Land Disposal Restriction


  low-level waste


  management and operations


  maximum contaminant levels


 mixed low-level  waste


 Minimum Technical Requirements


 National Contingency Plan


 National Environmental  Policy Act


 National Priority  List


 Net Present Value


 Nuclear Regulatory Commission


 New Site Identification


 New Waste Calcining Facility


Office of Management and Budget


operable unit


polychlorinated hiphenvl


remedial action objective
                                          A-\ii

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   RCRA




   RI/BRA




   RI/FS




   ROD




   RWMC




   SBW




   SNF




   SRPA




  SRS




  STP




  STP




  TAN




  TAP




  TBC




 TCLP




 TI




 TRA




 TRU




 TSCA




 USGS




 WAC




 WAG




 WIPP




WLAP
    Resource Conservation and Recovery Act




    remedial investigation/baseline risk assessment




    remedial investigation/feasibility study




   Record of Decision




   Radioactive Waste Management Complex




   Sodium Bearing Waste




   Spent Nuclear Fuel




   Snake River Plain Aquifer




  Savannah River Site




  Sewage Treatment Plant




  Site Treatment Plan




  Test Area North









  to be considered




  toxic characterization leaching procedure




 Technical Impracticability




 Test Reactor Area




 transuranic




 Toxic Substances  Control Act




 United States Geological Survey




 waste acceptance criteria




 waste area group




 Waste Isolation Pilot Plant




uastewater land application program

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A-\i\

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                 SUMMARY OF COMMENTS WITH RESPONSES

 Comments presented during the public comment period on the Proposed Plan for the 1VTEC
 Comprehend, RI/FS are given below. The public meetings were divided into a present an
  nformal quest.on-and-answ-er session, and a formal public comment sess.on.  The meeting! was
 described in published announcements, and meeting attendees were remmded of the formft at™e
 beg.nn.ng of the meetmg. The informal question-and-answer session was designed to prov d ^mediate
 responses to the publ.c s quest.ons and concerns.  Several quest.ons were answered during h  Zrmal
 penod ot the pubhc. meetings on the Proposed Plan. This Responsiveness Summarv does not a temm o
 summanze or respond to issues and concerns raised during the informal part of the public meet ne
 However  the Adrr.mstrat.ve Record contains complete transcripts of these meetings  whic™ mclude the
 Agencies  responses to these informal questions.

 Comments received during the formal comment session of the meetings and written comments received
 durng the publ.c comment penod are addressed by the Agencies in this Responsiveness Summ r^ The
 publ.c was requested to prov.de their comments in writing, orally during the public meeting or bv
 recordmg a message us.ng the INEEL's toll-free number.  The comments below are pnnted and
 occas.onally summarized. Edits made were to correct minor spelling, editorial errors, and elimination of
 non-comment related mformation. !n those cases where written comments were rece ved that were
 difficult to read, a best attempt to mterpret the comment is provided. Copies of the originally wriL
comments are provided in the Administrative Record file for INTEC.             °r,gmally * ntten

The comments made on the Proposed Plan, from the formal part of public meetings and written have




                      t, a resonse ha
 below.  For each comment, a response has been developed and is presented following the comment

             A. WAG 3 CLEANUP AND PUBLIC PARTICIPATION

 A.I. Overall Goals and Structure of the INEEL ER Program
        l  ' - H   - ArnCem T "Pressed that the ASenci« are looking at the risks associated with
       the .dent, hed sites m place or remediating them, but are not considering the other contaminated
sues which are still at the 1NTEC and thus, not looking at the "whole" picture. [TW-W]    °ntammated
      5u:ande^7hOWAr V ^Tr TK" " *** by <** ^ a"d Cxlendin8 from lhe '^dividual unit
   the OL and to the WAG 3 as a whole. The scope of the WAG 3. OU 3-13 is defined as the known or
suspected release sues .demified in the Federal  Facility Agreement and Consent Order (FF^CO and
suppon.ng documents.  Although we wi,l be rev.s.ting selected aspects of the WAG 3 investiSon under
the OL 3- 1 4 RI. FS. our evaluat.on ot source areas listed under the FFA CO. did address the potential

d^no -mo0 e!-hCirfeaCh ?°UrCe "" °n 1NTEC " a Whole" Consideration of the ' , i* tett   nd
t^lT    b"'«d'n.f .^structures at INTEC is not part of the scope for OU 3-. 3.  The Idaho Hiuh
Uxd \Va*te and Facilities D.spos.tion  Environmental Impact Statement (Idaho HLW & FD EIS) is^
currentl> cons.dering options for the disposition of INTEC facilities assoc.ated with the veneration
treatment, or storage of high lexel uaste (HLW,.  ,„ addition, the Idaho HLW & FD E.st also

So S tm RS^""^ ^ 'N [ EC fb?Cir JmpaCt °" thC Cumulative nsL With th- in ""'nd. the
Idaho HL\\  ^ M) hlh .should complement the WAG  3 RI FS in addressing the "whole picture "
Rcuncmcnk to the ri.sk calculation, u ill conunue as Mtcs are remediated and facilit.es and structures

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closed  Other programs (e.g.. Hazardous Waste Management Act [H WMA]. Governor's Agreement
[TAP]) oxersee other elements oflNEEL environmental management. Together alone with DOE-ID
decontamination and dismantlement ( D&D) planning, these programs should achieve a protective end
state for the luture.

Comment 2    : A concern was expressed that the Agencies seem to lack of a comprehensive decision
proces*.   * here w,l we be when we get there? What is this site going to be like when we're through

hLT!ng,hT ,   ^f    '^ T' "! PJ?Ce that y°U f°lkS are pr°pOSin^ t0 Put in an engineered landfill and
               °            *''  D°Wn '^ P0ad "e 3re               'Ot °f bits and Pi««? Bv the
  hn,h   ,                                                                             an
  rim* n?  ? tr m°     •!!?    *''  D°Wn '^ P0ad "e 3re g°ing t0 have a 'Ot °f bits and Pi««? Bv the
  time of tt AC 10 we will have made a lot of our commitments. There is no overall controlling philosoph
  for what is going on at the different WAGs. [BB-TI]                                      F»»"bopiiv
  ,   _,_   t-f*.  -p.   '               ._-_._._	»„ .„ .viiw.. ii \ji ju.-5fjcticu release sites identified in
  the FFA.CO. The process followed is a consistent one, applied for all INEEL WAG decisions made to
  date  \Ve do look at site-wide issues, but the hazards and potential hazards occur at the "source" level
  Our decision process is based on identification and response to threats posed on a source-by-source basis
  A case 'n point is the ICDF where we do attempt to look at the INEEL-wide needs through the creation of
  a site-wide LERCLA disposal facility. WAG 10 is intended to evaluate the cumulat'    '        •' h'
  ^l5^ fT th,C °rer/aPPinS groundwater plumes as a result of INEEL activities andto make a'final
  ,hf t   ,  °  CC  «*•'??! ?n  * 3   impaCtS-  AS SUCh' dedsions can be made at the individual WAGs and
  heSRpT  re i'nt° H H?       ana|ysis of cumulative risks.  In addition, the remedial actions taken on
  the SRPA are intended to ensure the aquifer  meets acceptable risk concentrations and drinking water
  maximum contaminant levels (MCLs) for future residents, and workers are protected from drinking water
 wn.cn exceeds MCLs or risk-based concentrations. For the SFE-20 Tank System, complete removal
 iknnTt' 3nr    P°      6 mos'cost effective and risk red"cing option evaluated. As for the ultimate
 disposition of waSterema,n,ng m the INTEC Tank Farm tanks, the decision is expected to be made in the
 ROD for the Idaho HLW & FD EIS, and the  HWMA closure process.

 Comment 3    :  A Commentor identified that as a visitor through the Chemical  Processing Plant when
 under construction around 50 years ago, he was interested in the clean up process now going on   It s too
 bad ,o many m.stakes were made in past years. I think your recommendations are the best available '
 Please contmue to protect the Snake River Aquifer from ANY serious contamination." [AT-W]    '

 Response: We thank the Commentor for his thoughts on the cleanup of INTEC.  One of the primary
 goals 01 the Ob 3-13 project is to ensure the portion of the SRPA. a sole source aquifer, impacted bv
 INTEC operations meets acceptable risk concentrations and drinking water MCLs for future residents
 and workers are protected from drinking water that exceeds  MCLs. or risk-based concentrations.

                              requested. "Simply get all the crap off of and out of the Aquifer!
«nA r    !vecapprCCiate.the comments and are committed to protecting potential future users of the
bRPA trom INEEL actmties. One of the primary goals of the OU 3-13 project is to ensure the portion of
  in!fn    S,   vei?,UrCrC Tter> im-PaCted by 'NTEC °Peralions "ieets Acceptable risk concentrations and
drmk.ng uater MCLs lor future residents, and workers are protected from drinking water which exceeds
ML L.s. or risk-based concentrations.

Comment 5     ; A concern uas expressed to the Agencies of the importance of the SRPA not onlv the
economic \.ilue. but the related perceptual value. [SR-TB]
                                             A-2

-------
                      ^ Commentor is correct in ^at perceptions were not formal* analvzed in the
                n impacts from perceptions can be assessed through our Community mvohemen
are contained in the DOE End State Planning document                    P ^


                                                     ^
                             the cumulate etfocts of,|10 waxes that will be placed u.thin the

-------
  landfill and establish limits to safeguard the aquifer.  This approach is consistent with our method for
  determining if an unacceptable risk exists under our baseline risk assessment, in the RI/'FS.

  Comment 9    :  One Commentor recommended that we adopt a comprehensive, INEEL-wide policy of
  minimizing further burial of radioactive and mixed wastes over the SRPA. and pursue alternatives to the
  accelerated use and full utilization of remaining RWMC Subsurface Disposal Area burial capacity. [L-W]

  Response: This comment relates to waste management practices at the INEEL and the future use of the
  RWMC. The proposed Plan and this ROD address the most cost-effective remedial action for past
  practice source areas at WAG 3. The ICDF will provide safe management for INEEL CERCLA waste.
  The RWMC also overlies the SRPA and is operated to dispose of low-level radioactive waste. The ICDF
  will accept soil and debris contaminated with both radionuclides and hazardous constituents   Disposal of
  the Toxic Substances Control Act (TSCA) and RCRA wastes require stringent engineering controls that
  the ICDF will incorporate.

 Comment 10   : A concern was expressed that the Agencies' plan on the Chem Plant cleanup seems fine
 in and of itself.  The problems lie mainly in that it doesn't address the difficult cleanup problems, nor
 does there seern to be an overall view of what the final outcome for the whole site will be. For example.
 the tank farm and the soil under it are considered in the Environmental Impact Statement (EIS). This will
 be a daunting and expensive cleanup project. Will there be money for this project?  Where and when
 does it fit in the final outcome—a clean  INEEL? [DH-W]

 Response: It is recognized that cleaning up will be a complex and difficult task. The Proposed Plan
 summarized the information contained in the  Remedial Investigation/Baseline Risk Assessment
 (RI/BRA) Report (DOE/ID-10534), Feasibility Study (FS) Report (DOE/ID-10572), and the Feasibility
 Study Supplement (FSS) Report (DOE/ID-10619), which can be found in the Administrative Record
 The final cleanup of INTEC will result in an acceptable risk (1 in 10,000 cumulative carcinogenic) for
 both the SRPA (also restored to safe drinking water standards) and surface receptors. The Idaho HLW &
 FD EIS will evaluate the treatment of the waste in the tanks and evaluate the disposition of facilities
 associated with  the generation, treatment, storage, and disposal of HLW. Concerning the funding issue,
 sufficient  funding will be requested from Congress to complete the cleanup activities. The decision to
 fund cleanup activities lies with Congress and the President. As facilities are closed and dispositioned.
 the impacts will be factored into the cumulative risk for INTEC.  Waste Area Group 10 will evaluate the
 cumulative impacts to the SRPA from across the entire INEEL.

 Comment II    : A concern was expressed to the Agencies that CERCLA requires 5-year reviews of
 decisions, even if they are not interim actions.  How many such reviews are contempla'ted for each OU at
 the Chem  Plant? [SRA-W]

 Response: As long as a CERCLA area requires restricted or limited access or use to safeguard human
 health and the environment, reviews at least even,' 5 years are required.  The entire area oflNTEC (ICPP).
covered by the scope of the ROD. would  be included into a single periodic review.  These 5-year reviews
will apply to both access and use restrictions.  In addition, these revie%vs will continue until the Agencies
determine  that they are no longer necessary.

Comment  12    : A que.stion was asked.  "Are there indi\ idual facilities or OUs that are covered both by-
Resource Conservation and Recovery Act (RCRA) and by CERCLA?  Will the CERCLA ROD
incorporate RCRA concerns?"[SRA-W]

Response:  The  Agencies are committed  to minimizing the duplication ot~ \\ork between the HWMA (i.e..
RCRA) iiiul CERCLA programs. Touard this end the FFA CO incorporates RCRA corrective  action and
                                             A-4

-------
   RCR A mvv,A  f       T    a f "gle PrOCeSS'  l" addition' cons'denng the general equivalency of the
   RCRA HVVMA closure and post-closure process to the FFA.CO remedial actions  the Agencies will make
   every attempt to ^corporate the monitoring and maintenance of closed units (e.g  Old Waste
   under this act.on. ,f requested by the authorized program.
   m^ toKTERCLA mrr *'" "^^ *" " Page 49' '" P8"1'"1 paragraph' °f the Pr°P°sed P'^-
   hints that CERCLA may be a permanent program at the INEEL. "When does the FFA/CO end and the

   under the^rOT:011 ^'T T' ?  R°Utme °Perati°nal K^S sh°uld not be incl"d*d - -w^tes
   under the FFA,CO. They must be addressed through a spill cleanup, or if a SWMU through RCRA
   Corrective Act.on. Once the RODs are written for OU3-14 and WAG 10, the CERCLA process aUCPP

       d                         "'5-year rCVieWS ^ °ng°ing — dia"0n' ™- <&** * na:'Cnew
Response:  The CERCLA and RCRA corrective action at INEEL is an ongoing program  The program is
re.pons.ble or assessing the risk from releases and potential releases of hazardous subsTances on thfe

 eieases from^CR^ WvT     $ ?* the.SUeS ^ ™°Kd l° aCCeptable risk'based Ie^]s- On«omK
releases from RCRA, H WM A  er                                                          "   ~
   eieases from^CR^ WvT     $ ?    te.SeS ^ ™°Kd l° aCCeptable risk'based     -
  releases from RCRA, H WM A permuted operat.ons are not addressed under the FFA/CO, but instead
  under the permu. Routme operational releases are not part of the FFA/CO. If the opera ional eieases
  represent an unacceptable rusk to human health and the environment, and are not unSer a RCIU HWMA
            '°           Under thC FFA/C° may be necessary and undertaken-  W"en newly i
                                                           is compiled and
 Response: Risks are compared against a national standard (the NCP) as to acceptable risk 1 OE-4 to 1 OE
 6 cumulanve caicmogcnic and a hazard index (HI) >1.  ,f risks are found outside this range remedTa
 acnon ,s necessary-. Comparing the risks from the INTEC Tank Farm soils against the wasteTn the n ts
 and trenches at the RWMC, would identify that both areas are outside the acceptable risTrange and
 requ.re remed.al act.on to be protective of human health and the environment.             §
 A.I.I  Results/Outcomes of the ER Program


          "the Pr^po™
 Response: The Cornmentor's summary was correct. Contaminated soil will be capped by this action
 either w,thm the iCDF, or under an existing building or contained in place.

 Comment 16   : A concern was expressed to the Agencies that, when the INEEL "cleanup" is done an
 enormous amount of nuclear contamination will remain above the Snake River Aquifer and we uon i
 know^the cumulat.ve extent of the remaining peril until most of the predicted cleanup resources are gone.
otheM-e^r,^-'I v°UrCH aVa'!able '° address nuclear contamination are indeed limited at INEEL and
other tedtral taulities.  However, we believe that the actions we have selected represent an appropriate
on IN^ue wiH^^U  ellect.ivencss- One ^ our goals is to reduce the footprint of contaminated areas
on INEEL ue u ill need to restrict access to and monitor indefinitely.  Another eoal is to clean up the
aquifer so that it is available to future generations.               '          ~              P tne

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                                                                                                            1
 Comment 17   : A concern was expressed that neither the tank farm nor the surrounding soil is covered
 m the current plan.  Decisions about the waste tanks themselves have yet to be made; those decisions may
 limit the soil cleanup options. Further, there are dozens of buildings at the Chem Plant, and some are
 highly contaminated.  The current plan doesn't address how or when to decontaminate those buildings.
 We won't even know what waste will be allowed in the ICDF until after it's approved.  Many of the
 specific concerns grow out of the general lack of a clear end state or end time for Chem Plant operation,
 remediation, and closure. [SRA-W]

 Response:  The Commentor is correct that highly contaminated areas at INTEC are located within the
 Tank Farm area. The  tanks and the waste in the tanks in the Tank  Farm are being addressed under the
 Idaho HLW & FD EIS.  Although the waste in the tanks is not covered in the Proposed Plan, the soils in
 the Tank Farm area are covered and are contained in Group 1 (Tank Farm Soils). We do not have a
 complete understanding of the threat posed to the underlying groundwater by the contaminated soil
 column at the Tank  Farm.  This is why we are implementing an interim action for the Tank Farm Soils.
 Concerning decisions made regarding the tanks and tank waste impacting the soils remediation, this is an
 issue that will be factored into the remedial action alternatives evaluation, in the OU 3-14 RLFS. For the
 ICDF, the soils and  debris that will be accepted will be limited to minimize the threat to the SRPA. Some
 soils and debris will likely require pretreatment prior to disposal in the repository or off-site disposal.  At
 this  time there is not an approved final end-state developed for INTEC.

 Comment 18   : A concern was expressed on how much residual  risk had been left site-wide after
 cleanup? What will be the cumulative risk left at the Chem Plant?  [SRA-W]

 Response: Remediation under the CERCLA program is directed at restoring the environment to an
 acceptable risk level (10E-4 to 10E-6 cumulative carcinogenic).  Cleanups that have occurred and will
 occur under this ROD are designed to reduce the risk from the 99 source areas to an acceptable level.
 Site-wide cumulative risk is being evaluated under WAG 10 for impacts on the ecological receptors and
 the SRPA  from IN'EEL operations and activities.

 Comment  19  : A  request was made to describe how much nuclear waste from the Chem Plant cleanup
 will  likely leave Idaho. [SRA-W]

 Response:  Both the transuranic (TRU) and HLW from INTEC cleanup under this ROD will be
 transported off-site for disposal. We do not estimate this to be a large volume. The wastes contained
within the High Level Tanks and Calciner Bins are a subject of the  Governor's Agreement and not
addressed under this action.

Comment 20   : A  Commentor exclaimed. "Cleanup this nuclear hazard ... Now!  With most of
Superlunds monies going to lawyers over litigation,  it is no wonder that when all is said and done, there is
more said than done! However, with t\vo facts clear to anyone concerned about their quality  of life in
Idaho: i.e.. (1) 200 million dollars over budget on cleanup. (2) 26 months behind schedule on cleanup."
[RK-W]

Response:  The Agencies are committed to expeditious cleanup at INEEL. These cleanups are funded
through agency (DOE) appropriations by Congress.  Implementation of federal facility remedial actions.
like that under the FFA CO. do not generally involve litigation.  The remedial action that the  Commentor
is referring to. the Pit 9 project, has experienced difficulties with >ub-comractors. Measures have been
taken to addre:* those problems and fulfill the requirements ofthis  earlier ROD.

A.2.  Public Participation  and Community Relations
                                             A-6

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                                ^

                                                                          tned '° spread
           heWri -SV"?, C°mn"Tr for the comm<™- The Agencies are committed to mformm, the
           he mfe and alternatives berng considered to remediate the contamination areas.


 Comment 24   :  A Commenlor requested an extension ofthe comment period. [HC-WJ

 circumstances, we extended the comment period until Februarv- 12*. 1990.

                                     thal cach panicipaling agency
                                                 ^
                       P,
cnvronmcnt. and undertakes environmental restoration actions based on permanent sout ons that w M
            r                    ilmentor heiieved that               ""
r?nPr'e: n ° 7COgniZC ^ imponancc 0t>uhllc Panicipation and deliberate execution of well founded
responses.  Our dcc,s,on e,n .mnmcni ,s hi,hl> dependent on invoKemcnt by Stakeholders and the  ublic.

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                              stablished nationally for the cleanup of .National Priorities List <\Pl i --,
        	,	•""•"-'"""-iud ensjmeennt? servir^ ™m~ .-ui    ••  ,       ' "uuuc:> List (i\ PL) sites
   contingency action for the drinking water LmTer"^^^ Th lhe St3te °f the Practice- Our
   standards and available for future generations.                     aqU'Ter is restored to drink'ng water

                                ^«^».s^^*^
   Response:  We thank the Commentor for their complement.
  [PR-TT]


  Response:  Evaluation of the ICDF was conducted as nan of a PFRn * •
  making process. It is the Agencies' position tha CERaA   f       H invest'8atlon and decision
  Environmental Policy Act (NEPA) nroce«  1    I     , * functionally equivalent to the National
  ICDF. Also, the ICDF would be restricted'*tteatra^T8' ^^ Or NEPA '"S required for th
  maximum concentration of 
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   A.3. Content and Organization of the Proposed Plan
                                                                                             •
 Comment 35   :  A Commentor recommended listing and definitions of acronyms used in the Plan.











Comment 36   :  A Commentor recommended providing a list of key references. (C2 1 -W]



SanSh:4T.ne *? f*™™ f°r !he OU 3~ ' 3 ProP°^ Plan .ere included in the text on Paue -
F aragraph 4. In the future, more attention will be given to pointing the readers to where addition-,7
mtormat.on can be found, either by highlighting or a table.      "                   additional



           »  ''  A .C°mmenlor ^commended the addition of a simplified method for enabling the


                        '          bem een "group numbers-" "operable units-" and

                                            A-9

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   .sites.  These release sites were assigned the CPP numbers  Th<* n»iM •„  ;
   numbers based on tvpe of release location of rele, T  t   u           " Were then SrouPed into OL'
   used in assessing therisk indf^u Hv  d as a  ^e fbr W "n TT'  ^ °U ^ C?P nUmberS w
   all release sites presented an unacceptable risk and ^          V -' * rCSUlt °* the risk assessment, not
   developing the FS. the unacceptable^sk release"           ^^    ™"  rUFther COnsidera»'°"-
                    -
contents of the plan Ieft the reader
without enough solid science and technnlnTS
cleanup reall^ means                   &
                                                  "P
                                                                                 H°wwer« the
                                                         of readmS a P'^n published in a hurry
                                                      P'an' and without a dear d^nition of 7hai
                                                                               P,an
                                                            h°Wthe C— ts rank from a
ROD. The use of the vear 209  rela es pmarflv toTh S J  k      VTOUS C°Cs 3re presented '" the
frame that government owne.hToTth'eT d u m ± ^ Be^T^1'^ tO be * ™°n^ time
what land use pressure may exist and unless  he re  r ^ Xr'fSto ™ T " " d'TfiCUlt C°
use « a reasonable scenario unless other extending c±n^ ex't"    '
                                                                        %V°Uld C0me
            n the	.
 much waste: and how much of the cost

 Response: Onlv a summary level dis^u^ion or me it i)Kvvn-o  ,     4-   ,.  „
 evaluation purposes in the FS and FeasiWIhv Stud^SuoDen^n^p '"    Pr°P°Sed P'an'  F°r
 alternative concerning on-site disposal was developed This cnnr,nf   .  I0"'' •* concePtual remed'*'
 (surface and groundwater) impacts alona with other criterin      <      alternative was evaluated for risk
 construction, wastes, and cost of the ICDF is eonni led '   h  Ron8 C°St'  Addltlonal details concerning

^^^^•^^™u^
Appendix  C of the FSS Report? Concern.'".. ,h- irrTc "     ° Was!es and. v_olumes can be found in
(page 4S) of the Proposed Plan presented
                                                                       '
                                           A-11)

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                                                            e   The ™- shown are
presented and used for the evaluation of de  up r^ na ( MCLs ?H°   ^ IT ™™™™* *™
values presented in the Proposed Plan are le^L        ?      nsks)' fn add''"'°n, some of the
values that were presented l™*^^^^? '" the RI'BRA ReP°«- For the Rl-BRA  the
                e presente   ™*                                          -   or   e   -RA
   without respect to spatial locations  ThLTesulted in    f   C°nCent.ratlons a< various time intervals
   together, resulting ,n over prediction of LpTcls     C°ntam'nants "™ ™'tiple locations to be added
                                                                     at
   were of concern? [C-W]                    ' ralonucl^ and mercury." What other contaminants
                                  ^^
                                            " SM'ed "        °             Plan, addiuona,
                                                  f lhe

                                                               «« Projected in Ne,PrKen,
assuming that the project !s completed vt^thn            ^ C°StS W°Uld be to DOE futu^ budgets
comes from the NCR and  s used to omv d,     "* ''^ lmPleme"^ion timeframe. The use of NPV

                      '
               purpo          .                    NT             "    '"
1 00 years was used in the calculations.    •                      ' estimates Presented, a timeframe of
Comment 45   • The IN'EEL TAR r^       4
future Proposed Plans. [CAB-W1   reC°mmended the use of simplified formats and nomenclature in
                are no, as
                                                                               '
                    '''     **
               WAG        -u                        » °-  *™« .mp^^ in the
                                         A-l I

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 Response: The Proposed Plan mentioned in the comment was developed after the OU 3-13 Proposed
 Plan and the amount of information contained and presented in the OU 3-13 Proposed Plan was
 considerably more than that contained in the WAG 1 Proposed Plan. Converting the OU 3-13 Proposed
 Plan to the format used for WAG 1  would have resulted in a much longer Proposed Plan. We agree that
 for simpler projects, the WAG 1 format should be used.

 Comment 47  : A Commentor recommended the addition of graphics or maps to'enhance the reader's
 ability to understand the terms used in the Proposed Plan [CAB-W]

 Response:  We recognize the confusion resulting from the use of the group numbers, OL's, and CPP
 numbers throughout the Proposed Plan.  In the FFA/CO, INTEC (WAG 3) was divided into 13 OUs.
 Within each of these OUs. a number of release sites were listed using the  CPP numbers. For the risk
 assessment conducted at [NTEC, the RI- BRA Report and scoping investigations (Track 1  and 2
 investigations), the release sites were evaluated on an individual basis (site by site using the CPP
 numbering system). At the conclusion of the RI/BRA. many release sites were found to present an
 acceptable risk and were not carried forward for remedial action under the FS Report.  With the reduced
 number of sites for the FS. the group numbers were developed based on expected remedial actions.
 geographic location, and other factors.

 Comment 48   :  The INEEL CAB  recommended that DOE-ID embrace  Secretary Richardson's recent
 suggestion to communicate with "plain language." [CAB-W]

 Response: We thank the  CAB for their comment.  INEEL Proposed Plans and Fact Sheets are generally
 written to be understandable by the general public. We recognize this as a continuing responsibility.

 Comment 49   :  A Commentor noted that the discussion of average flow rates in the SRPA could easily
 result in a conclusion that  the contaminant plume is moving at the same linear rate as the water. Plain
 language would enhance the public's ability to more fully understai.d the issues that challenge the aaencv
 [CAB-W]                                                                       SB.-

 Response:  For certain contaminants like tritium (H-3),  the movement of the contaminant  is  at the speed
of groundwater. This is because the  contaminant does not adsorb to the solid" media (basalt)  while
 moving with the groundwater. Other contaminants like  Sr-90 adsorb and desorb as the groundwater move
through the area. This results in the leading edge of a contamination plume moving with the
groundwater. However, the concentrations at the leading edge are not necessarily at a concentration
presenting a risk.  It  is recognized that this is a difficult topic to describe at a summary level.

Comment 50    : A  Commentor questioned why the term Contaminants of Concern didn't seem to be
carefully  followed throughout the Proposed Plan. [U-W]

Response:  The COCs for each of the groups are presented for the entire group. Within the various
remediation groups,  the COCs are dependent upon the location of contamination within the group. In the
case of Group 5, the COCs outside of the INTEC fence are a subset of the  entire set of COCs. Remedial
actions will be undertaken  to deal with the COCs at the spatial location of the remediation. As the
remediation for group 5 under this ROD is dealing with outside of the INTEC fence, the two COCs are I-
 120 and Sr-l>(). Both of these contaminants will be considered in the remedial design and remedial action
activities.

Comment 51   : A  Commentor questioned the use of OU'a. group numbers, and CPP numbers
Miiuiluincuu.tly as it vva> extremely confusing. [L'-W]
                                            A- i:

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  risks a, individual rdease sites w  eeva   ed   n

  grouped together into ,he remedial acta groups
                                                    bers ™ r"1* - ihe FFA    -
                                                     '"  """'   *'  ** eValUa'iOn '" "* RI'BRA-
                                                                   S UnaCce>"abls risks were
                                       *• « of ,echno-babble. in a p,an presented ,o .he Pubfe
 editor complete the job. [U-WJ
                                                h '
                                                h're
                                                             edllor' or did"'' ^ther letting the
technical ed.ting and a public focus group in

exasperated tha thev scmm   ev
WJ               '     ""'""
                                    of h!       "" " '"' "^ beCOme so i""ne<«atelv'
                                    of the presentation to pounce on every possible problem. [U-
a simplified and slraightforvvard manner.
                                                  5 RI FS- Presented a very complex project
                                                                                       n
                                    '" lh= E»l"a'i°»
                                                                     ofthe Proposed Plan.
                                                     contamed - thc R"F
                                               a-uc "• °ri1* Proposed pian- didn'' « iab
     js for exposure ,l,a, e.vis, a,  N

    INTEC »i,h the stack depicted
                                                         ..
                                                  '"' '" *   ""''fied
                                                                    thal a
                                                                                Va"°«s
                                        A-13

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  Comment 57    : A Commentor stated that the conceptual model graphic is lovely, and except for the
  incomplete labeling and too-small size, very informative.  [L'-W]

  Response:  We feel that the graphic presented a good conceptual representation of how the various
  exposure pathways are related to the contamination in the surface soils, perched water, contaminated
  groundwater.  In addition the graphic presented a depiction of how the contamination can migrate.

  Comment 58    : A Commentor stated. "Page 48. Table 11. The first heading is "Soil Group " That is
  wrong. The first group reads "Tank Farm." That is wrong. Under recommended alternatives listing anv
  lor Group 1 IN misleading. Only an interim action is described in the text. Under recommended
  alternatives, listing number 2 for Group 2 is misleading. The text indicates that Alternative 2 OR
  Alternative 3 may be selected, depending on discoveries made during D&D." [U-W]

  Response: The Commentor is correct. "Soil Group" is a misleading heading. "Remedial Action Group-
 would have  been a more accurate and clearer heading.  However, the Tank Farm Soils (Group I) are
 included within this ROD as a remedial action group. For Group 2. the selected remedy (recommended in
 the Proposed Plan) is Alternative 2.  Alternative 3 for Group 2 would only be implemented if D&D
 removes the structure.

 A.4. Current and Future Activities at I.NTEC

 Comment 59   : A Commentor stated that it was extremely unlikely that the  INTEC would ever become
 a residential  area, if only due to the lack of water and the location. This was an assumption which is too
 conservative and which drives  the conclusions to expensive alternatives. [TW-W]

 Response: The use of the 100-year future residential scenario serves as our point of departure for making
 risk-based decisions  that will affect the future use of the land for many generations.  Beyond 100 vears it
 is difficult to predict what land use pressure may exist. Unless other extenuating circumstances exist
 (e.g.. proximity to closed facilities requiring perpetual care) the assumption of future residential use
 provides a level of cleanup that assures the remedy will remain protective.

 Comment 60   : A Commentor stated that "Institutional memory is short and if the past is any auide
 people in the future may use contaminated resources for some time and make investments before they
 discover the contamination. They will then be  faced with wrenchina decisions of whether to abandon
 their investments or live with what would normally be unacceptable risk or pursue remediation that in
 many cases, may be far more costly than the original remediation and waste management solutions.'"
 [BB-TI]                                                                 "

 Response: As part of the implementation of the alternatives in the OU 3-13 ROD. a commitment is made
 to develop an "Institutional Control (1C) Plan."  The approach to institutional controls for each Group is
 discussed in Section  11 of the ROD. The 1C Plan will be developed during remedial act.on activities.
 This 1C Plan will discuss the contaminated areas and the controls and periodic evaluations that will be
 placed on the areas over the long-term. In addition, the 1C Plan discusses what will be required to release
 the  areas lor future developments or uses. This should minimize the impacts to future investments
concerning the u*c of \arious areas.

Comment ft I    :  A Commentor stated their personal concern about the percolation ponds and about the
UM: of the million;, of gallons of water that are. basically. M.cked up out of the aquifer, dispersed through
this DOE  lacihu and then dropped back doun into the aquifer, pushing contaminants alone  The
Commentor hehcxcd  that until cleanup \\a> accomplished in a satisfactory way. DOE should not  be»in
                                             A-14

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                                            an'CUiarly "'" USed the natural res°ur"> <"'«*«™ the
                    at are imohed m generating electricity for these enterprises. [PA-TB]
   Response: We share the Comments concern regarding the percolation ponds and their affect on the
   migra ,on o  contaminants based on their present location. This ,s why faction wi 1 r q   e he
          n°      °
             e  qu,    al their cuirent location and
 Comment 62
  Comment 62   :  A Commentor stated concerns about the ongoing work of the plant after the cleanup
  and continued waste being put into the environment and aquifers. [JJ-TM]                       P

  Response: The ICDF will be used to contain and control waste from impacting the SRPA and surface
                                                                             P" "    r C
                                                                           «*
                                                      wm occur at the lcpp in the
 Response: As the HLVV at INTEC is required to be "road ready" by 2035  it was assumed that all

 5d7 7 °ih h"LW " TuPleted by 2035'  M°St °f the °Peratlons Panned at NTEC Pn   o W
  v ,|| deal w.th the treatment of both the liquid waste in the Tank Farm and the waste in the c  c me bins
 In addmon activmes dealing with spent nuclear fuel will occur until 2035.  A period of 10 vS s waT
 assumed to be needed for the disposition of the necessary INTEC facilities,  wh'ch result  in'the ^year

 In^^^^"™?** ^ th:'dah° HLW & FD EIS' thC timeframes fon
 ot  LN i hL  tac.ht.es could change.  Currently, there is not a mission for the CPP-691 Facilitv
 futureoact,v,ties at ,NTEC wil! cons.der the use of CPP-691  to accompHsh the futrl Sty in th
Comment 64
               :  A Commentor questioned. "Where are we when we get there?" [VIMS-TT]
 thomnletin nf ,                       contaminated soi^ **» be left behind at INTEC fo||owin«
 the comletion of cleanup activ.t.es. However, completion of the cleanup activities will result in the
                                             ^'-"ated ^ » - acceptab,^ le.e,
              ''  A Pmmenl0r ^"^oned why the use of the year 2095. and the 1 00 vears fi

                Sru-w7  What arC the'r SlgmfiCdnCe?  The C0mme"t0r "^ th
Response:  The year 2095 and  100 years numbers are derived from the Long-Tenn Land TV, FMuw
S^nosfnr lke Idaho .Vatioaal Engineering Lahoraion:  In this future land use documen  the "rea of
 NTEC was assumed to remam  under federal control until 2095.  Bevond 2095 the future land use
document does not define the future land use at INTEC. Based on this future land ^use documen
remediation ot the INTEC area  needs to be completed bv 2095.                     document,
   nTum   ,i ? Con;men!°^uf Sti6n^ what is the actual basis for the future residem.evaluat.on
          '   "        "      la'ng t0 bU1'd hOUS" °Ut herC '" 10°  ™re? The Commen'
     r       f h       i                                                      Commentor
    er asked ,1 the Ageneie, could produce reg.onal economic forecasts, local county citv real estate
                                           A-15

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   association formulations. demonstrations, surveys. or plans that clearlv document that such an interest
   and or need exists? [L'-W]

   Response: In developing the Long-Tenn Land Cse Fim.ro Scenarios for ihe Idaho National Engineering
   Laboratory document with various interested parties and groups, no consensus could be reached
   concerning the use of the IN'EEL beyond 2095. Based on this, risk assessment scenarios (current and 1 00
   year future occupational along with 100-year future residential) were developed  These land use
   scenarios were used in the baseline risk assessment. This does not mean that INTEC will be used starting
  !h ^      J'T reSldential development. but these are reasonably conservative assumptions to ensure "
  that the remedial action is protective to future generations.

  Comment 67    :  A Commentor questioned that if no evidence exists to forecast a land scarcitv so
  pressing as to require use of current INEEL areas for future suburbs, it seems that institutional controls
  would be much, much cheaper and far, far more realistic than removal. [L'-W]
                          -,                                      s °Ur point of d£Parture for
                        w.il affect the future use of the land for many generations.  Beyond  1 00 years if
  is difficult to predict what land use pressure may exist.  Unless other extenuating circumstances exist  '
  (e.g.. proximity to closed facilities requiring perpetual care) the assumption of future residential use
  provides a level of cleanup that assures the remedy will remain protective.

 A.5.  WAG 3 Remediation Planning and Costs

 Comment 68    :  A Commentor recommended that a cost comparison be done between a Plan based on
 a high radiation dose and current Plan.  "The public should be informed of the cost differential' If the
 public is informed of the cost associated with little or no risk benefit, we do not believe they would
 benem "\C''T-PWI]ditUre °f mill'°ns of dol!ars on radiation protection that. provides no measurable
 £eSv-rnpSerFOr S'teS Hlted ,°n lhC N'PL' deanup "1USt proceed to achieve an Acceptable risk range listed in
 the NCP. Comparing the cleanup cost of a non-protective cleanup versus a protective cleanup is
 inappropriate.  Only protective Alternatives are evaluated which meet this goal and the most cost-
 effective alternative selected. While there is some controversy over what constitutes an acceptable
 radiation risk, our best evidence supports the current approach of the linear no-threshold theory  This
 forms the basis tor the protective levels established to protect our air and drinking water and is nationally
 accepted. As pan of our 5-year review process, we will periodically  review the protectiveness of our   '
 decisions and adjust to any updates in published protectiveness levels.

 Comment 69   :  A Commentor questioned why the Plan does not mention the fate of "IDW" still
 present at ICPP. [C-W]

 Response: The Commentor is correct.  A small amount of investigation derived waste (IDW) is
                                        	• —••• — «••» ^ i  4 11 w x.^ii i^unv/j | UU1 | % t*J \V C13LC I I \-J VV I  1^
remaining at INTEC. A section was added to this ROD to addressee disposition of the existing IDW

U Rj'FSSCCll0n '" the R°D aiS° d'SCUSSeS the disP°sition of IDW that uill be generated under "the OU 3-
Commem  0   :  A Commentor stated that the O&M costs for lea\ inu VES-SFE-20 in place will not he
increased significantly due to the fact that it is adjacent to CPP-AU3. Although it is shown to be a
Mjjmlicant COM over time, it will not be significant since..t u,ll he done in conjunction with CPP-6U1
Mirvc.llance COM>. [TW-W]
                                             A-16

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  Response: The evaluation undertaken under OL 3-13 is of past practice sites (e.u., spills and abandoned
  Mies),  other programs are currently evaluating operating and closing facilities to ensure that the public
  and env.ronment are protected. The closure of CPP-603 is outside the scope of this action and therefore
  the costs projected tor VES-SFE-20 do not assume potential cost savings that may  be realized.

  Comment  71    : The Commentor asked about the remediation of Group 7 being completed well before
  any substantive action is taken on the main Tank Farm? [DK-TT]

  Response: The Commentor is correct. The major portion of the remediation for the INTEC Tank Farm
  will occur  after 2008. Remediation of the Group 7 SFE-20 Hot Waste Tank System will be completed
  will before the  HLVV tank at the Tank Farm.                               '

  Comment 72   :  A Commentor stated "quit talking about nuclear waste clean up at INEEL and do it!"
  [RK-W]

  Response:  The CERCLA process at the INEEL is a carefully  engineered and structured program that
  leads to specified cleanup and risk reductions.  The process consists of: (I) evaluation of risks p)
  evaluation ot response actions to reduce risk to acceptable levels. (3) selection of the response 'action
  including public input on the selection process, and (4) implementation of the response action.  This ROD
  has selected the response action to be implemented for the various contaminated areas at INTEC
  Implementation of the various response actions will begin following approval (signature) of this ROD.

 Comment 73    : A concern was expressed that "cleanup is being planned out of context with the
 previous operations.  Although it is appropriate to indicate that the old  mission of chemical processing in
 1LPP has forever ceased, it is dangerous to forget what went  on there-the source of the waste and
 contamination.  We have learned through involvement with other organizations and  operations at other
 DOE sites that the cleanup of nuclear materials processing facilities requires careful  planning based on a
 detailed technical understanding of the conditions at the facility. For example the stabilization and
 cleanup of the PUREX and B-plant at Hanford.(WA) was based on significant detailed knowledge of the
 operations ot the facilities.  The public had  information on historic air emissions (including the Green
 Run), throughput ot spent fuel and output of plutonium and uranium (including but not limited to HEU)
 and HLW. This information was useful for providing certain specific technical information useful in
 planning the cleanup, as well as providing a general sense (with factual support) of the operations leading
 to the existing problems (recent or historic,  batch/campaign or steady state, etc.)." [SRA2-W]

 Response:  We understand the  Commentor's concern with using appropriate information in the  planning
 of cleanup activities.  Cleanup operations are planned using the  available information including
 information  from previous operations.  It is  not necessary to know every operation that was conducted at a
 release site to plan the cleanup activities. Appropriate summary information is sufficient for planning
 purposes. During the implementation of remedial actions, planning includes actions to deal with the"
 uncertainties. General information as to activities conducted at INTEC  are discussed in Section  1 of the
 RI BRA Report.  This information discusses the major activities and facilities at INTEC.  Discussion on
the sources of contamination are discussed in the Sections 8 through 26  of the RI-BRA Report
Additional information is contained in the various Track  I and Track 2 documents. The plannin- of
remedial actions  is ba>ed on the best available information. Information on historic air emissions can be
found m the  various monitoring report published at the INEEL.
                                             A-1

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                       B.  THE CERCLA PROCESS AT WAG 3

   Comment 74   : A Commentor felt that at Page 20. Alternative Development, I - paragraph if actual
   technologies are modified after the ROD during remedial design,  those modifications must be examTned
   CFRr, ! K reqUirHan ESD °r R°D amendmCm aS deSCribed in  CERCL^ 8«idance Tprepa
   CERCLA Decision documents.  The Public has reviewed and commented on the Plan  Sim
   modifications atter the ROD would diminish, or negate, the public participation process [C W]
        nnn-  Ifthe altemat'Ve is modified or changed following the approval
 Whether ,nV^PPon°r °' "l^"""' ^^ (ESD) °r ROD Amendment would be requTd
 * nether an ESD or ROD Amendment would be required depends to the significance of the change
 Pro'no S nir 'f^f" Were ™]™« in 0 of the inflltratinM -ater. uhich contribute to the observed perched water
ob ^  n^T'1      dlSCharfeS- Thc m°del USCd f°r thc Sinuilatlon ™ "libr^ed. based on
un labt on If h !C*-.ttalcr dexat!°nS- Moride' '^ Sr-90)' h ls the hest information currently
col S nt  , , n^   ".   7 reaS°nf y eonserx-at»e JuJ»^"»- ^ believe that our decision process ,„
 NTTC VM       l ,  ,-   ^tal° BU'danCC-  °ixCn lhe °Vera" u"«^«n«y in t«nspoh mechanism at the
I.NTF.C laul.tx and the tact that «e can control the anthropoyeme water, it has been determined that
                                           A-IX

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  moving the percolation ponds is certainly "best management" practice. Our position is supported not only
  by the public, but was supported by an external peer review of the vadose zone program at the INEEL.

  Concerning additional work at the Tank Farm, we are in the process of developing a Work Plan for
  conducting additional studies to better assess fate and transport questions for contaminants at the Tank
  Farm soils. This investigation will  focus on obtaining data to quantify the overall uncertainty in model
  predictions, concerning Tank Farm soils.  Also, we will obtain necessary data required for the purposes of
  calibrating the transport model in terms of concentrations as the existing model was calibrated to perched
  water elevations. This additional characterization may use tracers, if appropriate, to help quantifv the
  migration paths of subsurface solutes. In addition, we will monitor vadose zone state variables to
  determine m-situ moisture flux and direction. However, even these studies will not answer the entire
  uncertainty issue at the INTEC facility because of the temporal variability in recharge  from natural
  sources such as underflow, overflow, overland flows, rain. snow, and snowmelt.

  Comment 77   ; A Commentor inquired about the transport assumptions for the vadose zone that were
  used in the evaluations and modeling.  [SRA-VV]

  Response: In conducting the computer modeling for the vadose zone, a number of assumptions were
  used. The retardation coefficients for the various contaminants were based on default values that have
  been used for other INEEL evaluations. The vadose zone was assumed to be a homogeneous material
  with the surface soils, basalt layers, and major interbeds  contained within the vertical column  Average
 (non-varying) properties were used throughout the horizontal and vertical dimensions for the various"
 materials m the vadose zone. Known sources of water, both manmade and natural were also considered
 in the modeling.  A summary discussion of the baseline risk assessment modeling is contained in Section
 6of the RI/BRA  Report. The detailed  discussion, including modeling parameters and assumptions for
 the baseline risk assessment is contained in Appendix F of the RI/BRA Report. The modeling in support
   A cec          Rep0rtS are contained in Appendix B of each document.  The modeling used in the FS
 and FSS Reports  used the same assumptions and approach as used in the RI/BRA Report.

 Comment 78   :  A Commentor felt that in order to understand the full ranae of cleanup issues at the
 Chem Plant, the department should provide a detailed historic description of the operations conducted at
 the Chem Plant. [SRA2-W]

 Response: A summary of the operations and activities conducted at INTEC was presented in Section !
 of the RI/BRA Report, which is part of the Administrative Record. This summary information discuss
 the major activities and operations that  were conducted at INTEC. In addition, several of the major
 facilities were described in this section. For CERCLA investigation and evaluation purposes  this
 summary level ot  information was sufficient to conduct evaluations and make decisions.

 B.I.I  General Comments on the Rl/FS

 Comment 79  :  A Commentor stated  that  the entire cleanup plan reeks of "cart before the horse" and
 that the cleanup plan doesn't appear to be very technically thought out. [MMS-W-W]

 Response:  The Proposed Plan is a summary of the various remedial investigations and feasibility studies
conducted for INTEC. In the evaluation of both risk and remedial alternatives, the information that was
collected from the Track I. Track 2. and OU 3-13 remedial investigation were utilized. Although this '
information is not  perfect, there uas sufficient information to conduct the risk evaluations and evaluate
remedial action alternates. As INTEC will continue to operate for many years prior to final closure
remedial alternatives were developed and considered this usue during the evaluations  Most of the
relevant  inlorrnaimn and evaluations can he  found in the Rl BRA. FS. and FSS Reports  Additional
                                             A-19

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   information for the release sites at INTEC (1CPP) is contained in the Track !  and Track 2 documents  All
   ol these documents are contained in the Administrative Record.

   Comment 80   : A Commentor referred to Page 1 6. SFE-20. 1 *' paragraph in asking that an identification
   o  whether the waste .„ the tank is a RCRA listed or characteristic waste be provided.  The Commento
   leli that ,1 the character,™™ of the waste is not known, a more through investigation should be
   preformed. The Commentor also stated that "the 1984 investigation was not a CERCLA preliminary
   mvesugauon  and "don't characterize it as such." The Commentor also requested that statements be

                             vau" has leaked and that the site be removed from the Proposed plan umil
  Response:  The waste in the SFE-20 Tank is not suspected of having listed waste. There may be
  contaminants m the tank waste that have sufficient concentrations for the waste in the tank to be classified
  £i?? H  cha™;e"f'c- F"rther. detailed, characterization of the tank contents is the first activity in the
  wt no? nCr^r  A T'VC 4-Rem°Val- Treatmem' and DisP°sal>' We a^ee that the 1984 investigation
  NE^rFRri A   I    y~     ^ data tr°m non-CERCLA investigations is routinely used in *e
  NEEL CERCLA nsk assessment and alternative evaluation activities.  During the 1984 investigation
  here was evidence that water had infiltrated into the vault, which shows that water leaked into the vault
  and could leak out of the vault. Based on the available information and analysis conducted there is
  sufficient information to select a remedy for this site.                    '

  Comment 8 I    : A Commentor referred to Page 37. Alternative 2B, 2nd paragraph concerning the
  sampling location m the aquifer for the quarterly samples and whether the samples would be diluted with
  less-contaminated portions of the aquifer above or below that which bears the highest 1-129
 concentrations.  The Commentor stated a fear that the Agencies would take their samples, declare that
 action levels are met, due to dilution, and then decide that remedial action is not required  The
 Commentor also wanted to know when the investigation and evaluations would be completed on the
bL'SfwL^T*^111 thC C°mmentor-  DurinS construction of the monitoring wells, samples will
be collected and analyzed from various zones within the aquifer to determine the zone or zones with
    eStCOnCeratl0nS' Monito™  would
                      Monito™8 would continue in the zone or zones with the highest concentrations
                       a rate of at east 0.5 gpm.  An adequate and complete Rl/FS was conducted for
SRPA L -LJ :„%,  iLr?r ? * *t-    £ l° ™ke dedsionS concerninS the contaminated portion of ,he
SRPA oub.de ot the INTEC fencelme.  The active  remediation portion of the selected remedy
(Alternative 2B: Institutional Controls with Monitoring and Contingent Remediation) is only
implemented depending on the monitoring results obtained.  A Final interim action on the INTEC
groundwater plume in the SRPA outside of the INTEC fenceline is included in this ROD  The final
action on the INTEC groundwater plume inside the 1NTEC fenceline will be selected under OU 3-14.

Comment S2   : A Commentor stated that "Based on the comparisons men in Appendix F of the RI
100M n^SS ^^HTr ^ C°nc^tnuions are over Predict^ (by the" computer model) by factors of
10.000 o  100.000 (,t ,s  ditf.cult to tell tor sure with the huge log scale used). In addition, the predictions
shoxv  p utomum concentrations of hundreds of pCi- L in the perched water.  This is not supported bv the '
perched water data.  Based on these predictions, there is huge uncertainty in the models predicted Sr-90 or
p hi omum concentrat.ons in the aquifer. Any decisions made based on these predictions are being made
under e^entiallv unbounded uncertainty." [JM-VV]                                   '

Response:  For certain perched water wells, away from major Mnirco terms. lar»e over-predictions in the
conccninition> lor contaminants occur. However, near large  .source term-,. Sr-90 concentration
                                            A-20

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   predictions are «ithin a factor of 10. It is recognized that plutonium is over-predicted based on the
   rsp^r^^
   ^==s:s
   Lmt 3-14 may attempt to quantity the uncertainty in the modeled concentrations.       '
  crnnnHt       Commentor stated that "As shown in the vadose zone model transport calibration and
  Sr-90 Pred,ct,ons. contaminants are laterally spread much further in the computer model than isTupponed

  Sows vT,  f     /hllVad0? f0"6 I3teral Spreadmg haS been assumed to be conservative  nthatT
  ^k fa™Trf  SPT   '" L  m°dd tr°m '^ PerC°lati0n P°nds and Bi* Lost ^ to *e area under ne
  Howl!^ fh       T6    nnSP°f °f C0ntaminants from "K upper perched water to the aquifer
  However th,s overestimate of lateral spreading means there is an underestimate of vertical movement of

                      S- There°re- " JS P°SSible that the Vad°Se Zone c«»aminant travel time toThe
                               '" ^ m0dd therCby *— "S ** f-re risk in the
         e: The Commentor is correct. It is recognized that the Sr-90 is laterally spread in the model
  more than ,s observed m the measured values shown.  The true lateral spreading        "

                                                               '
    u,            H                   '                                 wazo  e
  esults trom the lateral spreading, but a.major impact (effect) is modeled in the deep perched water  The
  largest source terms are ,„ the Tank Farm Soils (Group 1 ) and the impacts on the SRP\ w.thin the
  fencelme will be further refined under OU 3- 14.                              *v™»«mnine
 Comment 84   :  A Commentor stated that "The inconsistencies between the computer model predictions
 ( hat dec,s,ons are based on) and the observed movement of contaminants m the perched watemusb

 she!! d h    T r ^  J^ UnCerta'nty in thC Predicted a^ifer risk should be q-Entified or teru ts
 ta°ed in this tono -eH m """^ ^ ^ ** ^^^ UnCertaint>' has not bee" sufficient
 stated m this Proposed Plan or in the supporting documentation for the Proposed Plan. [JM- W]    '

 Response: There are recognized differences between the modeling and measured results  These
 differences are shown graphically in Appendix F of the Rl/BRA Report, which  is pan of the
 Administrative Record. There are predicted impacts on the aquifer from the surface and near surface
 source terms, but the major impact currently and in the near future is from the use of the mj«.1on^H

 ^Pr^Tp,   °m thC maj°r T^ tCrm m ^ Tank Fam S°ils Wi" be refi^ under tfe OU 3  U
 assessment for OU i^11"1™17 d°CUment- ln addition' ^^^ «"* not quantified in the risk    '
Comment 85    : A Commentor felt that on Page 14. Perched Water, 2nd paragraph a statement should
have been made concerning the perched water having been contaminated wuh RCR1   ed ^ e A
Commentor requested that the specific Idaho Groundwater Quality Standards be identified and hat the
 •me trarne tor .mpacts on the aquifer be identified. The Commentor a.so inquired abo u^h "v ^ nee "hat
the perched water ,s a transport pathway between surface soils and the deep aquifer  Also  the

^dnlaveenrt0rt-VaS,C°nrTd f^f ^ "** ^ ^ contaminants absorbed adsorbed onto surtlcial soil
   t m ^h      i m         "  en dealing with infiltrating water. The Commentor requested that a "
,tat,mem be made concem.ng whether the perched water presents a risk to the aquifer from the

"™        Jn             aler°r fr0m additi°nal Contaniinants 'eached from so,l percolating
         . GiVC,- Ihc.1lcaks1thal h;Ue Occurred in th« T;lnk Farm, listed hazardous wastes are present in
          aqu,ler. Ma/ardou- constituents and characteristic ha/ardous waste was injected into the
                                           A -21

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                               ^
  does represent a threat to the SRPA  The intent of ,H        ^  S°UrCe   ^ f°r consumP"°".
  unsaturated : zone. The residua, contamination from these fail                 n
 dealing with contamination in the surficia, sediments     nerernatena   Bz
                                                                  ''ater does represent a threat to





















B.I.2. Inclusion of Sites in the RI/FS


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  Response:  V\ e do not understand what sites the Commentor is referring to. Ail sites were characterized
  re f ™0? Pr0fSS knowled§e' interviews, or actual sampling and analysis. Investigations under the
  FFA. CO have followed a tiered approach.  The approach started with Track I investigations along with
  analysis and then preceded through Track 2 investigations and analysis. These Track 1 and Track ~>
  investigations were then factored into the RI/FS Work Plan and further investigations were conducted
  where necessary. Some characterization activities will take place as part of the various remedial actions.

  Comment 89   : A Commentor felt that on Page 14, Other Surface Soils, Ist paragraph, "Soil which is
  currently stored m boxes and which was not generated during CERCLA investigation or removal
  activities (CPP-92). should not be included in this Group." The Commentor stated that "This waste is no
  rl  rvncr3; ™? ^ "^ ^^ by *" INEEL duri"8 routine maintenance or upgrade activities.
  I he iNhhL has facilities and dispose of such routine waste.  It should not be included in CERCLA
  simply because it simplifies, and may reduce, regulatory compliance requirements. Including this  kind of
  soil in the CERCLA program allows the INEEL a way to circumvent the RCRA disposal requirements
  which might otherwise attach to the soil.  Remove boxed soils, which did not originate from the CERCLA
  program from this Group. [C-W]

  Response:  We disagree with the Commentor. The soils in the Site CPP-92 were included in the FFA-'CO
  through the New  Site Identification (NSI) process. In order to add the site to the FFA/CO  concurrence
 was obtamed from both the EPA and Idaho Department of Health and Welfare/Division of Environmental
 Quality (IDHW/DEQ) along with DOE. Also, the waste that was generated and placed into the bo" «
 originated from CERCLA release sites. Lastly, the boxed soils at Site CPP-92 are subject to
 HWMA/RCRA ARARs, particularly hazardous waste determinations and land disposal restrictions and
 storage ARARs. No RCRA requirements were 'circumvented.'

 B.1.3. Classification of Contaminants
      Mi™  :uA ?mmentor felt that DOE faiied to c°™*tly categorize the other waste as mixed low-
 level (MLLW) which requires either approved treatment or disposal in a permitted RCRA Subtitle C
 hazardous waste dump. [CB-W]

 Response: An evaluation of whether the wastes are subject to RCRA disposal requirements in a RCRA
 Subtitle C landfill was made in the Feasibility Study Supplement Report, which is part of the
 Administrative Record.

 Comment 91    : A Commentor stated that "Two of the contaminated soil sites (CPP-28 and CPP-79)
 have transuranic (TRU) elements that cumulatively exceed the TRU definition of 100 nCi/g This waste
 must go to a Nuclear Regulatory (NRC), Environmental Protection Agency (EPA) approved geoloeic
 ICDF specifically permitted for TRU waste.  Since this contamination resulted from over i 00 leaks in the
 high-level liquid and calcine waste pipes, and acknowledged in DOE's work plan document as HLW a
 legitimate case can be make that it still HLW and subject to Nuclear Regulatory Commission disposal
 regulations.  [CB-W]

 Response:  Tank Farm source areas are identified with spills of HLW and SBW   However we are not
excavating Tank Farm contaminated soils under this action. There is no need to refine our definitions at
this time. Under the Tank Farm  Rl/FS. the issue of waste classification will be further evaluated
 Decisions concerning the waste classification may also be made under the Idaho HLW & FD EIS ROD
In addition, there were not over 100 releases of uaste at INTEC associated with the HLW operations or
tacilities.
                                            A-23

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  Comment 92   : A Commentor stated that trying to get the Agencies to properly characterize the waste
  has been an ongoing effort. The Commentor also stated that without proper characterization  disposal of
  the waste would not meet the basic requirements for disposal.  In addition, the Commentor felt that
  previous disposal activities have been illegal. [CB-TM]

  Response: An evaluation of whether the wastes are subject to RCRA Subtitle C was made in the FSS
  X?«i 'ySK'  thC Administrative Rec°rd. It was determined that there was a significant amount of '
  INhEL CERCLA soils and debris having contaminants other than and in addition to radidnuclides
  Management ofthe non-radionuclides is subject to the RCRA requirements.  We are unaware of any
  •illegal disposal actions taken under the FFA/CO or under previous RODs.  We have characterized
  contaminated media and wastes to  the extent necessary to properly manage them. At Test Area North
  (TAN) groundwater. when we learned that the waste was a listed hazardous waste  we voluntarily
  modified  the ROD through an ESD to achieve compliance.

  Comment 93   : A Commentor felt that the gravel pits were mixed waste based on the site treatment plan
  and that the waste would need to be dealt with as a RCRA listed waste. The Commentor also felt that the
  tlyash and the sewage lagoons had similar issues and could not be written off as "No Action Sites " In
  addition, the Commentor stated that further explanation is required in the document. [CB-TM]

  Response: The gravel pits, flyash pit and sewage lagoons do not appear in the 1NEEL STP The STP
 only deals with waste that has been generated and requires treatment under RCRA for dealing with the
 hazardous components.  These sites are under the CERCLA program and were assessed for risk  Both the
 human health and ecological risks were determined to be acceptable for the gravel pits and sewage
 lagoons.  Remedial action on the gravel pit will be undertaken in Groups 2 (closed pit) and 3 (open pit)
 For the flyash pit, the human health risk was determined to be acceptable, but presented a potential
 ecological risk. This site was transferred to WAG 10 for further ecological risk evaluation and
 remediation, if necessary.  Closure of both the sewage lagoons will occur under other programs The
 Proposed Plan is a summary document and does not have the detailed information and rationale
 Additional information can be found in the RI./BRA, FS, and FSS along with this ROD.

 Comment 94   :  A Comment stated that "There are a number of environmental media at ICPP which are
 known to be contaminated with RCRA listed waste.  They include the tank farm perched water system
 the aquifer, and several soil wastes.  There are other soil wastes that may be contaminated with RCRA'
 hsted wastes. It would be a good idea to address these problems through a risk-based deiisting in the
 ROD.  By establishing risk-based deiisting concentrations in the ROD, then media meeting those
 concentrations could be managed as non-listed (though they might still exhibit a characteristic of
 hazardous waste). This would simplify issues of AOC and LDR at the ICDF.  if it is built." [C-W]

 Response: The Commentor is correct.  There are areas at INTEC that have been contaminated with
 waste having listed waste constituents.  Deiisting ofthe waste is not being pursued under this ROD
 Deiisting would not change how the waste is managed on-site. In addition, deiisting decisions under the
 ROD would not apply to off-site shipments.
 rno        A, Commentor stated that "N°n<-' °f the SFE-20 Hot Waste Tank System (Group?)
(CPP-69, cleanup alternatives offered in the ICPP plan meet regulatory requirements." The Commentor
also stated that the classification ofthe waste in the SFE-20 Hot Waste Tank concerning TRU constituent
NX                 -
NX us not correct. [CB-
Response:  Preliminary information supports that concentrations of TRU may be hiah enouah to require
disposal ol the Tank\ contents at Waste Isolation Pilot Plant (WIPP,. However, due to the radiological
hazards and access controls, we have not completed characterization of this tank and do not know how
                                            A-24

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    on^m   V  ,         'ed ^ th'S time- AS Ue have elected to exca™e ™* remove the tanks and its
   contents ,„ lull compliance wuh all applicable regulations, we must d.sa.ree with the
   concernmg our comrmtmem to comply with regulatory requirements. .  ~
                      >' information suPPorts that concentrations of TRU mav be high enough to require
   r  tt o    w     e T^, " nT" """^ ^ tO *« M*™1 hazards and »*«*
   restncnons, we have not completed charactenzation of this tank, which would be required even if we
   elected to leave the tank ,„ place.  In addition, because the tank contents have not been complete
   characterized whether the contents of the tanks are mixed waste has not been determined Tnde
   eva uation , ot alternatives, we concluded that Alternative 4 (Removal, Treatment, Z DfepoS which
   includes characterization activities, best satisfies the evaluation criteria. In addition, as we have  e  ed to

   '                                        '
d'agree wmrCVomm  T  "   * ^^ ''" *" C°mP'ianCe W'th a" -PP'-able regulations we mus
disagree w,th the Commentor concernmg our commitment to comply with regulatory requirements.

Comment 97    . A Commentor felt that the Tank Farm soils are transuranic waste The Commentor also
mqu.red as to whether add.tiona! sampling would be conducted and if it would change the  ™™
classificauon.. The Commentor also stated that if the Tank Farm soils have sufficient concent   i
                                                                                        s of
                               as TRU waste the soils would                                 ot
  Response: Some of the data from sampling activities in the Tank Farm indicate that there may be soils
  ctssifiefarTRTr"1"1'0115 °! ;nePT mm (NP)' PiUt°nium (PU)' 3nd americium ^ Am) ^opes  o be
  F± R FS (OU 3 ,4) fodte^" \h  "^ ^'^ ^^ " ^ PIanned "nder ^ Tank
  farm Khhb (O\j 3-14) to determine the concentrations and classifications of the soils  Based on the new
     '      '211011' risks to t
   veoo    ife,
 wo,? h  ,'h  H      S, 3re CXCaVated 3nd 3re C'aSSified 3S TRU" disP°sal in a deeP geological [CDF
  vould be the disposal location. For alternatives that do not excavate (generate waste) the Ss  the soils
 lei  m place would not be subject to disposal at a deep geological ICDF. but would be requTred to meet a
 performance object.ve considering the impacts on the SRPA and surface receptors.
 B.2. Risk Assessment

                 ^Omment10r *'< that the definition ^ clean that the Department of Energy is usin, is

                                                 « "re the imp.os.on ^an. w,,,
                     ,-    H                  °f the Nati°nal Co"<^ency P.an risk ran.e. A risk
compliance uthe NC^VFP^ ^   f^"™ ^ additi°na' TOnsideratiO" concerning risks.  („
concemm f rh     H ?   '   ,  ,  IS.USmg the UPPer limh in makinS the "sk management decisions
concernmg the need tor remed.al act.on.  For the CERCL A, program, restoration activities are directed at
 es onng an area to an acceptable risk.  At the INEEL. an acceptable risk has been defined a"t 1 0 000
due to the background contaminant concentrations that represent a 1 x I O'5 risk  Therefore some
                                 clean"P a«ivi»«- *« the res.dua, is considered acc^ta™ from a
                   e
' ,mn          i T      f SuVeM  altemalives evaluated i" ^ ^al disposition of facilities, with
 imploding and leax ,ng the building in place being one of the alternatives.  Criteria (risk to the SRPA.

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   alternative, leaving the building in tf^tote^^*""??* ^ "* ^^ range for
   Closure decisions and approaches a'e S^ it e pun  " o fhe m M VRCR 7 f "
   interim status unit, not the CERCLA O( ' i n pnn  !?              RCRA closure Plans for
   closure plans are being «,£^hS                                   I1* HWM
   bu.lding. an engineered barrier (cap) mav be necessary to nf I   th P  L-     remed'a' alternative for the
   that for some facility closure. 4h imTosion                     "   * aCCeptab'C Ievels' !t is true'
                                         the
                                                                                *.
   concenlrations «r= Used lo
   developed and evaluated »
              („,„ te Proposed
                              s tte
                                                                  prepared
                                                               95%

                                                                           1»™.'iv«
                                                                                      is ihen
                                              t^
"Risk should be calculated aero   CTP ^ ^all of ^ERr 'A T^'  ^ Com'"e»'°'- ™«d that
in the Proposed Plan." The Comrnentor aTso reoueMrf S    '   ?' ""' J"S' thOSe ChosBn for indusion
INTEC be stated. [C-WJ                  requested that the cumulate risk from all CERCLA sites at

Response: The cumulative risk at INTEC for the CFRn A r»t
                                                                                   The
   ite, Section.ofthe^t
 uncenaintv can be quanffied The nmr  ,ou
 plmon.um inveraot? relea edtc I
                                                      nsk P«="ic.ions and whether the
                                                                           !" '"« Sr-90 and
    be funher i.ne.tisated and eva,ua«
presented in the Rl BRA. FS and FSSdid not
           »dJitio,,al an,oun, ofdafa    "
                                             f    R/FS Tot"  ,4,™, S°1£-I?™E ' '' "hich
                                                                    addition, the analysis
                                         A-26

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   Comment 1 02  :  A Commentor questioned whether some sites in this Plan present a real risk to human

                                  ^ Sh°U'd ^ ^^ ^ lhe ^ °' a V'able risk should be
  Response: We are not sure which sites the Commentor refers to. Release sites without an unacceptable

                           "         "   "                "       '
  Comment 103   . A Commentor wondered, since the proposed ICDF will be outside the 100-vear
  floodplam and thus w.ll be acceptable under both RCRA and TSCA. how long will the radioactive
  portion of the waste present a risk to the environment? DOE Order 5820.2A requires a risk assessment
  for the radionuchde portion of the waste. What are the results of this risk assessment? [C-W]

  Response:  In the evaluation of the materials for potential disposal in the ICDF, some waste could remain
  sufficiently radioactive to present an unacceptable risk to human health receptors for approximately 800
  years. Th,s information is presented in the RI/BRA, FS, and FSS Reports. In addition' the ICDF will be
  S"  ' ,constructed' Derated, and closed to not adversely impact the SRPA or surface receptors
  Additional nsk analysis will be conducted under remedial design activities. The specific WAC will be
  developed with agency concurrence during remedial design.

  B.2.I. Human Health Risk Assessment

  Comment 104 : A Commentor was concerned that DOE is not using "maximum" contaminant data
  For instance, the  Snake River Aquifer risk assessment -90 levels used by DOE is 8 I yet DOE's own '
 samplmg data m  the RI/FS shows  14 aquifer monitoring wells that exceed the MCL including USGS-047
 with Sr-90 evels over 60 PCi/L. [INEL-95/0056; D-19] DOE additionally fails to acknowledge aqulfe?
 tritium contamina .on m excess of the MCLs. DOE's use of arbitrarily low or averaged sample date
 results in unreliable and non-conservative risk assessments. [CB-W]

 Response:  There are a number of aquifer wells near the INTEC facility that currently measure
 concentrations of radionuclides exceeding the MCLs. In assessing the risk to a hypothetical future
 resident, the max, mum contaminant concentrations predicted by the computer modeling were used  The
 MCL for radionuclides. beta and gamma emitters is 4mrem/yr from all sources.  The MCLs listed are
 calculated as if they were the only radionuclide present. Tritium, Sr-90 and 1-129 all exceed MCLs todav
 However, the reasonable timeframe that we would expect before the aquifer may serve as a drinking
 water source m the vicinity of the ICPP by future residential users is year 2095.  MCLs for this year ^095
 future use scenario, are modeled to be within acceptable levels for all but Iodine- 129 and Sr-90 The 8 1
 p<_ i. L br-90 referred to by the Commentor is the predicted value, rather than a measured value.

 Comment 1 05 :  A Commentor thought the Proposed Plan for the clean up for the contaminated  soils in
 the groundwater appeared to be well done under the overall conservative assumpt.ons in the regulations
 b> which they have to abide. The major concern was with the estimate and the calculations in that overlv
 conservative values have been used due to using a linear- and no-threshold approach, which has been    '
 shown to be incorrect.

 The Commentor pointed to recent scientific values of at least 5 rem - and there are actually two more
 recent values or 10 and 20 rem that have been reported instead of the 15 mR would lead to much lower
cost inures tor accomplishing a cleanup. Therefore, they felt that either these higher figures should be
used, or at least evaluated as an alternative cost estimate basis.  [LJ-TI]
                                            A-2 7

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 Response: Although this issue is controversial, we must conclude that based on the limited data
 concerning low dose epidemiological studies, the epidemiological data base is of very limited value in
 assessing dose response relationships. Based on the assessment of our experts and others, no alternate-
 dose response relationship appears to be more plausible than the linear non-threshold model on the basis
 of present scientific knowledge.  For radiation protection purposes, the weight of evidence causes us to
 continue to conclude that the risk from radiation increases linearly with the dose, in the low dose range
 above natural background radiation levels.

 Comment  106   : The measure of acceptable risk to human health as being I in  10,000 is very
 conservative. However, we can accept that criterion if the risk assessment is done in an acceptable
 science-based manner. Our major concern is that the risk assessment values calculated in this plan are
 based upon a nonscientific hypothesis. All risk calculations are based on the "linear-no-threshold"
 hypothesis, which links risks of cancer to radiation doses down to zero. There is no scientific evidence to
 support this theory,  in fact the Council of Scientific Society Presidents has stated that radiation levels
 below 10 rem per year are not clearly linked to an increased risk of cancer for adults.  Therefore following
 recommendations are offered on the Proposed Plan. [C21-W]

 Response:  The use of 1 in 10,000 is the upper end of the NCP risk range. A risk of 1 in 1,000,000 is
 considered the point of departure. The INEEL is using the upper limit in making the risk management
 decisions concerning the need for remedial action.

 Although this issue  is controversial, we must conclude that based on the limited data concerning low close
 epidemiological studies, the epidemiological data base is of very limited value in assessing dose response
 relationships. Based on the assessment of our experts  and others, no alternate-dose response relationship
 appears to be more plausible than the linear non-threshold model on the basis of present scientific
 knowledge. For radiation protection purposes, the weight of evidence causes us to continue to conclude
 that the risk from radiation increases linearly with the dose, in the low dose range above natural
 background radiation levels.

 Comment 107  : A group of Commentors recommend that risk calculations be done based upon more
 scientific criteria. For example: Take the Federal Limit  on  Public Radiation Exposure from the NRC
 General Public Limit of 0.1 rem/yr as the baseline or threshold for zero risk of cancer for the public. Take
 the Federal Limit on Worker Radiation Exposure of 5.0 rem/yr as the baseline for zero risk of cancer to a
 worker. [C21-W]

 Response:  Within the EPA regulations, a dose of 15 mRem/yr is considered the maximum allowable
exposure for the general population.  This dose roughly corresponds a risk of 3 in 10,000. Because there
currently is not a. better theory on radiation dose effect than the linear-no-threshold hypothesis, risks are
calculated with zero risk at zero dose. A dose of 0.1 rem/yr (100 mRem/yr) would correspond to a risk of
7 in 10.000 and a dose of 5.0 rem/yr (5,000 mRem/yr) would correspond to a risk of 3 in 100. Both of
these doses are considerably over the EPA standard and would be considered an unacceptable risk.  In
addition, the EPA is considered the primary organization responsible for determining risks to human
 health and the environment.

Comment 108  : Regarding the human health risk assessment portion of the Proposed Plan, page  17. a
 Commentor questioned, "what happened to the future resident beyond 2095?  [C-W]

 Response:  We are sorry for the confusion. The risks to workers both current and future (2095 and
 beyond) \\ere analyzed in addition to the future resident (2095 and beyond).  There were not any release
 sites that had an unacceptable risk to workers, either current or future, that did not also have an
 unacceptable n-sk to the future resident.  Based on this, the need to take remedial  action for release sites


                                              A-2S

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   was specified using the future resident. It should be noted that for all land use scenarios (current and
   future worker along with future resident) an unacceptable risk was defined as ,  n 10 000  A"O\ orkers
   are addmonally protected wlth worker controls that were not taken into account in assessing the 'risks

   Comment 109  :  A Commentor stated, "but you promise to clean it up. And if I haven't died from trace
   exposure to atomic waste ,n my aquifer [ just may live to see it. [RK-VV]

   Response: The CERCLA program is committed to cleaning up the contaminated areas at the INEEL

  aUNTEcThtamTed T^" ™S R°° ^ SdeCted remed'al aCt'°nS t0 remediate van'ous areas located

  TtrHrodoS!he:f?f™
   i nis cnronic dose is evaluated as being received over many years HO vpar« for r^iA^,^\      • , '
  Even if the exposure results in a tumor" the tumor will Mn^^^^Z^^,
  -pacts from the INEEL that result in unacceptable risk to the public were discovered %the OL°3I


  B.2.2.  Ecological Risk Assessment
 RMponse: For the ecological risk evaluation (screening level risk analysis) conducted at WAG 3 or

        X=
 Som   r  h          f"^ "''" "^ ^ ****** f° addreSS the POte"tial ewto^.7S?SS
 Some sites had a potent.ai ecological risk without an unacceptable human health risk Fo  these sites ' the
 remediauon levels are des.gned to reduce the contamination to levels below the concentrations riul int
 n a potennallv unacceptable ecological risk.  One site. CPP-66: Fly Ash Pit, is being deS to WAG  10
 to address the potennal ecological risk impacts from the release site.  In add tion, a finaTlNEEL-wLe
 ecobg-ca. nsk assessment, mcluding the impacts on populations, will be conducted under the WAG 1 0


 Comment 111: A Commentor stated the ecological risk assessment method and results are
 ^represented ^and this section needs to be clarified. For example, the first step of the ERAprocess is a
 background and EBSL screening, however an additional (much less conservative) assessment s heV
 performed on those s.tes that are not eliminated by this screen. This information needs to be  ncluded or
 the paragraph rewntten, smce currently it gives the impression that the preliminary screen i  th  onlt s^,

and Ztl-  r',1111130^^ 'S thC indUSi°n °fan appr0pHate discuss'on co"«™-"g ^e additional s^
 PP A TJ       e'im'^t.on step requested by the DOE-ID. EPA, and IDH W. Based on the results of he
 ERA those S1«es that had hazard quotients ( HQs) greater than 1 .0 ,27 sites) were eliminated as a  oncem



                                            -^
                                         A-29

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 receptors by the risk assessment process.  Due to the uncertainty in the risk assessment process (also true
 of human health) it is not responsible to state that "no risk" (implying zero risk) is posed. [RV-W]

 Response:  No changes were made to the final Proposed Plan to address this issue. The ecological risk
 evaluation in this ROD was written and expanded upon the Proposed Plan to address this comment.

 B.3. Remedial Action Objectives

 Comment 112  : A Commentor was concerned that the RAO of 2E-4 is consistent neither with NCP nor
 the statement on page 17 of this Plan which states that:  "...total excess risk may not exceed one in
 10.000." achieved by adding the risks from groundwater and soil. The RAO should be to reduce the risk
 at the site, from all pathways to acceptable levels. In addition, CERCLA identifies 1E-4 as the point at
 which remediation is required, not the point at which it stops.  Ideally remediation, once begun, should
 reduce risk to as close to IE-6 as is possible within the CERCLA decision making criteria. Strongly
 suggest the RAO be modified to comply with the NCP.  [C-W]

 Response: The NCP defines the acceptable risk range as 1 x 10"4 to 1x10"". The RAO is to reduce the risk
 from all pathways to within this risk  range for the residential scenario. Due to the fact that the risk from
 background radiation at the INEEL is approximately 1 x 10°, it has been determined appropriate to
 remeidate to the upper end of the NCP risk range.  In addition, this RAO. is using a residential scenario for
 the INTEC. which is a conservative assumption.

 Comment 113  :  A Commentor felt it is not a reasonable presumption that a person might build a house
 inside the current, ICPP fence, but drill a drinking water well outside the current fence.  Thus establishing
 RAOs for the groundwater outside the fence only while allowing people to live within the fence is not
 acceptable or consistent. Choose - where will people live and get drinking water, inside or outside the
 fence? Be consistent!!  If this results in different, less aggressive, remedial actions inside the fence, that
 is acceptable, just make it clear to the public. [C-VV]

 Response:  The Commentor is correct. There is an apparent inconsistency in the approach for
 groundwater discussed in the Proposed Plan.  Due to this inconsistency issue, the remedy for the SRPA
 has been changed to an interim action the area outside of the INTEC fenceline. The final action on the
 SRPA. including the area inside the INTEC fenceline, will be evaluated and the decision made under the
 OU3-14 RI/FS project.

Comment 114 : Reserved.

 Response:

Comment 115 : A Commentor questioned whether the proposed 100 year RAO will adequately protect
the future value of regional groundwater resources and the economic activities  they support.  [L-W]

 Response: The remedial action objective (RAO)  of year 2095 is based on our  prediction that government
control of INEEL may end and uncontrolled development may occur unless we commit to additional
remedial controls. This scenario is used in our risk assessment process rather than assume that we will
maintain all of INEEL as a government facility in perpetuity.  Areas like the ICDF will have these
remedial controls placed on the ICDF area. It will be designed, constructed and maintained as long as the
threat to human health and the environment persists.  These controls will include periodic reviews that the
remedy remains protective, land use restrictions, cap maintenance and other tangible physical controls as
                                             A-30

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                                                berestored
Snate River Aouife, be   ,
                                                                            *<*
                                                                                      <"
             comrois wi,, corainile ,„ De
                                                        ^
       °f
                                                       own
                                                                  as more
                                                                      of the MCLs resul,ing in
  B.4. Compliance with ARARs
                                              *•

the restriction on the land use tor CPP-95: and ihat the ^her^m "wTcT ^^^ "^ BaSed On


within the areal extent of CPP-95. the restricted portion of CPP-95 is definedSThTAO^Th'10" T








         n-uiuidi.  i ms KUU i> making decisions for a  of the known relpT

'•"•- nu the \VAG 3 AOC Muwn reiea.se biteb at INTEC and is A-31


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 Comment 119   : A Commentor wanted to know what kind of air emission controls will be in place
 during Chem Plant cleanup, particularly soil movement? [SRA-W]

 Response:  Various controls and actions will be used during the remedial actions to control air emissions.
 These controls and actions, such as dust suppression, will be applied to all remedial actions, including soil
 movement as appropriate and necessary. Also, short term risk concerns for workers, the community, and
 the environment will be further addressed at part of the remedial design and cleanup activities to ensure
 protectiveness.

 Comment 120  : A Commentor noted perched water under ICPP  is considered to be "waters of the state"
 and is covered by Idaho Water Quality Standards. ARARs for this OU.  Alternative 2 does very little to
 actively pursue compliance with these requirements, these ARARs. Please do not boldly state that
 Alternative 2 meets all of the ARARs. It does not. The Agencies are lying to the public again. [C-W]

 Response: The selected remedy for Group 4 (Perched Water) consists of reducing recharge to the
 perching zones.  This remedy will ensure that in the future, insufficient quantities of water in the
 contaminated zones are available for drinking water purposes. During the drainout period, the perched
 zones will be institutionally controlled to ensure the perched water is not utilized for drinking water
 purposes. Additionally, this remedy will reduce the flux of surface contamination to the regional aquifer.
 Since much of the contaminant mass in  the vadose zone at INTEC is adsorbed to sedimentary material,
 rather than soluble in the perched water itself, actively pumping and treating these perched zones offers
 little additional  long-term benefit, at significantly increased expense. This issue was openly discussed
 during the public meetings for cleanup of OU 3-13. The selected remedy is consistent with the provisions
 of the Idaho Groundwater Quality Rule and meets ARARs.

Comment 121   : A Commentor noted,  regardless of the alternatives selected, clean-up activities must be
done in compliance with all mandated requirements. Most of the activities involved in WAG 3  are
 located within previously disturbed areas within the fenced area of INTEC. Historic structures are present
within the study area, and a complete assessment of effect will need to be completed.  This is required
 under Section 106 of the National Historic Preservation Act.(36 CFR 800.2(o)(l)) [SBT-W]

 Response: Compliance with Section 106 will be achieved as will compliance with all applicable or
relevant and appropriate requirements.

Comment 122  : A Commentor pointed out that groups 1, 3. 6. and 7 include preferred alternatives
which require surface-water control, and/or soil excavation.  These actions may disturb cultural resources
during excavation.  In that case, all work must halt if buried cultural resources are encountered,  and
notification made to the LIMITCO Cultural Resources Staff so that they can work with the Tribes in
assessing the resources, mitigating the damages as necessary, and authorizing continuance of excavation.
Group 2. Soils Under Buildings: The D&D of all buildings must be done in compliance with Section 106
of the Historic Preservation Act, as stated above. Soils  from the  borrow area need to be closely monitored
to insure that cultural deposits are not inadvertently introduced into the construction area.  If deposits are
 found, a stop-work policy should be put into place and notification made to the proper technical groups as
outlined in the Agreement in Principle (AIP) between the Shoshone Bannock Tribes and the DOE. For
Groups 3.4. and 5: selection and construction of the disposal areas will need to be carefully considered.
 The areas will need to be surveyed for cultural resources that may be present, which would require
 substantial testing.  This is especially true if the Big Lost River is diverted or lined because of the
 historical importance of the ri\er to the Tribes. [SBT-W]
                                              A-32

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   Response: Performing an archeological survey prior to any site disturbance is a lone practiced
   reqmrement at INEEL. If cultural resources are encountered, work will be halted or moved from the
   affected location until proper precautions can be taken to protect invaluable cultural resources.

   Comment 1 23  :  A Commentor noted that because of the proposed use. the facilities will be verv long
   17™' Trheueffect to cultural ^sources, in the event they are present in the area, would also be long tern
   Many of these resources are a non-renewable testament to the Shoshone-Bannock historv  or are *"
  resources that still have considerable importance to the Tribes. After the areas have been closelv
  inspected prior to construction, close monitoring during construction will  be required to insure that
  cultural resources are not damaged or destroyed. Mitigation of damage to cultural resource sites will need
  to be coordinated with the Shoshone Bannock Tribes and contractors as outlined in the AIP. [SBT-WJ

  Response:  Performing an archeological survey prior to any site disturbance is a long practiced
  requirement at INEEL.  If cultural resources are encountered, work will be halted or moved from the
  affected location until proper precautions can be taken to protect invaluable cultural  resources  The
  location of the ICDF is in a partially disturbed area. The Group 3 soils are in already disturbed areas
  Also, both of these areas are within the existing archeological survey zones.  This will help to minimize
  cultural resource impacts.                                      "                   K

  Comment 124 •:  A Commentor noted that where the preferred alternative calls for the removal  storaee
  and treatment of contaminated water, it should be kept in mind that this action might indirectly affect
  cultural resources.  The full scope treatment and storage plan will need to be reviewed and commented
  on. The feasibi ity of cleaning up water resources will need to be demonstrated, and assurances given that

                               * and aquifer waters win not cause more pr°biems and
 Response:  If necessary to restore the aquifer to drinking water quality, the groundwater extraction and
 treatment system will be sited so as to minimize the impact to cultural resources.  Implementation of the
 contingency act.on for aquifer cleanup, will only be in response to clear evidence that:  ( 1 ) extraction and
 treatment is necessary to meet the aquifer restoration timeframe; and (2) treatment technology can cost-
 effectively remove the hazardous contaminant (i.e., 1-129) from the groundwater.  Disposal of the treated
 groundwater will also be such as to minimize the impact on cultural resources and comply  with ARARs.

 Comment 1 25  : A Commentor suggested reasons against siting a new disposal site at the Chem Plant is
 found in the NRC's 10 CFR Part 61 regulations for land disposal of radioactive waste, which should be
 included with other Applicable or Relevant and Appropriate ("ARARs"). RCRA subtitle C requirements
 do not apply to LLW Under Part 61 , "The primary emphasis in disposal site suitability is given to
 isolation ot wastes, a matter having long-term impacts, and to disposal site features that the long-term
 performance objectives of Subpart C of this part are met. as opposed to short-term convenience or
 benet.tslO CFR 61.50(a). This same primary emphasis appears in the joint NRC-EPA siting guidelines
 N RC s regulations go on to note that "The disposal site must designed to complement and improve  where
appropriate, the ability, of the site's characteristics to assure that the performance objectives of Subpart
 C of this part will meet 10 CFR 61. 51(a)(4).'"[L~W]                  '       .             '

 Response:  The Commentor is correct.  RCRA Subtitle C requirements do not apply to disposal of LLW
However, the design criteria for a RCRA Subtitle C disposal facility are more conservative  and
prescriptive. DOE Order 435. 1 was added as a To Be Considered (TBC) ARAR to deal with the LLW
issue. In addition, the Commentor apparently cited an incorrect section of the Code of Federal
Regulations (CFR). The correct citation is 10 CFR 6i.5l(a)(3).
                                             A-33

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   Comment 126  :  A Commentor felt that the ICDF is a transient attempt bv the Agencies to avoid
   (rating m.xed waste to LDR standards prior to disposal. Please describe how a .roundvvate moni onn*
   .system would be designed to detect releases fronuhe ICDF when the "background" concetaZ of
   contammants ,s already h.gh?  Where would the upgradient "'clean"  well(sfbe located '7vtere'vou°d the
   downdgrad.ent wells be located so that on contamination from the ICDF would be detected? [C-W]

   Response:  The ICDF is not an attempt to avoid treating and appropriately disposing of mixed and other
   hazardous wastes. INEEL CERCLA waste (soil and debris) from within the AOC wou Tnot necessity

   fo?r STf Pn°r t0 d'SPOSaL Th£ in-A°C WaSte WOUld be re^uired to ™« the accep^nce cr  e a
   for the ICDF. If treatment ,s necessary for in-AOC waste to meet the acceptance criteria (stab"lizahon for
  subs.dence or leaching control), the w-aste would be treated prior to disposal.  INEEL CERCLA u^
  from outs.de the AOC. would be required to meet the requirements of Phase IV of the Land ofsoosa
  Restr.ct.ons (LDRs) regulations. For OU 3-13 soils and debris, which have triggered placement

   o?.rnR t0,?he P,haSe IV,LD,RS Wi" be reqUired Pn'0r t0 disP°Sal in 
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   Response: The alternatives in the FS and FSS Reports were developed and evaluated to reduce the risks
   to acceptable levels.  Alternatives were not developed to reduce the risks to different levels below and
   including acceptable levels g.ven the existing background contaminant concentration alternatives were
   not developed  All of the alternat.ves selected in this ROD will reduce the risk to acceptable levels A

   or"»e°n ana'VSiS VVOU'd ^ USefUl 'f deanUPS W6re bCing C°nSidered * di^»< I"*

   B.6. Implementation of Alternatives

  Comment 130  : A Commentor recommended that for Group 2 the contaminated dirt should be left in
  place. The Commentor thought this is logical, but in other instances, such as VES-SFE-20 you intend to
  perform total removal  This is not consistent.  If you can indeed leave Group 2 soil in place TfoT.ows
  that you should be able to leave VES-SFE-20 and other contamination in place. [TW-W]   '

  Response:  Group 2 represents a unique problem for managing contaminated soils at INEEL  These
  areas are still m operation and located under structures. We could have chosen to wait several decades for
  the determinations to be made on the above ground structures. However, we have elected to establish a
  performance standard at this time. The end state of these contaminated soils will be to provide sufficient
  protection to the underlying groundwater and future site users. As for the SFE-20 Tank System  the most
  cost effecnve and nsk reducing alternative is Alternative 4.  Based on this we concluded that A terna™
  4 (Removal, Treatment, and Disposal), best satisfied the evaluation criteria.               Alternative

  Comment 131   :  A Commentor wondered, how long are engineered barriers assumed to last* The
 engmeered barrier for the soil under buildings will be designed to last 1,000 years, but how does that
 relate to the length of time residual contamination will pose a hazard? [SRA-W]
           r.TPrifeM0f engineered barriers is based on the material used in the construction. The
           b at INTEC will present an unacceptable risk for a significant period of time (beyond 2095)
 Based on this the engmeered barriers will be constructed using native or natural material  havTng useful

 Shrift "I H' 8    IT' "m5rameS (' -000* yearS)" F°r m°St °f the rad''oactive contaminants
 decrease  r'n^rTv ,'"     ^ * ^'^ ^ Wi" reSU" J" ^3ter than  one ^onfold
 decrease from the initial concentrate, due to radioactive decay.  For non-radioactive metal
 contaminants these will remain hazardous indefinitely. Contaminants will not be placed in the landfill
 wh,ch have a h.gh potential to leach to groundwater.  Cap maintenance to prevent Lure intrusion w
 contmue as long as an unacceptable risk remains. The engineered barriers (caps) will be desTgned to
 remain effecnve to at least the amount of time that the contamination present would present M
 unacceptable risk.

 Comment 132  :  A Commentor asked, "will  any of the caps or covers proposed for the Chem Plant
 require maintenance?  Please describe this effort fully." [SRA-W]

 Response: Yes, there will be monitoring and maintenance activities for the engineered barriers (caps)
 following the construction activities. A strong post-closure monitoring and maintenance program is
required to insure that any landfill contains the disposed wastes. The final cover will be designed to
mimmize maintenance needs.  Requirements for the monitoring and maintenance plans will be developed
ab pan ot the remedial  design process.

B.6.1.  Environmental Monitoring
                                             A-35

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 Comment 133   : A Commentor wondered, since the preferred Alternative 2 calls for continuing existing
 environmental monitoring. What monitoring is currently underway? I know of no groundwater
 monitoring, in particular, which is intended, or capable, of detecting releases from any particular unit.
 Ho\v will the lack of such monitoring be deemed protective of human health and the environment? This
 Alternative is a "feel good" alternative because  it makes the public feel good - because they don't know
 enough to realize they've been hoodwinked again. This alternative, as worded, is not acceptable. [C-W]

 Response: Environmental monitoring for Group 2 soils where the hazard  is based on surface exposure is
 a periodic evaluation of what exposures workers and the public are exposed to in and around the Group 2
 buildings. A detailed post-ROD monitoring plan will be developed during remedial design/remedial
 action.

 Comment 13-4  : A Commentor stated that "Most of the Alternative include continued "environmental
 monitoring." The fact is few, if any. of these sites are currently subject to site-specific environmental
 monitoring. Your portrayal that they are is misleading, at best, and a damned lie, at worst. The INEEL
 cannot detect contaminant releases from any specific site, and would be lucky to detect additional releases
 from the ICPP as a whole." [C-W]

 Response: Discussion of the proposed type of environmental monitoring for the various remedial action
 groups is included within this ROD.  We recognize the difficulty in detecting releases at INTEC. A
 monitoring plan is being developed to conduct the long-term monitoring at 1NTEC. This monitoring plan
 will address the issue of releases from specific locations at INTEC.

 Comment 135  :  A Commentor when referring to Page 43, Alternative 1 stated that "There is no
 site-specific environmental monitoring, to my knowledge, at this site. Don't state there is; it's a lie "
 [C-W]

 Response: The environmental monitoring referred to for this non-selected  alternative would have
consisted of monitoring the perched water wells  in the immediate area.  In addition, two additional
 monitoring wells clusters would have been constructed next the SFE-20 Tank System and monitored to
 identify releases.

Comment 136   : A Commentor was unsure what the Proposed Plan meant in the Evaluation of Site
 Risks section. Environmental monitoring.  What will this consist of?  Is any such program currently
carried out at these sites?  If a specific environmental program now exists, what budget is it under? [L"-W]

Response: Environmental-monitoring activities can consist of \ arious types of monitoring (air exposure.
direct exposure, and groundwater contamination). The env ironmental monitoring for each of the remedial
action groups, if necessary, is different. Additional details concerning the environmental monitoring for
the  remedial action groups can be found in various sections of the ROD. Many of the sites requiring
remedial  action are not currently monitored for releases to the environment. Currently, there are several
programs conducting environmental monitoring at the INEEL.  Each of these monitoring programs has
different  criteria and purposes along with budgets.

B.6.2.  Institutional Controls

Comment 13^   : A  Commentor wanted to know how long arc  institutional controls (e.g.,.fences.
regulatory restrictions) assumed to last?  Page I1) says residences might be built at ICPP after 2095  but
that water >upply wells vvill be prohibited within the current fence.  How vvill that prohibition be
maintained? Bv whom?  How does the current ICPP fence relate to the 1-129 plume? [SRA-W]
                                             A-36

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   ^r?r   h           C°mrols VVlil bC maintained lo"g after 'the 2095-restoration timeframe has passed
   for areas where an unacceptable risk remains.  Whether fencina will be required or other controls are
   surticient to prevent unauthorized access to these areas is undeT review and w.ll be PTrt o  thT'emeLl

   S wSe I^TcT1^ ^H0'^ aCti0nS "^ ^ neC£SSary t0 deai W'th ^e conta^rnl " he
   wHI ^1    r  theINTEC knee and therefore an mtenm action will be implemented on the SRPA  This
   n e±l  Tl0nSll   'ak;n,t0 deal U'ith the contaminatio" °"ts,de the fence and additional '
   Fa! R. FS      Hg "    T6?'31 aCt'°n altematiVe eVaIuati°n t0 be Conducted in S"PP°* of the Tank-
   Farm RI/FS. Land use and other restrictions will be placed on the areas requiring Ions-term institutional
   control and w.ll be mamtained by DOE or another government agency. The are of theT-P9  p ume'ha

   Siif'S^ nSs?1* rdir (reeds drinking ™da^> «««* °L  £ i?
   outside of the INTEC (ICPP) fence downdgradient to approximately the Central Facilities Area (CFM
   The mst,tut,onal controls to be implemented under this ROD are contained in Sectio    Onhe ROD '
  These msmuuonal controls are presented in tabular  format for each of the remedial action groups

  Comment 138   :  A Commentor wondered how the  Agencies would implement institutional controls over
  engineered barriers or design a combination of the two? [SRA-W]                       ^nirois over
           f deCt,i0n °f insti™ionai and «>gi««ring controls is determined during the development of the
         acuon alternatives for evaluation purposes. Additional controls, both institutional and
  engineering, may be applied during the remedial design process. Combinat.ons are factored into the
  alternate as necessary. The ICDF will consist of a combination of institutional controls and physical
  (engmeermg) barriers.  Institutional controls, like land use restrictions are a necessary part of the remedial
  act,on  Prevention of b,o,ntrusion and material degradation are not institutional comrols bu these Sues
  are addressed by physical (engineering) controls.
 a^Tdoc'umenL'  Th^ST101" ** k W3S Undear how Iand use ™*<*ons can be, or will be, imposed
 and documented.  This BLM property is currently under DOE control. Will DOE provide a feral
 description of restricted property to the BLM? How will BLM control the restricted property- Please
 descr.be, in the ROD. how land use restrictions will be accomplished. [C-Wj

 Response: This ROD contains a description of institutional controls to be implemented.  A detailed 1C
 b ne ^h   H       PH dur'n^reniedial desjg" " d<^ribe the controls that will be placed on the land
 beneath and surrounding the CERCLA release site area at  INTEC.


                    C.  RELEASE SITE GROUPS AT WAG 3

 C.I. Group 1: Tank Farm Soils


 Comment  140  : A Commentor wondered if the cost of tank farm soil remediation included in the
 current ICPP cleanup cost estimates? [SRA-W]
          RnnT' Jfj™1 "mediation ofthe Tank Farm soils is not included in the cost estimates.
Under  h,, ROD for the Tank Farm Soils (Group I ), an interim action is selected. The Tank Farm Soils
    e, .mate only reflects the scope of items described in the mterim action alternative evaluation and

            T '"    r°f eStimatf-  F°r the fina' aCti°n °n the Tank Farm Soils- cost estimat" -ill be
(OL 3  14)      "        aCt'°n altematives that wi!l be developed and evaluated for Tank Farm RI FS


Comment 141  : A Commentor recommended that DOE move quickly in making its final risk
management decision for the Tank Farm Soils. [CAB-W I           '

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  Response: We support the need for action where feasible.  However, under the OU 3-13 RI/FS,
  evaluation of the 1NTEC Tank Farm Soils was done using the limited information from the scoping
  investigations (Track 1 and Track 2 studies) and process knowledge. With this limited knowledge'the
  final action the Tank Farm would have had a very large associated"contingency (hundreds of millions of
  dollars). Based on this, it was decided to consider an interim action on the Tank Farm Soils for the near
  future and collect the necessary information to make a decision without such a large uncertainty.
  Collecting and analyzing data along with the decision making activities is being conducted under the OL"
  3-14TankFarmRI,-FS.

 Comment 142  : A Commentor noted that the Proposed Plan states that a final risk management decision
 is anticipated  for the Tank Farm Soils in 2004. The Commentor wondered why it will take that long to
 make that decision and recommend DOE move quickly to safely manage the risks posed by the Tank
 Farm Soils. [CAB-W]

 Response:  We appreciate that we need to expedite the cleanup process where feasible. However, the
 tank farm soils interim action will  reduce the risk to the environment and in particular the SRPA.  Even if
 a final action would have been selected under this ROD, the  implementation of the alternative would have
 been phased in over a long period of time. The final part of the action would likely occur around 2045,
 following D&D of the area around the Tank Farm. The actions taken under the  interim action will be
 continued, along with other activities to reduce the impact on the environment, until the final activities are
 implemented.  This approach means that we will manage the risk at the Tank Farm safely and efficiently.
 Insufficient information was collected prior to and during the OU 3-13 RI/FS to make a final decision
 without a very large contingency and uncertainty. In order to collect the necessary information, develop
 and analyze alternatives, and conduct the decision making activities, a new RI/FS is being undertaken.
 This RI/FS (OU 3-14 Tank Farm RI/FS) will collect and analyze samples from within the Tank Farm. In
 addition, the results from the Idaho HLW & FD EIS will be considered in the remedial alternatives
 developed and analyzed. Recent evaluations on the scope, schedule and budget for the OU 3-14 RI/FS
 indicate that it will take more time  than expected when the Proposed Plan was released. A final  risk
 management decision for OU 3-14 is now expected to be completed prior to 2008.

 Comment 143  :  A Commentor had questions regarding Group I Tank Farm Soils: If only an interim
 action is currently contemplated, why is this site group/OU group/CPP group included in this Proposed
 P!an?[U-W]                                          ~

 Response: An interim action was selected for the INTEC Tank Farm to reduce the impact on the perched
 water and SRPA.  In the evaluation of risks to the groundwater. the largest source of contamination was
 identified as the INTEC Tank Farm. As the contamination is migrating vertically downward, reducing
 the driving mechanism (water) will increase the travel  time and decrease to impact on the groundwater.
The interim action selected is intended to significantly reduce the amount of water driving the
contamination into the groundwater.  As such, the sites within the INTEC Tank Farm group are included
 in this ROD.

Comment 144  :  A Commentor had questions regarding Group 1 Tank Farm Soils. It is stated that "non-
 radionuclide contaminants may be present." Why don't we know? Weren't the RI, BRA. FS, or FS
supplement completed?  Or were they incomplete? If so. why? If no, why isn't the characterization of
contaminants fully presented here?  If the complete characterization of the Tank Farm Soils has to be
deferred to the OU 3-14 RI FS. as stated on page 13. why not just pull this whole group out of this
document? [L'-W]

 Response:  Within the INTEC Tank Farm, there is incomplete knowledge concerning the contaminants.
both radiomiclide and non-radionuclide. and their corresponding concentrations.  Previous sampling
                                             A-3S

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           D                     aVC =enerall-v not analyzed tor non-radionuclides. The Rl, BRA FS
   and FSS Reports were complete documents. These documents identified the data gaps in the existing '

   FZ  AgR , J?    m    K^ gapS and make a m°re infomed and better Decision on  the INTEC Tank
   Farm  A RI FS project is being planned to resolve the data gaps, evaluate remedial action and eventually
   select the final remedy tor the INTEC Tank Farm group.                                  eveniuanv


   C.I.I.  Group 1  Description


   Comment 145  : A Commentor pointed out that Tank Farm Soils: Site CPP-33. listed as a Tank Farm
   Soils Group site on page 1 2. is not shown in Figure 4. [U-W]


   Response:  The Commentor is correct in that Site CPP-33 was left off of figure 4.  Site CPP-33 is part of
  remedial action group 1  (INTEC Tank Farm area).  For future documents, additional effort will be
  expended to insure that sites listed in text match the figures.


  C.I. 2. Group 1 Alternatives
  be°en Tnenil4r6H ''  * Comm?ntor ** ** ^^ * C°mro1 SUffaCe Water is an activity which should have
  However th  A " S°°n !*    * T ^^ '° ^^ *" ^^ W3tCr infiltration V*™** * risk
  However the Agencies have not demonstrated, through published/measured K* and measured infiltration
  rates, that surface percoiat.on is a risk-driver at this site. Therefore selection of this alternative in a ROD
  is premature. It would better fit a removal  action than a ROD. [C-W]             a.ternat.ve m a ROD
 Response: The infiltrating water requiring control is not only from the Tank Farm fenced area

 ttfTanknaFaTrR'TaCtS C(^^m^ drains Iocated on *e building and structures in and surrounding
  he Tank Farm  Reducing the mfiltrat.on of water through the Tank Farm Soils will increase the travel
 time of the conttunmants m the soils, irregardless of the contaminant specific retardation factor (£)  This

   ± 7 mRSn    ^   ' Subsec>uent|y reduce the impacts on both the Perched Water and SRPA
           Rn
 Tank Farm So?' " -n"^1" ^ ^ ^ "^ ^ >S bei"8 Undertaken'  The final actio" °"
 Tank Farm Soils will be evaluated and selected under the OU 3-14 project. There is no need to
                                                                        S°ils
 Comment 147  :  A Commentor was concerned the interim solution is. in essence, capping it putting
 some dirt on ,t, bury it. That's the first step.  Question: Is that going to be the 'first step towards a delcto

 3! S                            ^ ^ ** ^ thi"g to d° f°r the Ta"k *™ and to leave
Response: The proposed Tank Farm interim action is not a capping solution. The goal of the interim
action ,s to reduce the amount of water infiltrating through the soils within the Tank Farm area

Rl reSn e -ll6 ',        " 'r n0t T?Sarily th£ fifSt St£p m U d£faCt° CaPPJn* aPProach- The Of 3-14
K1;H> xvill evaluate a range of remedial action alternatives.
              s-: A C7mem°r Was conce^^ *« the interim solution will turn out. migrate into the
              \ ou made ,t very, very clear that this is merely an  interim solution and does not in anv
  ay atfect whatever the final solution will be made. [DK-TT]
Response:  The proposed Tank Farm intenm action is not a final action. Interim actions that are taken

                                             °U 3"'4 RI FS wi" CValuate a ran^e of remedial action
                                            A-39

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                     C0mmerr"°r ^SK"- a* 'l«.v soil's 10 cap around the Tank Farm, basically.'  And
                                     ' lhousl" Ihe Tank Famis                             '
  Response: In the development and evaluation of the proposed interim action, capping around the Tank
  Farm was not considered. Sealing the surface of the Tank Farm is a necessary component of the remedial
  action, in addition, reroutmg of the drainage from the various buildings in the Tank Farm area may be
  necessary- to reduce the mt.ltration. The evaluation, for the Tank Farm interim action, focused on a  «oal
  pi reducing to mhhration in the Tank Farm by 80%. The remedial design will further evaluate the  "
  infiltration issue and determine the specifics for the implementation. Concerning the leakage issue  there
  is no evidence that the tanks have leaked or are leaking. The known releases are^onlv fronTthe transfer
  lines and  valve boxes.  Actions have been taken to correct the leaking lines and valve boxes and to "
  prevent future releases.

  Comment  150  :  A Commentor wanted to emphasize the fact that they didn't want to see an interim
  action on  the Tank Farms get to  far - I don't want it to get past the point of no return where you put so

  bTthe 'fi'aTsotZ W^Zrn* thlS aCtI'°n ^ " beC°meS thC fina' S°!Uti0n WhCn " ^^ Sh°Uidnlt

  Response: We agree with the Commentor.  An interim action under CERCLA can not be inconsistent
  with the Imal action tor the site or OU. The evaluation of alternatives for the Tank Farm RI/FS will be*in
  w ,th the continuation of the interim act.on for the Tank Farm and build upon the interim action.

 C.2. Group 2: Soils Under Buildings and Structures

 Comment  151   : A Commentor noted that several spills, in addition to CPP-80. included both RCRA
 listed and characteristic waste.  The soils must be managed as listed waste, and possibly as characteristic
                         *" "^ UnderSta"d h°W much haz^dous waste is proposed for disposal at
                ICIJF w"l be designed and constructed to be compliant with the requirements of a RCRA
 m, ,   ,ty * . ^°'u.me eSUmates tor the INEEL CERCLA hazardous and mixed waste candidate
 materials (soils and debris) are presented in Appendix C of the FSS Report.

 Comment 152  : A Commentor wanted to know, if the sites are inaccessible and poorly characterized
 ZThT™  r\      '" ^^f^ar determined? How are the Agencies sure risk even exists at those sites
 that have not been sampled?  Those sites which have not been characterized and determined to present a
 mk to human health .and the environment should be removed from this Proposed Plan and discussed in
 the tuture when COCs. risk, and fate and transport are better understood. [C-W]

 Response: The analysis and evaluation conducted on the soils under building sites (Group 2) were based
 on what information was available.  The general characteristics of the material (waste) released to the '
 environment was known.  In addition, an approximate volume of material released was known For the
 evaluation of nsk and remedial actions, the COCs used were the constituents contained in the waste
 released. The risks were evaluated based on the mass (concentrations and volumes) of the COCs   As
 such, there was sufficient information available to evaluate the release site risk and remedial action
alternatives.

Comment 1 53  : A Commentor quoted from the Proposed Plan that, "...source releases are not well
dclmed and wanted the Agencies to "stop this nonsense until they are well defined and appropriate
                                             A-40

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   Sopotd       (CW                                       «" P"™   «=-.ive fram ,h,s

  have any quant.ty of what those materials amJm to?  J^S                        d° T
  are you looking at?" [PR-TT]                                           stabilizing them, or what

[DK-TT]

                                         A-41

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   Comment 156  : A Commentor offered the following recommendation regarding Group 2 C Soils under
   B                            - characleriza"on is incomplra- ' suggest * b
   Response:  For the Soils Under Buildings group, there is incomplete knowledge concerning the
   SS^Son? radl°nUClide and "— dionuc.ide, and their corresponding concenSn*.
   Development of the source terms evaluated was based on process knowledge  This process knowledge
   involved the waste stream released along with an estimate of the vo.ume. for two of he Set ' because- in fact! no decision has been
 made now" S"8 ^ ^ S°™ ^ ^'^ ™ ™ds< we're ^°in^ tO Wy this decisive
 made now. That doesn't make any sense. [DK-TT]

 Response: The Commentor is correct in that decisions under the OU 3- 1 3 project will be made prior to
 the decisions concerning the facility being made. The known scope of the FF A/CO for WAG 3 was
equated wuh.n the OU 3-13 RI-FS for a comprehensive evaluation.  The sites  within Group 2 a"
 idemmed scope m the FFA/CO.  Ultimate disposition (D&D) for the facilities above these sL has not
been determmed. Dec.sions concerning the D&D of these facilities mav result from the analysis being
Shth .• vh,r-               RCRA'HWMA Clo-e P'ans ^r Interm      Un
Should the lacihties be left m place, an engineered containment structure (Cap, will be constructed over
                                            A-42

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  the site to prevent the contamination from leaching and migrating to the SRPA. If the buildings were '
  removed, the contaminated soil would be removed and disposed."

  Comment 160  :  A Commemor felt that the alternative for Group 2 soils is the No Action Alternative
  because no action .s going to be done as a result of this decision. I mean, if we accept the recommended

  Jn^f »7l,  S 'SKg°M8 l°H haPPeu? ?* 3nSWer JS' abSOlUtdy n°thing Umil S0me °
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 Response: Yes. many of" the sites have contamination below 10 feet. Both Sites CPP-36 and -91 were
 specifically pointed out as they have significant contamination present below the 10 feet depth. However.
 most of the sites do not have significant contamination below 10 feet. A description of the nature and
 extent of contamination (including depth of contamination) at these soil sites is included in Section 5 of
 this ROD.

 C.3.I.  Group 3 Description

 Comment  164  : A Commentor noted that "nonradionuclide contaminants" are included in the COCs.
 Please state whether these soils are contaminated with RCRA listed waste or exhibit a characteristic of
 hazardous waste. This is important to determine how much hazardous waste is being proposed for
 disposal in the 1CDF.  [C-W]

 Response: The COCs were developed from a risk assessment standpoint.  Some release sites may have
 concentrations of "nonradionuclide contaminants" high enough to qualify as RCRA characteristic waste.
 In addition, some release sites have listed waste code issues. The sites with the listed waste code issues
 are presented in  Appendix G of the FS Report. Also, Appendix C of the FSS Report contains information
 on the candidate materials for disposal in the ICDF, including "nonradionuclide contaminants."

 Comment 165  : A Commentor had a question regarding whether soils pass or fail TCLP9 Is lead greater
 than 400 ppm? [C-W]

 Response: Sampling analysis conducted under the CERCLA program generally analyzed for total
 constituent concentrations. This analysis is not the same as the Toxic Characteristic Leaching Procedure
 (TCLP) sampling analysis conducted for hazardous waste characterization processes. There is a method
 to convert total metal analysis results to TCLP results for initial characterization. Under this method,
 there are release sites at INTEC that are potentially RCRA characteristic. Future sampling analysis would
 be conducted for final waste characterization.  None of the release sites under this ROD have
 concentrations of lead at or exceeding 400 mg/kg.

 C.3.2. Group 3  Alternatives

 Comment  166  :  A Commentor had a question regarding Other Surface Soils (Group3). The preferred
 Alternative 4-A is to excavate contaminated surface soils to a depth often feet. A review of the RL'FS
 Appendix C borehole sample data for Strontium-90 and Cesium-137 shows that DOE's arbitrary ten foot
depth would leave most of the contamination in place because it goes down generally to thirty feet.
 Unfortunately, there is not sample data for all of the sites in this group (and there should be), but at least
 four sites need to go to around 15 feet and four sites need to go to about 30 feet in order to recover the
bulk of the contamination. Stopping at ten feet is not acceptable and is not supported by the data.  To cite
an example. CPP-36 has 50,000 pCi/g of Sr-90 and 200,000 pCi/g of Cs-137 at fifteen feet of depth.
[INEL-95-0056] A fixed health base cleanup standard is needed and then require DOE keep digging until
the samples show that the contaminates do not exceed the standard is needed. [CB-W]

 Response:  It is recognized that there is contamination at depths below 10 feet. The 10 feet excavation
depth uas selected based on the residential scenario, which assumed a basement excavated to 10 feet, for
evaluation in the  RI  BRA Report. This assumption was also used in  the development of cost  estimates
and evaluations for the FS Report.  Using this information, an  excavation to 10 feet will result in
protection  for potential surface receptors.  The residential basement scenario is also protective of future
industrial or commercial  construction. However, some sites have large amount of contamination below
 10 feet.  During the remedial  design, the actual approach and excavation depths, which may go below  10
 feet, \\ill bo determined to ensure that the SRPA is protected from the contaminants. Although the


                                             A-44

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              10
           are disposed
   site disposal.
      ^-^^^
     presenting unacceptable risk to the aquifer versus off-
  expensive than an on-site solution
  disposal might be.  Particuiarlv if
  facility, which would include all the
  contractors and among
  the cost of disposal one
               ? the T of disposal for public
             t  ,SP°S  T"'' be marked'y m°re
                 'f 'S °f theSC °ther °ff-site °Ptions for
   «* TTh"8 " ""' " deVd°Ped °OE °n-site disP°sai
            c°kntrac;°r WOI-k- all the coordination amona
            lt be 3 ^'  'ded cost «*".*, not simply


          disposal ai
.he aquifer vmus olte dspol
                       »ithou, increased risk ,o
» c can c,tc. So ,here needs lo be ..
                                                            b
                                                          8° " '*
                            is in Wrilins and whal
A-45

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                                                                                                               1
   10 feet just because it's 10 feet.  You're only going to stop when you reach a level that won't continue to
   impact the perched water or the aquifer below whatever global limitations you've got there." [CB-TM]

   Response: It is recognized that there is contamination at depths below 10 feet.  The 10 feet excavation
   depth was selected based on the residential scenario, which assumed a basement excavated to 10 feet for
   evaluation in the RI. BRA Report.  This assumption was also used in the development of cost estimates
  and evaluations lor the FS Report. Using this information, an excavation to 10 feet will result in
  protection »or potential surface receptors.  However, some sites have large amount of contamination
  be ow  0 feet.  During the remedial design, the actual approach and excavation depths, which may go
  below  lOfe* will be determined to ensure that the SRPA is protected from the contaminants.  Although
  the remedial design may call for excavation to depth greater than 10 feet, we believe that the volume
  estimates are reasonable for evaluation purposes.

  Comment 171  : One Commentor recommended that we refine off-site waste disposal cost estimates
  based on input requested from the various commercial disposal service providers. Respondents should be
  provided with updated volume and waste type projections for all INEEL waste streams reasonably likely
  to require disposal, and be asked to identify closure, post-closure care, general and administrative    ' "
  overhead and other fees included in their estimates.  Verify that full life-cycle costs (including closure

  foTon reDoTd±mr T°hrin8'f,en,f 3l 3nd admi"istrative exPenses- *c.) are included in cost estimates
  foron-sue DOE disposal.  Th,s will allow meaningful comparison with "fully loaded" off-site disposal
 C?  w    r  ^ Pr°m0te "appi£S t0 3ppleS" comParis°ns, costs for Chem Plant disposal alternative
 should explicitly present the cost of an on-site facility sized to handle the same 83,000 cubic yards of
 waste analyzed for off-site burial.  I believe that these analytical refinements will reveal a much sma° er
 differential between on-site and off-site disposal costs. [L-W]

 Response: The cost estimates performed in the Feasibility Study do reflect actual costs from previous
 DOE disposal activities. These estimates are preliminary, order of magnitude estimates and will be

          rei
                                                    ,                               w   e
/nm r-reti;   f o fSIgn/,r°8reSSeS- The CStimates C0nform with Offlce of Management and Budget
(OMB) C.rcular A-94 guidelines and the NCP for comparison of life-cycle alternative costs.

               ''•£ C°mme"t°r noted CPP"36 and -9 ' have contamination that reaches to the basalt,
                                   S-S! Ca" be attribUt£d l° direCt CXP°sure on|y for that soil
 betvvn n mft h      f             -u                                     y or  at so  w     s
 between 0-10 ft bgs. Is there another, viable, risk pathway for the soil below 10 ft bgs? If not the
 proposed remedial action need not address the deeper soil contamination. [C-W]

 Response:  It is recognized that there is contamination at depths below 1 0 feet. The 1 0 feet excavation
 depth was selected based on the residential scenario, which assumed a basement excavated to 10 feet for
 evaluation in the RI/BRA Report. This assumption was also used in the development of cost estimates
 and evaluations tor the FS Report. Using this information, an excavation to  1 0 feet will result in
 protection for potential surface receptors.  The residential basement scenario is also protective of future
 In ILTn011 C°mmerCial ci°"s';ruc
-------
   Response:  It is recognized that there is contamination at depths below 10 feet  The 10 feet excavation
   depth was selected based on the resident.al scenario, which assumed a basement excava ted o 1 0 fee  L
   evaluation ,n the RI/BRA Report.  Th]S assumption was also used in the development of cosTesdmaL
   and evaluations for the FS Report. Using this information, an excavation to 1 0 feet w.n result  n

   OS™, f°r P?ten';f ' SUrfaCC ""P10"- HoWeVer< S°me Sites have examination belowlO feet
   Groundwater fate and transport modeling from the Group 3 sites indicated that groundwater ri k from

   be^'lOfeet'X   h  Hh°WCVer, 'T8 thC remedial deSign' the 3CtUal exca™ion depth may^o
   be ^eve Lt rh       g    remed'al ***** "^ <*" f°r eXCaVati°n tO dePth ^ater "™ "> feet We
   beheve that the volume est.mates are reasonable for evaluation purposes.
  w^nn'r^4 |-ACommentorwantedthe Aggies to consider above ground containment. Basically I
  want you to include m your .mpact statement and scoping studies the Nevada study that came out last

  Serf"    tranSP°7"'°n °f PlUt°niUm int° the water s"PP'y- The actual individual do esTpIontm if
  inhaled, resuspended, pumped up, integrated, and inhaled. I think, if you study it correctly you w°II see
   hat contamment above ground ,n barrels not only provides jobs for the INEEL. but Us he total be  t^v

    "
    "  ecu re      ov    H Ov.n? ?,"**    ^ ^^ W™* "* *>« s gomg to be much greater than
Response: \\'e agree with the Commentor.
H?.,  : t C.0mmen'°^vondered- «nce at some sites, the contamination extends downward
through 40 feet., why is only 10 feet going to be cleaned up? [U-W]

Response: The Commentor is correct in pointing out that there is contamination below 10 feet  An
...M-axation depth ot 10 feet uas used for the resident.al basement scenario in the RLBRA evaluations.  In
                                            A-4-

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 developing and analyzing the alternatives for the FS, the 10 feet depth %vas used. This 10 feet depth is
 protective for surface receptors.  During the remedial design, the actual approach and excavation depths,
 which may go below 10 feet, will be determined to ensure that the SRPA is protected from the
 contaminants.  Although the remedial design may call for excavation to depth greater than 10 feet, we
 believe that the volume estimates are reasonable for evaluation purposes.

 C.3.3. INEEL CERCLA Disposal Facility (ICDF)

 Comment 177  : A Commentor wanted to know, if this disposal facility is built, radioactive, mixed and
 toxic wastes would likely be directed there not only from INEEL but DOE facilities in other states as
 well. This concern is bolstered by my understanding that DOE is actively considering a regionalized
 disposal system, using two or three federal sites to be selected from a short list that includes INEEL. The
 contemplated disposal site would be very large, covering 54 acres with a capacity of more than 13 million
 cubic feet of waste. (By comparison, the eleven western states using the Richland, Washington
 commercial low-level radioactive waste disposal facility now ship about 100,000 cubic feet of waste per
 year). [L-W]

 Response:  We cannot emphasize enough that the ICDF is only for INEEL CERCLA  cleanup waste
 disposal.  These wastes already exist above the "sole source aquifer" and if not addressed will present a
 unacceptable risk if the INEEL land is developed for private use  in the future.  Waste acceptance criteria
 will be developed as part of the remedial design process. Only wastes which do not pose a threat of
 exceeding drinking water standards, or exceed a 1 in 10,000 excess carcinogenic risk in the underlying
 aquifer, whichever is more stringent, will be permitted to be disposed in the engineered landfill. WAG 3
 CERCLA wastes that cannot be safely managed on INEEL will be disposed of in an off-site disposal
 facility in full compliance with state and federal laws and regulations. Generation of LLW in Western
 States is not relevant to CERCLA disposal at the INEEL INTEC. The referenced site in Richland
 Washington would not be suitable for the mixed LLW addressed  in this ROD since it does not meet the
 rigorous design standards contemplated for the ICDF.

 Comment 178   :  A Commentor felt that the idea for an ICDF should be scrapped. That the Agencies,
 would site the facility above a sole source aquifer is ludicrous. Such a facility cannot be made "safe" for
 the many hundreds of years necessary for the radionuclides to decay.  It cannot be made "safe" for the
 hazardous and  polychlorinated biphenyl  (PCB) wastes which will not decay and which will eventually
 leak and reach  the aquifer. The double liners and leachate collection system merely delay the inevitable
 [C-W]

 Response: We disagree with the Commentor. The ICDF can be  designed, constructed, operated,  and
closed while remaining protective of the SRPA.  The ICDF would be designed to not adversely impact
the SRPA. Waste materials (soils and debris) from INEEL CERCLA projects would be required to meet
the acceptance criteria for ICDF.  If treatment is necessary to meet the acceptance criteria, the waste
would be treated prior to disposal. The engineered barrier (cap) will be designed to provide the long-term
protection of both the surface receptors and the SRPA, even if the bottom liners were to fail.

Comment 179   : A Commentor noted the facility capacity is expected to be 510,000 yd3. CERCLA is
expected to use about 466.000 yd'.  What waste is expected to  fill the remaining, seemingly excess,
capacity?  I trust that only CER'CLA-related waste will be admitted to the facility. [C-wf

 Response: For evaluation and analysis purposes, six disposal cells were considered.  Both percolation
ponds were included and evaluated as if retrofitted into tuo of the disposal cells.  The remaining four
disposal cells were all of the same size and shape. All six disposal cells were necessary to handle the
potential candidate materials (soil and debris) and results in the excess capacity. The ICDF would be


                                             A-4S

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   constructed and operated one cell at a time. As the operating cell is approaching capacity  the next
   d.sposal cell would be constructed.  Waste materials from onlv INEEL CERCLA proiec£ woukbe
   acceptable for the ICDF, provided that the waste meets the acceptance criteria      J

   Comment 180  :  A Commentor noted the first paragraph gives an estimated volume of 82 000 vd3 The
   thelgTS^^                                 VV3Ste 3t 466'°00 yd"'' Subtractin.g- °"e finds Ped as Pa"of the
 tnnd   H   T TT:     X %raStCS Which *° *"* pOSe * direal of ex^eding Idaho drinking water
 standards m the underlymg aqu.fer will be permitted to be disposed in the engineered landfill  WAG 3
 CERCLA wastes that cannot be safely managed on INEEL will be disposed of in an off-site disposal
 facility in full compliance with state and federal laws and regulations.

 Comment i 82  . A Commentor recommended that u hen you open the 26-acre plutonium dump, low
   in a,S jIIT    !t 'S ,eUur m.the '°ng mn t0 Simply C0ntain th''s material  in barrels, at this point thev
k' n .h"    .r'T' at    Cl! Pu? y°U Ca" rebaiTd them- (t is cheaPer"  [t Just Eak" so I""* inspection to
keep th,> stuff aboxe ground.  What 1 think you-a!l are i, m denial of that eventual end point  You arc
                                            A--W

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 systematical!) looking for closure on these cleanup projects as opposed to admitting that we have to
 contain this material above ground. [PR-TT]

 Response:  Containment of the waste above ground is a possible option that was not studied. There are a
 number of factors that limit the cost effectiveness and risk effectiveness of storage above ground.  As the
 waste being considered for the ICDF is a large volume with relatively low concentrations, a very large
 facility would need to be constructed. In addition, the waste would have to be packaged and monitored
 periodically. Both of these operations would increase the amount of exposure that workers would
 receive.  In addition, there would be an increase in the amount of exposure to which the public could be
 exposed.  With containment above ground the containers would be required not be leak any material and
 this would require periodic repackaging. Based on these issues, containment in an above ground facility
 does not make since from a risk or economical standpoint. For disposal in an engineered disposal facility.
 the material would be contained and not require continued repackaging or inspection. However, there
 would be long-term surveillance and monitoring to detect releases from the disposal cells. This would
 allow for corrective actions to be implemented to correct problems,  if necessary.

 Comment 183  : A Commentor wanted assurance that there will not be waste brought in from outside of
 INEEL to go in under any circumstances. [DK-TT]

 Response: The only wastes that will be candidates  for the ICDF will be from INEEL CERCLA projects.
 In addition, the authorization  for disposal at the ICDF from other WAGs would need to be in the WAGs
 respective RODs, which will  be subject to same the community involvement activities as  OU 3-13.

 Comment 184 : A Commentor recommended that the ROD include much more detailed information
 about the ICDF. [CAB-W]

 Response: The Proposed Plan contained only summary  level information concerning the remedial action
 alternatives. In the FS and FSS Reports, the details concerning the alternatives were presented.  For the
 ICDF, additional information is contained in this ROD dealing with  the conceptual alternative,
 implementation, and other considerations. The remedial  design will contain the detailed information
 concerning the design and construction of the ICDF.

 Comment 185 : A Commentor recommended that the ROD outline the exact location and size of each
of the six cells planned for the ICDF and describe how each will be constructed, used, and closed. [CAB-
 W)

 Response: This ROD identifies the area adjacent to the current percolation ponds as the location selected
 for the ICDF. The exact location and design along with sizing will be developed during the remedial
design activities.  This ROD discusses the criteria that will be used to determine compliance with the
 requirements during the construction, operation, and closure activ ities for the ICDF.

Comment 186 : The INEEL CAB recommends that the ICDF be constructed, filled, and closed using
 the phased approach referred to in presentations to the Board. We would like to see the ICDF to be as
small and manageable as possible, yet we noted no description of the phased approach in the Proposed
 Plan.  We recommend that the ROD include detailed information about how the phased approach will be
 implemented. [CAB-W]

 Response: The use of a phased approach is included into this ROD. Under this ROD. the expected
 INEEL capacity needed will be constructed. Selection of disposal in the ICDF for non OL" 3-13 soils and
 dehns \\ill be onered under other CERCLA decision documents. The remedial desitin will define the
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  actual design with a goal of minimizing the area used for the ICDF disposal cells. Also  this ROD
  discusses both the general approach and how the phased approach will be implemented for the ICDF.

  Comment 187  : A Commentor wanted to know why is the area near INTEC selected as the proposed
  location, as opposed to another location on the INEEL?  What administrative and engineering controls
  would be utilized to prevent possible future contamination of the Snake River Aquifer, and how would
  you know ,f that contamination originated from the new.disposal facility or existing sources of
  contamination underneath or near the INTEC. [MS-VV]

  Response:  This ROD is dealing with contaminated soils and debris from INTEC. An evaluation was
  performed concerning the use of a centralized disposal facility for dealing with all INEEL CERCLA soils
  and debns  This evaluation is presented in the FSS Report.  The largest volume of contaminated soil and
  debris are located at JNTEC. Based on  this, an area at INTEC was selected for the disposal facility  In
  addition, there was a desire to limit the locat.on of the ICDF to areas that have already been contaminated
  from past practices at the INEEL. The disposal facility will be engineered to prevent unacceptable
  impacts on the SRPA.  From the engineering (design) work, the waste acceptance criteria would be
  developed. Administrative controls would be implemented to ensure that the waste disposed in the
  facility would be within the acceptance criteria. A monitoring network will be developed for the disposal
  facility to monitor contaminant migration directly beneath the disposal facility. In addition  monitoring
  would be conducted upgradient of the disposal facility. This would allow for'determining whether the~
  contamination is from the disposal facility or from the INTEC area.

  Comment 188  : A Commentor want to know why is the area near INTEC selected as the proposed
  location, as opposed to another location on the INEEL? What administrative and engineering controls
  wou d be utilized to prevent possible future contamination of the Snake River Aquifer, and how would
 you know if that contamination originated from the new disposal facility or existing sources of
 contamination  underneath or near the INTEC. [MS-W]

 Response: This ROD is dealing with contaminated soils and debris from INTEC. An  evaluation was
 performed concerning the use of a centralized disposal facility for dealing with all INEEL CERCLA soils
 and debns  This evaluttion is presented  in the FSS Report.  The largest amount of contaminated soil and
 debns are located at INTEC. Based on this, an area at INTEC was selected for the disposal facility  In
 addition, there was a desire to limit the location of the ICDF to areas that have already been contaminated
 from past pract.ces at the INEEL. The disposal facility will be engineered to prevent unacceptable
 impacts on the SRPA.  From the engineering (design) work, the waste acceptance criteria would be
 developed. Administrative controls would be implemented to ensure that the waste disposed in the
 faci ity would be within the acceptance criteria.  A monitoring network will be developed for the disposal
 facility to monitor contaminant migration directly beneath the disposal facility,  in addition, monitoring
 would be conducted upgradient of the disposal facility.  This would allow for'determining whether the
 contamination is from the disposal facility or from the INTEC area.

 Comment 189  :  A Commentor wanted the Agencies to describe the types of waste that vou anticipate
 would  be disposed m this cell, and what types would need to be sent to off site facilities. Also what is
 your estimate of the hazard to workers as  a result of operating this facility? What is the cost comparison
 for  on sue disposal versus off site disposal at a commercial facility or other off site facility and finally
 are  you accepting  waste from off the INEEL for disposal at this facility? [MS-W]

 Response: Waste material generated as a result of INEEL CERCLA projects are bein*  considered as
candidate material tor disposal. This i.sclud-js both contaminated  soils and debris. Appendix C of the
 hbb Report (DOE. ID-10619) discusses the waste considered for disposal. Within the candidate materials
are  wastes that prelimmanK are categorized as hazardous, low-le\el radioactive, mixed  low-level
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  radioactive waste. Only waste that meets the acceptance criteria would be disposed in the disposal cells.
  Materials not meeting the acceptance criteria would require other disposal facilities, generally off-site.
  Hazards to workers implementing the operation of the disposal facility would be controlled to be within
  the applicable radiation (DOE Orders) and non-radiation (OSHA) standards.  In the evaluation of
  alternatives, both on-site and off-site disposal were considered as alternatives.  The cost of off-site
  disposal was estimated to cost approximately 3 times as much (S477 million additional) for off-site
  disposal at a commercial disposal facility for all candidate materials. For the waste material considered in
  OU 3-13, the cost of off-site was estimated to cost approximately 3 times as much (S154 million
  additional) for off-site disposal at a commercial disposal facility. Evaluation of the cost of disposal at an
  off-site DOE facility, such as the Nevada Test Site, was not conducted. Ho%vever, a major cost
  component for off-site is disposal is the transportation costs associated with transporting the waste to the
 off-site disposal facility.  As such, the cost of disposal at another DOE facility would be much greater
 than disposal in the new on-site disposal facility.  No waste from off the INEEL will be considered for
 disposal in the ICDF.

 Comment 190   :  A Commentor wanted to express concern over the plans for a radioactive waste
 disposal site above the SRPA. I am totally opposed to this plan because of the potential environmental
 damage it could do and the health hazards it may generate. [BR-Wj

 Response: Protection of the SRPA is of major importance. The ICDF can be designed, constructed,
 operated, and closed while remaining protective of the SRPA.  Limits will be place on materials that'are
 acceptable for disposal in the ICDF. Waste materials (soils and debris) from INEEL CERCLA projects
 meeting the acceptance criteria would be candidate materials for disposal in the ICDF.  If treatment is
 necessary to meet the acceptance criteria, the waste would be treated prior to disposal.  For waste that
 cannot meet the acceptance criteria (with treatment),  off-site disposal would be utilized.

 Comment 191  : A Commentor wanted to know why can't the waste proposed to be sent to the ICDF be
 sent instead to the RWMC?  Does it have to do, specifically, with (a) cost? Or (b) concentration? Or (c)
 specific contaminants contained (how could they be less dangerous at ICDF than at RWMC?) Or (d)
 RWMC capacity? Doesn't RWMC have capacity for more waste? [U-W]

 Response: Some of the waste anticipated to be disposed of at the ICDF could be disposed at the RWMC.
 However, much of the waste volume considered for ICDF has RCRA issues (listed or potentially
 characteristic).  The RWMC  is not designed to meet RCRA  Subtitle C standards, or permitted to accept
 listed hazardous waste. Also, the RWMC will be closing prior to completion of the remedial actions
 generating the waste considered for the ICDF. The RCRA issue is being dealt with for ICDF by the
 design being a facility meeting, or exceeding, the RCRA Subtitle C minimum technical requirements.
 The cost of packaging LLW without disposal  at the RWMC is greater than the total cost of disposal at the
 ICDF. The waste acceptance criteria will be determined during remedial design. Once the desiun is
completed, the waste acceptance criteria may  be developed and fate and transport modeling wilfbe
conducted to ensure that ARARs are met and  that the facility will not result in exceeding drinking water
standards at the SRPA. or a 1 in  10.000 excess cancer risks,  whichever is more stringent.

Comment 192  :  A Commentor asked, if the  1CDF (as presented here, a plan so vague and unprotective
 it can be mo*t succinctly described as a crazy  idea) isn't built, will the Group 3 waste (and other WAG 3
waste, and other INEEL waste) be sent to the  RWMC?  If not, why not. exactly? Wouldn't the cost of
storage at RWMC be cheaper than transporting to a commercial off-site facility and paying their fee?


Response: The ICDF has been selected as the remedial action for Group  3. If the ICDF had not been
>clccted. some \\astc. including some WAG 3 ua*tes. could  potentially be disposed of at the RWMC.
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  provided that the waste meets the acceptance criteria.  Waste with RCRA issues (listed or characteristic)
  cannot be disposed of at the R W.VIC.

  C.3.3.1  ICDF General Comments

  Comment 193  : A Commentor felt that there remain major uncertainties related to the siting location of
  the ICDF and the waste acceptance criteria. [CB-VV]

  Response: The ICDF will be designed and constructed to be protective for the SRPA and surface
  receptors.  Additionally the facility wilt be designed to meet, or exceed, the Minimum Technical
  Requirements (MTRs) fora RCRA Subtitle C hazardous waste landfill.  Materials being disposed of in
  the ICDF will be required to meet the WAC. which will be developed to be protective of the SRPA for
  both short and long-term impacts. Part of the remedial design  activities will involve the siting of the
  disposal cells in the selected ICDF.area. The site selection activities will consider relevant technical
  regulatory, and financial factors.  Based on these criteria, the best location(s) will be selected for the
  disposal cells in the ICDF area. The waste acceptance criteria  will be finalized following the remedial
  design and may result  in limits of disposal activities and masses or may require pretreatment of selected
  wastes prior to disposal.

 Comment 194  :  A Commentor stated, "Obviously, one of the more important things within the current
 plan that is a departure from the draft is a commitment to construct the subtitle C RCRA compliant ICDF
 That is a major step forward, and we're very encouraged by that." [CB-TM]

 Response: An evaluation of whether the wastes are subject to  RCRA Subtitle C was made in the  FSS
  rTrScT^co^ °f,the Administrative Record-  It was determined that there was a significant amount
 of INEEL CERCLA soils and debris having contaminants other than and in addition to radionuclides
 Management of the non-radionuclides is subject to the RCRA requirements.  Based on this it was
 decided that a facility that would be compliant with the RCRA Subtitle C requirements would be needed
 to manage and dispose  of the soil and debris wastes. 'With this information and analysis, the construction
 of a disposal facility compliant with RCRA Subtitle C requirements became the preferred alternative.

 Comment 195  : A Commentor noted that under the Plan's off-site disposal alternative, only about ? •>
 million cubic feet of generally homogeneous soil wastes would  require burial. Leveraging this much
 smaller burial need to justify building 13  million cubic feet of disposal capacity for an unspecified mix of
 heterogeneous wastes from multiple locations is particularly imprudent, given the high value eroundwater
 resource placed at risk.  [L-W]

 Response: The 2.2 M ft' referred to by the Commentor relates to WAG 3 soils only   If no other soils
 except WAG 3 soils were disposed of at the ICDF, it would still be cost effective to do this consolidation
 This conclusion is supported by information available in the Administrative Record.  Consolidation
 improves our ability to retain administrative controls over one large area versus numerous smaller areas
 resulting in economies for small and large volumes.

Comment  196  : One Commentor recommended that we reject the currently preferred alternative of
building a new disposal facility at Chem Plant or other location overlyine the SRPA   A commercial
rad.oactive waste disposal facility could not be licensed here, and the government should not adopt a
lower standard for protection of this vulnerable, high-value natural resource. If necessary, excavated
wastes can be stored pending identification of a permanent sound solution. [L-W]

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  Response: Based on our evaluation the most cost effective solution which is protective of the aquifer is
  Alternative 4a (ICDF). based on the design requirements and stringent waste acceptance criteria that will
  be applied for this action. Given the type of waste that will be accepted by the ICDF  we see no
  impediments to a privatized mixed low-level facility at this location in compliance with state and federal
  siting and design laws if in the future a new facility  is needed for other waste disposal.

  Comment 197  :  A Commentor wanted to know exactly which other  release sites at INEEL might be
  allowed to dispose of material at the ICDF, and what type of contaminants and  media  might be disposed
  from these other sites? [U-W]                                                            H

  Response: This ROD has selected an on-site disposal facility for WAG 3.  Future Records of Decision
  may specify on-site disposal as the selected remedy and the ICDF will  be expanded as necessary.  The
  ICDF will be constructed to dispose of both soils and debris. Potential candidate materials along with
  waste type are found in Appendix C of the FSS Report.

  C.3.3.2. ICDF Siting

  Comment 198  : A Commentor remarked that dumping the waste on top of the ground and mounding the
  cover over it will result in the cap eroding over the long-term which again  is unacceptable  DOE must
  designate another location for the ICDF that is not near a flood plain and preferably not over the aquifer
  DOE'S own study has identified at least two such sites where the Lemi  Range meets the Snake Riven


  Response: Waste will not be placed into the ICDF by placing the waste on the ground and then
 mounding over the waste. The ICDF will consist of disposal cells where waste will be  disposed and
 traceabihtv of wastes will be maintained.  Following  filling of a disposal cell, the cell will be closed by
 constructing an engineered containment barrier (Cap) over the cell, which would be designed to control
 erosion, infiltration, and intrusion.  The proposed location of the ICDF is not within the floodplain   A
 siting evaluation was conducted as part of this ROD to identify the best on-site location for the ICDF
 This evaluation looked at siting criteria developed for solid waste, hazardous waste, PCB waste and LLW
 landfills. The two locations identified in a previous study, which are not over the SRPA on the INEEL
 have other problems (near fault lines, on the side of a  mountain, etc.), making them unsuitable  In
 addition to location, the ICDF will be designed, constructed, and operated to maintain protection of the
 oKi A,

 Comment 199  : A Commentor was concerned that water sample data at the ICPP already showed
 massive  migration of pollution into the groundwater and that the choice  to locate it at the fcPP was
 misguided. [CB-W]

 Response: There is a contaminated groundwater plume beneath the INTEC (ICPP), which was primarily
 a result of the use of an injection well, %vhich introduced contaminants directly into the SRPA  Use of the
 injection well was discontinued in  1986 and the injection well was permanently closed using a pressured
 grouting technique in 1989. Restoring the aquifer to drinking water quality will be addressed by the
 Group  5  (Snake River Plain Aquifer) remedial alternative. The potential impact to the SRPA from the
 ICDF is dependent upon the design, construction, operation, and closure of the landfill.  In addition the
 ICDF will be restricted in both the types of contaminants  and wastes that it can accept.   As a result  we
 Jeel that construction of the ICDF at INTEC is an appropriate location.

 Comment 200   :  A Commentor stated that given the type of hydrogeologic environment, it would be
 impossible to meet the established federal requirements under the NRC 10 CFR. part 61. regulations
governing commercial disposal of low-level radioactive uaste on  INEEL. [SR-TB]
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  Response:  Unfortunately, we must disagree with the Commentor and apologize for the length of our
  response. However, this is a very important concern to the Agencies and deserves a detailed response
  Under 10 CFR 61. a disposal facility can be constructed at 1NEEL over a sole source aquifer provided it
  meets the criteria in the regulation.  Although 10 CFR 61  is not considered an ARAR for this project, we
  have considered the substantive requirements in developing our siting evaluation. The relevant sections
  concerning siting criteria are contained in Subpart D (10 CFR 61.50), under which there are 11 criteria
  that must be satisfied.  The criteria and how the ICDF will meet the criteria are discussed below.

         Criteria 1: "...site suitability is given to isolation of waste, a matter having long-term impacts,
  and to disposal site features that ensure that the long-term performance objectives ... are met..." As the
  ICDF will be designed, constructed, operated, and closed to not adversely impact the environment (SRPA
  and surface receptors) this criterion is satisfied. Both short and long-term impacts are being considered.

         Criteria 2: "site shall be capable of being characterized, modeled, analyzed, and monitored."  In
 conducting the Rl/FS, the site was characterized,  modeled, and analyzed. Additional characterization,
 modeling, and analysis will be conducted during the remedial design and development of the waste
 acceptance criteria.  Monitoring of the site is a part of the operation and long-term management of the
 site.

        Criteria 3: "... site should be selected so that projected population growth and future
 developments are not likely to affect the ability to meet the performance objectives ..." The proposed
 location for the ICDF is not currently near a residential or non-governmental industrial population and is
 located in an area of existing contamination  (i.e., CPP-95).

        Criteria 4: "Areas must be avoided having known natural resources which, if exploited, would
 result in failure to meet the performance objectives ..." The area of the ICDF will be controlled and
 restricted. In addition, the impacts on the  aquifer  will be minimized to not adversely impact the aquifer
 There are no known natural resources that, if exploited, would impact the ability of the ICDF to meet this
 performance objectives.

        Criteria 5: "... site must generally be well drained and free of areas of flooding or frequent
 ponding.  Waste disposal shall not  take place in a  100-year floodplain ..." The proposed area is not
 located within the 100-year floodplain. Also, the proposed area is  not subject to flooding or ponding of
 water. In addition, the facility will be designed, constructed, operated, and closed, to minimize and
 mitigate the future impacts of potential flooding and ponding.

       Criteria 6: "Upstream drainage areas must be minimized to decrease the amount of runoff which
 could erode or inundate waste disposal units." The proposed location is not near an upstream drainage
 area. In addition, the facility will be designed, constructed, operated, and closed, to minimize and
 mitigate the erosion and inundation of the disposal cells.

       Criteria 7: "... site must provide sufficient depth  to the water table that ground water intrusion.
perennial or otherwise, into the waste will not occur." The depth of groundwater in the proposed area is
approximately 460 feet below ground surface. Further, the location chosen is not inundated with perched
water so no ground water intrusion into the waste fill will occur.

       Criteria 8: "... hydrogeologic unit  used for disposal shall not discharge groundwater to the
surface within the disposal site."  The proposed area currently has a discharge of groundwater near the
proposed ICDF area (1NTEC percolation ponds).  However, as part of this ROD, these discharges will be
discontinued prior to start of ICDF  land tilling operations. An alternate disposal system for the
percolation ponds will be constructed, which  will not impact the ICDF or perched water areas. In
                                              A-55

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addition, the facility will be designed, constructed, operated, and closed, to prevent the discharge of
groundwater to the surface within the disposal site area.

        Criteria 9: "Areas must be avoided where tectonic processes such as faulting, folding, seismic
activity, or vulcanism may occur with such frequency and extent to significantly affect the ability to meet
the performance objectives ..." The proposed location for the ICDF is not near faults, folds, or other
seismic and vulcanism areas that would occur with sufficient frequency or extent to impact the ability of
the ICDF to meet the performance objectives.

        Criteria 10: "Areas must be avoided where surface geological processes such as mass wasting,
erosion, slumping, landsliding, or weathering occurs with such  frequency and extent to significantly affect
the ability to meet the performance objectives ..." The proposed area for the ICDF is a relatively flat area
which is not subject to mass wasting, slumping, or landslides. For the ICDF, only the engineered
containment structure (cap)  is proposed to be above ground level and subject erosion  or weathering. The
facility would be designed, constructed, operated, and closed, to minimize and mitigate the effects of
erosion  and weathering to allow the ICDF to meet the performance objectives.

        Criteria 11: "site must not be located where nearby facilities or activities could adversely impact
the ability of the site to meet the performance objectives ... or significantly mask the environmental
monitoring program." Activities at the 1NTEC facility will not impact the ability of the ICDF to meet its
performance objectives. In fact, the location of the ICDF facilitates the cleanup and consolidation of
contaminated soils and debris within the INTEC  facility  thus promoting continued use of INTEC.

        Based on  the above discussion,  the Agencies believe that the ICDF will be able to meet the
requirements of 10 CFR 61 and will provide the same level of restriction and protection as a commercial
facility would be required to demonstrate. The ICDF design, construction, operation, to include stringent
WAC, and its closure will cost-effectively reduce the footprint of contaminated soils at INEEL; freeing up
much of the land for future unrestricted  development.

Comment 201   :  A Commentor stated that the INEEL CERCLA disposal facility at the Chem Plant is
recognizably within the 100-year flood plain and will be located below the surface so that the wastes will
be at an elevation that is going to be vulnerable to flooding even within the 100-year scenario. [CB-TM]

Response: The engineered containment barriers (Caps)  for the ICDF will be designed to control erosion
against floodwaters. Also, the proposed location is not within the  100-year floodplain. Further, the
facility will be lined and capped to  isolate wastes and remain protective of the SRPA  for both  short and
long-term impacts.

Comment 202  :  A Commentor stated that he objected to the ICDF because of the potential for future
erosion  over the long term.  Also, as the 100-year flood assumes 7,260 cubic feet per  second in the Big
Lost River and  the 500-year flood assumes 9,680 cubic feet per second, which is 34 percent more, the
idea of putting -- of locating, of siting the ICDF in that region made no sense at all. [CB-TM]

Response: In deciding \\here to most cost-effectively site the ICDF. the Agencies performed a siting
evaluation which  is summarized in  the ROD. The majority of the  wastes we anticipate disposing of in the
ICDF are relatively short-lived radionuclides. like Cs-137 and Sr-90 contaminated soil and debris.  The
concentrations of these contaminants will decrease by over live orders of magnitude (-1/200.000) within
approximately 500 years from the date of disposal. The engineered containment barriers will  be designed
to con'rol erosion, infiltration, and  intrusion.  In addition. we will evaluate historic high water elevations
and potential future climatic events in our design assumption* to minimize eventual landfill leachate
generation.


                                               A-56

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         - u    ^ C°mmenlor stated that the ^^ ^mg, from their point of view, was to site the
        off the aquifer but on the INEEL real estate.  He identified sites at the base of the Lemh,  Range
   where the Lemh, kind of terminates at the Snake River plain, which is off of the aquifer and not in a flood
   plain, bo I think there are other locations for that particular facility that need to be included.  [CB-TM]

   Response: We share the Commentor's concerns about the need to protect the valuable groundwater
   resource of the SRPA. This is the reason that we have elected to require that the aquifer be restored to
   dnnkmg water standards within a timeframe that it may be needed for future consumption  The
   evaluation of on Aquifer and off- Aquifer location for the facility was evaluated as was off-site
   commercial disposal. A primary reason that the ICDF is the selected alternative is the limitations we are
   placing on waste acceptable for disposal within this facility. The design and construction of the ICDF
   will further ensure that the landfill is conservatively designed so that leachate to the underlying  sole
  source aquifer will never exceed drinking water standards. In addition, consolidation improves  our ability
  to retain administrative controls over one large area versus numerous smaller areas. Concerning the
  Commentor s suggested location, there are several faults that surround the INEEL.  In addition there are
  recharge zones for the SRPA that are not directly over the SRPA. Selection of the location for the ICDF
  considered a number of site selection criteria, including proximity to existing identified faults  This
  automatically  ruled out locations near existing faults. Additional analysis concerning this issue was
  conducted for the new Three Mile Island Dry Storage Area.

  Comment 204  : A Commentor remarked that the Proposed Plan called for construction of a new
  radioactive waste disposal facility overlying the SRPA, constructed near unlined radioactive liquid
  percolation ponds, which have already caused extensive contamination at the proposed location.  [HC-W]

  Response: Regarding the construction and location of the ICDF, an evaluation was conducted to
 determine the cost effectiveness of developing a centralized (consolidation) disposal facility for
 management of the INEEL CERCLA waste.  This facility is to manage INEEL only CERCLA waste
 le'rNFRT'r"1316? S0i'l' ^u d±rSed 3nd uncontained> throughout WAG 3 and other locations on
 the INEEL that present a risk to the SRPA due to less restrictive pathway in the current configuration

 fmn! rT h'VR°pnIaT    'I'5 at WAG 3 W°Uld reqUire S°me tyP£ of remedial action <° r<*uce an"
 impact to the SRPA  As a result, remedial action alternatives, including the ICDF were developed and
 evaluated.  For the ICDF alternative, the soils would be excavated and disposed of in a engineered
 fnTl ,   H '^M The,e"ginrred fadlity' ICDF- W0uld consist of RCRA comP^»t disposal cells, which
 pro'vfde proton S lilS?.     ^ "* ^^ ^"^ ^^ ^™ ***** '°
 In the evaluation of the ICDF, the location that was selected is within the contaminated footprint of WAG
 3  This has the effect of reducing, rather than expanding the overall contaminated footprint of the INEEL
 The current percolation ponds at WAG 3 will be shut down. This will result in more protection to the    '
 underlying aqu.fer and will reduce public and environmental risk. Further, aquifer protection will be
 provided with required long term disposal cell, soil and groundwater monitoring which will signal any
 containment system failures and allow for additional remedies and/or corrective actions to be
 implemented to address the problem, if necessary.

 Comment 205  :  A Commentor stated that the SRPA is one of Idaho's crown jewels  This hugelv
 productive "sole source" drinking water supply is also essential to the future of Idaho's agricultural
 economy. Experience has proven that the porous sand and gravel soils and fractured basalt geolosv
 overlying this world class water resource are insufficient protection against migrating chemical and
 radioactive contamination.  Relying on man-made materials of potential unproven lonaevitv to make up
 tor unsuitable sue conditions, as the Plan recommends, invites future environmental and economic
problems. [HC-W]
                                             A-57

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    not pose a threat of exceed,™ wJJ, ! P,    P " °f the remedial design Droce« n 7      S'nngen













  5^r*;s^^^
area versus numerous smaller areas.   P     ' ab'''ty t0 retam Administrative controls over one lanze

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                                                                                                            1
 travel time along a 100-foot flow path from the ed^e of engineered containment structure is less than 100
 years. [L-W]

 Response: Based on the groundwater modeling we performed in the RI/FS, and the types of
 contaminants (e.g., Cs-137) which will be disposed of at the ICDF, it may take thousands of years for
 selected contaminants to migrate to the SRPA, assuming no hydraulic barriers are in place. Further, the
 travel times to the underlying SRPA are significantly increased in an engineered structure like the ICDF,
 which will be designed to impede transport of contaminants.

 Comment 210   : A Commentor stated that, "The underlying eastern SRPA, formally designated a sole
 source aquifer by EPA in 1991, provides water used at the site and is an important economic resource for
 southeastern and south central Idaho. More than 3.000 people draw water from wells located within a 3-
 mile radius of the site. According to the Plan, regional groundwater now  velocities  5 ft./day, and
 generally flows even more rapidly beneath the Chem Plant." [L-W]

 Response:  INTEC is located in the central portion of the INEEL with the nearest site boundary
 approximately 8 miles away.  Groundwater extracted at the INEEL is carefully monitored to ensure that
 the workers are not being exposed to unacceptable levels of contamination from the consumption of
 SRPA groundwater. In addition, there are no  nonworker populations (such as towns or other
 communities) within 3 miles of INTEC. The extent of contamination at INEEL emanating from WAG 3
 has been mapped and measured for over 30 years. Sensitive studies of CI-36 have shown the
 downdgradient extent of the plume, which is measurable up to 8 miles  from the INEEL border. No off-
 INEEL drinking water users, or potential users will be exposed to contaminant levels above drinking
 water standards. The action being taken under this ROD is to restore the aquifer underlying INEEL to
 drinking water standards, within a reasonable  timeframe (i.e., 100 years).

 Comment 211   :  A Commentor stated that unforeseen releases would increase waste constituent
 concentrations in the area, resulting  in drinking water standards being exceeded and  further adverse
 effects from overlying perched water zones. The Commentor further stated that this circumstance could
 conflict with the NRC site suitability requirement that "disposal facility must not be  located where nearby
 facilities could ... significantly mask environmental monitoring program." 10 CFR 61.50(a)(l 1) [L-W]

 Response: The criteria referenced actually states: "The disposal site must not be located where nearby
 facilities or activities could adversely impact the ability of the site to meet the performance objectives ...
or significantly mask the environmental monitoring program." The ICDF  would be designed,
constructed, operated, and closed, to not adversely impact the aquifer (SRPA) and surface receptors.  For
environmental monitoring, the monitoring system would be designed, constructed, operated, and
maintained to determine the impacts on the aquifer from the ICDF. The actual design of both the disposal
cells and monitoring network will be developed during the remedial design phase of the project.

Comment 212   : One Commentor recommended that we determine whether a technically suitable
disposal location exists at the INEEL that is not underlain by the aquifer. If a suitable are'a exists, conduct
health and environmental risk assessments and otherwise develop and evaluate this alternative on-site
strategy. [L-W]

Response: Based on the waste that will be accepted; in addition to the  design, construction, and
operation of the  ICDF; the Agencies are confidant that the planned location is protective of human health,
the environment. The Agencies are committed to keeping the public  informed during the design and
construction phase through the issuance of fact sheets and holding workshops, as appropriate.
                                             A-59

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  Comment 213   : A Commentor remarked that pumping and treating the existing contaminated
  groundwater and perched water zones are challenging and expensive and this difficulty in performing
  corrective action should serve as  a limitation in selecting a site above the SRPA. [L-W]

  Response:  We agree that cleanup of past releases to groundwater in the perched zones and SRPA are
  challenging and expensive.  We appreciate that high cost of remediation to address the environmental
  decisions of the past. We must note, however, that the major source of groundwater contamination at the
  INTEC is from direct injection of hazardous and radioactive substances into the SRPA at the former
  injection well, not migration of contaminants from the shallow subsurface to the aquifer. However, given
  the potential difficulty in cleaning up the SRPA, the Agencies will consider the potential impacts of the
  ICDF on groundwater when selecting the site location and developing the final design. At a minimum,
  the Agencies plan to develop the ICDF to be protective and minimize potential exposures to either
  humans or the environment, including groundwater. for at least 1,000 years. The principal contaminants
  expected to be disposed in the ICDF include Cs-137 and Sr-90, which have relatively short half lives and
  will substantially decay before 1,000 years.

 Comment 214  : A Commentor suggested that the desire to concentrate waste over an already
 contaminated portion of environmentally vulnerable, economically vital sole source" aquifer is
 compounded by Department's actions to accelerate waste receipt at the existing,  Radioactive Management
 Complex Subsurface Disposal Area waste management program strategic plan. [L-W]

 Response:  We cannot emphasize enough that the ICDF is only for INEEL CERCLA cleanup waste
 disposal. These wastes already exist above the "sole source aquifer" and if not addressed will present  a
 unacceptable risk if the INEEL land is developed for private use in the future.  Stringent waste acceptance
 criteria will  be developed as part of the remedial design process. Only wastes that do not pose a threat of
 exceeding drinking water standards in the underlying aquifer will be permitted to be disposed in the
 engineered landfill. WAG 3  CERCLA wastes that cannot be safely managed on  INEEL will be disposed
 of in an off-site disposal facility in full compliance with state and federal laws and regulations

 Comment 215  :  The INEEL CAB recommended that use of clean areas to dispose of wastes be
 minimized to the extent possible. The Board restated its support in the past for using already
 contaminated areas as disposal sites for LLW.  Use of clean areas is much less desirable. [CAB-W]

 Response: Construction of the ICDF will occur in the area to the west of the existing INTEC percolation
 ponds. A siting study was completed resulting in the selected location for the ICDF area. Site CPP-95 is
 the contaminated area associated with releases from the main stack at INTEC. The area defined as the
 AOC will not be suitable for free release or unrestricted use for 100 years. This will require the area to be
 institutionally controlled with access and use restrictions and radiological surveillance. While the area
selected for the ICDF does not encompass the entire existing percolation ponds area, the selected ICDF
area is in a previously contaminated area requiring continued access restrictions.

Comment 216  :  A Commentor asked that the WAG 3 AOC be shown on a map. [U-W]

Response: A map showing the WAG 3 OU 3-13 AOC is included in this ROD.  The boundary extends
south of the existing percolation ponds. The entire proposed ICDF area is located within the OU 3-H
AOC.
                                             A-60

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C.3.3.3.. ICDF Design
                                                 ""


                             A-6!

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  Response: The operation of the ICDF is not dependent upon the natural protection offered by INEEL
  soils.  Design requirements and construction procedures address the operational concerns mentioned by
  the Commentor. The WAC provide further assurance that the aquifer will remain protected. Commercial
  landfills are located above fractured basalt. Siting criteria for the ICDF (which is limited in terms of what
  wastes may be accepted) is not the same as that of a commercial facility, which accepts manv forms of
  wastes.

 Comment 221  :  A Commentor asked about the design life for the ICDF liner and for the cover
 [SRA-W]

 Response: Both the liner (bottom of disposal cells) and cover (engineered barrier; cap) materials for the
 ICDF will have design life requirements.  The design life of the liner materials are grouped into two
 categories. The first category is the materials used for the leachate collection during the operational phase
 of the individual disposal cells. These leachate collection materials are the same as those used in the
 construction of RCRA Subtitle C facilities and have design lives of 30 years or more. The operational
 phase of the individual disposal cells is expected to be approximately 10 years. Proper cover design
 Should minimize infiltration, thereby preventing the need for long term operation of the leachate
 collection system. The second liner category is the materials used for the material beneath the feachate
 collection system and on top of the basalt. For materials beneath the leachate collection system, natural.
 native, or natural analog materials will be used.  These materials would have design lives of geological
 timescale (>1,000 years). These material will have sufficient design life to control the contaminant
 migrations until the level of contamination present do not present a risk to the environment.  In the case of
 the engineered barriers (covers), the material of construction would  be similar to the materials used
 beneath the leachate collection system.  As design specifications are part of the remedial design process,
 these issues will be further evaluated during the remedial design.

 Comment 222  : A Commentor stated that the concept of the  ICDF is flawed and unacceptable.  It does
 not afford sufficient protection  to the Snake River Aquifer since it will eventually leak (refer to the recent
 discovery at Envirocare of 2500 gallons of leachate between the liners). The Commentor asked, how will
 INEEL manage/dispose of leachate from this facility? Bonneville county was not allowed to construct a
 municipal landfill over the aquifer, why should DEQ allow construction of a hazardous/PCB waste
 landfill over the same aquifer?  DEQ should be consistent in their application of requirements to protect
 the aquifer.  Will this landfill accept only PCB waste between 50 and 500 ppm PCBs or will it accept
 >500 ppm PCBs? [C-W]                                                                   H

 Response:  We disagree  with the Commentor. Currently, there are several municipal landfills sited over
 the SRPA.  The ICDF will be designed, constructed, operated, and closed  to remain protective of human
 health and the environment, including the SRPA.  for at least 1,000 years.  The Agencies goal is to protect
 the aquifer.  Problems at  Envirocare are not relevant to the ICDF design, operation, or closure. Leachate
generated during the operation of the ICDF will be managed and treated at the SSST. The treated effluent
may be used for dust suppression during operations. The ICDF will  be designed to minimize the
generation of leachate after closure. This is the reason for the actions identified in the ROD.  Concerning
 PCB wastes, the ICDF will be limited to less than 500 mg. kg (ppm)  non-liquid PCBs.  Wastes containing
 free liquids will not be disposed in the ICDF.

Comment 223   : The INEEL CAB recommended that the ICDF be designed to avoid the effect of the
probable maximum flood. The  contaminants that would be disposed at the ICDF have radionuclides with
\ery long half lives. Design to avoid the impacts of a 100-year Hood mav not offer sufficient protection
[CAB-W]                                           '            '                   p
                                             A-62

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   Response: When evaluating the "probable maximum flood" it is necessary to know the frequency of the
   event. Most of the contaminated materials (soil and debris) to be disposed of in the ICDF will remain
   unacceptable fro ma human health perspective for less than 500 years.  The major effect on a landfill
   similar ID the ICDF would be the effect of errosion of the engineered containment structure (cap)
   Groundwater generally is not greatly impacted (short-term increase in contaminant migration along with a
   decrease in contemmant concentrations).  The engineered containment structure would be designed to
   deal w,th the effects of at least a 500-year flood. This will provide adequate protection for the ICDF from
   flooding effects along with protection of the SRPA.

  Comment 224 : The INEEL CAB recommended that the ICDF final design be fully compliant with the
  Resource Conservation and Recovery Act (RCRA) substantive requirements. DOE may need to dispose
  of waste containing RCRA-listed contaminants at the ICDF.  The design should accommodate that
  possibility to avoid expensive retrofitting  in the future. [CAB- W]

  Response:  The ICDF will be designed to meet the design requirements for a RCRA Subtitle C hazardous
  was e disposa facility.  Meetmg the RCRA Subtitle C requirements allows for RCRA waste (listed and
  tteated characteristic) to be d.sposed of in  the facility. In addition, hazardous waste materials (hazardous
  mixed, and LLW) from other INEEL CERCLA remedial and removal actions would be candidate

  TthTfurure    P°Sal '" "* ICDF'  ""^ ^ elimi"ate retrofittin8 the ICDF to meet RCRA requirements
 Comment 225  : A Commentor asked, "Regarding the ICDF:  How exactly will the design of the
 proposed ICDF prevent future percolation of contaminants into the groundwater?" [U-WJ
 adPCBChlmi^ W ^ H^ * "^ ** RCRA Subtitle C mi"imum technical "M^nts
 and PCB Chemical Waste Landfill design requirements. Our Waste Acceptance Criteria will assume that
 contaminants will eventually leach out of the waste in the ICDF and migrate toward the SRPA
 Therefore we will l.mit our waste acceptance to wastes with contaminant levels that, even if the long-
 term leachate collection and management system were to fail, would not cause an MCL or unacceptable
 risk level exceedence in the SRPA. based on modeling.                                  ^cFutuie

 C.3.3.4. ICDF Waste Acceptance Criteria
         wr i                        that the ICDF Engineering Design and Waste Acceptance
        ( WAC) must be developed with public involvement through a free and open discussion  Only
 un-contamenzed wastes that can be compacted during placement should be allowed so as to minimize
 subsidence caused by container decomposition.  Biodegradable, VOC, collapsible, soluble TRU or
 Greater than Class C Low-level, and Alpha-LL W must also be excluded from the ICDF dump and sent
 commenr n'T ^f1**6 ICDF Title H Desi§"- «o*sh°ps should be convened for stakeholders to
 comment on the proposal. Waste acceptance criteria maximum contaminate concentration levels must be
 determined from waste sampling prior to being mixed with any stabilizing materials. In other words
 dilution is not the solution to pollution." [CB-W]

 Response: Only INEEL CERCLA waste that is non-containerized, compactable, and non-biodegradable
 are being considered for d.sposal in the ICDF without the need for pretreatment. Containerized a~nd
 biodegradable wastes may require pretreatment and treatment, if necessary, to meet the waste acceptance
catena for d.sposal m the ICDF. In addition, no TRU waste or waste having concentrations of TRC
constituents exceed.ng 10 nCi/g are being considered as candidate waste for disposal in the ICDF  Also
the waste acceptance criteria, along with the design, will be diveloped to ensure that the SRPA is'
protected from potential contamination from the ICDF.  Further, the Auencies will keep the Community
mlormed as to the progress and content of the remedial desian througha series of Fact Sheets  In
                                            A-63

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  addition, presentations and discussions with the INEEL CAB and/or Focus Groups will be held during the
  development of the design and construction of the ICDF. Concerning the last point, stabilization is a
  treatment technology used to reduce the leaching potential of a waste.  It will not change the how wastes
  will be managed in the ICDF.  Prohibited wastes, like TRU and Alpha LLWs will not be diluted so as to
  meet the waste acceptance criteria for the ICDF.

  Comment 22?  :  A Commemor stated. "The volumes and contamination levels for the soil dump aren't
  clear.  It is inappropriate to ask the public to sign-off on the soil dump before its waste acceptance criteria
  are known.  Will the public have an opportunity to help develop and comment on the soil dump design
  and WAC?" [SRA-W]                                                                K    e

  Response: Under this ROD, soils and debris from CERCLA cleanup activities could be accepted into the
  INEEL CERCLA Disposal Facility. For the evaluation of remedial alternatives for Group 3 (Other
  Surface Soils), a volume of 82,000 yds' was considered. The volumes from the various release sites can
  be found in Appendix A.of the FS Report.  Information on the maximum contaminant concentrations for
  the various release sites can be found in Section 5 of the RI/BRA Report. The actual chemical-specific
 waste acceptance criteria will be developed during the remedial design.  However, general criteria have
 been identified in the ROD. The most important criterion is that the ICDF will only accept material such
 that the ICDF will not adversely impact the SRPA or surface receptors, over the long term.  Others
 include: only CERCLA wastes; only non-liquid wastes: and no High Level, TRU or Alpha LLW  will be
 acceptable. During the remedial design activities, we will develop and issue Fact Sheets on the various
 cleanup activities under this ROD.  In addition, we will be available to discuss the various remedial
 design and remedial action activities with interested public groups as appropriate.

 Comment 228  : A Commentor was concerned about being asked to comment on the ICDF when they
 didn't know what the waste acceptance criteria were. [MMS-W-W]

 Response: For the Other Surface Soils group, a conceptual ICDF was evaluated as a remedial alternative
 In evaluating the ICDF, candidate material for disposal in the ICDF were identified and evaluated (see
 Appendix C of the FSS Report, which is contained in the Administrative Record).  The actual waste
 acceptance criteria will be developed during the remedial design. However, the waste acceptance criteria
 will limit the material acceptable for disposal such that the ICDF will not adversely impact the SRPA or
 surface receptors.

 Comment 229  : A Commentor asked about, Page 28, Alternative 4A, Preferred Alternative. 4th
 paragraph, of the Proposed Plan  and wanted a definition on what wastes are "suitable for disposal" at this
 disposal  facility. [C-W]

 Response: Only waste materials from INEEL CERCLA remedial and removal actions which are
 primarily mixed LLW would be  acceptable for disposal in the ICDF, provided that the waste meets the
 acceptance criteria.  The in-AOC waste would be required to meet the acceptance criteria for the ICDF
 Waste materials (soils and debris) that do not have  the potential to adversely impact the SRPA from
contaminants leaching of the waste would be candidate materials for disposal (suitable for disposal)
 Further, wastes would be required to meet the requirements of Phase IV LDRs, as appropriate.  Pre-
treatment ofwastes,  as necessary to meet the acceptance criteria (stabilization for subsidence or teaching
control),  would be performed prior to disposal.

Comment 230  : One Commentor questioned the quantities, concentrations and size of the proposed
ICDF? AJso. \\ ill the facility serve as a retrievable storage area? Is there any plutonium uoinn into the
ICDF? So are you going to follow the 100 nCi standard?  If \\e use  10 nCi/n. how many"billions of
                                             A-64

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                                                                                                            1
  particles? The thing on the situation was legally, you could take less than 100 nCi transuranics from the
  Tank Farm, putting in this official RCRA endorsed low-level dump; right? [PR-TT]

  Response: The proposed ICDF, which would be a permanent disposal site, designed, constructed and
  monitored in accordance with applicable hazardous waste minimum technology design requirements, is
  expected to encompass less than 100 acres upon closure including a buffer zone. The maximum
  allowable radionuclide concentrations will be determined in the RD/RAWP. However, no contaminants
  will be placed in the ICDF, which would exceed the design capabilities of the facility and threaten the
  underlying SRPA.  For TRU contaminants, which include Pu-239, concentrations above 10 nCi/g (alpha
  low level) will not be accepted.

 Comment 231   : A Commentor questioned whether tank farm soils, if excavated would go to the ICDF?
 [PR-TT]

 Response:  Our Group I  interim action does not envision the excavation and disposal of tank farm soils.
 The ICDF will not accept TRU wastes above 10 nCi/g nor will it receive HLW. Stabilization of ICPP
 soils would only be to  the extent necessary to prevent future leaching and subsidence. There are LLW
 soils and debris currently stored at INTEC (Sites CPP-92, -96, -98, and -99) that originated from within
 the Tank Farm area. This soil and debris is candidate material for the ICDF, provided the material meets
 the ICDF acceptance criteria.  For soils and debris within the WAG 3 AOC that have triggered placement,
 the material is subject to Hazardous Waste Determinations and LDRs.  For the soils remaining in the
 Tank Farm, OU 3-14 will evaluate the risks and potential remedial actions.

 Comment 232  :  A Commentor stated, "This, to me, is the whole problem with piece mealing the whole
 situation. And even in the big picture, if every radionuciide leaked that was there, it would meet federal
 standards because the aquifer is so large.  And the big picture is that's why they view INEEL as the
 perfect place to have a  200-acre plutonium dump that they talk about is their event goal." [PR-TT]

 Response: Protection of the SRPA is one of the primary objectives of the OU 3-13 project. As there is
 already contamination in the SRPA that will require remediation, the ICDF will not be allowed to
 adversely impact the aquifer. Additional impacts would only make restoration of the aquifer harder and
 more costly. Based on  this, the maximum concentrations of leachate from the ICDF will be limited to
 control impacts on the aquifer so that the aquifer is not contaminated above drinking water standards from
 the ICDF. From the big picture standpoint, the impacts from the ICDF are considered in the overall
 (cumulative) impacts for WAG 3.

 Comment 233   :  A Commentor stated, "Literally, our water supply is large, but the medical view of
 radiation is. to -- the less human-added exposure the better, and with zero being the safest limit. And  we
 have a chance to contain all this material, and yet you're going through calculations you know will allow
 you to  rebury it. That's my problem with the whole cleanup. You actually  let it leak and it still meets
 your standards.  That's why mixing it with cement is acceptable to you and  putting it over the water
 supply is acceptable to you." [PR-TT]

 Response: The ICDF is for the consolidation of existing contaminated soils into a facility designed,
constructed, operated, and closed to control and minimize the leakage (leachate) from the material
disposed  in the cells.  The level of radiation that we are designing to be protective of human health is less
than  1 '20th the dose typically received by the general public in the nearby communities.  The disposal
cells will prevent the uncontrolled leakage of contamination to the SRPA.  Stabilization of INTEC soils
will be performed  to the extent necessary to prevent future leaching and subsidence.
                                             A-65

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     Comment 234  .- .4
                            ^
                                    ». wim i mtonium concentrations above 100 nCi. fPR-TT]
                                      o
  contaminated soils will be placed there ?n°t aVv  Tn rhf C, .b
  be safe for a thousand-pi usyears. OtheVth ±v"l
  breaking up buildings, contaminated SS wd
  Pieces. The volume will be contaminate^  b'ut ?„
  then certainly the debris from those buildings some or T« ?*
  go there because of too-high levels of rad ofc'tS.o snm
  d-sposal facility.  It is a centralized fac nt f r oSr cllwlr
  that does  rodu
                                                                   ,            —
                       ^^
    controls andor actions implemented   ?i£ fi^SS- ^ 'h "? "'^ *"' °thcr nccess^
    adverse impacts. The protection on the SRPA wnnlH   f   x   ',"n 6 'eachate tO Protect the S*pA for
    be limited to accepting^ *«^"£S!^ 10 nS/g °  ^ '" addit'°n< the ICDF


                                                          fodthe rr that
                                                          and I£ WI" be P«>perly capped and
                                                                      A"d We believe that w«'
                                                              ^  ''ncludl'ng COnCrete fr°m
                                                          if ,?^ br°ken "P im° bite-sizR
                                                        *           '' l° tear bui]dings down'
                                                                  '° 8° in there-  Some can»o'
                .                  c     r or clwr      T      ^ 'CDF is &  generalized
  that does produce soils or debris will go there  They til Z h   fh    '" P3™"'^ a"d an'VthinS else
  largely is due to economic arguments " [DK TT]                    OW" seParate reP°sitories.  That

  Response: The Commentor is correct  The irnp «,«  M w   .    j
  containment structure (cap).  The actual teTaST?     ?   W'"th the constru^'<>n of an engineered
  determined during remedial desto ^ based on echnL I    ^ ^ wilhl'n the 1CDF area- ^ &
  could be accepted^ the ICDF ^Sdetth so  and ibS"'^?' ^ finandal  factors' Wast- that

  ys^^s^
  occur if this remedia, option is seS
an appropriately designed public involvement
that does not meet the criteria should be
                                                            te acceptance
                                                               " l0ng'term point of view
                                                                      " *"
 Response: The waste acceptance criteria for the rrnp «.:ii K

 from unacceptable levels of wntamEn  PeS wnttm'     P"manly dcvd°ped f° pr°tect the ac>uifer
 be evaluated regardless of when the pe^ occumnTme ™  ^.^T"; impaCting the aquifer wi"
 protection from the impacts of the ICDF. Durinu "he TevJonn en 'rT   *' aquifer WJth '°ng-temi
 sheets and other documents will be developed to inform rhPM        W3Ste accePtance criteria, fact

 meeting the acceptance criteria will be dtjo*S "o ?«™h?di ™ ^ rAT'-N"L CERCLA WaSte "Ot
 necessan-.                         *P°*eQ of at other d^posal facilities including off-site disposal  if
C.4.  Group 4: Perched Water

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  Response:  In the evaluation of alternatives for the INTEC perched water, a replacement facility (new
  percolation ponds) was evaluated. Additional alternatives for replacement of the existing percolation
  ponds were evaluated and the information is contained in the Administrative Record.  A new set of
  percolation ponds will be constructed to deal with the existing service waste discharges.  If necessary,
  these ponds will be operated under this ROD until a new wastewater land application program (WLAP)
  permit to operate is obtained.  Upgrading or additional capacity would be conducted under a separate
  project in support of INTEC facility operations. As recommended the ROD contains more details
  concerning the timing issue and the implementation of the replacement facility for the existing percolation
  ponds.

  Comment 238  : A Commentor remarked that for Group 4, the perched water. 24 percent of the recharge
  was from the Big Lost River. Therefore, it seemed that the chances of doing something with the Big Lost
  River are pretty high because it was a quarter of the recharge. The Proposed Plan only stated that dealing
  with the Lost River, which is in Phase 2 was just a probability? [DK-TT]

  Response:  We agree that additional actions may be necessary to reduce  the infiltration of water at
  INTEC to de-water the area of the perched water. Removing the existing Percolation ponds represents
 over 2/3rds of the recharge.  Modeling shows that this may in itself be sufficient. If not, based on
 monitoring  results. Additional infiltration controls will be implemented which will reduce the river
 recharge in  the stretch  affecting the perched water and thus eliminate the  river as a source of recharge.

 C.4.I.  Group 4 Description

 Comment 239 : A Commentor questioned the consistency of Page 32 Perched Water, Alternative 1  of
 the Proposed Plan. "It first states that "controls will remain in place until 2095." Then it backpedals and
 states that perched water monitoring will only take place for 20 years after the ponds are taken out of
 service." ...  "What if perched water is still present 20 years after the ponds are taken out of service?"  [C-


 Rcsponse: For this non-selected alternative (Alternative 1: No Action with Monitoring), the percolation
 ponds were assumed to remain in service until all operations at INTEC had been completed.  Treatment of
 the waste at  INTEC would be completed by 2035 and a period of 10 years would be required to complete
 the facility disposition activities. This would result in the percolation ponds being removed from service
 in 2045. In the computer modeling, a period of approximately 14 years would be required for the perched
 water to drainout (change to an unsaturated zone). Perched Water monitoring would continue for 20
 years following the removal of the percolation ponds from service. Although the monitoring period
 would end before 2095, the access (institutional) controls would remain in effect until at least 2095.
 Should the perched water not drainout as expected, the monitoring would  be extended.  This extended
 monitoring would continue for a period after the drainout has occurred.

 Comment 240  :  A Commentor stated that there was no mention  that most of the contamination is the
 perched water was believed to have come from the tank farm  nor was there mention that the perched
 water was contaminated with RCRA listed waste.  [C-W]

 Response: The Commentor is correct. Waste containing.listed waste constituents were spilled in the
Tank Farm soils. Some contaminants have migrated from these soils downward to the perched  water
bodies and this water may contain RCRA-listed waste constituents.

Comment 241   : A Commentor stated that at Pages  34.and 35. of the Proposed Plan, short-term and
long-term effecmeness. no mention svas made of the contaminants already present in the basalt and
                                             A-67

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 interbeds and their impact on the perched, and deep, aquifers. The Commentor further asked. "What Kd
 studies have been done to support your answer?" [C-W]

 Response: The Commentor is correct in stating that there is known contamination present in both the
 basalt and interbed materials at INTEC (ICPP). The computer modeling that was conducted for the
 RJ BRA, FS, and FSS Reports did not consider the source term present in either the basalt or interbed
 materials. Instead the source terms modeled for most release sites considered the contamination
 remaining in the surface soils. For release sites where the constituent characteristics and volume of the
 liquid released to the surface soils were known or estimated, the source terms for these sites considered
 the released contaminant masses. In addition, these liquid release sites are the largest releases at INTEC.
 Although this does result in an uncertainty in the source term mass and subsequent modeling calculations,
 it should not significantly alter the results obtained from the modeling. Additional analysis will be
 conducted under OU 3-14 on source terms in the Tank Farm area and this analysis may be able to semi-
 quantitatively evaluate the impact of the source terms contained  in the basalt and interbed materials.  For
 the computer modeling, default retardation factors (Kd). which are generally conservative, were used.
 The KU values used in the modeling are presented in Appendix F, section F-5, of the RI/BRA Report.
 Studies to refine the transport mechanisms and rates will be conducted under the OU 3-14 project.

 C.4.2. Group 4 Alternatives

 Comment 242  :  A Commentor stated that the perched water preferred Alternative 2 alone did not meet
 regulatory requirements unless combined with Alternative 3 (pump and treat). Even so it would partially
 meet the requirements with the following exception that the existing ICPP percolation ponds will be taken
 out of service and replaced with new "like for like" percolation ponds not over the existing perched water.
 The Commentor felt that the contamination of the perched water currently was largely the result of using
 unlined percolation ponds to dispose of process waste. [CB-W]

 Response: If the Perched water was capable of sustainable drinking water at the future residential use
 hypothetical time frame, the Commentor would be correct that the Ground Water Protection Standards
 would not be met without implementing Alternative 3. However, the Perched water is not a sustainable
 source of drinking water. It largely exists because of DOE operations which discharge  more water into
 the soil than can naturally drain, thus resulting in a perched water zone. The perched water does serve to
 conduct leachate migrating from surface sources to the SRPA.  This is why removal of the existing
 percolation ponds is an important phase of the remedial action.

 Also, while it is true that disposal of radiological and hazardous waste occurred in the past at levels which
 impacted the aquifer, these impacts are what led to the INEEL facility being listed on the National
 Priority List (NPL) with cleanup being performed under the FFA/CO.  Current waste management
operations are covered under state and federal programs, which are outside the scope of this action but are
designed to protect health and the environment.

Comment 243  : A Commentor remarked that the Plan discounted the Perched Water as "No risk
because perched water is not capable of sustaining a pumping rate needed for future domestic water
supplies: therefore, it is not a source of potable water." Vet in ICPP Plan Alternative 3  (not the preferred
alternative). DOE acknowledges a perched water pump treat rate  of 46 million gallons over 25 years.
Applying simple arithmetic that works out to a daily pumping rate of 5.041 gallons per  day. which is
ItkeK adequate to sustain oxer ten households? [CB-W]

Response:  We are .-.orry for the confusion on this issue. The Perched Water is primarily sustained by the
pumping and disposing of approximately 2 MGD in the existing Percolation Ponds. If the  Percolation
Pond* are remo\ed from the vicinity of the perched water, the perched water would dissipate within less
                                             A-6S

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  than twenty years. In the evaluation of Alternative 3 for the Perched Water, the rate of withdraw! from
  the perched water varied over time (starting high and reducing) to account for the reduction in the
  available perched water.  Also, the amount of contaminant mass removed by Alternative 3 is insignificant
  compared to the amount of contamination present.  Our use of the 100-year future residential scenario and
  commitment to replace or relocate the Percolation Ponds will result in the availability of the SRPA for
  future drinking water consumption. The Perched Water is not capable of providing a sustainable drinking
  water supply, if DOE's use of the Percolation Ponds is ended.  Based on the evaluation of alternatives, we
  concluded that Alternative 2 (Institutional Controls with Aquifer Recharge Control), which includes
  removing the existing percolation ponds from service, best satisfied the evaluation criteria.

  Comment 244  : A Commentor stated that at Page 33, Perched Water (Group 4) - Alternative 3 of the
  Proposed Plan, "... regarding removal and treatment of 46 million gallons of perched water. I  recognize
  that very few alternatives are available for dealing with contaminated perched water, however, a back of
  the envelope calculation shows that in order to remove 100% of the Sr-90 estimated to  have been released
  to the environment (19,400 Ci) would require that the average concentration of perched water removed be
  100 million pCi/L. Therefore, to remove only 1% of the Sr-90, the average concentration will have to be
  1 million pCi/L, which at best could decrease the predicted future risk by 1%.  Although several wells
 have had measured concentrations in the hundreds of thousands of pCi/L, the average concentration is
 much lower and none have approached I million pCi/L. Therefore, this alternative cannot possibly
 provide any measurable risk reduction, regardless of the cost. The alternative should not be given'
 credibility by including it as an alternative.  By quantifying the risk reduction, the ineffectiveness of this
 alternative could have been quantitatively shown and eliminated." [JM-W]

 Response: Alternative 3 was included for Group 4 (Perched Water) to present a range of alternatives and
 to include at  least two viable alternatives. Alternative 3 is a more aggressive approach to the remediation
 of the Perched Water than Alternative 2.  We also feel that Alternative 3 would result in an insignificant
 risk reduction beyond the results obtained by implementing Alternative 2.

 Comment 245  : A Commentor questioned the technical and administrative implementabiliry the
 Perched Water (Group 4), Alternative 3, given the discontinuous nature of the perched water at  INTEC
 [JM-W]

 Response: Alternative 3 was included for Group 4 (Perched Water) to present a range of alternatives and
 to include at least two viable alternatives.  Alternative 3 is a more aggressive approach to the remediation
 of the Perched Water than Alternative 2.  We believe that Alternative 3 is an implementable alternative,
 but would only result in a minor risk reduction if implemented.

 Comment 246  :  A Commentor pointed out that on Page 35. Perched Water (Group 4) - Table 6 and
 sidebar, of the Proposed Plan, under Alternative 2 the Net Present Value is given as S35 6M but in the
 sidebar it is given as S20.0 M? [JM-W]

 Response: We are aware of the typographical error, but unfortunately were unable to correct it before the
 release of the Proposed Plan. The correct NPV cost for Table 6 is S20.0M.

Comment 247 :  A Commentor pointed out that on Page 33, Alternative 2, the last sentence  refers to the
OU 3-14 RI/FS studying the effects of the Big Lost River and Sewage Treatment Plant (STP) on the
perched water in addition to the tank farm. He stated. "If a strong connection exists between  the tank
 farm and the perched water, then the perched water site should be removed from this Proposed Plan and
included in the OU 3-14 Plan and ROD." [C-W]
                                             A-69

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  Response:  We are sorry for the confusion. Under the OU 3-13 project, the impacts of the Big Lost River
  (BLR) and Sewage Treatment Plant (STP) would be investigated and evaluated for impacts on the
  perched water during the perched water remedial action  implementation.  The computer modeling
  conducted for OU 3-13 showed a linkage between the various sources of water (percolation ponds, BLR
  STP.etc.) infiltrating the subsurface and the perched water bodies. Operable unit 3-14 will use the
  existing information from OU 3-13, including removal of infiltrating water source to evaluate localized
  SRPA contamination within the INTEC fence line.

  Comment 248  : A Commentor pointed out that on page 36. Ist partial paragraph. Phase 2 of the
  Proposed Plan addresses diverting or lining the Big Lost river and/or taking action on the STP perched
  water, rather than evaluating under OU3-14. [C-VV]

  Response: The scope of OU 3-14 has changed since the project was initially discussed. Under the OU 3-
  13 project, the success of removal of the Percolation Ponds will be assessed against the expected
 dewatering of the Perched Water.  If the goals are not achieved. Additional infiltration controls will be
 implemented which will include lining of the BLR. It is not expected that relocation of the STP is
 necessary given its small contribution to recharge.

 C.5. Group 5: Snake River Plain Aquifer

 Comment 249  : A Commentor was concerned that the percolating ponds will still be running and that
 contaminants in them were flooding or going into the aquifers. [JJ-TM]

 Response: We share the Commentor's concern regarding the percolation ponds and their affect on the
 migration of contaminants based on their present location. This is why this action will require the
 shutdown of the ponds at their current location and relocation.

 Comment 250  : A Commentor stated their belief that the Proposed Plan needed to take a fundamentally
 different view on how to protect the SRPA. The policy towards protecting the aquifer should be the
 overriding alternative looked at and other alternatives should flow out of that. [SR-TB]

 Response: We agree with the Commentor in that protection  of the SRPA is a primary objective in the
 restoration of the INEEL. Also, with the SRPA, a sole source aquifer, protection of the aquifer is a
 primary concern for remedial actions.  The remedial alternatives that were developed and evaluated
 considered the impacts on the SRPA.  With this in mind, remedial alternatives that do not adversely
 impact the SRPA are viable alternatives for consideration.

Comment 251  : A  Commentor stated that in addition to serving drinking water needs, the SRPA
provides vast quantities of water for Idaho agriculture and stated"that competing demands for water on
 Idaho and other western water sources will certainly intensify over the proposed 100-vear cleanuo
timeframe.  [L-W]                                     '                      '

Response:  We agree with the Commentor that water is a very valuable commodity. Most of the water
extracted from the SRPA at the INEEL is returned to the aquifer. Under this ROD. the SRPA area
associated with INTEC operations outside of the INTEC fence will be restored to drinking water
standards.  This \\ ill  make the aquifer useable after 2095 for other activities.

Comment 252  : A Commentor asked. "How widespread is the contamination in the plume?  Is there
going to be an attempt to retrieve and contain this contamination, or is it just uoinu to be monitored and
assumed to he below federal standards?" [PR-TT]
                                             A-TO

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                                                                                                           1
          vd                  ,      °f th£ C°ntaminan< P'ume in *e SRP A extends approximately 8
           T          A    boundary< however, contaminant concentrations above drinking water
          * do not extend beyond the INEEL site boundaries, nor are they expected to in heTuture  We
                                qUeSti°ned where the drinki"g -ater standards were to be met in the
  WAG03gerounEerg tum^Tto^rinkTn'Tf" timeframe'the SRPA wi!l be restored Remediation of the
  SRPA oS" thTcurent^               *™***** '" ^ INTEC °perations imPacted Portion °f the

  C.5.1. Group 5 Description

  Comment 254  :  A Commentor stated that there was insufficient information presented on I-129
  distnbu,,™ ,n <,w, . remedy for he aquifer The modd pred.cts possjbie c;ncentraetdo°n^w^h are
                      » water standard, yet no data exists to support the theory that the HI interbed
                       "r/SS!A   el?6 Commentor f^her stated that it was absurd to propose a
                         (NPV) or $56.2 (1997 dollars) based on a model prediction. The Agencies
                         '       •"""the inJectio« well and then determine if there really is a problem
                                    e whether any reasonable or workable treatment alternatives were
                                    with ion exchange, which currently will not work cost effectively
 Cnmmm-« i" *= Admtai, a vecord


                                       ^
                                           ^^^
                       contamination in the HI interbed and other vertical and horiLiuoSTn
                                                          er verca an   oruon
Commentor ,s not correct m that the active remediation of the aquifer will cost S56 2M (1997 doZs)
Th,s cost est,mate mcludes the long-term monitoring of the SRPA that will be required egardles of
whether the HI mterbed ,s extensively contaminated or not. The active remediation
est.rn.te amounts to S28.2M which includes the installation of extraction wells,
                                                            con wes,          aci H
treatab.!^ studies, and associated costs.  Under OU 3- . 3, remediation of the SRPA wS n the NTEC
fencehne  mcludmg the area near the injection well, was not evaluated or analyzed  A final
       ™OU   u      dd


technologies uw cons.dered and eliminated from further consideration in the beginning of he FS
Repon During the development of the FS and FSS Report, discussions concerning a Techn cal
lmpmc,,cab,l,ty (TI) wa.ver were held. Ion exchange is not the only physical- chemical treatment option

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  available. Given the small flow rates expected, evaporation of the pumped water and management of the
  residual sludges on-site is also a viable option.  We will perform treatability studies prior to implementing
  the contingent remedy. If it is determined that the remedy cannot be implemented, a TI waiver for the   *
  INTEC SRPA groundwater plume, will be pursued.

  Comment 255  : A Commentor stated that of the 39 aquifer well sampling results (from 1995) presented
  in the RIPS, only 4 wells had concentrations greater than the detection limit.  Also none of them were
  statistically above the legal MCL of 1 pCi- L. [JM-W]

  Response:  The Commentor is not correct.  Data obtained in  1995 for 1-129 is not useable in that the
  detection limit was not low enough to determine if 1-129 exceeded a concentration of 1 PCi/L.  For
  evaluation and the decision process, the USGS analytical data for I-129 from  1990-1991 were used  In
  the USGS data, 10 xvells exceeded a concentration of 1 pCi/L for 1-129. It should be noted that these are
  open  interval monitoring wells.  In the computer modeling, the aquifer was modeled as discrete layers.
  As such, mixing during sampling was not taken into account to determine risk levels.

  Comment 256  :  A Commentor stated that because the interbed sediment permeabilities are relatively
  low. a receptor would not pump water from the interbed. Therefore, if the 1-129 is in fact trapped in the
  low permeability sediments, no receptor will drink the water.  If the natural water filter exists and is
 operating as simulated in the computer model, it is good for the Snake River Plain water quality. [JM-W]

 Response: It is recognized that removal of water from the interbed area would be problematic  If high
 levels of contamination occur in the interbed, remediation may be required. However extraction of
 contaminated water from the highly contaminated zone would need to be at a sustainable rate of at least
 0.5 gpm, for future use.

 Comment 257   : A Commentor stated that if the I-129 is not trapped  in the sediments, then the model
 hypotheses are incorrect. If 1-129 is not trapped in the interbed, and the a computer model would predict
 thatl-129 concentrations are significantly lower than the current models predicted peak concentrations
 Under this scenario, 1-129 concentrations would probably not be predicted to be above the MCL of 1
 pCi/L  in year 2095. [JM-W]

 Response: If high levels of 1-129 are not found in the interbed, or other low permeability material the
 contingency would not need to be implemented as the aquifer would be restored to drinking water
 standards (MCLs) prior to 2095 by natural attenuation.

 Comment 258  : A Commentor stated that the predicted I-129 peak concentrations in year ^095
 corresponded to a 2 in 100,000 risk level (see Table 1, page 18 of the Proposed Plan) which is
 significantly below the risk based action level of 1  in 10,000. The 2 in  100,000 risk level is a very
 conservative estimate because it assumes the future receptor will pump from the relatively low
 permeability (high 1-129 concentration) interbed rather than the high permeability (low I-'l29
 concentration) basalt.  Therefore, this contingent remediation plan  is not risk based but rather MCL based
 on water that, in all probability, would not be pumped from the aquifer. [JM-W]

 Response:  An acceptable risk level of I in 10.000 includes all the contaminants of concern (total
carcinogenic risk).  In addition to carcinogenic risk, state and federal drinking water standards (MCLs)
must be achie\ed so that the water can be consumed. Both of these standards must be met.. The SRPA  is
required to  be restored to the drinking water standards < MCLs) by 2095.
                                             A-72

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   Comment 259  :


 needed for chromium.                                   s suc' rest°">"°" of 'he aquifer is nol

oonheNTEc encdin ^ """" ""S R°D' "'" ^ >Vi'h Ihe c°"'^i-,ed groundwater
                                       •  A-73

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 C.5.2. Group 5 Alternatives

 Comment 264  :  A Commentor stated that the Snake River Plain Aquifer (Group 5) should be
 remediated with a pump and treat (Alternative 3) for the same reasons the perched water should be
 removed and treated. [CB-W]

 Response: The preferred remedy for the SRPA that was presented in the Proposed Plan is protective and
 will result in extraction and above-ground treatment, as necessary, to achieve aquifer usability within 100
 years. There are some significant differences between the preferred Alternative 2B and Alternative 3.  In
 the case of Alternative 2B, contamination would be removed, if necessary, from the areas within the
 SRPA which would not be restored to drinking water standards or risk-based levels without active
 remediation. For Alternative 3. contamination would be removed, if necessary, across the entire
 contaminated region of the SRPA. The timeframe for both alternatives to restore the SRPA is the same
 (year 2095). For the SRPA. Alternative 2B is the most cost-effective alternative, while reducing the risk
 to acceptable levels, evaluated.  Based on this we concluded that Alternative 2B (Institutional Controls
 with Monitoring and Contingent Remediation) best satisfied the evaluation criteria.

 Comment 265  : A Commentor questioned the Proposed Plan's conclusion that treatment of
 contaminated groundwater is not cost-effective if the assumption were tested against future water value
 projections. [L-W]

 Response: The selected alternatives for the perched groundwater and SRPA will meet RAO's and insure
 that the SRPA is protected for future generations. The question of cost-effectiveness relates to the time
 versus cost for additional measures to remove contaminants from the SRPA and perched groundwater.

 Comment 266  :  A Commentor stated that Alternative 2B for the SRPA includes provisions for pumping
 groundwater from a low permeability layer. However, pumping water from low permeability layers when
 those layers are surrounded by higher permeability layers is not  feasible. The Commentor recommended
 that the Agencies select Alternative 2A. [CC-W]

 Response: Alternative 2B does have a contingent active remediation component for the portion of the
 SRPA sufficiently contaminated that active remediation may be necessary to restore the aquifer to
 drinking  water standard at the end of the restoration timeframe (i.e., 2095). Based on the groundwater
 modeling that was conducted in support of both the  RI/BRA and FS Reports, the long-term contamination
 in the aquifer is in the low permeability zone surrounded by higher permeability zones.  This does present
a challenge in the extraction of the contaminated porewater.  Removal of the contaminated porewater will
not be easy. However, the trigger level (monitoring criteria) has a concentration value 11 pCi/L in 2000)
with a specified rate of extraction of at least 0.5 gpm continuous. Extraction of 0.5  gpm from the low-
permeability zone within a well is not highly probable.  As a result, water for the high permeability zones
will be bled into the extraction area of the monitoring well to allow for an extraction rate of 0.5 gpm. The
mixed water would then be used to demonstrate whether active remediation would be required. The
purpose of the aquifer restoration is not to restore it  to pristine conditions, but to restore the aquifer to
acceptable levels (drinking water standards; MCLs). With the bleeding of the high  permeability zones
water into the low permeability zone  water,  it is feasible to extract 0.5 gpm to determined compliance
with the monitoring levels.

Comment 26?  : A Commentor asked how long monitoring will be maintained? [SRA-VV]

Response: Monitoring of the SRPA  will be performed until the Agencies determine that there is no
longer a ri>k that the MCLs will be exceeded after 2095.  This \\ilfbe evaluated during the 5-year
                                             A-74  .

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                                                                                                              1
  Comment 268   : A Commentor stated that it didn't look as if there was an implementable treatment
  technology if the groundwater has to be cleaned and asked what efforts were going forward throughout
  the DOE complex to address this lack? [SRA-W]

  Response: No treatability studies have been conducted to determine the cost and performance data for
  treating low level I-129 contaminated groundwater. If extraction and treatment is necessary, via ion
  exchange, we will perform these necessary studies to determine a cost-effective solution to"treating the
  groundwater. If we choose to go forward with evaporation and residuals management, this approach
  should not present a technical impracticability concern, especially given the small flow rates anticipated.

  Comment 269  : A Commentor asked several questions concerning the preferred alternative and I-129
  cleanup. A concern was that the peak 1-129 concentrations in  the aquifer are predicted (in the computer
  model) to still be relatively high in year 2095, trapped in interbed sediments (a natural water filter) with
  permeabilities far lower than the surrounding basalt aquifer. The Proposed Plan does not say whether or
  not the interbed will be the sole focus of this monitoring plan.  [JM-W]

  Response:  Modeling predicted that the long-term levels of 1-129 above the MCL would be  found in the
 sedimentary interbed in the aquifer, because this material impedes the flow of contaminated  groundwater
 relative to flow in the bedrock fractures.  Monitoring wells will be sampled during construction to
 determine the zone or zones of highest contaminant concentrations.  The zone or zones with  the highest
 concentrations will be monitored long-term to determine remedy effectiveness. It should be noted that a
 sustainable extraction rate of at least 0.5 gpm will be used for determining  if the contamination exceeds
 the action levels.

 Comment 270 : A Commentor asked  the Agencies to not put this I-129 based aquifer contingent
 remediation plan into a record of decision (ROD) that could force: (1) current decision makers to spend
 money drilling wells and placing well screens in the aquifer in  low permeability zones that will be useless
 for monitoring contaminant migration from the INTEC facility. Monitoring wells should be  screened at
 depths that will likely be used by future residents so that useful data can be collected to support computer
 model calibration and reliable predictions of future contaminant concentrations; and (2) future decision
 makers to spend money on  very likely ineffective and unnecessary treatability studies and possibly an
 I-l29 remediation project. [JM-W]

 Response: Monitoring under this ROD is to determine remedy effectiveness, not investigative
 information  for future uses. Future users may screen their well  within any water bearing zone in the
 SRPA. The monitoring will be conducted in the  highest contamination zone(s) whether the
 contamination occurs in the basalt or interbed layers at a sustainable extraction rate of at least 0.5 gpm,
 which could be used by a future resident.  The treatability studies and subsequent aquifer remediation '
 only will be implemented if the concentrations in the highest zone exceed the action levels at a
 sustainable extraction rate of at least 0.5 gpm and the extent of the hot spot  is sufficient in areal extent to
 warrant removal.

Comment 271   :  A Commentor requested that the Agencies put into the ROD that monitoring of I-129 is
 needed to confirm that it is not a COC. The Commentor believed that the detection of relatively high I-
 129 concentrations in the aquifer will  negate the hypotheses upon which the current computer model is
based and require that the 1-129  source and its transport in the subsurface be reevaluated in light of the
new information.  The Commentor stated that new predictions will have  to be made at that time to
estimated the I-129 concentrations expected after year 2095 and that' Aquifer remediation decisions
should be based on the results of this future analysis. [JM-W]

-------
     Response:  The Commentor is discussing I- 1 ^9 a< , rnr ;
     M29 in the aquifer is that it was disposed of d7rectlv^?n rh  S°T ^ at °U 3'13' The sour<* of the
     the 1-129 from surface and ^rf^^™^"^™*™!"* the inJ««'on well.  Impacts of
     term aquifer impacts.  Refinement of the aqu Jfc  c£Cs S±Sv^?>0 ** ^ P'Ume
     l-fce the Tank Farm soils and associated risks vvm^e Inducted Under OL 3™*
                                                        m   d                            a»
    contamination. [CAB-W]                Fomenting  pump and treat strategies for the aquifer


                                                                          i- ^ase, where the

          But they doubted that the "pump and M^S wo™!^ ^^ f°Und tO exceed trigger
   that ex,st at WAG 3, and encouraged the Agenc.es S Sn^th " bj/ffect've under the circumstances
               Thecosts associate^ Puan-r
                                                          above the MCL wi|, be found in the
         to flow in the bedrock fractures. ^^^^^"L^ of™*««"X* groundwater
 monuored long-term to determine if remedial action s waited  If !*£* C°ncentrations -i.| be
  v 11 be taken to remove sufficient contaminated groundwa™  < ?'££ ^ PUmp and treat aPP™ach
 2095. It should be noted that onlv zones capable of sustafnLl.T  ^  * restoratl'on by the year
 be pumped as these are the zones that could b* ?USed n  thS,  r      '^ rate °f at least °'5 8Pm »i»
 « h^hly soluble in groundwater and attenuates onlv sliLhUvon the' pr°!ldl^drinki"8 water.  As 1-129
 ground water will also result in the removal of th ^M29 hofsoo    w"    ^-^^ extraction of
 CAB has regardin  other                                  "    ^
                               e remova o  th  M29 hosoo    w       -
 CAB has regarding other uses of pump and treat technol^iesr"    ^T™ ^ C°"Cerns that the
 when W0rk,ng with non-aqueous wastes or with                      «

 C.6. Group 6: Buried Gas Cylinders
                                                           .    — "over-pressurization" in the
teniperature. Further the Commentor  k« ^  half "o  er wnri^ ^ "^ ^^ in
needed to .dentify the imminent safety hazard assorted «^™^ ^ the ^'"cies



                                                                      "Ot ^ beSt term we couid
Response: We apologize for our poor choice of
have used to describe the problems at these sttes Con      of     r                         e co
not being able to maintain or handle the internal nress^e  A      7'"^ WI" FeSult in the c-vlinder^
contents into the environment. In the ca " o^S ie CPP S4 *V 7 /' the Cylinders wi" ^en leak their
been uncovered by past flooding conditions  Site C?S cvltndl       "* CUm5ntly bUried' but have
-> -rd associated with these sites is the "2^^^^^


                                                         «« ^"^r Sites, the descript.on in no
      and questioned uln is this site in this Pro~P,an-.  ^ '"   '° '1Uman °F CC°lo^cal *^
                                            A-76

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  Response: The typical CERCLA risk from these sites is following the release of the cylinders contents
  As these sites represent a "threat of release" to the environment, these sites were added to the FFA CO
  Currently, there are no existing INEEL programs, other than CERCLA, for dealing with these cylinders
 • The major safety pathway for the cylinders is from disturbing the cylinders without adequate safety
  controls. The disturbance, intentional or accidental, will be an acute hazard.  These cylinders are not
  likely to explode or over-pressurize, but these are possible scenarios.  Neither scenario is considered an
  imminent event.

 C.6.1. Group 6 Description

 Comment 276  : A Commentor asked the Agencies to note that the acetylene cylinders may contain
 liquid acetone used to dissolve the acetylene gas and stated that based on the site description, the site is
 not well characterized and risk to human health and the environment had not been determined.  The
 Commentor suggested that this be done prior to conducting a remedial action.  [C-VV]

 Response: We, unfortunately must disagree with the Commentor.  The analysis and evaluation
 conducted on the Buried Gas Cylinder sites (Group 6) was based on the information available to us  The
 general characteristics of the material (waste) contained in the cylinders is known  The risks from these
 sites is not  a traditional CERCLA risk (chronic exposure), but more like that risk posed by unexploded
 ordnance (acute risk).  This acute risk will occur from disturbing the buried gas cylinders  Further
 characterization involves the removal of the cylinders and proper disposal, which requires
 characterization, which is what the remedial action calls for.

 Comment 277  : A Commentor asked the Agencies to note that if HF is in the cylinders then it is a
 RCRA listed waste.  [C-W]

 Response:  The Commentor is correct that HF can be a listed hazardous waste. Treatment will be utilized
 to render the HF nonhazardous in compliance with ARARs.

 C.6.2. Group 6 Alternatives

 Comment 278  : A  Commentor stated that at Page 40, Alternative 2, of the Proposed Plan it states that
 the alternative will also include initial site characterization and questioned why characterization was
 being performed after the ROD rather than during the RI/FS. [C-W]

 Response: The analysis and evaluation conducted on the Buried Gas Cylinder sites (Group 6) was based
 on the information available to us. The general characteristics of the material (waste) contained in the
 cylinders js known. The risks from these sites  is not a traditional CERCLA risk (chronic exposure)  but
 more like that risk posed by unexploded ordnance (acute risk). This acute risk will occur from disturbing
 the buried gas cylinders.  Further characterization involves the removal of the cylinders and proper
 disposal, which requires characterization, which is what the remedial action calls for. The sites have been
 sufficiently characterized to develop remedial action alternatives. The characterization activities
 described under the alternative are necessary to implement the remedy, not characterize the site for risk
 assessment purposes.

 Comment 279  : A Commentor remarked that there was no doubt in his my mind that Alternative ~> dig
 it up and do  the right thing, is still the only thing that should be done. [DK-TT]

 Response:  We thank the Commentor.  The best and most cost effective alternative for Group 6 is the
preferred alternative (Alternative 2:  removal, treatment and disposal).
                                             A-77

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 C.7. Group 7: SFE-20 Hot Waste Tank System

 Comment 280  : A Commentor stated that the Proposed Plan had a conflicting statement concerning
 when SFE-20 Hot Waste Tank System was taken out of service. [C-W]

 Response:  We are sorry for the confusion. The tank system was removed from service in 1976.  The
 1977 date shown  in the Proposed Plan was a typographical error.

 C.7.1. Group 7 Description

 Comment 281  :  A Commentor questioned the risk basis for taking action on the SFE-20 Hot Waste
 Tank System since there was no exposure pathway as the tank is contained within a vault, and the "'risk
 of release" is certainly small. [C-W]

 Response: The SFE-20 Hot Waste Tank System is listed as a release site on the FFA/CO.  The tank
 contents represent a threat of release to the environment, which is within the purview of CERCLA. The
 tank contents will eventually leak out of the tank and into the tank vault. During the 1984 investigation,
 there was evidence that water had infiltrated into the vault, which shows that water which leaked into the
 vault could also leak out of the vault. Soils beneath the SFE-20 Hot Waste Tank System are considered
 part of the release site and will be dealt with as part of the remedial action.  Further, detailed,
 characterization of the tank contents is the first activity in the selected remedy (Alternative 4:Removal,
 Treatment, and Disposal).  Based on the available information and analysis conducted, there is sufficient
 information to select a remedy under CERCLA for this site.

 Comment 282  :  A Commentor stated that the SFE-20 tank had not been shown to be a release site, or
 that of an  imminent release. The Commentor thought that the tank held hazardous waste and should have
been placed on the RCRA Part A application or addressed under the D&D  program. [C-W]

 Response: The SFE-20 tank and associated structure are a source term that threatens the environment,
the SRPA in particular. Since the tank was abandoned prior to the effective date of RCRA application to
mixed wastes, the  SFE-20 Hot Waste Tank System is listed as a release site on the FFA/CO. The tank
contents will eventually leak out of the tank and into the tank vault.  Based on the available information
and analysis conducted, there is sufficient information to select a remedy under CERCLA for this site.
The tank contents  are not known to have listed waste constituents, but there may be characteristic
concentrations of other hazardous constituents.

C.7.2. Group 7 Alternatives

Comment 283 :  A Commentor stated, "Once again, DOE fails to correctly classify the waste in SFE-20
tank in a blatant attempt to circumvent regulatory requirements. The Rl/FS sample data of the tank, (see
table below) shows clearly that the tank contents (liquid and sludge) as well as the tank concrete vault
contents meet the definition of mixed transuranic (TRU) waste, and by regulatory definition, it must go to
a deep geologic repository. Grouting (mixing with cement) as proposed by DOE, is a thoroughly
discredited disposal method B tried and failed at Han ford." [CB-W]

Response: Preliminary1 information supports that concentrations of TRU may be high enough to require
disposal of the Tank's contents at WIPP. However, due to the radiological hazards and access
restrictions. we have not completed characterization of this tank, which will be required even if we
elected to  leave the tank in place.  Under evaluation of alternatives, we concluded that Alternative 4

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  Comment 285  : A Commentor stated that the concept of clean closure VES SFF ?n H'H  ,   u
    "^^^^

                      ^
         VHS-SPB,0 bJ'
                                                    ' be high
                                                   I access controls, we have
                                            I even if we elected to leave the tank in
                                                               For the
                                                             t effective and

 rtrttlhT;'r^
 s^r conc'uded thai Aitt™tivc 4 
-------
  and treatment of the SFE °0 Hot
  be required.  For A.ternatil, 3.
  required.
  conducted on site? [C-W]
                                                                                  ™>n>»nng „,„
                                                               -term surveillance and monitoring is
                                   ^
                                          Concrete) be Abject to and it the treatment would be
    Response:  Treatment may be necessarv to meet the
    ctn i/*t i t *>A  T*L  »                     ..**v*<"*'»vtijc*v, i~s i' eiuLTfrinn/"*** s*t*it*»****i i*   t
    oiruciure, I tie trp.Tfmpnr /L-f^u;i;-. *•     .. ..,,       ^-*-'i «^v.cptdntc criiena ror the ^mntiA^ f«—i    j

    WAO 3 AOC. wh« ™S. " °"- "***«*»• » •»•".). ^ necessary. u,l, be coTcttd"-th^tH,
    that ,f the tank was left in the Proposed Plan
about what will be done with the waste. [C-W]
                                                                             , th,s waste: the
                                                         EnVIr°CarJ? The Commentor went on to

                                                             ' "   ed t0 be much more
matenals from this site ma
                                                  at
                         rem()ved wastes
                                                          consent concentrate exceeding 90

                                                                      '°Wen  S°me debris
                                         ^

                                              ^^                         - have no, deve,oped
 concencrating on preparing ,he ROD and ,Ws Rns™enes^      ^ '" th
-------
  Response:  It is recognized that the largest amount of contamination at INTEC occurs in the Tank Farm
  area. The ultimate disposition of the waste in the INTEC Tank Farm tanks is being evaluated in the Idaho
  HLW & FD EIS. In addition, this EIS is evaluating the disposition of the tanks within the INTEC Tank
  Farm. Evaluation of the soils surrounding the INTEC Tank Farm is being further investigated and
  evaluated under the OU 3-14 RI/FS project.  With CERCLA being functionally equivalent to NEPA the
  RI/FS will meet the needs of an EIS under NEPA and no EIS process will be conducted for the Tank
  Farm soils.  Several remedial action alternatives for dealing with the soil will be evaluated under the OU
  3-14 RI/FS. Concerning the schedule, the INTEC Tank Farm is an active facility and implementation of
  the final action will  need to be conducted following the closure activities. Prior to the final disposition of
  the INTEC Tank Farm area, actions may be taken to reduce the impacts on human health and the
  environment. These actions will be continued until the final actions are completed on the INTEC Tank
  Farm area.

  D.2. Decontamination, Decommissioning, and Dismantlement

  Comment 293   :  A Commentor inquired if impiosion-in-place was a likely alternative for some of the
  more contaminated buildings at the Chem Plant and though that although, residual risk "belongs" to D&D
  rather then ER,  it was appropriate to discuss it in the Proposed Plan. [SRA-W]

 Response: Evaluation of alternatives for the disposition of facilities at INTEC is not part of the OU 3-13
 project.  The disposition of certain INTEC facilities is, however, being evaluated under the Idaho HLW &
 FD EIS. Implosion or grouting in place is an alternative being evaluated. The intent of the OU 3-13
 project is to reduce the risk to the environment at INTEC to acceptable levels. The residual risk from the
 INTEC facilities closed in place will need to be factored into the cumulative risk and the cumulative risk
 will need to be maintained at an acceptable level.

 Comment 294   : A Commentor asked what the schedule was for transfer to EM-60 of facilities whose
 missions have ended (e.g., ICPP 601)? [SRA-W]

 Response: When the mission for a facility at INEEL has ended and no future mission is identified  the
 facility ownership is transferred to the EM-60 organization for facility deactivation, as the Commentor
 stated. Following the deactivation activities, ownership of the facility is transferred to the EM-40
 organization for final disposition (dismantlement). Occasionally, the EM-60 conducts activities on a
 facility to include the final disposition.  For example, the CPP-601  facility is currently under EM-60
 ownership.

 Comment 295  :  A Commentor was concerned that the Agencies stated that the selected alternative [for
 Group 2 soils] is consistent with expected D&D activities. Since when is this a requirement of
 CERCLA? Do the Agencies expect these D&D activities to be conducted as part of CERCLA? If so,
 what are the decision documents the public should expect to review, prior to these activities? [C-W]

 Response: Closure of the facilities at INTEC will be designed and implemented to remain protective of
 human health and environment, in particular the SRPA. As the remediation of the SRPA is being
conducted under CERCLA, impact to the aquifer need to be coordinated with the CERCLA Program.
Aspect or parts of INTEC facility closures may end up being within future CERCLA projects.  If
activities for INTEC facility closures are conducted under CERCLA, the appropriate documents will be
developed and public  participation activities  will be conducted.
                                            A-81

-------
                                                                                                            1
    D.3.  Pit 9
                          ^^^^
             Agenc.es admitted in writing that rhey'had never done them ^PR Trj                  C"C


              ^










                                 ^








 D.4. Other Disposal Facilities
                       -,             s














arc .ubjoa ,o ,he ,00 >W Hoodphin a^^h^^^J
                                            A-.S2

-------
   D.4.I. Radioactive Wasee Management Comple* (RWMC)
                             d          lhe issue of usins Ih
                           ^^^^
                                                            ,„
  .=r. =:~ S S-™--"— s-
                         '
  the RWMC fac,li,y   ud be unsufo   dpof MLLW.'


                                                S,.,emen, (,d,ho
 ofthe HLW was compleKdly 2035^ periS o'f 10 ™  "  Y ^ " "M aSSUmed *" a" treatra-'
 of the necessary INTEC facilities which result 2e veS 5Sf n  i° " ""^ "" "» disposili<»'
   .daho HLW * FD H,S, ,he did^T,                               fOT

       oanoun
 alternatives is incited ^n "Je P° pos'Jd n^r R^a" ' "" dlSCUSS'°" °f "" 'dah° HLW & FD £'S
                                    *"
                                    the
                                             s not
replacement. [CAB-VV]               conducted before determining how to proceed with
                            A-83

-------
                                                  tributiris io the m'

                                 "=-T^-— ---"
                           ^^

                        .ve     characteriz,in8 the dls
  .he „««„„.                       '       ""





                                          ^
 D.6. Unconfirmed Information at INTEC


                                 stackins
                                ,,                        io •—
 referred ,o by ,he Commenlor are ,he no
-------
  Plutonium that it can receive, thus prevent the migration of contaminants like plutonium to the SRPA at
  concentrations that present an unacceptable risk.

  D.8.  Nuclear Energy

  Comment 307  :  A Commentor wanted the Agencies to get on with this reduction of risk to our unborn
  generations to follow. Stop promoting this risky energy source and military deterrent around the world.
  [RK-W]

  Response: Cleanup activities at INEEL, including both the environmental restoration and waste
  management programs, are intended to reduce the risk to human health and the environment. There are
  current ongoing projects to reduce the risk from waste in storage and previous contamination.
  Implementation of this ROD will quantify and reduce the risk from various areas at INTEC to acceptable
  levels. The CERCLA actions are aimed at cleanup from past operations and do not promote energy or
  power generation from any source. Since part of the DOE's mission is the research and development of
  nuclear energy sources the cleanup activities must consider these kind of missions as part of cleanup
 responsibilities.

 Comment 308  : A Commentor stated, "While 1 don't oppose foreign countries sending us the spent
 nuclear waste from peaceful use of the atom. It is only because it is the lesser of two evils. Let this waste
 be used by a mad man to build a nuclear bomb or try safe containment, that the INEEL has not been able
 to do." [RK-W]

 Response: Some spent nuclear fuel from foreign nations is being received at INEEL for temporary
 storage.  This foreign spent nuclear fuel will  eventually be packaged for final disposition in an approved
 disposal  facility. While there has been contamination as a result of operations (accidental and past waste
 management practices) at INTEC, the storage of spent nuclear fuel at the INEEL has been and will
 continue to be safe.

 Comment 309  :  A Commentor wanted help in getting the permanent repository for high-grade nuclear
 waste open. [RK-W]

 Response: We believe that the Commentor is referring to the High Level Waste Repository.  There are
 currently two permanent repositories being considered by the Department of Energy.  The first repository
 will deal  with TRU waste (waste containing fransuranic constituents concentrations of 100 nCi/g or
 greater).  This facility is referred to as  the WIPP and is located near Carlsbad, New Mexico. The second
 repository will deal with commercial and DOE produced spent nuclear fuel and DOE produced HLW.
 The proposed facility is referred to as Yucca Mountain and is located in western Nevada.  Progress is
 being made to open both of these facilities to accept the appropriate waste materials. The DOE is
 responsible for both repositories and is attempting to open both repositories as soon as possible.

 D.9. Research and Development

 Comment 310  :  A Commentor wanted support for more research  to support alternative renewable
 energy sources (i.e.. solar voltaics, superconductivity at lower temps). [RK-W]

 Response: It is recognized that research and  development of technologies is needed for the future. There
are efforts to bring new missions to the (NEEL. The technologies thanhe Commentor is referred to may
end up among the technologies undergoing further and future research and development at the INEEL. '
                                            A-85

-------
 D.IO. Idaho Space Port

 Comment 311  :  A Commentor wanted DOE to aggressively pursue the Idaho Space Port location at
 INEEL. [RK-W]'

 Response: The INEEL is supporting the State of Idaho in pursuing a Space Port located at the INEEL.
 There are several other states also trying to secure the Space Port. Selection of the location of the Space
 Port will be determined in the future. The Space Port is a privatized venture and not specifically under
 the authority of the DOE.

 D.I1. INTEC Operations

 Comment 312  : A Commentor believed that a systematic review of operations, including SNF and HEU
 throughout history and a mass balance review, is required to understand the status  of the INTEC facility
 with adequate rigor to undertake the cleanup safely. If necessary, the DOE should prepare a classified
 appendix to cover these issues.  "If possible, any classified information should be reviewed to determine
 whether the restrictions on public access (including L'NCI) continue to be required. DOE headquarters
 committed to releasing a public document on HEU inventories, comparable to •'Plutonium' The First 50
 Years: in 1997." [SRA2-W]

 Response:  There is adequate historical information available concerning historical operations and
 activities at INTEC.. We agree with the Commentor that there is a lack understanding by the public
 concerning the operations at INTEC. Generally, the uranium extracted during the reprocessing operations
 was sent to the Savannah River Site (SRS).  At SRS, the uranium was generally used in SRS nuclear
 reactors to produce both tritium (H-3) and plutonium. As part of the INEEL cleanup activities, there is an
 ongoing program to identify and remove/reduce unstable nuclear material from INEEL facility. For
 example, a recent project at INTEC removed uranium from the ROVER facility located in CPP-640.
 Mass balances have been historically maintained during operations at INTEC. including waste
 management activities. In both the Spent Nuclear Fuel (SNF) EIS and Idaho HLVV & FD EIS, mass
 balances are taken into account when evaluating the waste volumes, treatment, disposal, and other
 criteria^ Also, the CERCLA project considers mass balances. No appendix is planned to be developed
 (classified or unclassified) containing information on SNF and  Highly Enriched Uranium (HEU).
 Currently, there is no report developed on HEU inventories.  However. DOE is in the process of
developing a report.
                                            A-S6

-------
                              INDEX OF COMMENTS

 Shown below is an index of the comments received on the Proposed Plan during the public comment
 period. Presented in this index are the 3 12 numbered comments received. Thislndex shows both the
 various Commentors and their associated numbered comments.

 Albert Taylor
   Comment 3 [[[                    ^_-,
 Anonymous
   Comment 175 [[[                    ..47
   Comment 254 [[[ .                   ^_7I
 Barbara Robertson
   Comment 190 [[[                       A  5?
 Beatrice Brailsford
   Comment II                                                                   A 4
                                                                           ..........
   Comment 1 16 ........... . [[[ _                    -
   Comment 1 19 ............................. . [[[ .......................... A ^
   Comment 12 [[[                 ......  A 4
   Comment 131 [[[                             ,  ,
   Comment 132 [[[                        A 35
   Comment 137 [[[              ........... ^_,,
   Comment 138 .......................... . [[[    ................ A^7
   Comment 14 [[[                                       » «
   Comment 140 [[[                 .......  A-37
   Comment 15 [[[                           ................  .5
   Comment 16 ............................ [[[                           '» 5
   Comment 17 [[[ '_ ............................... ,                       A_^
   Comment 18 .................................................. . ...............................................        ......................  , ^
   Comment 19 [[[                            ........................ \,
   Comment 2 ..................................... . .................. ... ....................................                 ............ ^_T
   Comment 221 [[[               \-(p
   Comment 227 .................. . [[[  ................................ '_"
   Comment 267 .......................
                         [[[                 \-l4
  Comment 268 .................................... ', ...............................                                 ^.75

-------
 Comment 102	A-27
 Comment 103	A-27
 Comment 108	A-29
 Comment 110	A-30
 Comment 112	A-30
 Comment 113	A-30
 Comment 118	A-31
 Comment 120	A-32
 Comment 126	A-33
 Comment 127	A-34
 Comment 13	A-5
 Comment 133	A-35
 Comment 134	A-36
 Comment 135	A-36
 Comment 139	A-37
 Comment 146	A-39
 Comment 151	,	A-40
 Comment 152	A-40
 Comment 153	,	A-40
 Comment 164	A-44
 Comment 165	A-44
 Comment 172	A-46
 Comment 173	A-46
 Comment 178	A-48
 Comment 179	A-48
 Comment 180	A-49
 Comment 222	A-62
 Comment 229	A-64
 Comment 239	A-67
 Comment 240	A-67
 Comment 241	A-67
 Comment 247	A-69
 Comment 248	A-70
 Comment 262	A-73
 Comment 263	A-73
Comment 274	A-76
Comment 276	A-77
Comment 277	;	A-77
Comment 278	A-77
Comment 280	A-78
Comment 281	A-78
Comment 282	A-78
Comment 288	:	..A-80
Comment 289	A-81
Comment 295	A-l 1
Comment 42	A-l 1
Comment 43	A-l 1
Comment 69	.'	\	A-16
Comment 74	A-18
Comment SO	A-20
                                    A-SS

-------
    Comment 81 .....................................                                                    .,
    Comment 85 ............................... -..'-^ZZZZZZ'^'ZZZZ .......................................... 41?
    Comment 86 [[[   [[[ *~~.,
    Comment 88 ....... . [[[              ........................................ ' ' ~~~
    Comment 89 .............................................                [[[ ' ~~~
    Comment 94 ..................... . [[[  [[[ ' ~~
  Chuck Broscious                                             ................................................ "~
    Comment 104 ...... .' ......... . [[[
    Comment 166 ................................ '. ..............                       ........................................... " "~
    Comment 170 .............................. .'...!.'.!.'.'"!!!.".".'." ........................................... ' ............................ ........... ?~,7
    Comment 193 ......................................      [[[ '^  '
    Comment 194 ....... . ............................... .".".' [[[ *~"
    Comment 198 ............. . ............................. '"."."".' [[[ ' .......... * .j
    Comment 199 .....................................    [[[ ^"^
   Comment 201 .............. ....................... "..'"" .......................................... ' ..................................... ' ......... *~-
   Comment 202 ......................... . ................ ""
                            . ................
   Comment 203 ............. ......................... ..ZZZ"""'"'''-"ZZZ^ [[[ A 57
   Comment 21 ................................. . .................                      ..................... ' .................... ""
   Comment 2 17 ...................................... "".' [[[ TV,
   Comment 218 .............                [[[ *~°
   Comment 226 .....................................    [[[ ' ........ : ........................... *'*!
   Comment 242 ...........                       ....... ' [[[ *;£
   Comment 243 ..................................... ..... ' [[[ ~'°°
   Comment 264 .......................................         ............................. " ................................................ *~r
   Comment 283 ....................................... ..".. ......... ................................................ ' ........ '
                                  ....
   Comment 298 ..............................     ................................. ' [[[ *  *
   Comment 305 ....................................      .................................. • .................................. ' ..................
   Comment 33                           ''"''"'"''"""""'":""'
                                        ............                               9
  Comment 34 [[[      [[[ ................. ^
  Comment 75 ................. . ..................... ....".... [[[ "  "^
  Comment 87 ........................... . ............. '-"""""^"""'"'""""J. [[[ \~-,*
  Comment 90 [[[ ;     [[[ ' ........ ."^
  Comment 91 ....................................... .'.'.'.".'.'".".".' ...................  [[[ t"
  Comment 92 .................................. .....    [[[ '
                                  """
                              .....
  Comment 93 ..... ..................... .............. !!.""!."!!!.'."."!.'.".'.'."!.'.".".".' ........... ...... ............................................. 4^4
  Comment 95 [[[ !.."!.."'."'...' [[[ '"7
  Comment 96
  Comment 97 ..........................                                      ...................................  ~.

-------
  Comment 29	A-8
  Comment 30	A-8
  Comment 303	.	A-83
  Comment 304 v	A-84
  Comment 45	A-l 1
  Comment 46	A-11
  Comment 47	A-12
  Comment 48	,	A-12
  Comment 49	A-12
David Hensel
  Comment 10	A-4
David Kipping
  Comment 147	A-39
  Comment 148	A-39
  Comment 155	A-41
  Comment 159	A-42
  Comment 160	,	A-43
  Comment 183....	A-50
  Comment 235	A-66
  Comment 238	A-67
  Comment 253	A-71
  Comment 279	A-77
  Commenf290	A-80
  Comment 291	A-80
  Comment 292	A-80
  Comment 302	>	A-83
  Comment 71	:.	A-17
Frank Priestley
  Comment 181	A-49
Helen Chenoweth
  Comment 204	A-57
  Comment 205	A-57
  Comment 206	A-58
  Comment 24	A-7
  Comment?	A-3
Jack Lemley
  Comment 115	A-30
  Comment 125	A-33
  Comment 171	A-46
  Comment 177	A-48
  Comment 195	A-53
  Comment 196	.A-53
  Comment 207	A-58
  Comment 208	A-58
  Comment 209	A-58
  Comment 210	.....A-59
  Comment 211	A-59
  Comment 212	'.	A-59
  Comment 213	A-60
  Comment 214	A-60
  Comment 219	A-61
                                       A-90

-------
  Comment 220 .......                                                              , /-,
  .-,       ,_       " ............................................. • .................................................. ........................ A-o!
  Comment 25                                                                  _. 7
                                                                 .......................... ''
 Comment 187
 Comment 1S8
                                                                              , 70
                                                                               .  -,
                                                                              A 74
                                                                               .  ,
                                                                               "  ,
  Comment 251 .... [[[
  Comment 26 ........ . ................... ........................... .                      ......
  Comment 265 ............ .............................................
  Comment 8 [[[ .                      .........
  Comment 9 ............................................ .....................................
James McCarthy
  Comment 101 [[[                          . 26
  Comment 117 [[[                   .................... \ -,,
  Comment 129 [[[ ........................ .......................... ^ ,4
  Comment 244 [[[                  ............. . gg
  Comment 245 ........................... . ....................................                           ............. A ,-q
  Comment 246 .................................................. . .................................           ..................... " ..... . 69
  Comment 255 [[[                         ........... . 7-,
  Comment 256 [[[                              . -^
  Comment 257 ........ . [[[ _                           .......... .  7^
  Comment 258 [[[             ........................ *.  yX
  Comment 259 [[[            ......................... .  ^
  Comment 260 [[[                     ........................ \  -,-,
  Comment 261 ........................ .- [[[                ................... »  7,
  Comment269 [[[ _              ................... ..... .   75
  Comment 270 [[[                       .................. ^_7g
  Comment 271 ........................................... .. ......................................               .................... A_7-
  Comment41 [[[                            .............. A ]0
  Comment 82 ............ . [[[ ........................................  _7
  Comment 83
                                                                            >

-------
  Comment 189	                      A-51
 Mr. Jobe
  Comment 105	A-27
 Pamela AI lister
  Comment 22	A-7
  Comment 32	A-9
  Comment 6	A-3
  Comment 61	A-14
 Paul Randolph
  Comment 4	A-2
 Peter Rickards
  Comment 149	A-40
  Comment 154	A-41
  Comment 158	A-42
  Comment 174	A-47
  Comment 182	.A-49
  Comment 230	...A-64
  Comment 231	A-65
  Comment 232	A-65
  Comment 233	A-65
  Comment 234	A-66
  Comment 252	A-70
  Comment 28	A-8
  Comment 296	A-82
  Comment 297	A-82
  Comment 306	A-84
Richard Kuehn
  Comment 109	A-29
  Comment 20	A-6
  Comment 307	A-85
  Comment 308	,	'..A-85
  Comment 309	A-85
  Comment 310	A-85
  Comment 311	A-86
  Comment 72	..A-17
Robert Bobo
  Comment 121	A-32
  Comment 122	A-32
  Comment 123	,	A-33
  Comment 124	A-33
Robin VanHorn
  Comment 111	'.	A-39
Shannon Ansley
  Comment 76	A-18
Steve Ramono
  Comment 167	A-45
  Comment 168	A-45
  Comment 169	'.	A-45
  Comment 200	A-54
  Comment 250	A-70
  Comment 299	A-83
                                       A-92

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   Comment 5
 Thornton Waite                                  	  	
   Comment 1	
   Comment 128	...........'.	"	A"'
   Comment 130	...."......	A~34
   Comment 284	-.	'".'.'.".".'.	A"35
   Comment 285	„     	A"79
   Comment 286	".'."."	'	A'79
   Comment 287	.'....	"	A'79
   Comment 44	.'.".".'.'.'.'.'.'1'.'	;	A"?9
  Comment 59	'."	A"n
  Comment 70	   	A"14
Unknown                      	'	A'i6
  Comment 136	
  Comment 143	"Z...1.."	A"36
  Comment 144	   	A'38
  Comment 145	.....'......."	A'38
  Comment 156	...."	'	'	"""	A"39
  Comment 157.....	'"	'	A'42
  Comment 161	.'."Z.".".'	'""	A~42
  Comment 162	ZiZZi	A"43
  Comment 163	".'."ZZ"	-..A-43
  Comment 176	Z	'	'	A"43
  Comment 191	.'.!.'.".".'."""''•	•	A"47
  Comment 192	,	A"52
  Comment 197	'.".."	'	'	A'52
  Comment 216	  	'	A"54
 Comment 225	."..'	'	.'	'	...A-60
 Comment 275	".".	A'63
 Comment 31	!".".'.'.'".'."!.'.'.'".".'.".'.'.'".".".'.'"'"	A"76
 Comment 50	          	:...A-8
 Comment 51	......"..'...	A"12
 Comment 52	                   	"	
 Comment 53	""""'	•	'	A'13
 Comment 54	'	A"13
 Comment 55	1!.'.".'.".'"."."	"	A"13
 Comment 56	'.	!""""""'"	A"'3
 Comment 57	                 	'	
 Comment 58	"'ZZ"'Z"""i	'	A"'4
 Comment 65	"'."!	A''i
 Comment 66....	''"""""'!^"""""'.	A"'-
 Cornment 67	                               	...A-n
                  	A-16

-------

-------
       Appendix B
E"9ineeri"9 and Environmental Laboratory
 Record File Index for the Comprehensive^
RI/FS of Operable Unit 3-13
        08/10/99

-------

-------
                                  Appendix B


                               Notice to Reviewer

Appendix B—The administrative record for this ROD is being updated. The final index to the
Administrative Record File will be sent under separate cover prior to ROD signature.
                                      H-l

-------

-------
         IDAHO NATIONAL ENGINEERING AND ENVIRONMENTAL LABORATORY
       ADMINISTRATIVE RECORD FILE INDEX FOR THE COMPREHENSIVE RI/FS OF
                               OPERABLE UNIT 3-13
                                     09/22/99


 FILE NUMBER

 AR1.1       BACKGROUND

 '     Document #: *3533
       Title:        Contaminants of Concern in the Test Area North Groundwater
       Author:      Zimmerle, J.R.
       Recipient:    N/A
       Date:        01/08/92

 >-     Document #: *3534
       Title:        Summary of RCRA Facility Investigation Activities at TAN
       Author:      Zimmerle, J.R.
       Recipient:    N/A
       Date:        01/08/92

 *•     Document #: *5169
       Title:        Assessment of the groundwater pathway from the leaching of surficial
                   and buried contamination
       Author:      N/A
       Recipient:    N/A
       Date:        07/29/92

  This document can be found in Administrative Record binder Operable Unit 1-07A, Vol. I

'•     Document #:  10986
      Title:         Response  to Notice  of  Deficiency (NOD) for Closure Plan  Submittal
                   Received from the EPA/State
      Author:      Solecki, J.E.
      Recipient:     Gearheard, M.
      Date:   %      1 1.15/89

'•     Document #:  14143
      Title:         Background Concentrations of Selected Metals and Radionuclides in the
                   Big Lost River Alluvium at the Idaho Chemical Processing Plant
      Author:      WINCO
      Recipient:     Not specified
      Date:        02/28/94
                                      B-1

-------
                   OPERABLE UNIT 3-1 3                  09/22/99
 FILE NUMBER

 AR1.1       BACKGROUND (continued)

 •'•     Document #:  18017
       Title:         Disposal of Drill Cuttings from Monitoring Well (MW)-18
       Author:       Jenkins, T.W.
       Recipient:     Orlean,  H.; Reno, S.L.
       Date:         10/23/95

 >      Document #:  2549
       Title:         USGS Comments on Closure plan for CPP-63 Hexone spill by CPP-710
       Author:       Mann, L.J.
       Recipient:     Feigner, K.D.
       Date:         08/27/87

 '•     Document  #:  2558
       Title:         USGS Comments on Ground-water monitoring plan, ICPP Injection Well
       Author:       Mann, L.J.
       Recipient: ,    Pierre, W.
       Date:         05/27/87

 *»      Document #:  2559
       Title:         USGS Comments on Closure plan, ICPP Injection Well
       Author:      Mann, L.J.
       Recipient:    Pierre, W.
       Date:        05/27/87

 *      Document #: 2560
      Title:        USGS Comments on Closure plan for the Hexone spill west of CPP-660
      Author:      Mann, L.J.
      Recipient:    Pierre, W.
      Date:        06/01/87

>     Document #: 2801
      Title:        USGS Comments on Closure plan for CPP-55, Mercury contaminated area
                   (South of ICPP T-15)
      Author:      Mann, L.J.
      Recipient:    Pierre, W.
      Date:        04/29/87

<*     Document #: 3077
      Title:        Closure Plan for CPP-64 (Hexone Spill West of CPP-660)
      Author:      Solecki, J.E.
      Recipient:    Gearheard. M.
      Date:        07 1 9 90
                                       B-2

-------
                   OPERABLE UNIT 3-13                   09/22/99


 FILE NUMBER

 AR1.1       BACKGROUND (continued)

 '•     Document #:  3090
       Title:         Closure Plan for Land Disposal Unit CPP-48 -Excess Chemical French
                    Drain
       Author:       Not specified
       Recipient:     Not specified
       Date:         06/10/91

 '•     Document #:  4962
       Title:         Flooding Potential  at the Idaho Chemical Processing Plant
       Author:       Niccum, M.R.
       Recipient:     Not specified
       Date:        04/01/73

'-     Document #: 610
       Title:        Final Closure Report for CPP-55, Mercury Contaminated Area
      Author:      Solecki,  J.E.
      Recipient:    Gearheard, M.
      Date:        12/03/90

 -     Document #:  611
      Title:         Final Closure Plan for CPP-39, Hydrofluoric Acid Storage Tank
      Author:       Solecki, J.E.
      Recipient:    Gearheard, M.
      Date:         12/05/90

 •     Document #: 61 1 1
      Title:        Revision  of Closure Plan for Land Disposal Unit (LDU) CPP-63  Hexone
                  Leak Near Building CPP-710
     Author:      Solecki, J.E.
     Recipient:    Gearheard, M.
     Date:        08/22/89

•    Document #: 6533
     Title:        WINCO Comments on EPA Region X Review of Summary Assessments
                  CPP-41, CPP-43. CPP-70. CPP-71.  CPP-76, and CPP-77
     Author:    •  Matule, A.J.
     Recipient:     Weiler, F.H.
     Date:        11/07/89
                                      B-3

-------
                                                                                       1
                  OPERABLE UN.T 3-1 3


 FILE NUMBER

 AR1.1       BACKGROUND (continued)

 y-     Document #: 6589

       luthor:      E^eJ0RKPr°leCt
       Recipient:    Williamson, D.J
       Date:        10/13/91

y-     Document #: 6594
      Recipient:
      Date:
              Williamson, D.J
              12/18/91
  Document #: 6596
  Title:        Sites Within OU 3-07
  Author:      Mascarenas, C.S.
  Recipient:    Williams, J.L.
  Date:        10/29/91

 Document #:  6614
     Recipient:
     Date:
             Mascarenas, C.S
             10/22/92
 Document #: 6622
 Title:
    Author:
    Recipient:
    Date:
             Malik. L.E.
             McGee, W.D.
             06/08/92
Document #:  10707
    Recipient:
    Date:
            Ellis, D. L.
            09/20/99
                                                    09/22/9g
                                                                Utilities
                                       Contaminated So,
                                               Detecto, ,or Operabie Unit 3-07
                                B-4

-------
                  OPERABLE UNIT 3-13
                                           09/22/99
FILE NUMBER
AR1.1
BACKGROUND (continued)
      Document #:
      Title:

      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:
      6623
      Portable Pipe Mapper (PPM) Field Test at the Idaho Chemical Process
      Plant IICPP)
      Motazed, B.
      Not specified
      01/01/92

      6625
      Idaho Chemical Processing Plant (ICPP) Waste Area Group Assessment
      Not specified
      Not specified
      01/04/91

      6626
      Meeting -Injection Well
      Valentine, J.
      Not specified
      05/08/86

      6628
      Final Report for CPP-42I
      Hanson, N.W.
      Poland,  D.J.
      09/14/88                                                 •
     Document #: RC-10-98
     Title:         Multi-Agency   Radiation  Survey  and  Site  Investigation  Manual
                  (MARISSIM) Investigation for CPP-709 Radionuclides
     Author:      Chambers, R.
     Recipient:    Rodman, G.R.
     Date:         09/21/98

     Document ff: RDG-03-97
     Title:         Waste Area Group (WAG) 3 Core Samples
     Author:      Greenwell, R.D.
     Recipient:    Connolly, J.M.
     Date:         03/20/97
                                      B-5

-------
                     OPERABLE UNIT3-13                  og/22/9g


   FILE NUMRFR


   AR1.1       BACKGROUND (continued)

   '•    Document #: RDG-03-99
        Title:        cn
                     Compensation,  and Liability Act  fCFRn A. c^''Onimental   Response,
                     Area (RMA) and Storage Yard     '^C"ULA) Rad.ological  Management
        Author:       Greenwell,  R.D.
        Recipient:     Distribution
        Date:        04/14/99

        Document #: RFM-41-89

                                                  Report
       Recipient:    Shadley, D.E.
       Date:        12/11/89

 '•     Document #:  RHM-33-84
       Title:         CPP-601 Pro
       Author:       Meservey ^H^  ^ A' B/ C' D' & L D&D
       Recipient:    Brehm, J.
       Date:        10/26/84

A      Document #:  SGS-1 27-91
      Title:         Information Request
      Author:       Bergeman, N.L
      Recipient:     Hinman,  M.B.
      Date:         04/25/91

'•     Document ft: SGS-289-91  .
      Title:        Tank Closure Notification
      Author:      Evans, T.A.
      Recipient:    Lyle, J.L.
      Date:        07/31/91

      Document*: SGS-334-91
     T|t'e:        Tank Closure Notification
     Author:     Evans, T.A.
     Recipient:    Lyle, J.L.
     Date:        08/22/91
                                     B-6

-------
                     OPERABLE UNIT 3-13                  09/22/99


   RLE NUMBER


   AR1.1       BACKGROUND (continued)

   '•     Document #: SGS-353-91
         T|tle:        Tank Closure Notification
         Author:      Evans, T.A.
         Recipient:    Lyle, J.L."
         Date:        09/10/91
  *
         Document #: SMB-05-94
        Recipient:    Koch, D.
        Date:        07/15/94

        Document #:  TAI-05-84

                    ^ulp'mem' COmr°'S ** 'he Deco"«mi"«- °< Low Level Waste P,o,ect
        Author:      Ikenberry, T.A.
        Recipient:    Bingham, G.E.; Cukurs, M.; Beesley  L M
        Date:        07/19/84                       '

        Document #:  6634
       Recipient:     Kennedy, K.K.
       Date:         01/16/76

 A     Document #:  6660
       Title:         Maps for CPP-14
       Author:      WINCO
       Recipient:    Not specified
       Date:        05/01/90

x-     Document #: 903-1188
       Title:        ICPP Geophysical Survey
       Author:      Retzlaff, R.
       Recipient:    Williams, J.L.
       Date:        08/17/92

'     Document #:  965
      Title:
      Author:
      Recipient:    Gearheard, M.
      Date:        11/06/90
                                      B-7

-------
                  OPERABLE UNIT 3-1 3
                                                        09/22/99
FILE NUMBER
AR1.1
             BACKGROUND (continued)
      Document #: ACI-110
      Title:         Buried Waste Line Register for National Reactor Testing Station (NRTS)
                   Part IV CPP
      Author:      Paige, B.E.
      Recipient:    Not specified
      Date:         06/01/72

      Document #: 6648
      Title:         Project Initiation Request -Demolition of Abandoned Sewage Plant -CPP-
                   703 & CPP-715
      Author:      Soderberg, J.D.
      Recipient:    Not specified
      Date:         02/04/83

      Document #: 6650
      Title:         Characteristics of the ICPP Sanitary Waste Collection Systems
      Author:      WINCO
      Recipient:    Not specified
      Date:         09/01/80

      Document #:  6722
Title:

Author:
Recipient:
Date:

Document #:
Title:
Author:
Recipient:
Date:

Document #:
Title:
Author:
Recipient:
Date:
                  Transmittal of the Closure Plan for LDU CPP-34 (Soil Storage Area in the
                  NE Corner of the ICPP)
                  Solecki, J.E.
                  Gearheard, M.
                  06/19/90

                  7756
                  Hazardous Waste Streams at CPP
                  Wallace, M.T.
                  Winder, T.
                  01/15/86
                   8472
                   Revised Closure Plan Approach for Land Disposal Units (LDU'
                   Solecki, J.E.
                   Gearheard, M.F.
                   01/15/86
                                                                           s)
                                       B-8

-------
                     OPERABLE UNIT 3-13                  09/22/99


   FILE NUMBER

   AR1.1      . BACKGROUND (continued)

   '      Document #: 6632

         A   u              e'''K rarm Contaminated Soil Investigation
         **uznor:      Miof Qr^o/^ifiofi
                     >mjt oLfcoiiieci
         Recipient:    Not specified
         Date:        01/04/91

  '•     Document #:  6638
        Title*         R


        Rec'Sm:     SHS^^"^^"o-anta, Services
        Date:         10/01/89

  '•     Document  ft: NEJ-28-91

       Authnr-      ?na' ReP°rt °n R°botic Ge°PhYS'cai Survey
       Author:      Josten, N.E.
       Recipient:    Urbanski, C.J.
       Date:        12/02/91

       Document #: KLF-150-97
       Title:        Listinn C.nHac  Ar^i;—^ui^ *„(->•
                                          ro uisposition of Investigation Derived Waste
       Author:      Falconer, K.L^
       Recipient:    Hovinga, J.E.
       Date:        07/08/97

'•     Document #: KLF-1 59-95
      Title
      Author:             '^^on-Derived Waste Aquifer We., Purge Water
      Recipient:    Green, L.A.
      Date:         05/15/95

      Document #:  NEB-3-86
      Title:         Sources of Information for CERCLA Study
      Author:       Nebeker, R.L.
      Recipient:     Pointer, T.F.
      Date:         02/02/86
                                      B-9

-------
                  OPERABLE UNIT 3-13
                                           09/22/99
RLE NUMBER
AR1.1
BACKGROUND (continued)
      Document*: MK-83-E-1 792
      Title:        Disposition of Stockpiled Low Level Contaminated Soil Excavated During
                   the Low Level Waste Project  Phase I at ICPP -M-K Project S-2258,
                   ICWA 83-49
      Author:      Hicks, F.E.
      Recipient:    Bingham, G.E.
      Date:        11 /28/S3

      Document #: KXJ-9-92
      Title:        State of Idaho, Request for Information
      Author:      Jones, K.L.
      Recipient:    Distribution
      Date:        01/14/92
      Document #:
      Title:
      Author:
      Recipient:
      Date:
      JFE-13-84   '
      Location of Contaminated Dirt Burial
      Erben, J.F.
      Distribution
      04/16/84
      Document*:  DLS-31-85
      Title:         Summary of RALA D&D Status
      Author:       Smith, D.L.
      Recipient:     Meservey, R.H.
      Date:         08/09/85

      Document*:  DWR-01-93
      Title:         Evaluation of  Records for  Waste  Generated  at  the  Idaho  Chemical
                   Processing Plant  (ICPP) and  Disposed  at  the Radioactive Waste
                   Management Complex (RWMC) During the Period  of 1960-1983
      Author:       Rhodes, D.W.
      Recipient:     Nitschke, R.L.
      Date:         01/08/93

      Document #:  CJU-05-92
      Title:         Subsurface  Imaging Results  for the  High  Level Waste  Tank  Farm
                   Replacement (HLWTFR)  Project
      Author:       Urbanski, C.J.
      Recipient:     Distribution
      Date:         02; 19/92
                                       B-10

-------
                  OPERABLE UNIT 3-13
                                            09/22/99
FILE NUMBER
AR1.1
BACKGROUND (continued)
      Document #: BING-106-83
      Title:         Disposition of Stockpiled Soil
      Author:      Bingham, G.E.
      Recipient:    Hicks, F.E.
      Date:         12/08/83

      Document #: AMU-161 -90
      Title:         CPP-59 Closure Plan Submittal
      Author:      Umek, A.M.
      Recipient:    Lyle, J.L.
      Date:         11/08/90

      Document #: DDN-01-85
      Title:         Identification of Radioactive Mixed Waste Streams at the Idaho Chemical
                   Processing Plant
      Author:       Nishimoto, D.D.
      Recipient:    Falconer, K.L.
      Date:         04/11/85

      Document #:  SGS-464-91
      Title:         Tank Closure Notification
      Author:       Evans, T.A.
      Recipient:     Sato, W.N.
      Date:         11/06/91

      Document*:  WINCO-1021
     Title:

     Author:
     Recipient:
     Date:
     Radiological Characterization and Decision Analysis for the SFE-20 Waste
     Tank and Vault
     Moser, C.L.; Schmidt, D.A.
     Not specified
     09/01/84
     Document*: WINCO-1032
     Title:         RALA  Off-Gas  Cell  and  Storage  Tank  (CPP-631
                  Decontamination and  Decommissioning Plan
     Author:      Moser, C.L.
     Recipient:    Not specified
     Date:         07/01/85
                                                       and  VES-702)
                                      B-1 1

-------
                  OPERABLE UNIT 3-1 3
                                                        09/22/99
FILE NUMBER


AR1.1       BACKGROUND (continued)

'••     Document #: WIN-86-0034-CPP
  Author:
  Recipient:
  Date:
                   Lee, J.L.
                   Green, M.J.
                   10/24/86
 Document #: WIN-86-0032-CPP

 luihor:      LeTj.
 Recipient:    Moffitt, W.C.
 Date:        10/24/86
     Document #: WINCO-1123, Revision 1
 Author:
 Recipient:
 Date:
                  Wenzel, D.R.
                  Not specified
                  02/01/94
     Document #: DJK-09-96-A
                                                                         '"
                                                                                o«
                                                    Contamina«* Liquid Spil,
                                         iS ComPuter
                                                                 (RSAC-5) User' s
Author:
Recipient:
Date:
                             Radi0l°9iCally C°ntaminated Surplus Facilities from EM-60
                 Kenoyer, D.J.
                 Moriarty, T.P.
                 11/13/96
    Document #: DOE/ID-1 0392, Rev. 0
    Title:         Well Fitness Evaluation for the Idaho National Engineering Laboratory,

    Author:       Sehlke, G.; Davis. D.E.; Tullock. W.W.- Williams  J A
    Recipient:     Not specified                        vv.mams, J.A.
    Date:         06/01/93

    Document  #:  DOE/ID- 10392, Rev. 0
    Title:         well Fitness Evaluation for the .daho National Engineering Laboratory,

    Author:       Sehlke, G.; Davis, D.E.; Tullock, W.W.; Williams  J A
    Recipient:     Not specified                               '
    Date:        06/01/93
                                    B-12

-------
                   OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR1.1        BACKGROUND (continued)

 >.     Document*: DOE/ID-10392, Rev. 0
       Title:         Well Fitness Evaluation for the Idaho National Engineering Laboratory
                    Vol. Ill
       Author:      Sehlke, G.; Davis, D.E.; Tullock,  W.W.; Williams, J.A.
       Recipient:    Not specified
       Date:         06/01/93

 >•     Document*: ERD-210-91
       Title:         Closure Plan for CPP-33, Contaminated Soil in Tank Farm Area Near WL-
                    102, NEof CPP-604
       Author:       Burns, T.F.
       Recipient:    Not specified
       Date:         06/04/91

 >-     Document #:  DOE/ID-10402, Rev. 3
       Title:         Comprehensive  Well Survey for  the  Idaho  National  Engineering
                    Laboratory, Vol. II
       Author:       Not specified
       Recipient:     Not specified
       Date:         05/01/94

'•     Document*:  893-1195.950
      Title:         Report on Surface Geophysical Surveys at the Idaho Chemical Processing
                    Plant
      Author:       Golder Associates, Inc.
      Recipient:     Not specified
      Date:        09/04/91

>-    Document #: ERD-229-91
      Title:        Closure Plan for CPP-48, Excess Chemical Dump Tank (French Drain
                   South of CPP-633)
      Author:      Burns, T.F.
      Recipient:    Gearheard, M.
      Date:        06/13/91

>     Document #: ERD-075-91
      T'tle:        Notification of Modification of Part A Permit for the INEL
      Author:      Burns, T.F.
      Recipient:    Donavan, R.P.
      Date:        03/14/91
                                       B-13

-------
                  OPERABLE UNIT 3-13                  09/22/99
 FILE NUMBER

 AR1.1       BACKGROUND (continued)

 >      Document//: ERD-105-91
       Title:        Characterization Data anrl Other Information Regarding COCA Units CPP-
                   39,-51,-54,-59, and-64
       Author:      Burns, T.F.
       Recipient:    Ledger, J.D.
       Date:        03/28/91

 >      Document #: ERD-102-91
       Title:        Document Review -Closure Plan for Land Disposal Unit CPP-40 at the
                   Idaho Chemical Processing Plant, Idaho National Engineering Laboratory
       Author:      Ford, J.S.
       Recipient:    Mann, S.A.
       Date:        07/16/91

AR1.3             PRELIMINARY ASSESSMENT (PA) REPORT

 A      Document #: 6637
       Title:        Site Assessment Documentation Packages for CPP-13, CPP-15, CPP-27,
                   CPP-29, CPP-35, CPP-36, CPP-58 E, and CPP-58 W
       Author:      Gulp, B.
       Recipient:    Not specified
       Date:        03/31/92

AR1.4             SITE INVESTIGATION (SI) REPORT

*<      Document #: 6630
       Title:        COCA Unit Discovery at the ICPP
       Author:      Nygard, D.
       Recipient:    Weiler,  H.
       Date:        11/06/89

AR1.7             INITIAL ASSESSMENTS

>•      Document #: 5403
       Title:        CPP-39, CPP HF Storage Tank (YDB-105) and Dry Well, OU 3-13
       Author:      N/A
       Recipient:    N/A
       Date:        07/08/87
                                      B-14

-------
                   OPERABLE UNIT 3-1 3                   09/22/99


  FILE NUMBER

  AR1-7             INITIAL ASSESSMENTS (continued)

  *•    Document #: 5412
       Title:        CPP-48,  French Drain South of CPP-633  OU3-13
       Author:
       Recipient:    N/A
       Date:        10/15/86

 x-     Document #:  6645
       Title:         CPP-1 3, Pressurization of the Solid Storage Cyclone NE of CPP-633
       Author:       N/A
       Recipient:     N/A
       Date:         07/07/87

 *•     Document #: 6674
       Title:        CPP-8, CPP-603 Basin Filter System Line Failure
       Author:      N/A
       Recipient:    N/A
       Date:        10/07/86

x-     Document #: 6675
       Title:        CPP-9, Soil Contamination Near the NE Corner of CPP-603 South Basin
       Author:      N/A
       Recipient:    N/A
       Date:        10/07/86

'•     Document #:  6676
      Title:         CPP-10, CPP-603 Plastic Pipeline Break
      Author:       N/A
      Recipient:     N/A
      Date:         10/07/86

      Document #: 6677
      Title:        CPP-1 1 , CPP-603 Sludge and Water Release
      Author:      N/A
      Recipient:    N/A
      Date:        10/07/86

      Document #:  6678
      Title:        CPP-1 2, Contaminated Paint  Chips and Pad South of CPP-603
      Author:      Poland, D.J.
      Recipient:    N/A
      Date:        10/07/86
                                     B-15

-------
                   OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR1.7              INITIAL ASSESSMENTS (continued)

 -*     Document #:  6679
       Title:         CPP-13, Pressurization of  the Solid Storage Cyclone NE of CPP-633
       Author:       Poland, D.J.
       Recipient:    N/A
       Date:         07/08/87

 >•     Document #:  6680
       Title:         CPP-1 5, Solvent Burner East of CPP-605
       Author:       Poland, D.J.
       Recipient:    N/A
       Date:         10/07/86

 *      Document #:  6681
       Title:         CPP-16, Contaminated Soil from Leak in Line from WM-181 to PEW
       Author:       Poland, D.J.
       Recipient:    N/A
       Date:         10/07/86

 >-    Document #:  6682
      Title:        CPP-17, Soil Storage Area Near Peach Bottom Fuel Storage Area
      Author:      Poland, D.J.
      Recipient:    N/A
      Date:         10/07/86

 '•    Document it: 6683
      Title:        CPP-18, Gas Storage Building
      Author:      Poland, D.J.
      Recipient:    N/A
      Date:        10/07/86

'     Document #: 6684
      Title:        CPP-19, CPP-603 to CPP-604 Line Leak
      Author:      Poland, D.J.
      Recipient:    N/A
      Date:        10/07/86

>     Document ff: 6685
      Title:        CPP-20, CPP-604 Radioactive Waste Unloading Area
      Author:      Poland, D.J.
      Recipient:    N;A
      Date:        07/08.87
                                      B-16

-------
                   OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR1 -7             INITIAL ASSESSMENTS (continued)

 >•     Document #:  6673
       Title:         CPP-7, Soil Contamination Northwest of CPP-642 {East of CPP-6CHI
       Author:       Poland, D.J.
       Recipient:     N/A
       Date:         10/07/86

 AR1.9       NEW SITE IDENTIFICATION/INCLUSION

 '•     Document #:  16760
       Title:        New Site Identification - Tank Farm Soil Stockpiles - CPP-97
       Author:      DOE; EPA; IDHW
       Recipient:    Not specified
       Date:        10/16/98

 *      Document #:  16807
       Title:        New Site Identification - Tank Farm Shoring Boxes - CPP-98
      Author:      DOE; EPA; IDHW
      Recipient:    Not specified
      Date:        11/03/98

'     Document #:  16808
      Title:        New Site Identification - Boxed Soil - CPP-99
      Author:      DOE; EPA; IDHW
      Recipient:    Not specified
      Date:        12/15/98

 -     Document*: 12899
      Title:        New Site Identification -Buried Cylinders East -CPP-94
      Author:      DOE
      Recipient:    Not specified
      Date:        02/20/97

      Document #: 14345
      Title:        New Site Identification -Simulated Calcine Trench NU-1 95 -CPP-91
      Author:      DOE
      Recipient:    Not specified
      Date:        01/25/95
                                     B-17

-------
OPERABLE UNIT 3-13

FILE NUMBER
                          09/22/99
AR1.9
NEW SITE IDENTIFICATION/INCLUSION (continued)
       Document ft:
       Title:

       Author:
       Recipient:
       Date:
AR2.3
      DOE.-'ID-10705
      Evaluation and Site Selection For A New Service Waste Disposal Facility
      For The Idaho Nuclear Technology and Engineering Center
      Not specified
      Not specified
      09/01/99

      EE/CA APPROVAL MEMORANDUM
       Document
       Title:

       Author:
       Recipient:
       Date:
AR2.4
      10315
      Approval  Memorandum for the  Idaho Chemical
      Radionuclide-Contaminated Soils Removal Action
      N/A
      DOE, EPA, 1DHW
      02/01/97

      EE/CA
Processing  Plant
      Document it: DOE/ID-10568, Rev. 0
      Title:        Engineering Evaluation/Cost Analysis for Radionuclide-Contaminated Soils
                   Removal Action at the Idaho Chemical Processing Plant
      Author:      Francis, C.S.; Hall, M.; Heidkamp,  H.A.; Heilman,  D.; Henderson,  L.;
                   Nicklaus, D.M.; Sorman, K.L.; Wells, R.P.
      Recipient:    Not specified
      Date:        02/01/97

      Document ft: OPE-ER-29-97
      Title:        Transmittal of the Engineering Evaluation/Cost Analysis for Radionuclide-
                   Contaminated Soils Removal Action at the Idaho Chemical Processing
                   Plant
      Author:      Jensen, N.R,
      Recipient:    Pierre, W.; Nygard, D.
      Date:        02/28/97

      Document #: DOE/ID-10568, Rev. 1
      Title:        Engineering Evaluation;Cost Analysis for Radionuclide-Contaminated Sons
                   Removal Action at the Idaho Chemical Processing Plant
      Author:      Francis. C.S.; Hall. M.; Heidkamp,  H.A.; Heilman,  D.; Henderson,  L.;
                   Nicklaus, D.M.; Sorman, K.L.; Wells, R.P.
      Recipient:    Not specified
      Date:        06/01/97
                                       B-18

-------
FILE NUMBER
AR2.4
                  OPERABLE UNIT 3-13
                    EE/CA (continued)
                                                       09/22/99
      Document #:  OPE-ER-102-97
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
     Author:

     Recipient:
     Date:
                    Transmittal of the Engineering Evaluation/Cost Analysis for Radionucl.de-
                    Contammated Soils Removal Action at the Idaho Chemical Processing

                    Jensen, N.R.
                    Pierre, W.; Nygard. D.
                    06/24/97

                    10543*
                    Idaho Chemical Processing Plant Windblown Area, Section 9 of the
                    Engineering   Evaluation/Cost  Analysis  for  Operable  Unit' 10-06
                    Radipnuclide-Contaminated Soils Removal Action at the Idaho Nat.onal
                    bngmeering Laboratory, Volume I, INEL-95/0259 Rev  0
                    Jessmore,  P.J • Rood, S.M.; Haney, T.J.; Paarmann, M.L; VanHorn  R L •
                    Harris, G.A.; Stepan, I.E.; Burns, S.M.
                    Not specified
                   06/01/95
•The entire document may be found in Administrative Record OU 10-06. Volume I

AR2-5              ACTION MEMORANDUM

>-     Document #:  DOE/ID-10588
      Title:         Action  Memorandum  for  the  Idaho Chemical  Processing  Plant
                   Radionuchde-Contaminated Soils Removal Action
      Author:       Not specified
                   Not specified
                   05/01/97
    Recipient:
    Date:
      Document #: 5280

      luthor:
      Recipient:    Williams, A.C.
     .Date:        05/28/93
                                                                 Processin9
    Document #: 5281

    luthor:      Actton^Memorandum -Removal Action -Idaho Chemical Processing Plant

    Recipient:    Williams, A.C.
    Date:        05/28/93
                                   B-.19

-------
                                                                                              1
 FILE NUMBER

 AR2.5
                  OPERABLE UNIT 3-13
ACTION MEMORANDUM (continued)
                                     09/22/99
 A     Document ff: OKE-64-93
       Title:        Action Memorandum For Time-Critical Removal Actions Planned for FY-
                   93  at the Idaho  Chemical Processing Plant for  Inclusion  Into the
                   Administrative Record File
       Author:      Earle, O.K.
       Recipient:    Williams, A.C.
       Date:        05/28/93

AR2.7             HEALTH AND SAFETY PLAN

A     Document #: INEL/EXT-97-00132, Rev. 1
       Title:        Health and  Safety  Plan  for  ICPP Radionuclide-Contaminated  Soils
                   Removal Action
       Author:      Arrowood, J.; Gurney, L.; Steed, K.; Haight, R.
       Recipient:    Not specified
       Date:        05/01/97

AR2.8             WORK PLAN

A     Document  #: DOE/EXT-97-00116, Rev. 0
       Title:        Removal  Action  Plan  for the  Idaho Chemical  Processing  Plant
                   Radionuclide-Contaminated Soils Removal Action
       Author:      Cram, A.
       Recipient:    Not specified
       Date:        06/01/97

AR3.1             SAMPLING AND ANALYSIS PLAN

*      Document  #: 18021
       Title:        Sampling and Analysis Plan for the ICPP Percolation Ponds 1 and 2
       Author:      Wastren Remediation, Inc.
       Recipient:    Not specified
       Date:        03/24/93

A     Document  #: 14084
       Title:        Sampling   and Analysis Plan  for  Boxed  Soils from  Solid  Waste
                   Management  Unit CPP-58 and Basement Exit  Excavations  at CPP-
                   604/605 at the Idaho Chemical Processing Plant
       Author:      Colder Associates  Inc.
       Recipient:    Not specified
       Date:        07/01/93
                                       B-20

-------
                  OPERABLE UNIT 3-13
                                      09/22/99
FILE NUMBER
AR3.1
      Document #:
      Title:
      Author:
      Recipient:    Burns, S.M.
 SAMPLING AND ANALYSIS PLAN (continued)

 93MSE/ID-225
 Transmittal of WAG 3/WAG 10 Sampling and Analysis Plan
 Barry, G.A.
      Date:
 08/02/93
      Document #:  6744
      Title:         Sampling and  Analysis  Plan  for  WAG
                   Contaminated Soils Treatability Study
      Author:       Barry,  G.A.; Doornbos, M.H.
      Recipient:     Not specified
      Date:         08/01/93

      Document #:  AM/ERWM-RPO-1 73-92
                                        3/WAG  10  Radionuclide-
      Title:
      Author:
      Recipient:
      Date:
Transmittal of the Closure Addendum for the Draft Sampling and Analysis
Plans (SAP) for Operable Units (OU) 3-07  and  -08 (Tank Farm I & II,
respectively), and WAG 3 Quality Assurance Project Plan (QAPjP)
Lyle, J.L.
Pierre, W.; Nygard, D.
07/31/92
      Document*: AM/ERWM-RPO-154-92
     Title:
     Author:
     Recipient:
     Date:
Transmittal of the Modifications to Operable Unit (OU) 3-07, the Tank
Farm Sampling and Analysis Plan (SAP) at the Idaho Chemical Process
Plant (ICPP) Waste Area Group 3 (WAG 3)
Lyle, J.L.
Pierre, W.; Nygard, D.
07/10/92
     Document #: 893-1195.320
     Title:        Report for  the  Idaho  Chemical  Processing  Plant (ICPP) Drilling and
                  Sampling Program at Land Disposal Unit CPP-59
     Author:      Golder Associates, Inc.
     Recipient:    Not specified
     Date:        01/01/91

     Document.ff: 893-1195.330
     Title:        Report for  the  Idaho  Chemical  Processing  Plant (ICPP) Drilling and
                  Sampling Program at Land Disposal Unit CPP-64
     Author: •     Golder Associates, Inc.
     Recipient:    Not specified
     Date:        01/01/91
                                      B-21

-------
                  OPERABLE UNIT 3-13
                                      09/22/99
FILE NUMBER

AR3.1
 SAMPLING AND ANALYSIS PLAN (continued)
      Document #: 893-1195.360
      Title:        Report for  the  Idaho  Chemical e-ocessing  Plant (ICPP) Drilling and
                   Sampling Program at Land Disposal Unit CPP-54
      Author:      Golder Associates, Inc.
      Recipient:    Not specified
      Date:        01/01/91

      Document #: INEL-95/0064
      Title:

      Author:
      Recipient:
      Date:
Report of 1993-'94 Tank Farm Drilling and Sampling Investigation at the
Idaho Chemical Processing Plant
Not specified
Not specified
02/01/95
      Document #:  893-1195.530
      Title:

      Author:
      Recipient:
      Date:
Report of the Idaho Chemical Processing Plant Drilling and  Sampling
Program at the HLLW Tank, Farm and LDU CPP-33
Golder Associates, Inc.
Not specified
12/19/91
      Document*: 903-1171
      Title:

      Author:
      Recipient:
      Date:
Report for the Idaho Chemical Processing Plant Sampling and Analysis
Program at Service Waste Percolation Pond No. 2
Golder Associates, Inc.
Not specified
04/1 5/92
      Document #: ERD1-098-92
      Title:        Transmittal of the Sampling and Analysis Plan (SAP) for Operable Unit
                  (OU) 3-08 at the Idaho Chemical Processing Plant (ICPP) Waste Area
                  Group  3 (WAG 3)
      Author:      Lyle, J.L.
      Recipient:   Pierre,  W.; Nygard. D.
      Date:        04/07/92

      Document #: INEEL/EXT-97-00677, Rev. 0
      Title:        Limited Scope and Hazard Characterization Plan  for Soil Disturbance
                  CERCLA Radiological  Characterization at ICPP -CPP-701  Petroleum
                  Contaminated  Soil
      Author:      Jones, R.K.; Willis, B.J.
      Recipient:   Not specified
      Date:        06.'01/9 7
                                      B-22

-------
                  OPERABLE UNIT 3-13
                                     09/22/99
FILE NUMBER
AR3.1
      Document #:
      Title:

      Author:
      Recipient:
      Date:
AR3.2
      Document #:
      Title:
      Author:
      Recipient:
      Date:
SAMPLING AND ANALYSIS PLAN (continued)

INEL-95/0137, Rev. 0
Sampling and  Analysis Plan for  the Waste Area Group 3 Remedial
Investigation/Feasibility Study Work Plan (FINAL)
Meyer, T.J.
Not specified
08/01/95

SAMPLING AND ANALYSIS DATA/CHAIN OF CUSTODY FORMS (COC)

RM-06-93-A
Validation of Organochlorine Herbicide  Data from the  Fourth Quarter
1992 Groundwater Sampling Effort at the Westinghouse Idaho Chemical
Processing Plant: Sample Delivery Groups
Marty, R.C.
Williams, J.L.
02/24/93
      Document #:  RPW-44-94
      Title:         Transmittal of Limitations and Validation Report (L&V) Idaho Chemical
                   Processing Plant (ICPP), Operable Unit 3-07,  Radiochemical Analysis,
                   Sample Delivery Group #3PG10301BG
      Author:       Wells, R.P.
      Recipient:     Holder, K.D.
      Date:         04/12/94

      Document #:  6629
      Title:         Final Report for 2nd PECR
      Author:       Hunter, B.R.
      Recipient:     Stalke, A.K.
      Date:       -07/27/87

      Document #:  OPE-ER-052-95
      Title:         Transmittal of the Validated Data for Perched Water Sampling December
                   1994 and January 1995
      Author:       Green, L.A.
      Recipient:     Pierre, W.; Nygard, D.
      Date:         03/23/95
                                      B-23

-------
                    OPERABLE UNIT 3-13                  09/22/99


  FILE NUMBER


  AR3'2       (continueTPLING ^ ANALYS'S DATA/CHAIN OF CUSTODY FORMS (COC)

  >-     Document ff: INEL/EXT-97-00341, Rev. 0

                    rFRre|dAS0Ct!?e,an-d  ^Zard Characterization Plan for Soil Disturbance
                    v-cnuuM Kadiological Characterization at ICPP
       Author:      Jones, R.K.
       Recipient:    Not specified
       Date:        03/01/97

 '     Document ff:  DLF-01-89
       Title:         Review of Documents (QA/QC Samples)
       Author:       Forsberg, D.L.
       Recipient:     Minkin, S.C.
       Date:        09/27/89

>•     Document #: OPE-ER-254-97
       Title:        Transmittal of the Validated Analytical Sampling Data for Idaho Chemical
                   ProceSs,ng  Plant (ICPP)  Radionuc.ide-Contaminated  Soi.8  Non-Tme

      Author:      S.^      °" " ^ ^° ^^ ^^^ "^
      Recipient:    Pierre, W.; Nygard D
      Date:        11/25/97

f      Document #:  ERD-011-91

                   ^PD^c!31™5^!"^3,^ Ana|Vtical Data for  Investigations at the'ICPP
                   lurH-51, CPP-54, CPP-59, and CPP-64)
      Author:      Solecki, J.E.
      Recipient:    Humphrey, D.L.
      Date:        01/11/91

      Document #:  ERD-036-91
      Title:
     Author:      Solecki, J.E.
     Recipient:    Humphrey, D.L.
     Date:        02/27/91
                                     B-24

-------
                                                                                              1
                  OPERABLE UNIT 3-13
                                       09/22/99
FILE NUMBER
AR3.3             WORK PLAN

>     Document #: INEL-95/0056, Rev. 0
      Title:

      Author:
      Recipient:
      Date:
  Waste Area Group 3 Comprehensive Remedial Investigation/Feasibility
  Study Work Plan (FINAL), Vol. I, through 8. References
  N/A
  N/A
  08/01/95
      Document ft:  INEL-95/0056, Rev. 0
      Title:

      Author:
      Recipient:
      Date:
 Waste Area Group 3 Comprehensive Remedial Investigation/Feasibility
 Study Work Plan (FINAL), Vol. I, Appendices
 N/A
 N/A
 08/01/95
      Document ft: INEL-95/0056, Rev. 0
      Title:

      Author:
      Recipient:
      Date:
 Waste Area Group 3 Comprehensive Remedial Investigation/Feasibility
 Study Work Plan (FINAL), Vol. II, through Attachment 5
 N/A     .
 N/A
 08/01/95
     Document ft: INEL-95/0056, Rev. 0
     Title:

     Author:
     Recipient:
     Date:
 Waste Area Group 3 Comprehensive Remedial Investigation/Feasibility
 Study Work Plan (FINAL), Vol. II, Attachment 6
 N/A
 N/A
 08/01/95
     Document ft:  6658
     Title:
     Author:
     Recipient:
     Date:
Technical Work Plan for the Idaho Chemical Processing Plant, Sampling
and Analysis Program at Solid Waste Management Unit CPP-14  Vol I
Rev. 1                                                    ...
Colder Associates, Inc.
N/A
01/11/91
     Document ft: 6659
     Title:
     Author:
     Recipient:
     Date:
Technical Work Plan for the Idaho Chemical Processing Plant, Quality
Assurance Project Plan for Drilling and Sampling Activities at Solid Waste
Management Unit CPP-14, Vol. II, Rev. 1
Golder Associates, Inc.
Not specified
01/11/91
                                     B-25

-------
 FILE NUMBER
 AR3.3
                    OPERABLE UN,T 3-,3                   03/22/ag
                    WORK PLAN (continued)
       Document #: 6636
       Title:
     Author:           	
     Recipient:    Pierre, W.; Nygard, D
     Date:        04/26/94

     Document*:  OPE-ER-127-95
     Title:
     Author:      Green, i.A.
     Recipient:    Pierre, W.; Nygard D
     Date:        07/05/95

     Document ff: 893-1195.450  Vol I
    Title:
   Author:      Golder Associates, Inc"
   Recipient:    Not specified
   Date:        07/25/90
       Author:       Golder Associates, Inc
       Recipient:     N/A
       °ate:         12/16/91

'•      Document tt: 893-1195.310
       I IZI6!        RsDOft fnr tho IrJ-^k^. /-*u _ •_ . n
                                                          Plant,

      Author:      Golder Associates, Inc
      Recipient:    Ledger, J.D.
      Date:        01/01/91

      Document #:  OPE-ER-099-94
      ' Itlei         Trancmittai nf »u_ Draft
                 __	               		   .                 . Plant
    Author:      Golder Associates, Inc
    Recipient:    Not specified
    Date:         07/25/90

    Document ff:  893-1195.450, Vol. II
    •'tie:         Dl ralitv/ Ao<-,.,~	r>__-    —.
                                            for
                                    B-26

-------
                    OPERABLE UNIT 3-13
                                                          09/22/99
  FILE NUMBER
  AR3.3
                     WORK PLAN (continued)
       Document ft: INEEL/EXT-98-01097, Rev. 0
       Title:        Treatahilin/ £tnr4«/ \A/***b p|an for
                                                    Segmented Gate System Technology
 AR3.4
       Author:      Wells, R.P.
       Recipient:    Not specified
       Date:        04/01/99

             Rl REPORTS
       Document #:
       Title:

       Author:
       Recipient:
       Date:
                   OPE-ER-122-96
                   Transmittal  of  the  Comprehensive RI/FS for the  Idaho  Chemical
                   Processmg Plant OU 3-13 at the INEL-Part A,  RI/BRA Report (Draft)
                   Jensen, N.R.
                   Pierre, W.; Nygard, D.
                   08/05/96
AR3.8       RISK ASSESSMENT

^     Document #:  OPE-ER-117-95
      Title:         Transmittal  of
                   Assessment
      Author:      Green, L.A.
      Recipient:     Pierre, W.; Nygard, D.
      Date:         06/19/95
                                                                              Risk
AR3.9
            QUALITY ASSURANCE PROJECT PLAN
      Document #:
      Title:
      Author:
      Recipient:
      Date:
                  QAPjP-E-035, Revision 0
                  Quality Assurance Project Plan for Characterization Activities at WAG 3

                  Not specified
                  07/21/92
      Document #: INEL-95/0086, Rev. 4 (formerly EGG-WM-10076)
      Title:

      Author:
      Recipient:
      Date:
                  Quality Assurance Project Plan for Waste Area Groups 1  23456
                  7, and 10                                          ••.,..
                  Baumer, A.R.; Flynn, S.C.; Watkins, C.S.
                  Not specified
                  03/01/95
                                      B-27

-------
                    OPERABLE UN.T3-W                 09/22/99

   FILE NUMRFR


  AR3.9      °"AUTY ASSURANCE PROJECT PLAN (cominued,
        Docun,en, * DWW-10687. Rev. 5 m,rmerly ,NEL-95,0086)
                                          Plan for w-               .. 3. 4. 5,
  >•
                                                              -.. C.S.
        Date:       12/01/97

 AR3.10     SCOPE OF WORK

 x-    Document #: 5791
       Recipient:    N/A
       Date:        10/14/94

       Document ff: OPE-ER-283-94
      Recipient:    Pierre, W.; Nygard D
      Date:        10/21/94
x-     Document #:  RPO-001-92
      Title:                                        for
     Ah
     Author:     [_yle, J.L.
     Recipient:    Pierre, W.; Nygard  D
     Date:        01/10/92
     Document #: OPE-ER-035-93
                                                                     h 3-OSA
     Author:      Lyle, J.L.
     Recipient:    Pierre. W.; Nygard D
     Da*e:        11/15/93

     Document ff:  6590

                         °raft                              . Tan,

                                                       i. D.
                                  B-28

-------

                   OPERABLE UNIT 3-1 3                   09/22/99


 FILE NUMBER

 AR3.10      SCOPE OF WORK (continued)

 '•     Document ff: 6591
       Title:        Review of Draft Scope of Work for Operable Unit-7, Tank Farm
       Author:      Mejia, C.
       Recipient:    Williamson, D.; Fourr, B.; Williams. J.; Gombert D
       Date:        10/18/91

 >•     Document ff: 6592
       Title:        Review of Draft Scope of Work for Operable Unit-7, Tank Farm
       Author:      Mejia, C.
       Recipient:    Williamson, D.; Fourr, B.; Williams. J.; Gombert D
       Date:        10/18/91

 >•     Document ff: OPE-ER-047-94
       Title:         Transmittal of the Draft Final Scope of Work for Operable Unit 3-08A
                    (ICPP North Area RI/FS)
       Author: .     Lyle, J.L.
       Recipient:     Pierre, W.; Nygard, D.
       Date:        02/18/94

AR3.11      FIELD SAMPLING

>-      Document ff: DOE/ID-10579, Rev. 0
       Title:        Field Sampling Plan for the Idaho Chemical Processing Plant Radionuciide-
                   Contaminated Soils Removal Action
       Author:      Wells, R.P.
       Recipient:    Not specified
       Date:        05/01/97

>•      Document #: OPE-ER-91-97
       Title:        Transmittal of the Field Sampling Plan for the Idaho Chemical Processing
                   Plant Radionuciide-Contaminated Soils Removal Action and the Removal
                   Action  Plan for the  ICPP Radionuciide-Contaminated Soils  Removal
                   Action
      Author:      Jensen, N.R.
      Recipient:    Pierre, W.; Nygard, D.
      Date:        06/12/97
                                       B-29

-------
                  OPERABLE UNIT 3-13
                                            09/22/99
FILE NUMBER
AR3.11
FIELD SAMPLING (continued)
       Document #: INEEL/EXT-97-00805
       Title:        Field Sampling Plan for t!'.e D&D ;' Cne CPP-631 RaLa Building, and CPP-
                   709 and CPP-734 Monitoring Stations at the Idaho Chemical Processing
                   Plant
       Author:      Jones, R.W.
       Recipient:    Not specified
       Date:        08/01/97
AR3.12
RI/FS REPORTS
       Document*: OPE-ER-106-97
       Title:        Transmittal of the Draft Comprehensive RI/FS for the Idaho Chemical
                   Processing Plant OU 3-13 at the INEEL
       Author:      Jines, A.T.
       Recipient:    Pierre, W.; Nygard, D.
       Date:        06/27/97

       Document #: OPE-ER-127-97
       Title:        Transmittal of the Draft Comprehensive RI/FS for the Idaho Chemical
                   Processing Plant OU 3-13 at the INEEL
       Author:      Hain, K.E.
       Recipient:    Pierre, W.; Nygard, D.
       Date:        08/14/97

       Document*: DOE/ID-10534
       Title:        Comprehensive RI/FS for the Idaho Chemical Processing Plant OU 3-13
                   at the INEEL-Part A, RI/BRA Report (Final), Binder 1
       Author:      Rodriguez, R.R.; Schafer, A.L.; McCarthy,  J.; Martian, P.; Burns, D.E.;
                   Raunig, D.E.; Burch, N.A.; VanHorn, R.L.
       Recipient:    Not specified
       Date:        11/01/97

       Document #: DOE/ID-10534
       Title:        Comprehensive RI/FS for the Idaho Chemical Processing Plant OU 3-13
                   at the INEEL-Part A, RI/BRA Report (Final), Binder 2
       Author:      Rodriguez, R.R.; Schafer. A.L.; McCarthy,  J.; Martian, P.; Burns, D.E.;
                   Raunig, D.E.; Burch, N.A.; VanHorn, R.L.
       Recipient:    Not specified
       Date:        11/01/97
                                       B-30

-------
                  OPERABLE UNIT 3-13
                                      09/22/99
FILE NUMBER
AR3.12      RI/FS REPORTS (continued)
      Document #:
      Title:

      Author:

      Recipient:
      Date:
 DOE/1D-10534
 Comprehensive RI/FS for the Idaho Chemical Processing Plant OU 3-13
 at the INEEL--Part A, RI/BRA Report (Final),  Binder 3
 Rodriguez, R.R.; Schafer, A.L.; McCarthy, J.; Martian, P.; Burns, D.E.;
 Raunig, D.E.; Burch, N.A.; VanHorn, R.L.
 Not specified
 11/01/97
      Document #:  DOE/ID-10572
      Title:

      Author:

      Recipient:
      Date:
 Comprehensive RI/FS for the Idaho Chemical Processing Plant OU 3-13
 at the INEEL-Part B, FS Report (Final), Binder 1
 Rodriguez, R.R.; Schafer, A.L.; McCarthy, J.; Martian, P.; Burns, D.E.;
 Raunig, D.E.; Burch, N.A.; VanHorn, R.L.
 Not specified
 11/01/97
      Document #: DOE/ID-10572
      Title:

      Author:

      Recipient:
      Date:
Comprehensive RI/FS for the Idaho Chemical Processing Plant OU 3-13
at the INEEL-Part B, FS Report (Final), Binder 2
Rodriguez, R.R.; Schafer, A.L.; McCarthy, J.; Martian, P.; Burns, D.E.;
Raunig, D.E.; Burch, N.A.; VanHorn, R.L.
Not specified
11/01/97
     Document #: DOE/ID-10619, Rev. 2
     Title:

     Author:
     Recipient:
     Date:
Comprehensive RI/FS for the Idaho Chemical Processing Plant OU 3-13
at the INEEL - Part B, FS Supplement Report, Vol. 1 and 2
Greenwell, R.D.;  Evans, C.S.
Not specified
10/01/98
     Document*: OPE-ER-160-98
     Title:
     Author:
     Recipient:
     Date:
Transmittal of the Final Comprehensive RI/FS  for the Idaho Chemical
Processing Plant OU 3-13 at the INEEL-Part B, FS Supplement Report
(Revision 2}
Hain, K.E.
Pierre, W.; Nygard, D.
10/14/98
                                      B-31

-------
                    OPERABLE UNIT 3-13
 EikUVUMBER

 AR3.12  .   RI/FS REPORTS (continued,

 '     Document #:  OPE-EP&SA-98-002
       Title:
                                                         09/22/99
       Author:
       Recipient:
       Date:
                Idaho National
                Proposed Plan ;„,
                Depperschmidt, J.
                Distribution
                01/05/98
                                                 '          Operable u"« 3-13 at the
                                                                          a"« D«"
'•     Document tt:  OPE-ER-95-222
      Title:
     Author:
     Recipient:
     Date:
               Pierre, W.; Nygard  D
               12/05/95
     Document #:  DEB-20-97
     Title:
    Author:
    Recipient:
    Date:
              Microshield Modeling Results
              Burns, D.E.
              Henry, R.L.
              10/13/97
    Document #:  OPE-ER-253-97
    Title:
    Author:
    Recipient:
    Date:
             Jenkins, T.W.
             Pierre, W.; Nygard D
             11/25/97
 Document*: OPE-ER-1 74.97
 Title:        Transmittal of the

Author:
Recipient:    Pierre, W.; Nygard D
°ate:        10/30/97
                                        p,r, = i

                                                                    Study (RI/FSI
                                                     RI//FS for
                                                            RI;/FS  for the
                                   B-32

-------
                   OPERABLE UNIT 3-13                  09/22/99


 RLE NUMBER

 AR3.14      TRACK 2 SUMMARY REPORT

 >      Document #: OPE-ER-308-94
        Title:        Transmittal of the Revised Track 2 Summary Report for Operable Unit 3-
                    09
        Author:      Jenkins, T.W.
        Recipient:    Pierre, W.; Nygard, D.
        Date:        11/22/94

 AR3.15      HEALTH AND SAFETY PLAN

 >•      Document #: 6621
        Title:         Site Specific Health and  Safety Plan -FY-1992  Drilling and  Sampling
                    Program -Track 2 Investigation of OU 3-07 Tank Farm and  OU 3-08
                    Tank Farm II
       Author:      Mascarenas, C.S.
       Recipient:     Not specified
       Date:         08/10/92

 >-     Document*:  6651
       Title:        Site Specific Health and Safety Plan  -Solid Waste Management Unit
                   (SWMU)CPP-14
       Author:      Alcalde, A.
       Recipient:    Not specified
       Date:         10/16/90

 >•      Document #: 6652
       Title:        Site Specific Health and Safety Plan -Solid Waste Management Unit
                   (SWMU) CPP-36 INEL
       Author:      Alcalde, A.
       Recipient:    Not specified
       Date:        10/16/90

 *•      Document #: 6656
       Title:        Site Specific Health and Safety Plan -Land Disposal Unit (LDU) CPP-63
       Author:      Alcalde, A.
       Recipient:    Not specified
       Date:        10/16/90

*•      Document #:  6655
       Title:        Site Specific Health and Safety Plan -ICPP Land Disposal Unit (LDU) CPP-
                   48
       Author:      Alcalde, A.
    •   Recipient:    Not specified
       Date:        10'16.90
                                      B-33

-------
                  OPERABLE UNIT 3-13
                                                  09/22/99
FILE NUMBER

AR3.15      HEALTH AND SAFETY PLAN (continued)


>     Document #: 6653
      Title:        Site Specific Health and Safety Plan -ICPP Land Disposal Unit (LDU) CPP-
                   37
      Author:      Alcalde, A.
      Recipient:    Not specified
      Date:        10/16/90

>     Document #: 6654
      Title:        Site Specific Health and Safety Plan -Land Disposal Unit (LDU) CPP-40;
                   LDU  CPP-47
      Author:      Alcalde, A.
      Recipient:    Not specified
      Date:        10/16/90
                                                          3/WAG  10  Radionuclide-
Document #: EGG-ER-10922, Rev. 0
Title:         Health  and  Safety Plan for  the  WAG
             Contaminated Soils Treatability Study
Author:      Barry, G.A.; Nuthak, S.A.; Pickett, S.L.
Recipient:    Not specified
Date:         08/01/93

Document #: INEL-95/0136, Rev. 0
Title:         Health and Safety  Plan for the Waste Area Group  3  Comprehensive
             Remedial Investigation/Feasibility Study (Final)
Author:      Meyer, T.J.
Recipient:    Not specified
Date:         08/01/95

Document #: INEL-95/0136, Rev. 2
Title:         Health and Safety  Plan for the Waste Area Group  3  Comprehensive
             Remedial Investigation. Feasibility Study
Author:      Meyer, T.J.
Recipient:    Not specified
Date:         07/01/95

Document ff: INEL-95/0292, Rev. 0
Title:         Health and Safety Plan for D&D of CPP-631, -709, -734
Author:      LaBuy, S.A.; Peterson, D.A.
Recipient:    Not specified
Date:         06/01.95
                                       B-34

-------
                                                            .   :  -   -   •'          •        -   1


                   OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR3.15     HEALTH AND SAFETY PLAN (continued)

 >-     Document #:  INEL-95/0292, Rev. 1
       Title:         Health and Safety Plan for D&D of CPP-631, -709, -734
       Author:       LaBuy, S.A.; Peterson, D.A.
       Recipient:     Not specified
       Date:         06/01/97

 AR3.17      REMEDIAL INVESTIGATION AND BASELINE RISK ASSESSMENT REPORT

 >      Document  #:  KLF-210-95
       Title:         Modification to the WAG 3 Baseline Risk Assessment Approach
       Author:       Rodriguez, R.R.
       Recipient:     Green, L.A.
       Date:         06/21/95

 AR3.20      TREATABILITY STUDY

 >•     Document  #:  PTL-02-94
       Title:        Comments on the Draft Technical Work Plan for the WAG 3 and WAG
                    10 Radionuclide Contaminated Soils Treatability Study
       Author:      Laney, P.T.
       Recipient:    Honeycutt, T.K.
       Date:        03/22/94

 >      Document #: GMH-01-93
       Title:        Comments concerning the treatability study of INEL soils, including ICPP
                   soils
       Author:      Huestis, G.M.
       Recipient:    Daum,  K.A.
       Date:        08/04/93

AR3.21      SCHEDULE

 >-      Document #: OPE-ER-1 31-96
       Title:        Transmittal of the Revised WAG 3 Operable Unit 3-13 Comprehensive
                   RI/FS Schedule
       Author:      Jensen, N.R.
       Recipient:    Pierre, W.; Nygard, D.
       Date:        08/27/96
                                      B-35

-------
                   OPERABLE UNIT 3-13
                                            09/22/99
 FILE NUMBER
 AR3.21
 SCHEDULE (continued)
       Document #:  OPE-ER-33-97
       Title:

       Author:
       Recipient:
       Date:

       Document  #:
       Title:
       Author:
       Recipient:
       Date:
       Transmittal of the Revised WAG 3 Operable Unit 3-13 Comprehensive
       RI/FS Schedule
       Jines, A.T.
       Pierre, W.; Nygard, D.
       03/05/97

       10110
       Revised Closure Plan Schedule
       Solecki, J.E.
       Monson, S.
       09/29/89
       Document tt: 8206
       Title:        Detailed Schedules for Preparation of Closure Plans
       Author:      Solecki, J.E.
       Recipient:    Gearheard, M.F.
       Date:        01/11/90

       Document #: KHK-147-89
       Title:        Detailed Schedules for Preparation of Closure Plans
       Author:      Blumberg, D.J.
       Recipient:    Sato, W.N.
       Date:        12/22/89
AR4.2
FS REPORTS
      Document #: OPE-ER-18-98
      Title:        Transmittal of the Draft OU 3-13 Feasibility Study Supplement to the
                   Final OU 3-13 Comprehensive RI/.-'FS for the Idaho Chemical Processing
                   Plant OU  3-13 at the INEEL
      Author:      Jenkins, T.W.
      Recipient:    Pierre, W.; Nygard, D.
      Date:        01/29/98

      Document*: OPE-ER-1 28-98
      Title:        Transmittal of the Revised Draft  Comprehensive RI//FS for the  Idaho
                   Chemical  Processing Plant OU 3-13 at the INEEL -Part B, FS Supplement
                   Report (Revision 1)
      Author:      Jenkins, T.W.
      Recipient:    Pierre, W.; Nygard, 0
      Date:        08/06/98
                                       B-36

-------
                   OPERABLE UNIT 3-13
                                                         09/22/99
 FJLENUMBER
 AR4.2       FS REPORTS (continued)
       Document #:
       Title:
       Author:
       Recipient:
       Date:

       Document  #:
       Title:

       Author:
       Recipient:
       Date:
               OPE-ER-40-98
               Transmittal of Documents for Review of WAG 3 Cost Estimates
               Jenkins, T.W.
               Pierre, W.; Nygard, D.
               03/12/98

               FL-92-0234
               Feasibility  of Performing Gamma Isotopic Profiles in the Idaho Chemical
               Processing Plant Waste Tank Farm Observations Wells
              Battaglia, P.J.
              Alexander, D.
              09/29/92
AR4.3
       PROPOSED PLAN
      Document #:
      Title:

      Author:
      Recipient:
      Date:

      Document  #:
      Title:
              10542
              Proposed Plan for Waste Area Group 3 at the Idaho Chemical Processing
              Plant Idaho National Engineering and Environmental Laboratory
              INEEL Community Relations
              Not specified
              10/01/98

              OPE-ER-1 59-98
              Transmittal of the Final Proposed Plan {Rev 6} for Waste Area Group 3-
              Idaho  Chemical  Processing  Plant, Idaho  National  Engineering  and
              Environmental Laboratory
Author:       Main,  K.E.
Recipient:    Pierre, W.; Nygard, D.
Date:         10/14/98

Document #:  15054
Title:        DOE-HQ Approval  and Comments on  the Draft Proposed  Plan for
             Remediation  of the Idaho National  Engineering  and Environmental
             Laboratory, Waste Area Group 3. Operable Unit 3-13, Idaho Chemical
Author-      ^50^31?™' C°mprehensive Remedia< Investigation/Feasibility Study
Recipient:     Hain, K.E.
Date:        11/14/97
                                     B-37

-------
                   OPERABLE UNIT 3-13
                                                         09/22/99
 FILE NUMRFR


 AR4.3       PROPOSED PLAN (continued)


 '      Document tt:  OPE-ER-68-98
       Title:
/.
                and Environmental Laboratory
   Author:      Jenkins, T.W.
   Recipient:    Pierre, W.; Nygard, D
   Date:        04/17/98


   Document #:  OPE-ER-78-98
   Title:
                  and Environmental Laboratory
      Author:      Jenkins, T.W.
      Recipient:    Pierre, W.; Nygard, D
      Date:        05/14/98


      Document*: OPE-ER-104-98
      Title:
              and Environmental Laboratory
 Author:      Jenkins, T.W.
 Recipient:    Pierre, W.; Nygard  D
 Date:        06/22/98


 Document tt:  OPE-ER-261-97
 Title:
                                                                Na"°na' E"9™ering
                                                               » «*

                                                             a"°m'
                                                                              A™.
                                                                 3I
                                                               Nat'°nal E"9ineering
             Laboratory
 Author:      Jenkins, T.W.
 Recipient:    Pierre, W.; Nygard  D
 Date:        12/04/97


 Document*: OPE-ER-133-98

 Title:        Transmittal of the Revised Draft Proposed I
             Group 3. Idaho Chemical Processing Plant
             and Environmental Laboratory
Author:      Jenkins, T.W.
Recipient:    Pierre, W.; Nygard D
Date:        08/17/98
                                                                               O
                                                      Engineering and Environmental
                                   B-38

-------
                   OPERABLE UNIT 3-13
                                            09/22/99
 FILE NUMBER

 AR4.3       PROPOSED PLAN (continued)

 >•     Document #: OPE-ER-148-98
       Title:
       Author:
       Recipient:
       Date:
       Transmittal of the Revised Draft Proposed Plan (Rev 5) for Waste Area
       Group 3, Idaho Chemical Processing  Plant, Idaho National Engineering
       and Environmental Laboratory
       Jenkins, T.W.
       Pierre, W.; Nygard, D.
       09/15/98
       Document #: OPE-ER-28-98
       Title:
      Author:
      Recipient:
      Date:
       Transmittal of the Revised Draft Proposed Plan for Waste Area Group 3,
       Idaho  Chemical Processing  Plant,  Idaho National Engineering  and
       Environmental Laboratory
       Jenkins, T.W.
       Pierre, W.; Nygard, D.
       02/13/98
AR5.1
RECORD OF DECISION
      Document #: OPE-ER-44-99
      Title:
      Author:
      Recipient:
      Date:
      Transmittal of the Draft Record of Decision -Idaho Nuclear Technology
      and Engineering Center, Idaho National Engineering and Environmental
      Laboratory
      Main, K.E.
      Pierre, W.; Nygard, D.
      03/29/99
      Document #: OPE-ER-1 19-99
      Title:         Transmittal of the Final Record of Decision -Idaho Nuclear Technology
                   and Engineering Center, Idaho National Engineering and Environmental
                   Laboratory
      Author:      Hain, K.E.
      Recipient:    Pierre, W.; Nygard, D.
      Date:         08/30/99

      Document #: OPE-ER-99-99
      Title:         Transmittal of the Draft Final  Record of  Decision - Idaho  Nuclear
                   Technology and  Engineering Center,  Idaho National Engineering and
                   Environmental Laboratory
      Author:      Hain, K.E.
      Recipient:    Pierre, W.; Nygard, D.
      Date:         07/20/99
                                       B-39

-------
                    OPERABLE UNIT 3-13                   09/22/99
  FILE NUMBFR


  AR5.1       RECORD OF DECISION (continued)

  y      Document #: OPE-ER-28-99
        Title:
 AR5.4
              	,                                      and Environmental
 Author:      Hain, K.E.
 Recipient:    Kluk, A.
 Date:        02/17/99

      RECORD OF DECISION REVIEW COMMENTS

Document #:  10679
Title:
       Author:      Not specified
       Recipient:    Jenkins, T.W
       Date:        03/01/99

'•      Document #:  10681
      Title:
      Author:
      Recipient:    Hain, K.E.
      Date:        05/14/99

      Document #: 10682
      Title:
     Author:
     Recipient:    Hain, K.E.
     Date:        08/04/99

     Document #:  10683

     Title:         EPA Review of Draft Final Record of Decision (ROD) for O U 3 n IH H
                  Chemical Processing Plant                 i™-^; ror u.u. 3-13, Idaho
     Author:       Pierre, W.
     Recipient:     Hain, K.E.                                                 -
     Date:        08/04/99
                                    B-40

-------
                  OPERABLE UNIT 3-13
                                           09/22/99
FILE NUMBER
AR10.1
COMMENTS AND RESPONSES
      Document #:  18079
      Title:         Concern over Department'  s Proposed Plan for Waste Area Group 3 at
                   the Idaho Chemical Processing Plant at INEEL and Request Personal
                   Attention  in Redirecting Critical Aspects of  Effort  -Request Public
                   Comment be Extended for Thirty Days
      Author:       Chenoweth, H.
      Recipient:     Richardson, B., DOE-HQ
      Date:         12/18/98

      Document  #:  18080
      Title:         Response to Congresswoman Helen Chenoweth
      Author:       Owendoff, J.M.
      Recipient:     Richardson, B., DOE-HQ
      Date:         02/01/99

      Document  #:  18081
     Title:

     Author:
     Recipient:
     Date:
      Response to Congresswoman Helen Chenoweth -Public Comment Period
      on Proposed Plan for INTEC Extended
      Richardson, B., DOE-HQ
      Chenoweth, H.
      02/22/99
     Document 8:  OPE-ER-73-98
     Title:

     Author:
     Recipient:
     Date:
     Response to Recommendation on Proposed Soils Repository at the Idaho
     National Engineering and Environmental Laboratory
     Jenkins, T.W.
     Rice, C.M.
     04/29/98
     Document #:  OPE-ER-48-99
     Tltle:         Response to Recommendation on the Proposed Plan for Remedial Action
                  at the Idaho Chemical Processing Plant (Waste Area Group 3)
     Author:       Jenkins, T.W.
     Recipient:    Rice, C.M.
     Date:         03/31/99

     Document #:  10684
     Title:         Comments  on the WAG 3 Proposed Plan
     Author:       Christinna
     Recipient:    Lyle, J.  L
     OdU-:         12/17-98
                                     B-41

-------
                  OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR10.1      COMMENTS AND RESPONSES (continued)

 y-     Document #: 10685
       Title:        Comments on WAG 3
       Author:      Priestley, F.
       Recipient:    Chenoweth,  H.
       Date:        01/01/99

*      Document if:  10686
      Title:        Comment on the Proposed Plan for WAG 3
      Author:      Vanhorn, R. L.
      Recipient:    Simpson, E. A.
      Date:        12/15/98

'•     Document #: 10687
      Title:        WAG 3 Comments
      Author:      Ansley, Shannon L.
      Recipient:    Simpson, E. A.
      Date:        12/02/98

      Document #:  10688
     Title:        Comments on WAG  3   •
     Author:      Taylor, A. E.
     Recipient:    Simpson, E. A.
     Date:        10/31/98

     Document #:  10689
     Title:        Comments on  WAG 3
     Author:      Randolph, P.
     Recipient:    Simpson, E. A.
     Date:        10/27/9

     Document #: 10690
                                             (INTEC)
    Recipient:    Lyle, J. L.
    Date:        12/01/98

    Document #:  10691
    Title:         ^°mtments on Proposed Clean-up  Ran for INEEL Chemical Processing

    Author:       Lemley, J. K.
    Recipient:     Lyle, J. L.
    Date:         12/18.-'98
                                    B-42

-------
                                                                                           1
                  OPERABLE UNIT 3-13
                                          09/22/99
FILE NUMBER
AR10.1
COMMENTS AND RESPONSES (continued)
      Document tt:
      Title:
      Author:
      Recipient:
      Date:
      10692
      Comments on WAG 3
      Hobson, S.
      Chenoweth, H.
      02/08/99
      Document #: 10693
      Title:        Comments on WAG 3
      Author:      Crapo, M; Craig, L.; Simpson, M.
      Recipient:    Bergholz, W.
      Date:        02/09/99
      Document #:
      Title:
      Author:
      Recipient:
      Date:
      10694
      Comments on WAG 3
      Robertson, B. B.
      DOE-ID
      02/11/99
      Document #: 10695
      Title:        Comments on WAG 3
      Author:      Kuehn, R. M.
      Recipient:    Simpson, E. A.
      Date:        02/08/99

      Document*: 10696
      Title:        Comments on Environmental Remediation at Idaho National Engineering
                  Laboratory,  Idaho  Chemical  Processing  Plant  Radioactive  Waste
                  Management Complex
      Author:      Broscious,  C.
      Recipient:    Community Relations Coordinator
      Date:        04/06/99

      Document #: 10697
      Title:        Draft Comments (7/14/98) ICPP Draft Cleanup Plan
      Author:      Broscious,  C.
      Recipient:    Community Relations Coordinator
      Date:        07/14/98
                                     B-43

-------
                  OPERABLE UNIT 3-13
                                                       09/22/99
FILE NUMBER
AR10.1

>
            COMMENTS AND RESPONSES (continued)
>•
      Document #:  10698
      Title:         Comments ICPP Draft Cleanup Plan
      Author:       Broscious, C.
      Recipient:    Pierre W.; Trever,  K.; Wichmann, T.
      Date:         08/14/98

      Document #:  106,99
      Title:         Comments on Department of Energy  Idaho National Engineering  and
                   Environmental Laboratory Idaho Chemical Processing  Plan  Proposed
                   Cleanup Plan
      Author:       Broscious, C.
      Recipient:     Community Relations Coordinator
      Date:         11/19/98

      Document #:  10700
      Title:        Comments on Proposed Plan for Idaho  Chemical Processing Plant
      Author:      Coperfield, C.
      Recipient:    Lyle, J. L.
      Date:        12/21/98

      Document  tf: 10701                    •
      Title:

      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:
                  Public Comment Clean Up Plan for Waste Area Group 3 (Idaho Chemical
                  Processing Plant) INEEL
                  Stewart, M. M.
                  Community Relations Coordinator
                  12/22/98

                  10702
                  Idaho Chemical Processing Plant (INTEC) Proposed Plan -Comment
                  Hensel, D.
                  Community Relations Coordinator
                  12/22/98

                  10703
                  Comments to WAG 3 Proposed Plan
                  Robo,  R.
                  Lyle, J. L.
                  12/21/98
                                     B-44

-------
                    OPERABLE UNIT 3-13
                                                          09/22/99
  FILE NUMBER
  AR10.1
  COMMENTS AND RESPONSES (continued)
        Document #:
        Title:
        Author:
        Recipient:
        Date:

        Document #:
        Title:
        Author:
        Recipient:
        Date:

       Document #:
       Title:
       Author:
       Recipient:
       Date:
        10704
        Comments on the Proposed Plan for Waste Area Group 3-Waho Chemical
        Processing  Plant  Idaho  National  Engineering  and  Environmental
        Laboratory-Snake River Alliance
        Brailsford, B.
        Community Relations Coordinator
        1 2/22/98

        10705
       Comments on ICPP Proposed Plan
       McCarthy, J. M.
       Community Relations Coordinator
       1 2/22/98

       10706
       WAG 3 Comments
       Citizens Advisory Board
       Community Relations Coordinator
       11/18/98
AR10.3
PUBLIC NOTICE(S)
       Document #:
       Title:

       Author:
       Recipient:
       Date:
      10545
      Notice of Availability - Meetings Scheduled on Cleanup of Idaho Nuclear
      Technology and Engineering Center
      INEEL Community Relations
      Not specified
      10/22/98
'•     Document #:  16878
      Title:

      Author:
      Recipient:
      Date:
      Notice of Availability - Comment Period Extended on Proposed Cleanup
      Plan for Idaho Nuclear Technology and Engineering Center
      INEEL Community Relations
      Not specified
      01/11/99
                                     B-45

-------
                     OPERABLE UNIT 3-13
                                                          09/22/99
    FILE NUMRFR


    AR10.4     PUBLIC MEETING TRANSCRIPTS

    '-    Document #:  10675
         Title:
         Author:      |NEEL Community 'Relations
         Rec.p.ent:    Not specified
         Da«e:        11/16/98

         Document ft:  10676
         Title:
        Author:
        Recipient:
        Date:
              Community Relations
        Not specified
        11/17/98
        Document ft: 10677
        Title:
       Author:     INEEL Community"^,^^*
       Recipient:    Not specified
       Da«e:       11/18/98

       Document #: 10678
       Title:
       Author:
       Recipient:
       Date:
            Community Relations
      Not specified
      11/19/98
AR10.6
FACT SHEETS AND PRESS RELEASES
      Document #: 14841
      Title:
      Author:
      Recipient:
      Date:
           Community Relations
      Not specified
      11/01/97
                                                             "-
                                                              identifies
                                    B-46

-------
                                                                                           \
                  OPERABLE UNIT 3-13
                                                       09/22/99
FILENUMBER
AR10.6     FACT SHEETS AND PRESS RELEASES (continued)

      Document #:  14840
      Title:

      Author:
      Recipient:
      Date:
  Update Fact Sheet - Waste Area Group 3 environmental investigation
  nearly complete
  INEEL Community Relations
  Not specified
  09/01/98
      Document #: 6520
      Title:

      Author:
      Recipient:
      Date:

      Document #:
      Title:

      Author:
      Recipient:
      Date:
 DOE NEWS  -for Immediate  Release -WINCO Coordinates  Effort  to
 Recycle Contaminated Metal
 Bugger, B.
 Not specified
 06/01/93

 6548
 DOE NEWS -for Immediate Release -DOE Completes Environmental
 Assessment on Upgrading Chem Plant Tank Farm
 Coe, M.
 Not specified
 06/24/93
     Document #•: 6710
     Title:

     Author:
     Recipient:
     Date:
 DOE NEWS -for Immediate Release -Idaho Chemical Processing Plant
 Transition Plan Made Available to the Public
 Coe, M.
 Not specified
 08/05/93
     Document #: 6805
     Title:

     Author:
     Recipient:
     Date:

     Document #:
     Title:

     Author:
     Recipient:
     Date:
DOE NEWS -for Immediate Release -Removal Actions to Take Place at
the Idaho Chemical Processing Plant
Bugger, B.
Not specified
09/24/93

6836
DOE  NEWS  - for  Immediate Release  -  WINCO,  Private  Vendor
Demonstrates Technology for Cleaner Decontamination
Bugger, B.
Not specified  .
10/15/93
                                    B-47

-------
                     OPERABLE UNIT 3-13                  09/22/9g


    RLE NUMRFR


    AR10.6      FACT SHEETS AND PRESS RELEASES (continued,

    '•    Document #: 7559
         Title:        DOE
                     Melt „. ^Wl
         Author:     Bugger, B.
         Recipient:    Not specified
         Date:        03/30/94

   '•     Document #: 7595
                             .
        Recipient:    Not specified
        Date:       04/01/94

  AR11.1      EPA HEADQUARTERS GUIDANCE

  A     Document #: 14842
       Recipient:    Jenkins, T.
       Date:       08/05/98

 ART 1.4      TECHNICAL SOURCES

 4      Document ff: WM-F1 -83-006
                  	_,,_..                              J, M.W.
      Date:       05/01/83'

f     Document #: WM-F1 -83-024
      ''t'e:        Internal Too K,-,;,-.,. „	^  „  ...
                                                     Characterizati
      Author-      c'T'-T T U'C v-rr-DU>;f J-uel-Element Cutti
      rtutnor.      Schmidt, D.A.; Smith  D L
                         ,   .
      Recipient:    Not specified
      Date:        09/01/83
                                    B-48

-------
                   OPERABLE UNIT 3-13
                                           09/22/99
 FILE NUMBER
 AR11.4
TECHNICAL SOURCES (continued)
       Document #:
       Title:
       Author:
       Recipient:
       Date:
      WM-F1-81-004
      Internal Technical Report -CPP-633 NaK Furnace Characterization
      Smith, D.L.; Bradford, D.J.
      Not specified
      03/01/81
       Document #: WM-F 1-81-010
       Title:

       Author:
       Recipient:
       Date:
      Internal Technical Report -Characterization of the RALA Off-Gas Cell
      CPP-631
      Smith, D.L.; Bradford, D.J.
      Not specified
      05/01/81
       Document #: WM-F1-81-023, Rev. 1
       Title:

       Author:
       Recipient:
       Date:
      Internal Technical Report -Radioactive Waste Characterization of CPP-
      603 Cleanup Basin System -CPP-740
      Low, J.O.
      Not specified
      05/01/82
AR11.6      TECHNICAL MEMORANDUM
      Document #:
      Title:

      Author:
      Recipient:
      Date:
     17286
     Transmittal of the Draft Technical Memorandum on the Hydrogeology at
     the Idaho Chemical Process Plant
     Jenkins, T.W.
     Jones, E.; Reno,  S.L.
     10/28/94
      Document*:  OPE-ER-199-96
      Title:
      Author:
      Recipient:
      Date:
     Transmittal of the Three Technical Memoranda on Technology Screening,
     Remedial Action Objectives, and Applicable or Relevant and Appropriate
     Requirements
     Jensen, N.R.
     Pierre, W.; Nygard, D.                            .
     12/23/96
                                      B-49

-------
                  OPERABLE UNIT 3-13
                                                  09/22/99
FILE NUMBER
AR11.6
       TECHNICAL MEMORANDUM (continued)
       Document #: WINCO-1060
       Title:        Modeling Hypothetical Groundwater Transport of Nitrates, Chromium,
                   and Cadmium at the Idaho Chemical Processing Plant
       Author:      Thomas, T.R.
       Recipient:    Not specified
       Date:        11/01/88

       Document #: EGG-ER-11101
       Title:        Technical Memorandum for the WAG 3 and WAG 10 Soils Treatability
                   Study:  Physical Separation of Radionuclides in Soils
       Author:      Gombert, D.: Honeycutt, T.K.; Goettsche, J.H.; Huestis, G.M.; Tranter
                   T.J.
       Recipient:    Not specified
       Date:        12/01/93
AR12.1
      EPA COMMENTS
                                                                              and
Document #:  5776
Title:         Comments on  the Technical  Memorandum  Conceptual  Flow
             Transport Models of the Unsaturated and Saturated Zones for the
             WAG 3 Comprehensive RI/FS
Author:       Meyer, L.
Recipient:     Green, L.
Date:         06/17/94

Document #:  5778
Title:         EPA  Comments  on  the  Draft  Aquifer  Characteristics  Technical
             Memorandum
Author:       Meyer, L.
Recipient:     Green, L.
Date:         08/10/94

Document ff:  5777
Title:         Review Comments of the Draft Technical Work Plan for the WAG 3 and
             WAG 10 Radionuclide-Contaminated Soils Treatability Study
Author:    .   Liverman, E.
Recipient:     Green, L.
Date:         03:18/94
                                      B-50

-------
                                                                                          1
                  OPERABLE UNIT 3-13
                                                       09/22/99
flLENUMBER
AR12.1      EPA COMMENTS (continued)
      Document #:
      Title:

      Author:
      Recipient:
      Date:

      Document #:
      Title:

      Author:
      Recipient:
      Date:

      Document #:
      Title:
     Author:
     Recipient:
     Date:
  5783
  EPA Comments, Draft  Scope of Work for the  Waste Area Group  3
  Comprehensive RI/FS
  Meyer, L.
  Green, L.
  08/08/94

  10429
  EPA Comments, Draft Comprehensive RI/FS for the  Idaho Chem.cal
  Processing Plant (OU 3-13)
  Orlean, H.
  Main, K.E.
 08/13/97

  15038
 EPA Comments on Idaho Chemical Processing Plant (ICPP)  INEL Waste
 Area Group (WAG) 3 Technical Workplan for Perched Water Pumping
 and Tracer Tests
 Jones, E.
 Green, L.A.
 10/19/94
     Document #: 15053
     Title:

     Author:
     Recipient:
     Date:
Additional EPA Comments on Draft Comprehensive RI/FS for the Idaho
Chemical Processing Plant (OU 3-13)
Orlean, H.
Hain, K.E.
09/12/97
     Document #: 18066
    Title:
    Author:
    Recipient:
    Date:
Idaho Chemical Processing Plant (ICPP), INEL Waste Area Group (WAG)
3 Technical Memorandum for Radiologically Contaminated Soils  (New
Unit NU-21.93)
Jones, E.
Green, L.A.
11/18/94
                                    B-51

-------
                  OPERABLE UNIT 3-13                  09/22/99
FILE NUMBER

AR12.1      EPA COMMENTS (continued)

'•     Document ff: 18071
       Title:        EPA Review of "Draft ICPP Radionuclide-Contaminated Soils Removal
                   Action EE/CA"
       Author:      Pierre, W.                                           '
       Recipient:    Jensen, N.R.
       Date:        01/30/97

>      Document #: 18077
       Title:        EPA Comments  on  the Supplemental Feasibility Study for the Idaho
                   Chemical Processing Plan by the Environmental Protection Agency
       Author:            EPA
       Recipient:    Not specified
       Date:        09/09/99

A     Document #: 18078
       Title:     '   EPA Comments on the Draft Final Proposed Plan for the ICPP
       Author:      Rose, K.R.
       Recipient:    Not specified
       Date:        09/09/99

'.     Document #: 12995
      Title:        EPA Comments on Draft Comprehensive RI/FS for the  Idaho Chemical
                   Processing Plant OU 3-13 -Part A, RI/BRA  Report
      Author:       Orlean, H.
      Recipient:    Jensen, N.R.
       Date:        10/04/96

>      Document #: 2317
      Title:        EPA Comments on INEL Initial Assessment Ranking Update on CPP-55
                   Closure Plan Review, and  CPP-77 Summary Assessment Review
      Author:       Feigner, K.D.
      Recipient:    Gesell, T.F.
      Date:        12/24/87

*      Document #: 2494
      Title:        EPA Review of Selected Summary Assessments
      Author:       Feigner, K.D.
       Recipient:    Gesell, T.F.
      Date:        01/05/88
                                      B-52

-------
                  OPERABLE UNIT 3-13
                                                       09/22/99
FILE NUMBER
AR12.1
EPA COMMENTS (continued)
      Document ft:  2668
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:

      Document #:
      Title:
      Author:
      Recipient:
      Date:

     Document #:
     Title:
     Author:
     Recipient:
     Date:
      EPA Review of INEL Closure Plan Reviews for TAN-726, Jon Exchange
      Treatment Unit, TAN-674 Tank, IET Container Storage Unit, and Hg
      Contaminated Area -CPP-55
      Feigner, K.D.
      Gesell, T.F.; Clark, C.E.
      TO/27/87

      3537
      EPA Review Summary Assessments
      Gearheard, M.; Koshuta, C.
      Weiler, H.
      10/16/89

      6318
      EPA Closure Plan Review Mercury Contaminated Area CPP-55
      Tetra Tech, Inc.
      Not specified
      10/01/87

      6497
      EPA Summary Assessment Reviews
     Feigner, K.D.
     Clark, C.E.
     05/21/87

     6709
     EPA Notice of Deficiency for Closure Plan Submittal
     Gearheard, M.F.; Koshuta, C.R.
     Solecki, J.E.
     10/26/89
     Document #: 8682
     Title:
     Author:
     Recipient:
     Date:
     EPA/IDHW Notice of Deficiencies for Sixteen INEL Closure Plans- CPP-55
     CPP-37, CPP-33, CPP-34, CPP-48, CPP-39, CPP-63, CPP-47 'cPP-4o'
     CPP-59, CPP-64, TSF Disposal Pond, CFA-03, CFA-02, TAN-629 and
     CFA Motor Pool  Pond
     Gearheard, M.F.; Koshuta, C.R.
     Weiler,  F.H.
     11/08/86
                                     B-53

-------
                    OPERABLE UNIT 3-13                   09/22/g9


  FILE NUMBER


  AR12.2      IDHW COMMENTS

  '      Document #: 5779
        Title:
       Author:
       Recipient:    Jenkins, T.
       Date:        08/30/94

       Document #:  5782
       Title:
                         I— - — •••'•issivwill/l *J                                         r^
       Author:      Reno, S.L.
       Recipient:    Green, L.
       Date:        08/10/94

'•     Document #: 15034
      Title:         IDHW/DFn
                   • ^i ivv/u/cu «-uiiiiMtJnis on IJraft TQ^K^;^—i  m_
                                                                              Area
                   A    "    '       '	"-"<»ivc  neineaiai  lnve«;Tinatir>o   D^

      Author:       S^T Meth°dOl°^ °U 3-13. S^JZTl9M
      Recipient:     Jenkins, T.W.
      Date:         11/01/94

      Document #:  15035
      Title:
     Author:
     Recipient:    Green, L.A.
     Date:        10/06/94

     Document ff:  1 5040
     Title:
    Author:
    Recipient:    Jenkins, T.W.
    Date:        11 /22/94
                                    B-54

-------
                  OPERABLE UNIT 3-13
                                                       09/22/99
FILE NUMBER
AR12.2     IDHW COMMENTS (continued)
      Document #:
      Title:

      Author:
  1 5045
  IDHW/DEQ Review and Comment Period for Draft Sampling and Analysis
  Plan for the Waste Area Group 3 Remedial Investigation/Feasibility Study
  Reno, S.L.
      Recipient:    Jenkins, T.W.
      Date:
 02/17/95
      Document #: 15051
      Title:

      Author:
      Recipient:
      Date:
 IDHW/DEQ Comments  on the Comprehensive RI/FS  for  the  Idaho
 Chemical Processing Plant OU 3-13 at the INEEL (Draft), June 1997
 Reno, S.L.
 Haih, K.E.
 09/03/97
     Document ff:  5784
     Title:
     Author:
     Recipient:
     Date:
 IDHW/DEQ Informal Comments on Technical Memorandum Assessment
 of Porflow Boundary Conditions  for Use in the ICPP Unsaturated Zone
 Model and Attachment  A Assessment of the Cylindrical Coordinate
 Option in Porflow
 Reno, S.L.
 Jenkins, T.
 08/30/94
     Document ff: 5785
     Title:

     Author:
     Recipient:
     Date:
IDHW/DEQ Concurrence with Draft Final Scope of Work, Waste Area
Group (WAG) 3 Comprehensive RI/FS
Reno, S.L.
Green, L.
10/06/94
     Document ff: 15039
     Title:
     Author:
     Recipient:
     Date:
IDHW/DEQ Comments on Draft Technical Memorandum for the Water
Quality Trend Analysis in the Snake River Plain Aquifer, Idaho Chemical
Processing Plant, October 6, 1994, OU 3-13
Reno, S.L.
Jenkins, T.W.
1 1 /07/94
                                    B-55

-------
                    OPERABLE UNIT 3-13                  09/22/99


  FILE NUMBER

  AR12.2     IDHW COMMENTS (continued)

  '     Document ff: 15044

        ™K        C™, :ora' C°mmemS °°  Dra« WAQ 3  *« 2°ne
        Author:      Reno, S.L.
        Recipient:    Jenkins, T.W.
        Date:        01/09/95

 y      Document ff:  15036   '

        ™,L:     LaneW/RDEQ C°mmemS "" C'°SU'e Pla" '<" CPP-34/,NEL
       Recipient:    Monson, B.R.
       Date:        08/14/90

 '•     Document ff: 75037
       Title:
      Author:      Reno, S.L.
      Recipient:    Jenkins, T.W
      Date:        10/18/94

'•     Document ff:  18069
      Title:
                  «CPP). Waste Area G; up 3 (WAG 3, "^ °hemiCal Pr°CeSSin9
      Author:      Stoops, T.M.
      Recipient:    Green, L.A.
      Date:        06/09/93

      Document ff: 18040
      Title:
     Author:
     Recipient:   Green, L.A.
     Date:        03/09/94
                                    B-56

-------
                  OPERABLE UNIT 3-13
                                     09/22/99
FILE NUMBER
AR12.2     IDHW COMMENTS (continued)
      Document #:
      Title:

      Author:
      Recipient:
      Date:
 18041
 IDHW/DEQ Review of Draft SOW for Waste Area Group 03, Operable
 Unit 08a; Idaho Chemical Processing Plant
 Stoops, T.M.
 Green, L.A.
 01/19/94
      Document #: 15055
      Title:

      Author:
      Recipient:
      Date:

      Document #:
      Title:

      Author:
      Recipient:
      Date:
      Document #:
      Title:.

      Author:
      Recipient:
      Date:
 IDHW/DEQ Comments  on the Comprehensive RI/FS  for  the  Idaho
 Chemical Processing Plant OU 3-13 at the INEEL (Draft Final)
 Reno, S.L.
 Hain, K.E.
 11/14/97

 15059
 IDHW/DEQ Informal Comments on the Working Draft of Proposed Plan
 for Waste Area Group 3, Idaho Chemical Processing Plant
 Reno, SfL.
 Jenkins, T.W.
 01/09/98
 18023
 IDHW/DEQ Comments on Waste Area Group 3 Comprehensive Remedial
 Investigation/Feasibility Study Work Plan (Draft)
 Reno, S.L.
Green, L.A.
05/01/95
     Document #:  18068
     Title:         IDHW/DEQ  Comments  on Technical Memorandum  for  the ICPP
                  Radiologically Contaminated Soils {New Unit NU-21.93), OU 3-13
     Author:      Reno, S.L.
     Recipient:    Jenkins, T.W.
     Date:         11/18/94

     Document #:  12996
     Title:         IDHW/DEQ Comments on Comprehensive RI/FS for the Idaho Chemical
                  Processing  Plant OU 3-13 at the  INEL -Part A, RI/BRA {Draft! (DOE ID-
                  10534, August 1996, Revision 0)
     Author:      Reno, S.L.
     Recipient:    Jensen, N.R.
     Date:         10/08/96
                                     B-57

-------
                  OPERABLE UNIT 3-13
09/22/99
FILE NUMBER

AR12.2     IDHW COMMENTS (continued)

>     Document #: 14351
      Title:        IDHW/DEQ  Comments on  Engineering Evaluation/Cost Analysis  for
                   Radionuclide-Contaminated Soils Removal Action at the Idaho Chemical
                   Processing Plant (DOE.-ID-10568, February 1997)
      Author:       Reno, S.L.
      Recipient:    Jensen, N.R.
      Date:        03/27/97

A    Document #: 16292
      Title:        IDHW/DEQ Comments on the Revised Draft Proposed Plan for Waste
                   Group 3 at the Idaho Chemical Processing Plant
      Author:       Reno, S.L.
      Recipient:    Hain, K.E.
      Date:        03/06/98

A    Document #: 16293
      Title:        IDHW/DEQ Comments on the Draft Comprehensive RI/FS for the Idaho
                   Chemical  Processing Plant OU 3-13 at the INEEL -Part B, FS Supplement
                   Report
      Author:       Reno, S.L.
      Recipient:    Hain, K.E.
      Date:        03/26/98

>     Document ft: 6112
      Title:        IDHW/DEQ Comments Concerning  the Public Comment Period  for  the
                   Closure Plan for CPP-55
      Author:      Donovan, R.P.; Findley, C.E.
      Recipient:    Barry, J.H.
      Date:        09/19/89

>      Document ff: 6725
      Title:        IDHW/DEQ Review of the Revised Closure Plan for CPP-23
       Author:      Koshuta,  C.R.
       Recipient:    Solecki, J.E.
       Date:        04/17/90
                                       B-58

-------
                                                                                            1
                   OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR12.3     DOE RESPONSE TO COMMENTS

 *-     Document #:  2820
       Title:         Caliper Logs for CPP-23 Injection Well
       Author:       Solecki, J.E.
       Recipient:     Monson, B.R.
       Date:         08/22/90

 *•     Document  #:  6036
       T'tle'         Summary Assessments
       Author:       Solecki, J.E.
       Recipient:     Gearheard, M.
       Date:        03/13/90

>-     Document #: 906
       Title:        State of  Idaho Request for Information Concerning the Status of "A
                   Shallow Seepage Pit on the West Side of CPP-603" (SWMU CPP-2)
       Author: .     Solecki, J.E.
       Recipient:    Nygard, D.
       Date:        12/07/89

•*-      Document #:  6635
       T'tle:         Response to State Questions
      Author:      Green, L.A.
      Recipient:    Hendrickson, B.
      Date:        04/26/90

 •     Document #:  OPE-EP-131-97
      Title:         Regulatory Position on the Status of CPP 709 and CPP 734
      Author:       Wessman, D.L.
      Recipient:     Steger, R.
      Date:        04/10/97

 •     Document*: OKE-21-90
      T'tle:        Strontium 90 in Borehole CPP-55-06
      Author:      Earle, O.K.
      Recipient:    Lyle, J.L.
      Date:         12/06/90
                                      B-59


-------
                  OPERABLE UNIT 3-13
                                          09/22/99
FILE NUMBER
AR12.3
DOE RESPONSE TO COMMENTS (continued)
      Document #:  OKE-13-91
      Title:        Revised LDU Questionnaires
      Author:      Earle, O.K.
      Recipient:    Lyle, J.L.
      Date:        02/04/91

      Document #:  OKE-18-90
      Title:        Strontium 90 in Borehole CPP-55-06
      Author:      Earle, O.K.
      Recipient:    Sato, W.N.
      Date:        11/19/90

      Document*:  OPE-ER-101-97
      Title:        Response  to  Recommendation on the Technology  Screening  and
                   Alternative Development for WAG  3 Comprehensive Feasibility Study
                   Report
      Author:      Jenkins, T.W.
      Recipient:    Rice, C.M.
      Date:        06/18/97

      Document #:  DJB-41-89
      Title:        Summary Assessment Review Letter from the EPA/STATE
      Author:      Blumberg, D.J.
      Recipient:    Weiler, F.H.
      Date:        11/09/89

      Document #: DJB-49-90
      Title:        October 16, 1989 EPA Request for Additional Information for Deletion
                   of Selected SWMU' s from the COCA through the Summary Assessment
                   Process
       Author:             Blumberg, D.J.
       Recipient:    Panasiti, J.D.
       Date:        05/23/90

       Document #: DJB-09-90
       Title:        Summary Assessment Review Letter from the EPA/STATE
       Author:      Blumberg, D.J.
       Recipient:    Weiler, F.H.
       Date:        01/12.-90
                                        B-60

-------
                  OPERABLE UNIT 3-13
                                     09/22/99
FILE NUMBER
AR12.3      DOE RESPONSE TO COMMENTS (continued)
      Document #:
      Title:

      Author:
      Recipient:
      Date:
 AJM-23-89
 EPA Region X and Idaho Department of Health and Welfare Conditions
 for Closure of LDU CPP-55
 Matule, A.J.
 Weiler, F.H.
 05/26/89
>•     Document #:  OPE-ER-196-96
      Title:
      Author:
      Recipient:
      Date:
 Response  to  Comments  for  the  Waste  Area  Group  3,  Draft
 Comprehensive Remedial  Investigation  and Baseline Risk Assessment
 Report (RI/BRA), Part A of the Comprehensive Remedial Investigation,
 Feasibility Study Report
 Jines, A.T.
 Pierre, W.; Nygard, D.
 12/17/96
      Document #: DJB-40-89
      Title:

      Author:
      Recipient:
      Date:
Response to Notice of Deficiency for Closure Plan Submittal Received
from the EPA/STATE
Blumberg, D.J.
Weiler, F.H.
11 /09/89
      Document #: GS-04-90
      Title:

      Author:
      Recipient:
      Date:
Revision of WINCO' s Response to EPA Region X' s Review of Summary
Assessments CPP-41, CPP-43, CPP-70, CPP-71, CPP-76, and CPP-77
Sehlke, G.
Blumberg, D.J.
03/07/90
      Document*: GS-15-89
      Title:        Response to EPA' s Notice of Deficiency for WINCO' s Accelerated
                  Closure Plan Schedule
      Author:      Sehlke, G.
      Recipient:    Blumberg, D.J.
      Date:        11/08/89
                                     B-61

-------
                   OPERABLE UNIT 3-13                  09/22/99


 FILE NUMBER

 AR12.3     DOE RESPONSE TO COMMENTS (continued)

 '•     Document tt:  ERD-161-91
       Title:         Response to Informat.on Request by  Mr.  Walker Howell Regarding
                    Sampling Data at CPP-55-06
       Author:       Lyle, J.L.
       Recipient:     Ledger, J.D.
       Date:         05/09/91

 >      Document ff:  ERD-209-91
       Title:         Response to Regulatory Comments on Closure Plan for CPP-59, Kerosene
                   TanK Overflow
       Author:      Burns, T.F.
       Recipient:    Gearheard, M.
       Date:        05/30/91

AR12.4      EXTENSION REQUESTS AND APPROVALS

'     Document #:  10298
      Title:         Extension of Review Period on the Comprehensive RI/FS for the Idaho
                                          °U 3'13 3t the 'NEL"Part A' R'/BRA
      Author:      Reno, S.L.
      Recipient:    Jensen, N.R.; Pierre, W.
      Date:        08/29/96

      Document tt: 10430
      Title:        Extension of Review Period on the Comprehensive RI/FS for the Idaho
                  Chemical Processing  Plant OU 3-13  at  the INEEL  (Draft) -  (DOE ID-
                  10572, June 1997)
      Author:      Reno, S.L.
      Recipient:    Hain, K.E.; Pierre, W.
      Date:        08/11/97

      Document tt: OPE-ER-67-98
      Inrhn        2e?Ue!tcf°r Extension of th* OU 3:1 3 Draft ROD and Related Documents
      Muinor.      Ham, K.E.
      Recipient:    Pierre, W.; Nygard, D.
      Date:        05/15/98
                                     B-62

-------
                                                                                          1
                  OPERABLE UNIT 3-13
                                           09/22/99
FILE NUMBER
AR12.4
EXTENSION REQUESTS AND APPROVALS (continued)
      Document #: 10446
      Title:         Concurrence with  enforceable schedule extension for OU 3-13 Draft
                   Record of Decision
      Author:      Nygard, D.
      Recipient:    Main, K.E.
      Date:         05/27/98

      Document #: 10447
      Title:         Concurrence on Request for Extension of Enforceable Milestone for OU
                   3-13 Draft Record  of Decision (ROD)
      Author:      Pierre, W.
      Recipient:    Hain, K.E.
      Date:         05/27/98

      Document #: 1 5057
      Title:         Request for 20-Day Extension of Comment Period on the Draft Proposed
                   Plan for the Idaho Chemical Processing Plant at INEEL
      Author:      Rose, K.A.
      Recipient:    Hain, K.E.
      Date:         12/30/97

      Document #: 6115
      Title:         Receipt of your Notice of Delay dated 9/28/92 for submission of Track
                   Two  Summary Reports for Operable Units 3-07 and 3-08
      Author:      Stoops, T.M.
      Recipient:    Lyle, J.L.
      Date:         10/26/92

      Document #: 905
      Title:         INEL Request for Extension for Closure Plans for COCA Units CPP-64,
                   CPP-59 and CPP-39
      Author:      Gearheard, M.F.; Koshuta, C.R.
      Recipient:    Solecki, J.E.
      Date:         08/03/90
                                       B-63

-------
                                                                                              1

                    OPERABLE UNIT 3-13                  09/22/99

  FILE NUMBER

  AR12.4      EXTENSION REQUESTS AND APPROVALS (continued,
  '     Document *: OPE-ER-102-95
        Title:
                             • of Comment Resolution Period  on the Waste Area Group 3
        Author-      r   "7 lnvest'9a"°n;Feasibility Study Work Plan
        Muinor.      (jreen, L.A.
        Recipient:     Pierre, W.; Nygard, D
        Date:        06/05/95


 '•     Document*:  OPE-ER-173-96

        Title:         J,^^0^ ^tension Notification for Submittal of
                                                           . Q(J 3_
       Author-'            Jenkins, T.W.
       Recipient:    Pierre, W.; INJygard  D
       Date:        11/13/96


       Document*:  ERD-197-91

       I'u'thor:       ^^^^ Extension of the CPP-59 C.osure Plan Revision Schedule
       Recipient:    Ledger. J.D./Gearheard  M
       Date:        05/21/91
NOTE:
                                                   Technical Support  Building,  1580
                                      B-64

-------

-------

-------
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-------

-------
                              PB99-964606
                              EPA541-R99-095
                              1999
EPA Superfimd
      Record of Decision:
      Idaho National Engineering Lab (USDOE)
      OU3-13
      Idaho Falls, ID
      9/28/1999

-------

-------
DOE/ID-1Q6W
Revision I)
           Final Record of Decision

         Idaho Nuclear Technology and
               Engineering Center

                   Operable Unit 3-13
       Idaho Nauonal Engineering and Environmental Laboratory
                    Idaho Kails, Idaho

-------

-------
                                         DOE/ID-10660
                                            Revision 0
       Final Record of Decision
   Idaho Nuclear Technology and
         Engineering Center
              September 1999
             Operable Unit 3-13
Idaho National Engineering and Environmental Laboratory
             Idaho Falls, Idaho

-------

-------
                 DECLARATION OF THE RECORD OF DECISION

                                Site Name and Location


  Idaho Nuclear Technology and Engineering Center, Waste Area Group 3
  Operable Unit 3-13
  Idaho National Engineering and Environmental Laboratory (CERCLIS ID 4890008952)
  Idaho Falls. Idaho


                          Statement of Basis and  Purpose


       The Idaho Nuclear Technology and Engineering Center (INTEC) (formerly the Idaho Chemical
 Processing Plant) Waste Area Group (WAG) 3 is one of 10 Idaho National Engineering and
 Environmental Laboratory (IN'EEL) WAGs identified in the Federal Facility Agreement and Consent
 Order (FFA CO) by the U.S. Department of Energy Idaho Operations Office (DOE-ID), the U S
 Environmental Protection Agency (EPA) Region 10, and the Idaho Department of Health and Welfare
 (IDHW).  Operable Unit (OU) 3-13 is listed as the "WAG 3 Comprehensive Remedial Investigation
 (RD/Feas.b.hty Study (FS)" in the FFA/CO (DOE-ID  1991).  The objective of the comprehensive RI/FS
 is to: (1) review previous WAG 3 investigations, (2) investigate release sites not previously evaluated,
 (3) determine the risks posed by individual release sites and the overall risk posed by the WAG, and
 (4) identify, screen, and analyze remedial alternatives for release sites where risks are determined to be
 greater than allowable levels.

      This Record of Decision (ROD) presents the disposition of 101 identified release sites including
 four newly identified sites.  Sixty-one release sites were determined to exhibit unacceptable risks that if
 not addressed may present an imminent and substantial endangerment to human health and the
 environment.  Appropriate remedies for 55 of the sites are described in this ROD, while the remaining six
 sites were judged to be more appropriately managed under other OUs, WAGs, or INEEL regulatory
 programs. Information is provided in this ROD to support the remedial action decisions for the 55'release
 sues where contamination presents unacceptable risks or poses a threat, and to support the "No Action"
 and "No Further Action" decisions for the other 40 sites.  These remedial actions are chosen in
 accordance with the Comprehensive Environmental Response, Compensation, and  Liability Act
 (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of
 1986. and to the extent practicable, with the National Oil and Hazardous Substances Pollution
 Contingency Plan (NCP). The selected remedial actions are also intended to satisfy the requirements of
 the FFA/CO.  These decisions are based on the Administrative Record for WAG 3, OU 3-13.

      The DOE-ID is the lead agency for the remedy decisions under Executive Order 12580. The EPA
 approves the decisions, and along with the IDHW, has participated in the selection of the final remedies
 The IDHW concurs with the selected remedies for the WAG 3 sites of concern, the "No Action" and "No
 Further Action" determinations, and the sites that will be administered under other INEEL regulatory
 programs.  The basis for decisions arc made in this ROD and documented in the Administrative Record
 tor WAG 3, OU 3-13. The DOE. EPA. and IDHW will be collectively referred to as the Auencies in this
document.

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                                Assessment of the Site


      Fift\-fi\e of the 101 identified release sites uithin WAG 3 have actual or threatened releases of
hazardous substances that, if not addressed by implementing the response actions selected in this ROD.
may present an imminent and substantial endangerment to human health and or the environment. Six
oilier sues are identified  in this ROD that will be managed under other OL's. WAGs, or INEEL regulatory
programs.  The response actions selected in this ROD are designed to reduce the potential threats to
human health and or the  en\ ironment to acceptable levels. The remaining 40 sites are designated as "No
Action" or "No Further Action" sites. Thirty-four of these 40 sites are determined to have an acceptable
risk to human health and or the environment, under current industrial and future potential residential land
use. and are designated as "No Action" sites. The six other sites are identified as "No Further Action"
and may present an unacceptable risk to human health if land use changes prior to 2095 or if future
construction requires excavations below the assumed 3 m (10  ft) residential basement scenario.

                       Description of the Selected Remedies


      The  WAG 3 release sites were grouped according to shared characteristics or common contaminant
sources. The seven groups include: (I) Tank Farm Soils. (2) Soils Under Buildings and Structures,
(3) Other Surface Soils. (4) Perched Water. (5) Snake River Plain Aquifer (SRPA), (6) Buried Gas
Cylinders, and (7) SFE-20 Hot Waste Tank System.  Because the release sites in each group have
common characteristics or contaminants, a single remedy is selected for all release sites within each
group. In addition, those sites classified as "No Further Action" sites require institutional controls to
remain protective. Institutional Controls are also a part of the  remedy for each of the seven groups
described below. Institutional Controls will be established in accordance with the requirements set forth
in the April 1999. EPA Region  10 Policy. The selected remedy for each group  is described below.

Tank Farm Soils Interim Action (Group 1)

      The Tank Farm Soils represent principal threat wastes due to direct radiation exposure to workers
or the public: and due to  potential leaching and transport of contaminants to the perched water or the
SRPA. u sole source aquifer.  A final remedy for the Tank Farm Soils release sites  has been deferred
pending further characterization and coordination of any proposed remedial actions with the Idaho High
Level Waste (HLW) and Facilities  Disposition (FD) Environmental Impact Statement (EIS),  currently in
preparation. A separate RI.-'FS,  Proposed Plan, and ROD will be prepared for the Tank Farm  Soils under
OU 3-14.  Interim actions uere evaluated to provide protection until a final remedy is developed and
implemented.  The selected Tank Farm Soils Interim Action is Institutional Controls with Surface Water
Control. The major components of this remedy include:

      •     Restrict access to control exposure to Corkers and prevent exposure to the public from -;oils
            at the Tank  Farm until implementation of the final remedy under OU 3-14

      •     Accommodate a I  in 25-year. 24-hour storm e\ent with surface water run-on diversion
            channels

      •     Mmimi/e precipitation infiltration by grading and surface sealing  the Tank Farm Soils
            sufficient to dnert Xi)% of the average annual precipitation tailing on the Tank Farm Soils
            area

      •     Improve exterior building drainage to direct \\aier aua\ from the contaminated  areas,.
                                              i\

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       The Agencies believe this interim action will be protective of human health and the environment
 while the OU 3-14 RI/FS is being performed and a final remedy is selected. The interim action will
 comply with applicable or relevant and appropriate requirements (ARARs), be cost effective, and is
 consistent with the expected final Tank Farm remedy or the HLW&FD EIS. The Tank Farm Soils group
 includes one new site, CPP-96 (Tank Farm Interstitial Soils).  Site CPP-96 is a consolidation of all of the
 previously identified Tank Farm Soils sites and the intervening interstitial soils within the site CPP-96
 boundary.

 Soils Under Buildings and Structures (Group 2)

       The major threats posed by Soils Under Buildings and Structures release sites are direct radiation
 exposure to workers or the public caused by intrusion into contaminated soils and potential soil
 contaminant leaching and transport to perched water or the SRPA. The purpose of the selected remedy is
 to minimize the potential for direct exposure to contaminated soils and to prevent or reduce the leachinu
 of contamination from the soils to the perched water or SRPA.

      Until the buildings and structures above these sites are closed, and decontamination and
dismantlement (D&D) occurs, it is assumed that the building or structure limits infiltration of water
through the contaminated soils and prevents direct exposure to the contaminated soils. The selected
deferred action remedy  for Soils Under Buildings and Structures is Institutional Controls and
Containment. The major components of the selected remedy include:
•
            Implement institutional controls, including site access restrictions, and periodic inspections
            of buildings or structures to ensure that infiltration is limited and exposures to contaminated
            soil is prevented.  Access to the Group 2 sites will be restricted through the use of warning
            signs. Notification of this restriction will be made to the affected local county governments,
            ShoBan Tribal Council, General Services Administration (GSA), U.S. Bureau of Land
            Management (BLM), and other agencies, as necessary.

            Assess completed D&D building or structure and release site configuration to determine if
            they prevent radiation exposures or limit contaminant migration to the SRPA, as would be
            achieved through meeting the substantive requirements of Idaho Administrative Procedures
            Act (IDAPA) 16.01.05.008 (40 Code of Federal Regulations [CFR] 264.310).  If the
           completed D&D configuration is assessed as inadequate for long-term protection of human
           health and the environment, then contaminated soils will be capped in conformance with the
           above referenced hazardous waste landfill closure requirements with an engineered barrier.
           or removed and disposed on-Site as discussed in the following section for Group 3 soils.
           Environmental monitoring and maintenance requirements will be included in the OU 3-13
           post-ROD monitoring plan.

           The Waste Calciner Facility (VVCF) has been closed under an approved Hazardous Waste
           Management Act (HWMA) closure plan and a post-closure monitoring and maintenance
           plan is required. In order to reduce the duplication of effort for monitoring and maintenance
           of the WCF. maintain consistency with the publicly-noticed WCF closure plan, and
           acknowledge the Resource Conservation and Recovery Act (RCRA)/CERCLA parity policy
           these requirements will be addressed under this ROD as ARARs. The WCF will be "included
           during the CERCLA 5-year reviews uith the Group 2 Soils Under Buildings and Structures
           sites and will address the substantive requirements of IDAPA 16.01.05.008 (40 CFR
           264.310). Additionally these requirements \\ill  be incorporated into the post-ROD
           monitoring plan for OU 3-13.

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Other Surface Soils (Group 3)


      The Other Surface Soils release sites are also principal threat wastes due to potential external
exposure of workers or the public to radionuclide-contaminated soils. The purpose of the selected remedy
is to prevent external exposure to radionuclides at these sites and to allow these sites to be released for
unrestricted use in the future.  The selected remedy for Other Surface Soils is Removal and Onsite
Disposal in the 1NEEL CERCLA Disposal Facility 
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                                                                                          1
 Engineer to meet IDAPA 16.01.05.008 (40 CFR 264.301)Tor hazardous waste.
 40 CFR 761.75 lor PCB. and DOE Order 435.1 for radioactive waste landfill design
 and operating substantive requirements.

 Locate in an area meeting hazardous waste. PCB waste, and low-level radioactive
 waste (LLRW) landfill siting requirements. Through a preliminary evaluation of all
 the relevant decision criteria, the Agencies have determined the "Study Area" for
 suing the ICDF to be the CPP-67 Percolation Ponds and adjacent area's to the west.
 However, the specific ICDF  cell locations will be determined through the completion
 ot a comprehensive geotechmcal evaluation of the entire Study Area, which shall be
 reviewed and approved by the Agencies.  Siting criteria for the location of the ICDF
 included:

       Outside the  100-year Hood plain

       Outside of wetland areas

       Not in active seismic zones

       Not in high surface erosion areas

       Not in an area of high historic groundwater table.

Construct and operate an ICDF supporting complex, including a waste Storage.
Sizing, Staging, and Treatment (SSST) facility, in accordance with the substantive
requirements of IDAPA 16.01.05.008 (40 CFR 264 Subparts DD, I, J, and X) and
IDAPA 16.01.05.006.01 and  16.01.05.006.02 (40 CFR 262.34[a][l]). It is anticipated
that this facility will consist of a storage/staging building, an evaporation  surface
impoundment, a  waste shredder, solidification/stabilization tanks, and associated
equipment. Operations at the-facility will include chemical/physical treatment to
prepare ICDF wastes to meet  Agency-approved WAC and RCRA land  disposal
restrictions (LDRs).

Use one or more remediation  waste staging and storage areas to stage and handle
remediation waste.  Operate the storage areas in accordance with the substantive
requirements of IDAPA 16.01.05.006^.01  and 16.01.05.006.02 (40 CFR 262.34[a][l j).

Manage and treat monitoring  well construction and sampling wastes generated prior .to
construction of the  ICDF and  SSST (i.e.. purge water, decontamination water, and
drill cuttings) using remediation waste  staging piles and temporary treatment units in
accordance with the substantive requirements of IDAPA 16.01.05.008 (40 CFR
264.553 and 40 CFR 264.554). Accomplish treatment using mobile tankage and
physical, chemical treatment and comply with the substantive requirements of
IDAPA 16.01.05.008 (40 CFR 264 Subpart J. BB. and CC).

Construct and designate an evaporation pond as a Corrective Action Management
Unit (CAMU) in accordance with the substantive requirements of IDAPA
16.01.05.008 (40 CFR 264.552 and 40  CFR 264 Subparts K. and CC) for the purpose
ot  managing ICDF  leaehate and other aqueous wastes generated as a result of
operating the ICDF complex.

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                 Operate, close and post-close the ICDF complex in accordance with the substantive
                 requirements of IDAPA 16.01.05.008 (40 CFR 264 Subparts G, F, and N) and
                 pTriod3'" S'te aCCCSS restnctlons and institutional c°ntrols throughout the post-closure

 Perched Water (Group 4)
 threat \ti '^h  ^^ ^ ^ "?' CUrrent!y P°SC a direct human health »*or environmental
 ~F^^^^
5S°F^^^
contammauon.  The perched zone may impact SRPA groundwater quality because it is a contaminant
uansport pathway between contaminated surface soils and the SRPA. Although a future vv° t rTppl -
 e   ic S wmh   P    ? WatCr KS "Ot CaP3ble °f Pr°Viding SUftldent "ater for dom^tic"i pulses
re.tncl.on, w,|| be requ.red to prevent any future attempts to use perched water after 2095 when INTEL
wide inst.tut.onal controls are projected to end. A response action is necessary to m nimize  or elimfnfte'
                00" °fCOn         fr°m the P-hed — to the SRP^A and to
                             *****
 Implement institutional controls (to include a DOE-ID Directive limiting access) to prevent
 tPher±h rich' dVhi'e 7HEC °hPerati°nS C°minUe 3nd t0 Prevent futu- Sg'nto o
 through the perched zone (through noticing this restriction to local county governments
 ShoBan Trrbal Council. GSA. BL.M, and other agencies as necessary).       emments'

 Implement remedies to control surface water recharge to perched water beneath INTEC by
      " "   mg    '  Slin INT    erC°                 are estimated to comnbue
                   "o? hmg   h' HSling INT^ PerC°Iati0n P°"ch are estimated to comnbue
                   min im '^  r  "TT^' °Ut °f Sm'iCe' Limitin8 infiltration to the P«ched
                           P     3l reIeaSCS t0 the SRPA ^ reducinS the volume of water
                                            ig"' C0nstruction' and °Perate replacement ponds
                       A  r                  f°"owing the removai of the existin« INTEC
                 n oPn°nn ft r°m tfmCe' -The replacement Percolatio" P^ds will be shed about
          December - ?            ^ Ot    INTEC a"d wi" be °Perational on °r before
In addition, minimize recharge to the perched water from lawn irrigation, and lininu the Bi*
co ^ro s ^are?rnt C0nt"br8 l° ll]^EC Perched -ter zones, if additional infihratbn
 °        neCeb:>ar'- ^'^nt
                                                                 ,
         Pr   < v                    additional infiltration controls if the recession of the
         Perched VV ater zone does not occur as predicted by the Rl/FS vadose zone model « ithin
         ? year* ot removmg the percolation ponds. If implementation of the additional infiltration
         controls is necessary, implement as a second phase to the Group 4 remedy.

         Measure moisture content and contaminant of concern (COC) concentration(s) in the
         perched water zones to determine if water contents and contaminant fluxes are decreasing as

                                                                                  ^
                                          in

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 Snake River Plain Aquifer (Group 5)


      The major human health threat posed by contaminated SRPA groundwater is exposure to
 radionuclides via ingestion by future groundwater users. Based on the groundwater simulations presented
 in the FS (DOE-ID !997a) and FS Supplement (FSS) (DOE-ID I998a), removal of the existing
 percolation ponds from service will significantly reduce the concentrations of contaminants in SRPA
 groundwater by 2095. Additional remedial action may be necessary to meet the groundwater maximum
 contaminant levels (MCLs) of 4 mRem/yr for beta particle and photon-emitting radionuclides.  Remedial
 action for the SRPA is bounded by the contaminant plume that exceeds Idaho groundwater quality
 standards or the federal MCLs for 1-129, H-3, and Sr-90.

      An  interim action is selected for the SRPA. While the remediation of contaminated SRPA
groundwater outside of the current INTEC security fence is final, the final remedy for the contaminated
portion of the SRPA inside of the INTEC fence line is deferred to OU 3-14. As a result of dividing the
SRPA groundwater contaminant plume associated with INTEC operations into two zones, the remedial
action described herein is classified as an interim action. The selected interim action remedy for the
SRPA is Institutional Controls with Monitoring and Contingent Remediation. The SRPA interim action
remedy includes:

     •     Implement institutional controls over the area of the aquifer that exceeds the MCLs for H-3.
           1-129, and Sr-90 (to include a DOE-ID Directive limiting access) to prevent groundwater use
           while INTEC operations continue, and to restrict future groundwater use (through noticing
           this restriction to local county governments, ShoBan Tribal Council, GSA, BLM, etc.),
           including site access restrictions, drilling restrictions, and maintenance during DOE
           operations at INTEC.

     •     Implement institutional controls, including land use restrictions to prevent the use of SRPA
           groundwater over the area of the aquifer that exceeds the MCLs for H-3,1-129, and Sr-90,
           until drinking water standards are met, which are projected to be achieved by 2095.

     •     Construct new SRPA monitoring wells outside of the current INTEC security fence to assess
           whether MCLs will be exceeded after 2095.

     •     If observed COC(s) concentrations exceed their action levels  at a sustained pumping rate of
           at least 0.5 gpm for 24 hours, implement pump and treatment remedial action. Extract
           contaminated SRPA groundwater from the zone of highest contamination and treat  to reduce
           the contaminant concentrations to meet MCLs by 2095.  The action level is the modeled
           maximum concentration predicted in the year 2000 so that the MCL will not be exceeded in
           2095 (the projected end of the institutional control period).

     •     It is anticipated that standard pump and chemical/physical treatment (which may include
           evaporation in the ICDF Complex surface impoundment) will be able to meet the aquifer
           restoration goal. Conduct treatability studies, which include a technical  evaluation of
           treating the 1-129 and other COCs. as part of this remedy.  These studies may include
           evaluation of the ability to treat and selectively withdraw contaminants from the aquifer.  It
           is estimated that these studies will not extend more than  ! 2 months and are  limited to a total
          cost of S2 million.                                                   •
            V
     •      If the treatability studies  indicate the presence of sufficient quantities of 1-129 and other
           COCs. and contaminated groundwater can be selectively extracted and cost-effectivelv
                                            IX

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            treated to meet the drinking water MCLs outside the current INTEC security fence by 2095.
            then implement active remediation.

      •     Either return treated water to the aquifer through land recharge in accordance with the Idaho
            \Vaste\vater Land Application ARARs if a recharge impoundment is used; or in accordance
            with National Pollutant Discharge Elimination System (NPDES).State Pollutant Discharge
            Elimination System (SPDES) ARARs if the treated effluent is discharged to the Big Lost
            Riser, which recharges the aquifer downstream of the INTEC facility: or evaporate in the
            1CDF complex evaporation pond or equivalent.

Buried Gas Cylinders (Group 6)

      The Buried Gas Cylinders pose a safety hazard to inadvertent intruders (i.e., backhoe operators or
drillers). The cylinders are presumed to be pressurized and could burst during excavation. In addition.
hydrofluoric acid, which may be present in the cylinders, is very corrosive, reacts violently with moisture.
and can generate explosive concentrations of hydrogen gas. The selected remedy for the Buried Gas
Cylinders is Removal. Treatment, and Disposal. This alternative includes:

      •     Remove the gas cylinders using a contractor specializing in gas cylinder removal

      •     Treat the cylinder contents, if necessary

      •     Recycle or'dispose of the empty gas cylinder containers.

      The Agencies may elect to pursue a contingent remedy of capping in place pursuant to the
substantive requirements of IDAPA 16.01.05.008 (40 CFR 264.310) if safety concerns with excavation
and removal prevent implementation of the selected remedy.

SFE-20 Hot Waste Tank System (Group 7)

      The major threat posed by the SFE-20 Hot Waste Tank System  is leaching and transport of
contaminants to the SRPA and subsequent exposure of future groundwater users to radionuclides v. ia
ingestion. The selected alternative for the SFE-20 Hot Waste Tank System is  Removal. Treatment, and
Disposal. This alternative includes:

      •     Remove and treat on-site the liquid and  sludge contents of the tank.

      •     Excavate and remove the tank, vault, and associated structures.

      •     Land dispose treated waste, the tank, vault,  and other debris.  The preferred disposal site i-,
            the ICDF; however, if any residue or material fails to meet the ICDF WAC. an alternate
            suitable disposal facility will be identified during the remedial design.

      •     Remove and treat off-site, if wastes found in the tank are alpha-LLW (i.e.. exceed 10 nCi g
            transtiranic [TRU] constituents [alpha emitters \\ ith an atomic number greater than 92 and a
            half-life exceeding 20 years]I or TRL' wastes (i.e.. greater than 100 nCi g  TRL'l.

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   "No Action" Sites

        Ten sites were determined to be "No Action" sites with the signing of the FFA/CO. Twenty-four
  additional "No Action" sites have been determined in this ROD.  These sites each represent less than
  1x10  risk and a hazard index (HI) of less than 1 for the potential  residential scenario, and could be
  available for current unrestricted use.

  "No Further Action" Sites

       Six of the 101 sites addressed in this ROD are classified as "No Further Action" sites and require
  only institutional controls to remain protective.  These controls will ensure that the land use will remain
  industrial until at least 2095 at which time contaminant levels will be reduced sufficiently to be protective
  for residential use. Those sites with contamination at depths below  traditional residential construction
  (i.e., 3  m [10 ft]), that do not require remedial action to safeguard the drinking water aquifer from future
  contaminant releases, will continue to require institutional controls to prevent excavation or drilling below
  3 m (10 ft) to remain protective.

 Closed and Closing RCRA/HWMA Sites

      Sites being closed under RCRA/HWMA will be handled as previously described for the WCF
 The WCF has been closed under an approved HWMA closure plan and a post-closure monitoring and
 maintenance plan is required.  In order to reduce the duplication of effort for monitoring and maintenance
 of the WCF, maintain consistency with the publicity-noticed WCF closure plan, and acknowledge the
 RCRA/CERCLA parity policy, these requirements will be addressed under this ROD as ARARs  The
 WCF will be included during the CERCLA 5-year reviews with the Group 2 Soils Under Buildings and
 Structures release sites and will address the substantive requirements of IDAPA 16.01.05.008
 (40 CFR 264.310).  Additionally these requirements will be incorporated into the post-ROD monitoring
 plan forOU 3-13.

 Disturbances of OU 3-13 Sites

      The INTEC facility is an operating facility. As such, periodic maintenance and upgrade activities
 will be conducted during the implementation of the remedial actions under this ROD. Prior to conducting
 any site disturbance activities, the Agencies will be notified to the extent of any disturbance, and will be &
 provided a plan for their approval, including necessary  corrective actions that will be performed to ensure
 that the remedies identified in this ROD remain operational and functional. A formal system for
 notification and approval of disturbances to OU 3-13 sites  will be developed during the remedial design.

      Sites Managed Under Other Operable Units, WAGs, or INEEL
                                 Regulatory Programs

      Six of the release sites identified in WAG 3 are outside the scope of this ROD and, therefore, will
be managed under other OUs. WAGs, or other INEEL regulatory programs.  Site CPP-38 (asbestos in
nine INTEC buildings) will be addressed by the INEEL Asbestos Management Program. Site CPP-65
(Sewage Treatment Plant Lagoons) will be addressed under the Idaho Wastewater Land  Application
Rules. Site CPP-66 (Steam Plant Fly Ash Pits) only presents a potential ecological risk and will be
addressed under CERCLA OL 10-04. which focuses on INEEL-wide ecological risk concerns.  Sites
CPP-61.-Sl.and-S2 will be further e\aluated and addressed under the OU 3-14 RI.FS.

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                                          New Sites

       Four new sites are identified in this ROD. Site CPP-96 (Tank Farm Interstitial Soils) is a
 consolidation of all of the previously identified Tank Farm release sites and the intervening interstitial
 .soils within the site CPP-96 boundary.  This site also includes three sites that were determined through
 the Track 2 process to be "No Action" sites. The final remedy for release site CPP-96 will be addressed
 in the OL' 3-14 Tank Farm  RI FS along with other Group 1 sites. Release site CPP-97 (Tank Farm Soil
'Stockpile). CPP-9X (Tank Farm Shoring Boxes), and CPP-99 (Boxed Soil) are added to this ROD to
 address soil stockpiles and wood construction debris that originated from the Tank Farm upgrade and. or
 the building CPP-604 tunnel egress projects.  These sites are included as part of the OU 3-13 Group 3
 sites and will be remediated accordingly.

                                Statutory Determination


      The selected remedy for each release site group, the "No Action" sites, and "No Further Action"
 sites have been determined  to be protective of human health and/or the environment, to comply with
 federal and state regulations that are ARARs for the remedial actions, and to be cost-effective.

      The selected remedies use permanent solutions and alternative treatment technologies to the
 maximum extent practicable.  The selected remedies for the Buried Gas Cylinder sites (Group 6) and the
 SFE-20 Hot Waste Tank System (Group 7) incorporate treatment, and the selected interim action remedy
 for the SRPA (Group 5) incorporates treatment if COCs in the aquifer outside the current 1NTEC security
 fence exceed action levels.  However, treatment of radionuclide-contaminated soil and perched water was
not found to be practicable for the other groups and, therefore, the selected remedies for the Soils Under
Buildings or Structures (Group 2), Other Surface Soils (Group 3). and Perched  Water (Group 4) do not
satisfy the statutory preference for treatment as a principal element of the remedy. The EPA's preferred
remedy for sites that pose relatively low. long-term threats, or where treatment is impracticable, is
engineering controls, such as containment. The selected remedial alternatives for Soils Under Buildings
or Structures (Group 2) and Perched Water (Group  4) will result in contaminants left in place at
concentrations exceeding health-based concentrations for direct exposure, but the contaminants will not
be available to present unacceptable risk to human health and/or the environment.

      Because these remedies will result in hazardous substances, pollutants, or contaminants remaining
onsite above levels that allow  for unlimited use and unrestricted exposure, a statutory review will be
conducted within 5 years after initiation of the remedial actions to ensure that each remedy is. or will be.
protective of human health and the environment. This review will also assess the need for continued
long-term environmental monitoring, administrative controls, and institutional controls at each group and
"No Further Action" site. Reviews will be held no  less  frequently than every 5  years thereafter to ensure
that the remedies continue to be protective. These periodic reviews will be discontinued when the
Agencies determine that the sites no longer pose an unacceptable risk to human health and, or the
em ironment and site access or use restrictions are no longer required.

      The 5->ear reviews will e\aluate factors such as contaminant migration from sites where
contamination has been left in place, newly discovered sites, effectiveness of institutional controls, and
effectiveness of the remedial actions. For remedies incorporating institutional controls, it is assumed that
institutional controls will  remain effectixe until the  year 2095. Additional institutional controls will apply
to specific sites after 2095.  This time period is consistent with the  100-\ear industrial land use
a.v»umption for the INTEC.
                                              \n

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                                                                                                               1
       Sites for which "No Further Action" determinations were made, based on an industrial land use
 assumption through 2095, and residential thereafter, will be included in the 5-year reviews. These
 reviews will evaluate whether the "No Further Action" determination  is still appropriate for the current
 and projected land uses at the time of the review.

       Sites for which "No Action" determinations have been made based on no evidence of a source or
 release or where the risk is less than 1 x  10'4 or a HI less than 1  will not require institutional controls or
 5-year reviews.

       It is possible that new information will be discovered in the future during routine operations.
 maintenance activities, and/or D&D activities that will require additional remedial actions be taken at the
 sites listed in this ROD. Through the 5-year review process, the Agencies will evaluate new information
 to ensure that the selected remedy, including institutional controls, remain protective.

      As IN.TEC is an operating facility, it is possible that changes in physical configuration of INTEC
 may uncover new sites or change the residual risk posed by those sites addressed under this ROD. Any
planned disturbance at a site for which action is required under this ROD (including the "No Further
Action" sites with institutional controls) will be preceded by appropriate planning documents to be
submitted to and concurred on by the Agencies prior to implementation. Newly discovered sites will be
subject to remedial action pursuant to the terms and conditions of the FFA/CO.

      The following information is included in the decision summary section of this  ROD; additional
information can be found in the Administrative Record for WAG 3:

      •     COCs and their respective concentrations

      •     Baseline risks represented by the COCs

      •     Cleanup levels established for the COCs and the basis for  the action levels

      •     Current and future land and groundwater use assumptions

      •      Land and groundwater use available at the site as a result of the remedy

      •      Estimated capital, operations and maintenance, and net present value costs,  discount rate.
            and number of years over which costs are projected

      •      Description of alternatives

      •      Evaluation of the remedial action alternatives

      •      Decision factors that lead to selection of the remedies.
                                              XIII

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M\

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                                                                                   1
                              Signature Sheet
by the Idaho Departmenof Healh  < wfe
                                                               , with concurrnce
Chuck Clarke, Regional Administrator
Region 10
U.S. Environmental Protection Agency
                                                 Date
                                                    54.^
                                  XV

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                             Signature Sheet




                          °f Dedsi°n for °Perable Unit 3-13< for the Idaho Nuclear

     US oar       f T' ^U*""*™* En^e-ng and Environmental Laboratory,
ru  r,  Department of Energy and the U.S. Environmental Protection Agency with concurrence
Waho Department of Health and Welfare.                                 '      concurrence
              1, Administrator

 ^vision of Environmental Quality

Idaho Department of Health and Welfare
                                                   Date
                                   XVII

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                                   Signature Sheet

     Signature sheet for the Record of Decision for Operable Unit 3-13, for the Idaho Nuclear
Technology and Engineering Center, of the Idaho National Engineering and Environmental Laboratory,
between the U.S. Department of Energy and the U.S. Environmental Protection Agency, with concurrence
by the Idaho Department of Health and Welfare.
 Beverly A. Cdok; Manager                                 Date
 Idaho Operations Office
 U.S. Department of Energy
                                          XIX

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                                     CONTENTS

 DECLARA riON OF THE RECORD OF DECISION	
 1.    DECISION SUMMARY	

      1.1   Site Name. Location, and Description.
 2.   SITE HISTORY AND ENFORCEMENT ACTIVITIES	        M
     2.1   INTEC History	                ,

     2.2   FFA'CO Implementation at INTEC	                    •> ,

     2.3   Other Regulatory Programs at INTEC	               ->.-


3.   HIGHLIGHTS OF COMMUNITY PARTICIPATION	               M

4.   SCOPE AND ROLE OF OPERABLE UNITS AND RESPONSE ACTIONS	    4.;
     4.1    Tank Farm Soils (Group 1)	      ...                           ,  ,

     4.2    Soils b'nder Buildings and Structures (Group 2)	                         4.7

     4.3   Other Surface Soils (Group 3)	                  4_s

     4.4   Perched Water (Group 4)	                              49

     4.5   Snake River Plain Aquifer (Group 5)	                 4_y

     4.6   Buried Gas Cylinders (Group 6)	             4_IQ

     4.7   SFE-20 Hot Waste Tank System (Group 7)	   4.10

     4.8   "No Action" And "No Further Action" Sites	    4. j(,

          4.8.1   "No Action/No Further Action" Sites Determined in OU 3-13 ROD	   4-1 i
          4.S.2   "No Action" Sites Designated in the FFA/'CO	      4.if,
     4.9   New Soil Release Sites.
          4.9.1   CPP-96—Tank Farm Interstitial Soils	                4.;,x
          4.9.2   CPP-97—Tank Farm Soil Stockpiles	•"	   4_is
          49.3   CPP-98—Tank Farm Shoring Boxes	                      j.-s
          4 9.4   CPP-99—Boxed Soil	'.	'..;....'..'.'.'."".   4-1 s

    4. ] 0  Sites Addressed Under Other WAGs or Regulatory Programs	
          4. ID. 1  CPP-3S—Asbestos in Nine INTEC Buildings.
          4 I" 2  ( TP-65—Sewage Treatment Plant Lagoon	
                                         xxi

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            4,10.3  CPP-66—Steam Plant Fly Ash Pit	   4.19


 5.    SUMMARY OF SITE CHARACTERISTICS	   5.]

      5.1   Physiography. Geology, and Hydrology	    j.j.

            5.1.1   Conceptual Model of Water Sources and Hydrogeology at WAG 3	    5-1

      5,2   Conceptual Model of Contaminant Distribution and Transport at WAG 3	5-4

      5.3   Nature and Extent of Contamination	,.,.    5.9

            5.3.1   Tank Farm Soils (Group 1)	    5.9
            5.3.2   Soils Under Buildings or Structures (Group 2)	   5-15
            5.3,3   Other Surface Soils (Group 3)	          5-17
            5.3,4   Perched Water (Group 4)	   5.51
            5.3.5   Snake River Plain Aquifer (Group 5)	   5-"0
            5.3.6   Buried Gas Cylinders (Group 6)	   5.77
            5.3.7   SFE-20 Hot Waste Tank System (Group 7)	   5.7-


6.    CURRENT AND POTENTIAL SITE AND RESOURCE USES	    6-1
      6.1    Current Land Uses	         (,_[

      6.2    Reasonably Anticipated Future Land Use	    6-1

      6.3    Basis for Future Land Use Assumptions	    6-2

      6.4    Groundwater Uses	    6-2

      6.5    Grounduater Classification and Basis	     6-3
7.    SUMMARY OF SITE RISKS	
      7.1   Human Health Risk Evaluation.
            "1.1   Derivation of Exposure-Point Concentrations.
             1.2   Site Source and Contaminant Identification....
            ". 1.3   Human Health Risk Assessment	
            ".1.4   Toxicity Assessment	
            ", 1,5   Human Health Risk Characterization	
            * 1.6   Human Health Risk Uncertainty	
           Kcolouical Evaluation.
                  Si-c and Contaminant Screening.
                  Exposure Assessment	
                   I'oxicity Assessment	
                  Risk Characterization	
                  Additional Screening	
                                            xxn

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       7.3   Ba-10
            •S.I.6   Buried Gas Cylinders (Group 6)	    $_1 \
            S.I."   SFI£— 20 Hot Waste Tank System (Group 7)	   g.| t

9.    DESCRIPTION of ALTERNATIVES	'.	 9_i
      9.1    Tank Farm Soils Interim Action (Group 1)	    9.]

            9.1.1    Interim Alternatives Descriptions	    9.)

      9.2    Soils L'nder Buildings or Structures (Group 2)	    9-2

            9.2.1    Alternatives Descriptions	       9.2

      9.3    Other Surface Soils (Group 3)	                  9.3

            9.3.1    Alternatives Descriptions	     9.3

      9.4    Perched Water (Group 4)	     9.4

            9.4.1    Alternatives Descriptions	          9.4

      9.5    Snake River Plain Aquifer Interim Action (Group 5)	     9-5

           9.5.1    Alternatives Descriptions	4.5

      9.6   Buried Gas Cylinders (Group 6)	     9.7

           9.6.1    Alternatives Descriptions	         9.7

      9."   SFF.-20  Hot Waste Tank System (Group 7)	    9-S

           9 ~.l    Alternatives Descriptions	     9-,x


10.   SL'MMARV OF COMPARATIVE ANALYSIS OF ALTERNATIVES	    10-1
      10.1  Tank Farm Soils Interim Action (Group 1)	    !0-2
           1" i.!  Overall Protection of Human Health and the Environment	    10-2
           !" !  2  Compliance with ARARs	  iO-2
                                            XX1U

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       10 1.3  Long-term Effectiveness and Permanence	.-.	    jo-2
       10.1.4  Reduction of Toxicity. Mobility, or Volume Through Treatment	    10-2
       10.1.5  Short-term Effectiveness	              KJ_?
       10.1.6  Implementability	           JQ.-^
       10.1.7  Cost	            IQ/-

 10.2  Soils  I'nder Buildings and Structures (Group 2)	    10-4

       102.1  Overall Protection of Human Health and the Environment	    10-4
       10,2.2  Compliance with ARARs	    fo-4
       10.2.3  Long-term Effectiveness and Permanence	,	    10-4
       10.2.4  Reduction of Toxicity, Mobility, or Volume Through Treatment	    10-4
      10.2.5  Short-term Effectiveness	,	         10.5
      10.2.6  Implementability	                                           10 5
      10.2.7  cost	;	i"i"i"i";;;"";;;;;;    10.5

 10.3  Other Surface Soils (Group 3)	   10.5

      10 3,1  Overall Protection of Human Health and the Environment	   10-6
      10.3.2  Compliance with ARARs	   10-6
      10.3.3  Long-term Effectiveness and Permanence	   10-6
      10.3.4  Reduction of Toxicity, Mobility, or Volume Through Treatment	   10-6
      10.3.5  Short-term Effectiveness	   10-7
      10.3.6  Implementability	   10-7
      10.3.7  Cost	[.[[]".'.'.'.'.'.".'.   10-8

10.4  Perched Water (Group 4)	    10-8

      10.4.1   Overall Protection of Human Health and the Environment	    10-8
      10.4.2  Compliance with ARARs	     K)-8
      10.4.3  Long-Term Effectiveness and Permanence	   10-8
      10.4.4  Reduction of Toxicity, Mobility, or Volume Through Treatment	   10-9
      10.4.5  Short-term Effectiveness	  10-9
      10 4.6  Implementability	   10-10
      10.4."  Cost	   10-10

10.5  Snake River Plain Aquifer Interim Action (Group 5)	   10-10

      10.5.1   Overall Protection of Human Health and the Environment	   Id-lu
      10.5.2  Compliance with ARARs	....:	   10-10
      10.5.3  Long-term Effectiveness and Permanence....	   10-13
      10.5.4  Reduction of Toxicicy, Mobility, or Volume Through Treatment	   10-13
      10.5.5  Short-term Effectiveness	   10-13
      10.5.6  Implementability	   10-13
      :05.~  Cost	   jo-14

10 6  Buried Gas Cylinders (Group 6)	'...'.   10-14

      '.'>.().;   < herall Protection of Human Health and the Environment	   ;o-!4
      '.o.d 2  ('omphance with ARARs	   HI-]4
                                       xxiv

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             10.6.3  Long-term Effectiveness and Permanence....	                          ln ,4
             10.6.4  Reduction of Toxicity, Mobility, or Volume Through Treatment	'""	   ;0-N
             10.6o  Short-term Effectiveness	                          ,,-, ,'1
             10.6.6  Impiementability		   'n"i-
             :o.6.7  cost	          	'	'	
       10.-   SFE-20 Hot Waste Tank System (Group 7).
                                                                                         :0-16
             10.-.1   Overall Protection of Human Health and the Environment...                 \Q i6
             10. ".2   Compliance with ARARs .................................................            ...... ""  ,() I6
             10.7.3   Long-term Effectiveness and Permanence ..............................     ................  !(j.16
             10.7.4   Reduction of Toxicity, Mobility, or Volume Through Treatment ....................  10-P
             10.7o   Short-term Effectiveness [[[          .......  I0_r
             10. T. 6   [mplementability .........                                  .........................  mi-*
             10-7-7   c»si ................................... ::                                           "'
       10.8  Modifying Criteria
            10..S.I  State Acceptance	                            ,()  ,y
            10.S.2  Community Acceptance	^""	   10_lx
 11.   SELECTED REMEDY	
      11.1   Descriptions of the Selected Remedies	„„

            11.1.1   Tank Farm Soils Interim Action (Group 1)....	          H.p
            '1.1.2  Soils Under Buildings and Structures (Group 2)	       	   n-14
             1.1.3   Other Surface Soils (Group 3)	       [[	   I!_15
             1.1.4  Perched Water (Group 4)	..J"."!...l".....	   11'.^
             1.1.5   Snake River Plain Aquifer Interim Action (Group 5)	.'."'"	   11-->5
             1. t .6   Buried Gas Cylinders (Group 6)	         [""_[	   11.?9
             1.1.7   SFE-20 Hot Waste Tank System (Group 7)	..1..".^...^......'.'.''......   -j I -30
             1.1 .S   Future Site Closures Under RCRA and D&D	            11.31
            1 1.1.9   Five-Year Reviews	
            1 ! 1.10 Post-Closure Care and Monitoring	^	
      1 1 .2  Estimated Costs of Selected Remedies

      1 1.3  Expected Outcome of Selected Remedy
12.   STATUTORY DETERMINATION [[[ . ...............................      p.,
      12.1  .Protection of Human Health and the Environment ........... . ...............................................   12-1
           121.1  "No Action" Sites	
           12 1.2  "No Further Action" Sites	
           1 2.'.  3   ! ank Farm Soils Interim Action Selected Remedy: Alternative 3—
                  Institutional Controls with Surface Water Controls	;...
           '. 2.:  4  Soils I 'nder Buildings or Structures Selected Remedy: Alternative .
                  2   Existing and Additional Institutional Controls and Containment...

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            12 !.6  Perched Water Selected Remedy: Alternative 2—Existing and
                   Additional Institutional Controls with Aquifer Recharge Control	  12-4
            12,1."  Snake River Plain Aquifer Interim Action Selected Remedy:
                   Alternative 2B—Institutional Controls with Monitoring and
                   Contingent Remediation	'.	    12-5
            12.1.8  Buried Gas Cylinders Selected Remedy:  Alternative 2—Removal.
                   Treatment and Disposal	    12-6
            12.1 .«>  SFE-20 Hot Waste Tank System Selected Remedy:  Alternative 4—
                   l:\isting Institutional Controls, Removing and Treating Tank Liquid
                   and Sludge Contents, and Removing the Tank and Associated
                   Structures	    12-"
            12 1.10 Sites Under Other Regulatory Authority	    12-"
            12.1,1 I  Five-Year Reviews	    12-S

      12.2  Compliance with ARARs	    12-9

            12.2.1   Tank Farm Soils Interim Action: Alternative 3—Institutional
                   Controls with Surface Water Control	   12-9
            12.2.2  Soils Under Buildings and Structures Selected Remedy: Alternative
                   2—Institutional Controls with Containment	   12-12
            12.2.3   Other Surface Soils Selected Remedy: Alternative 4A—Removal
                   and On-Site Disposal	   12-15
            12.2.4  Perched Water Selected Remedy: Alternative 2—Institutional
                   Controls with Aquifer Recharge Control	   12-23
           12.2.5   Snake  River Plain Aquifer Interim Action Selected Remedy:
                   Alternative 2B—Institutional Controls with Monitoring and
                   Contingent Remediation	   12-26
           12.2.6   Buried Gas Cylinders Selected Remedy:  Alternative 2—Removal,
                   Treatment and Disposal	   12-29
           12.2.7   SFE-20 Hot Waste Tank System Selected Remedy:  Alternative 4—
                   Removal. Treatment and Disposal	   12- 3

      12 3  Cost  liftectiveness	   12- 6

           12.3,1   Tank Farm Soils Interim Action (Group 1)	   12- 6
           12,3.2   Soils Under Buildings and Structures (Group 2)	   12- 6
           12.3.3   Other Surface Soils (Group 3)	   12- 6
           12.3.4  Perched Water (Group 4)	   12- ~
            12.3.5   Snake  River Plain Aquifer Interim Action (Group 5)	   12- "
            12.3.6  Buried Gas Cylinders (Group 6)	   12- ~
            12.3.7  SFE-20 Hot Waste Tanks System (Group 7)	   12- "

      124  Utilization Of Permanent Solution And Alternative Treatment Technology
            I'o The  Maximum Extent Practicable	   12-.^

      12.5  Preference  tor  Treatment as a Principal Element	  ;2-3l>

      12,d  h\e-Yea:- Review	12-4(1
13.   DOCl'\|[ NTAI'ION OF SIGNIFICANT CHANGES
                                             XXVI

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            Nev\ Sue*.
            13.1.1  CPP-96—Tank Farm Interstitial Soils	                            p]
            13.1.2  CPP-97—Tank Farm Soil Stockpiles	   	'	    ,][",
            13.1.3  CPP-98—Tank Farm Shonng Boxes                   	    p  ,
            13.1.4  CPP-99—Boxed Soils...	!."ZZ."Z.""Z"	    H-l

      13.2  Sites Included in Other Programs or Other OUs	                      1 ;.j

      13.3  Other Chanues	
                                                                                           .,
 14.   RES PONS IVF.NIESS SUMMARY [[[         14_,
 15.   REFERENCES
                                                                                           ,
Appendix A- Operable Unit 3-13 Responsiveness Summary-Public Comments and Responses on the
OU 3-13 Proposed Plan


Appendix B— Idaho National Engineering and Environmental Laboratory Administrative Record File
Index tor the C. omprehensive RI/FS Index for the Comprehensive RI/FS of Operable Unit 3-13 06.- 10 99


                                        FIGURES


1-1.    Location of the Idaho Nuclear Technology and Engineering Center ......... . ..........................     1-2

I -2.    Land ownership distribution in the vicinity of the INEEL and onsite areas open
       for permit grazing [[[                         , ,
                                                                                         _ >
 1-3.   Group 1: Tank Farm Soils numbered release sites	


 1-4.   Group 2: Soils Under Building and Structures numbered release sites	    1-6

 1-5.   Group 3: Other Surface Soils numbered release sites	           i _-

 1-6.   Group 4: Appropriate extent of the Perched Water at the INTEC (CPP-83)	     i-S

 1-7.   Group 5: Estimated extent of the 1-129 plume in the Snake River Plain Aquifer
       (CPP-23)	                                         . j  9


 1-8.   Group 6: Buried Gas Cylinders numbered release sites	               \.\<)


 1-9.   Group 7: SFE-20 Hot Waste Tank System numbered release sites	   1-11

 1-10.   Ol" 3-13 area of contamination (CPP-95)	,	;...,                    ;.;->


5-1.   100-year :".oodplam map at INTEC (USGS 1998)	    ;_T

3-2.   Cross section of the vadose zone at the INTEC illustrating the generalized

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 5-3    IN Il:C site conceptual model	   ...;                 -.<

 5-4    SRPA tritium plume 11995 data)	,	„	           5.-

 ->>    SRPA Sr-9() plume 11995 data)	       5-.x

 5-6    IN II,C ueli map showing wells where perched water has been observed	     5-h(,

 5-~.    Sr-90eoncentration in the upper perched groundwater (May-June 1995)	 	5-6"

 5-^    SRPA sampling wells location map	;	.,	       ,.    5.-2

 "-1     WAG 3 conceptual site model	       ~-L5

 ! i-l,   Schematic cross-section of the ICDF facility	,....,.	\\-\t,

 11-2.   Conceptual cross-section of the ICDF cap (typical Hanford Barrier)	; !-!"

 11-3.   Summan-of the AHP decision evaluation criteria for the preliminary ICDF sitinu
        evaluation	,	;   1 1-20

 11-4,   Proposed study area for the ICDF	   i l_2i

 11-5,   Location of replacement percolation ponds	„.'..  ] 1-24

 11-0.   SRPA contingent remediation decision flow chart	   1 l-2~




                                          TABLES


-i-l     WAG 3 CPP release sites and site grouping	    4-2

5-1.     Intimated volume of water recharging the perched water bodies at INTF-C	    5~i.

  2.    Summan' sampling results statistics for Tank Farm i Group 1) soil contaminants	    5-'.fi
 -
       Summary sampling results statistics for soil contaminants at Site CPP-89
       (excavated soil \\as placed into boxes that are currently stored in Site CPP-92).
••-•N
       Summary sampling results statistic* for soil contaminant at Site CPP-35	,	-   5,2"

       Summan -Numplmg results statistics for soil contaminants at Site CPP-36	   5-2'.

5-6.    Summary sampling results statistics for soil contaminants in CPP-91 soil borings	   5-24

*-"    Mimnun >amplmg results statistics for soil contaminants at Site CPP-01	   5-2(>

5-^    Sum:v.ar\ -amnimi: results statistics for radioniichdes at Sites CPP-04 05	   5-2^

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  5-9.    Summary sampling results statistics for soil contaminants at Site CPP-08/09	   5-29

  5-10.   Summary sampling results statistics for soil contaminants at Site CPP-10	   5.31;

  5-11.   Summary sampling results statistics for soil contaminants at Site CPP-11	   ^ \

  5-12.   Summary sampling results statistics for soil contaminants at Site CPP-03	      5.",4

 5-13.   Summar> sampling results statistics for soil contaminants at Site CPP-67	    5.35

 5-14.   Summan,- sampling results statistics for soil contaminants at Site CPP-34.	        5.39

 5-15.   Summary sampling results statistics for soil contaminants at Site CPP-13	    5-41

 5-16.   Summary- sampling results statistics for soil contaminants at Site CPP-19	    5-43

 5-17.   Summary sampling results statistics soil contaminants for Site CPP-93	    5-46

 5-18.   Summary sampling results statistics for soil contaminants at Site CPP-14	    5.49
 5-19.   Summary sampling results statistics for soil contaminants at Site CPP-37A
        Gravel Pit =?1	
                                                                                            5-55
5-20.   Summan,- sampling results statistics for soil contaminants at Site CPP-37B,
        Gravel Pit =*2	
5-21.   Summary sampling results statistics for soil contaminants at Site CPP-48	    5-59

5-22.   Summary statistics for soil contaminants at Site CPP-44	    S-62

5-23.   Summary- statistics for soil contaminants at Site CPP-55	               5-6"?

5-24.   Summan,- sampling results statistics for contaminants in the perched water wells
        (May-June 1995)	....                   5.64

5-25.   Activity of radionuclides discharged to the ICPP injection well (RWMIS
        Database)	                                       5-"l

5-26.   Summary sampling results statistics for contaminants in the SRPA Wells (Mav-
        June 1995)	           '              >.T-

5-27.   Summan.- analytical results for the SFE-20 hot waste tank system	:	    5-~9

7-1.     Results of the site and chemical screening processes	     "-2

7-2.     Summary of the identified groundwater COPCs	    "-12

7-3.     rOPl" exposure-point concentrations in air	    ^-13
                                              xxix

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   -4.
        Potentially complete exposure pathways quantitatively evaluated for WAG 3 and
        associated soil depths by exposure route	'....
 7-5.    Cancer risks due to COPC concentrations in air
 7-6.    Noncarcmogenic hazards due to COPC concentrations in air	     7.->0
 >•-1.     Summary of RI BRA conclusions and recommendations for groups and sites of
         concern.	
               • 	~""-"->-"<-"'^ *»">j n-^umiiiciiuiiiiuris ior groups ana sites ot
        iMltli'i'rn
                                                                      	-	-	   7-21


7-8.    Human health baseline risk assessment summary for WAG 3 sites of concern...	     -.26


7-9.    Screening of liquid effluent concentrations at the Sewage Treatment Plant
        CPP-65	                  '                 _,.


7-10.    Screening of nonradionuclide liquid effluent concentrations at CPP-67,
        Percolation Ponds	;...                                  '                    -, ,,,
 7-11.   Threatened and endangered species, special species of concern, and sensitive
        species that may be found on the INEEL.* [[[
7-12.   Results of additional site/contaminant evaluation and screening ...... . .............................      7.34


7-13.   Sites and COCs which may present an unacceptable risk to ecological receptors. .-. .............   7.35


8-1.    Soil risk-based remediation goals ...............................................                            c ,


8-2.    SRPA remediation goals [[[                             ,-. ,


10-1.   Summary of comparative analyses for the Tank Farm Soils Intenm Action,
        Group! ..............................                                         '                 ,r
            '             [[[ . ................ ..   iO-.i


10-2.   Summary of comparative analyses for the Soils Under Buildings and Structures

        Groi'P- [[[ '. ......... ......   io-5


10-3.   Summary of comparative analyses for the Other Surface Soils, Group 3 .............................   10-7


10-4.   Summary of comparative analyses for the Perched Water. Group 4 ........ '. .....................        10-9


10-5.   Summary of comparative analyses for the Snake River Plain Aquifer Interim
        Action. Group 5 [[[                            |()_, .


10-6.   Summary of comparative analyses for the Buried Gas Cylinders. Group 6 .......................... , 10- if


10-7.   Sur.m.ir;. ofcomparative analyses for the SFE-20 Tank System. Group 7 ..........................  lu-r



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  M-3.   Estimated Capua! .and Operates Costs (100 years) for Soils L'nder Building
         ana Structures Selected Alternative 2. Costs are ,n 1997 dollars except as Sd	  1 I -34


  11 -4.   Estimated Capual and Operations Costs (100 years) for Other Surface Soils
         Selected Alternate 4A. Costs are ,n 1997 dollars except as noted.	        M _^-
            ™.,( "P',tal and °Pe7l°nS,C°StS (100 years) for Perched Water Selected
            -mativ e 2.  ( osts are in 1997 dollars except as noted                                , ,  ,A
                                                r          	   ll-j>6

  11 -6.  Esumated Capual and Operations Costs (100 years) for Snake River Plain
        Aquitcr Intenm Action Selected Alternative 2B.  Costs are in 1997 dollars except
        as noted	                                                         "
                       	   11-3-

  11-7.  Estimated Capual and Operations Costs (100 years) for Buned Gas Cylinder  '
        Sues Selected Alternative 2. Costs are in 1997 dollars except as noted	   ;, _^


 11-8.   hsnmated Capual and Operations Costs (100 years) for SFE-20 Hot Waste Tank
        System Selected Alternative 4. Costs are in 1997 dollars except as noted	   11.39


 12-1.   Comphance wuh ARARs for Group 1-Tank Farm Soils Intenm Action Selected
        Kemedv	
                      	'	-	  12-10

 12-2.   Comphance wuh ARARs for Group 2-Soils under Bu.ldings and Structures
        Selected Remedv	
                            	  12-13

 12-3.   Comphance wuh ARARs for GroupS-Other Surface Soils Selected Remedy	  i2-16

 12-4.   Comphance wuh ARARs for Group 4—Perched Water Selected Remedy	  i2-24


 12-5.   Comphance wuh ARARs for Group 5-Snake River Plain Aquifer Intenm
        Action Selected Remedv	
12-6.   Comphance wuh ARARs for Group 6-Buned Gas Cylinders Selected Remedy.


12-7.   < omphanee « uh ARARs for Group 7—SFE-20 Hot Waste Tank System
       Selected Remedv	
                           	-.	  12-34

12-8.   Comparison of costsj of alternatives" for WAG 3	                   , -, V)
                                            XXXI

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ll\\\

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                            ACRONYMS

  A LARA       as lou a> reasonably achie\able

  AOC          area of contamination

  ARAR         applicable or relexant and appropriate requirement

  bgs            belosv ground surface

  BRA           Baseline Risk Assessment

  CERCLA      Comprehensive En\ ironmental Response, Compensation, and
               Liability Act

  BLM          U.S. Bureau of Land Management

 CAB          Citizens Adx isory Board

 CFR          Code of Federal Regulations

 COC          contaminant of concern

 COCA         Consent Order and Compliance Agreement

 COPC         contaminant of potential concern

 cpm           counts per minute

..CSV!          conceptual site model

 COPC         contaminant  of potential concern

 D&D          decontamination and dismantlement

 DEQ          Division of Environmental Quality

 DOE          U.S. Department of Energy

 DOE-ID        U.S. Department of Energy Idaho Operations Office

 F.BR           Experimental Breeder Reactor

 I'BSL          ecologicaih based  screening le\el

 F.E- C'A         engineering evaluation cost analysis

 HIS            I:n% ironmental Impact Statement

 L-PA           I ,S. Fin ironmental ProtectionAucnc\
                                \\\IH

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 ERA           ecological risk assessment

 ESRP          Eastern Snake Riser Plain

 FFA CO       Federal Facility Agreement Consent Order

 FD            facilities disposition

 FR            Federal Register

 FS             feasibility study

 FSS            feasibility study supplement

 GSA          General Services Administration

 HEPA         high-efficiency paniculate air

 HEU          Highly Enriched Uranium

 HHRA         human health risk assessment

 HI             hazard index

 H-I            a designation for a sedimentary interbed located between the H
               and I basalt layers.

 HLW          high-level waste

 HLLW         high-level liquid waste

 HQ            hazard quotient

 HWMA        Hazardous Waste Management Act

 ICDF          INEEL CERCLA Disposal Facility

 1CPP           Idaho Chemical Proce>smg Plant

 1DAP.A         Idaho Administrative Procedure* Act

 IDH W         Idaho Department of Health and Welfare

 IDW           inve.itigation derived \\aste

INEEL         Idaho National Engineering and Environmental Laboratory

INThC         Idaho Nuclear Technolog> and Engineering Center

LDR           Land Dispo-al  Re.-tnctionx

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  LITCO




  LLW




  LMITCO




  \!CL




  MCP




  NCP




  NEPA




 NESHAPS




 NPL




 NSR




 NWCF




 O&M




 OU




 OSWER




 PCB




 PEW




 PPE




 R&A




 RAO




 RCRA




 RD RA




 RID




Rl




Rl BRA




Ron
  Lockheed Idaho Technology Companv. Inc.




  low-lev el waste




  Lockheed Manm Idaho Technologies Company




  maximum containment level




  Management Control Procedure




  National Contingency Plan




  National Environmental Policy Act




 National Emission Standards for Hazardous Air Pollutants




 National Priorities List




 no surface risks




 New Vv'aste Calcining Facility




 operating and maintenance




 operable unit




 Office of Solid Waste and  Emergency Response




 polychlorinated biphenyl




 Process  Equipment Waste




 personal protective equipment




 relevant  and appropriate




 remedial action objectives




 Resource Conservation and Recovery Act




 remedial design remedial action




 reference dose




remedial investigation




remedial investigation baseline risk assessment




Record of Decision
                                 \\\v

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 RWMC       Radioactive Waste Management Complex




 SARA         Superfund Amendment Reauthon/ation Act




 SC'M          Mte conceptual model




 SF            slope factor




 SLERA        >creening level ecological risk assessment




 SNF           spent nuclear fuel




 SRPA         Snake River Plain Aquifer




 SSST          storage, stagings, sizing, and treatment




 STP           sewage treatment plant




 SVOC         semi-volatile organic compound




 S\VP           service waste percolation pond




 TBC           to-be-considered




 TCLP          toxicity characteristic leaching procedure




 T E            threatened and. or endangered




TRA           Test Reactor Area




TRU           transuranic




TRV           toxicity reference value




TSCA          Toxic Substances Control Act




TSDF          treatment, storage, and disposal facility




TU            temporary unit




 LCL           upper confidence level




 I RF.P          L'tility Replacement and Expansion Project




 I TL           upper tolerance level




 VOC           volatile organic compound




 \V-\cJ          w.iste area group
                                 \\\\ i

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WCF          Waste Calcining Facility




^ERF         Waste Experimental Reduction Facility




\VINCO        Westinghou.se Idaho N'uclear Company. Inc.




WIPP          Waste Isolation Pilot Plant




WWP          vVarm Waste Pond
                                \\\\ i

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\\\\ 111

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                          Final Record of Decision
      Idaho Nuclear Technology and  Engineering Center
                               Operable Unit 3-13
                             1.    DECISION SUMMARY
  NOTE: The Idaho \uclear Technology and Engineering Center f/.VTEO urn formerly known as the
  Idaho Chemical Processmg Plan, (ICPP,. The facility name Was changed in 199ft to more accurately
  reflect (he operational mission. The previously published supporting documents use the ICPP
  nomenclature.
                  1.1    Site Name, Location,  and Description

      The Idaho National Engineering and Environmental Laboratory (INEEL) is a government facilitv
 managed by the U.S. Department of Energy (DOE), located 51.5 km (32 mi) west ofldaho Falls Idaho
 and occup.es 2,305 km- (890 mr) of the northeastern portion of the Eastern Snake River Plain (ESRP)'
 ,h  IVPC?     uar Technol°gy and Engineering Center , INTEC) ,s located in the south-central portion of
 the INEEL. as shown in Figure 1-1.

      Facilities at the INEEL are primarily dedicated to nuclear research, development and waste
 management. Surrounding areas are for multipurpose use and are managed by the U.S Bureau of Land
 Management (BLM). The developed area within the INEEL is surrounded by a 1 ^95-km: (500-mi:>
 buffer zone used for cattle and  sheep grazing.  Communities nearest to the INTEC are Atomic City
 (south), Arco (west), Butte City (west), Howe (northwest). Mud Lake (northeast) and Terreton  '
 (northeast). In the count.es surrounding the INEEL. approximatelv 45% is  agricultural land. 45% is open
 land, and I0>-o is urban. Sheep, cattle,  hogs, poultry, and dairy cattle are produced: and potatoes  suaar
 beets, wheat, barley, oats, forage, and seed crops are cultivated.  Private individuals or the U S
 Government own most of the land surrounding the INEEL. as shoun in Figure 1-2.

      Public access to the  INEEL.is strictly controlled by  fences and security personnel  State
 Highways _2. 28. and 33 cross  the northeastern portion of the  INEEL approximately 32.2 km POm.)
 v ™'NTfC' a"d LLS- "'ghwa.vs ^O and 26 cross the southern port.on approximately 8 km (5 mi, from
 INTEC.  A total ot  145 km (90  mi) of paved highways pass through the  INEEL and are used bv the
 general public.                                          "                      -

      To better manage environmental investigations, the INEEL ,s divided into 10 waste area  -roups
 (WAGs). Identified contaminant release sites in each WAG were grouped into operable units (6l\) to
 expedite the investigations  and any required remedial actions.  The INTEC is designated as WAG ^
 which was subdivided mto  13 OUs that were investigated for contaminant releases to environmental
 pathways.  \V .thin these 13 OUs. 101 release sites were identified. Thus Record of Deasion (ROD)
 applies to xi of the  101 sites, which, on the basis of the comprehensive remedial investigation
(RI )• teasibil.tv studv (FS) for WAG 3 (OU 3-13). were identified as posin* a potential risk or threat to
 human health and or the environment. Of the 101  sites. 4.0 are recommended for "No Action" or "No
 Further Action.'  The MX remaining sites (CPP-65. CPP-3X. CPP-fih. CPP-ftl. CPP-S1  and CPP-S^ u.|l
be managed under other Ol'x \V..\Gs. or INEEL reuulatorv programs.

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 0)

 3
 O)
iZ

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 f'l^P~   !v~s^ Eoe'~~-V^.^- "-"'•: ;.:"••,•


Figure 1-2. [.and ounership distnhuti.on in the % iciniu ot'the INHHL and onsite areas open for permit

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        The 55 release sites \\ ith identified risks greater than I  < HP or that pose a threat to human health
  and or the environment require remedial aetion to mitigate these risks or threats.  The 55 sites were
  divided into seven groups based on Mmilar media, contaminants of concern iCOCs). accessibility, or
  geographic proximity. The >e\. en groups are:

        •     Group 1: Tank Farm Soils

        •     Group 2: Soils Under Buildings and Structures

        •     Group 3: Other Surface Soils

        •     Group 4: Perched Water

       •     Group 5:  Snake River Plain Aquifer

       •     Group 6:  Buried Gas Cylinders

       •     Group 7:  SFE-20 Hot Waste Tank Svstem.

       The locations of these groups are shown in Figures 1-3 through  1-9.

       During the RI FS and subsequent remedy development, data gaps were identified. In some cases
 the missing data were important enough to prevent selection of final remedies. Because delays in
 restoration were undesirable. OU 3-14 was created.  Where available information was insufficient to
 select a final remedy in OU 3-13. interim actions were developed for implementation in the OU 3-13
 ROD with the final remedy relegated to OU 3-14. Specifically, Group 1, Tank Farm Soils, and Group <
 the Snake River Plain Aquifer (SRPA). are interim actions in this ROD and are included in OU 3-14 for
 final remedy selection.

      To allow flexibility in managing the remediation of the various groups discussed above, an
 OL 3-13 area of contamination (AOC) was designated as shown in Figure 1-10. An AOC is an area of
 contiguous surface contamination that can be used for consolidation of remediation wastes without
 triggering Land Disposal Resolutions and  other Resource Conservation and Recovery Act (RCRA)
 requirements.

      Action sites and cleanup levels are based on a 1 * \ O'4 carcinogenic risk. For Cs-137,
contaminated soils will be cleaned up to below 23 pCi g. for the future residential use scenario. The
background Cs-137 activity is approximately 1 pCi g. which is equivalent to a lk.^ The acceptable risk for cleanup to future residential standards for Cs-137 is 1 x 1I)"1 by the \ ear
2095. "No Further Action" sites are sites that represent a threat if land use was residential, but do not
represent a threat under an industrial land use scenario.

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             =J
Portion of CPP-26
having no further
action recommendation.
                                                                    26
                                                      ;u
                                              INTEC Main Stack
Figure 1-3. Group I: Tank Farm Soils numbered release Mies.

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                 £f
                          1.1   Jn11
                                       • 
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     INTEC  Main Stack   Q
     iReferencel
            48
   Note:
   Sj'.es 98 and 99 consist of waste
   siorage ooxes
   Re!ocat-on o( tnese soxes adjacent
   'o site 92 s penamg
                                                                                    CT99 OO59
                                                                                    Rev 1
Figure 1-5, Group 3: Other Surface Soils numbered release

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 c

       Mt.«OU-i

                                                                                       0..

                                                                                                                       CcnoljlKfl ISintli TjnL
                                                                                                                       F-m U^TtC Bou.id.ii)
                                           0    MO   400   top    101  1000 f
Figure 1-6.
\ppro*muic sxcent of ihe Perchtd Water ai the INTEC (CPP-83).

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                         Iodine-129 concentrations  (pCi/L)
                                                                TRA
           Area covered by map
                                                                                CFA
     RWMC
                                          2000   J(XX)  MXX) SIKH) Pea
                                                            2 VMe,
Nulcs:
I The MCI. for I- 129 is I pCj/i..

2. The- Jala used 10 produce ihc.sc
contours came directly imm ihe
Jucumcni DOU/ID- 221 IS 'Indine-
m the Snukc River Plain Aquilcr
nl and ncarlhi: IJahu Naliunul
lingmixnng l_irKirjniry. Idaho
iWO-MI" (U.S. Ucological Survey
Walcr- Resources Invcsli-atiou
Rcpon 44-40531 pg.')- I.V
                                                                             I- 12l)CnnccniniiK)n m pCi/L
Figure 1-7.  Group 5: Estimated extent of the 1-129 plume m the Snake River Plam Aquifer (CPP-231


                                                1-9

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                                                                  W
                                                  INTEC Main  Stack
                                                 (Reference)
                                                                           94
                                                               50C   >:CO Fee:
                                                                    53C Vie:e-
Figure 1-8. Group 6: Buried Gas Cylinders numbered release sites.

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                                             INTEC
                                             Main  Stack
                                             (Reference)
                                      D  r~]  -g
                                                       Group  7
                                                  69. SFE-20
                                                        Hot Waste
                                         \  648   ^  Tank System
                                                        0:9900-10
Figure 1-9. Group 7: SFE-20 Hot AVaste Tank Sv.tem numbered release sites.

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                                                                                 .5
                                                     CFA
Figure 1-10.  Ol' ."-I? area ofconiaiiiination
                                              i-i:

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           2.   SITE HISTORY AND ENFORCEMENT ACTIVITIES
Nation!"
(NCR). The EPA issued a
Register [FR] 29820)  As a result  the
EnvironmentI, Response. C^
and Consent Order (FFA.-CO) and associated
Office [DOE-IDJ 1991 ) uw d^lo^ to
                                                 A>
                                 «  ed
                                                              *" «re tranfe™d „ la™
Se,s). Calcinin. achie" ^, an °i -l ° o one
nuclear fuel
                                           * "*" "'^ '° lhe """">«"™  The
                                               r""^ '" 'hiCk COnCreK vau"s 
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       Following procedures identified in the action plan, preliminary scoping Track I  and or Track 2
 investigations were completed for all sites except the  10 "No Action" sites and 4 ne\\ sites. CPP-96. -9".
 -9S. and -99, recently added to the FFA CO. A Track 1  investigation is a site evaluation using existing
 data to qualitatively determine if an actual or potential threat to human health or the environment exists.
 Track I investigations include very limited or no field characterization. A Track 2 investigation is a more
 detailed evaluation in which existing data and additional field characterization data are used to determine
 release site risks. Track 1  and Track 2 investigation identify if sufficient information exists to determine
• \\hether an unacceptable risk exists,  and recommend steps to either: (a) conduct "No Action" or "No
 Further Action." (b) conduct an interim action or removal action, or (c) conduct additional investigation
 under the Rl FS process.

       Site CPP-95. the Windblown Area for INTEC. was evaluated in the OU 10-06 RLFS. which
 became an engineering evaluation/cost analysis (EE.CA) for a removal action (Lockheed Idaho
 Technologies Company [L1TCO] 1995a)

       Four new sites were recently added to OU 3-13. Site CPP-96. is considered part of the Group 1
 Tank Farm soils and will be addressed by both the Tank Farm Interim Action under OU 3-13 and the
 Final Action selected under OU 3-14. Sites CPP-97. CPP-98, and CPP-99 will be remediated under the
 selected remedy for OU 3-13 Group  3. The Agencies have determined that six other sites. CPP-38.
 CPP-61. CPP-65. CPP-66. CPP-81, and CPP-82 are more appropriately dispositioned under other OUs or
 regulatory programs other than CERCLA.  Site CPP-38 will be administered and remediated, if
 necessary, under the IN'EEL Asbestos Abatement Program. Site CPP-65 will be handled under  the Idaho
 Wastevvater Land Application Rules. Site CPP-66 may pose an ecological risk and was transferred to
 OU 10-04 for further evaluation and  remedy selection, if necessary.

       In 1997.  a remedial investigation/baseline risk assessment (Rl/BRA) (DOE-ID 1997b) was
 conducted to determine the comprehensive risks posed by past releases at WAG 3.  That document
 addressed all known release sites including those previously subject to Track  1 or Track 2 investigations.
 The final  RI-'BRA was issued in November 1997. Concurrently, an FS (DOE-ID 1997a) was written to
 determine and evaluate feasible remedial alternatives. During preparation of the FS, the need for
 additional information was identified. Because of the cost of the remedies recommended at the  INTEC.
 review by the National Remedy Review Board was required. The Board recommended modifications to
 the Feasibility Study concerning the Snake River Plain Aquifer alternatives and the cost estimates.  To
 support the board's recommendations, an FS supplement was written and published in  1998
 (DOE-ID 1998a).

       Four CERCLA removal actions have been completed to date at WAG 3. The contents of a buried
 acid pipeline were removed during the summer of 1993 at  Site CPP-81. The pipe was cleaned but was
 left in place.  A second removal action was performed in the summer of 1993 on Calcine Bin Set 3 to
 prevent precipitation runoff from migrating through soil that was previously contaminated by a  calcine
 spill. The contaminated soil was removed and disposed. A third removal  action, completed in the  fall of
 1993. consisted of removing sludge from the Horizontal Filter Basin (CPP-740) and a dry well
 (CPP-301). The OU 3-13  Rl BRA (DOE-ID 1997b) \%as performed after these three removal actions, and
 therefore, the source removal was accounted for in the BRA. The fourth removal action, completed in the
 fall of I99X. consisted of consolidating four Cs-137 contaminated soil stockpiles from  INTEC into the
 Test Reactor Area (TRA) Warm Waste Pond (WWP) 195" Cell.  The stockpiles identified as Acid
 Rccvele. New Control Room. Electrical Utility System Upgrade, and Irradiated Fuel Storage Facility, all
 contained low activity radionuclide-contaminated soil.

       Four polvchlonnatcd hiphenvl (PC'B) site,-, had undergone removal actions prior to the signing of
 the FFA CO, These sites CPP-41). -5n. -51. and -M comprised Ol  3-01.  The sites were evaluated in .1

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                               , I*1"    ^^ InC' [WINC01 1992a> and were a" ^ermined to
   heen    hi <       J".   *£" °f available dean UP ™* sampling information,  in this ROD
   the Agency have determined that additional information is needed to make a final decision for site   '
   CPP-61 and have transferred it to OU 3-14 for further evaluation.

                    2.3    Other Regulatory Programs at INTEC

       . Inl992- the State of Idaho and DOE-ID entered into a Consent Order to resolve alleged violations
  'X^W  ^P'*™' » ' "0 <»• the EPA.  The Consent Order ^modlSTn
   hat bv June 30  "oo? rh  nor"   ni°dlficatlon-J which '"percedes the first modification, stipulated
  that bv June 30. 2003. the DOE must cease use of high-level waste Tanks WM-182 through WM-186-
  ceasing use means emptying the tanks to the heels. However, Tank WM- 1 85 could be used as emergency

  Scon e^f1" ^r mil ^^ Wlume '" °ther tanks became available' <" ^ ^
  second Consent Order mod.ficat.on st.pulated that on or before December 31, 2012  the DOE must
  nnTvv-u"! LC^ uS£ °f thC.SiX °ther tankS kn°Wn HS WM- ' 80> WM- 1 8 1 , WM- 1 87. WM- 1 88  WM- 1 89
  first ank"    3     e"" aSS°Ciated VaUltS' A d°SUre Pla" mUSt bC SUbmitted by December 3 ' ' 200°  for the'
  and trealm^at1 IXTFar ^rl^ ^ DOE "^ * se«lement ag^men. that would guide waste storage
  and treatment at INTEC. The agreement ,s commonly known as the Batt Agreement. Amone many other
  requirements, the Batt Agreement stipulated the following:                             S     *

             The DOE shall complete the process of calcining all remaining nonsodium-bearing HLLW
             currently located at INEEL by June 30, 1998.

       •     The DOE shall treat all high level waste (HLW) currently at the INEEL so that it is ready for
             disposal outside of Idaho by a target date of 2035.

            The DOE shall commence negotiating a plan and schedule with the State of Idaho for
            calcined waste treatment (into a form suitable for transport to a permanent repository- or
            interim storage) by December 31, 1999.                                      *     '

      •     The DOE shall commence calcination of sodium-bearing waste by June 1, 2001.

      •     The DOE shall complete calcination of sodium-bearing waste by December 3 1, 2012.

            The DOE shall submit to the State of Idaho an application for a RCRA Part-B permit bv
            December 1. 201 2 for the treatment of calcined waste at INEEL into a form suitable for
            transport to a permanent repository or interim storage.
                    onnn        the HLLW evaPorator as to reduce Tank Farm volumes bv no less
            than 1,249.000 L (330.000 gal, by December 31. 1997. After December 31  1997 efforts
            u,!l continue to reduce the remaining volume of the Tank Farm liquid waste bv operation of
            the HLLvV evaporator.                                               '
a. Loiter from ,ho State ofldahoN Hnan R. M,,,,M>n I0 Don Ra>ch. DOlMn. on Jan,- 12. |«MK  Attached uas the "Second
Modmcunon ,o C o^n, Order." .duho Code 30.4413. ,\o .uhjca hne or mimhtfr ucrc provlt],d t"Seu«*>   ^"^

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        •     The DOE agrees to treat spent fuel. HLW. and transuramc (TRU) wastes in Idaho requiring
             treatment so as to permit ultimate disposal outside the State of Idaho.

        Several RCRA-regulated units operate at the 1 NT-EC. Currently, the INTEC Process Equipment
 Wa.Me (PEW)  Evaporators. Tank Farm. N\VCF. and Calcine Storage Facility operate under RCRA
 interim status. A RCRA Part-B permit application will be submitted to the Idaho Division of
 Environmental Quality (DEQ) at a future date. The Percolation Ponds 1 and 2 vyere initially under the
 RCRA interim status permit but were RCRA-closed in 1995. The ponds are currently operated under a
 wastevvater land application permit issued by the State of Idaho.  The DEQ has agreed that these ponds
 have met clean closure requirements. The radionuclide contaminants in the pond^sediments and potential
 subsurface contamination were evaluated in the RI. BRA as Site CPP-67 in OU 3-13.J

       The NWCF is a facility that converts radioactive liquid waste solutions into a granular solid calcine
 material.  Liquid  wastes are evaporated in a fluidized bed allowing the dissolved metals and fission
 products to be  converted to salts and oxides which are subsequently stored in the calcine bin-sets.  The
 NWCF operates under a Permit to Construct issued by the State of Idaho and Federal National Emission
 Standards for Hazardous Air Pollutants (NESHAPs) administered by EPA and the state of Idaho.
 Although the EPA has proposed to revise air emission and operational requirements for hazardous waste
 incinerators (EPA 1997). those regulations have not yet been promulgated.

       By June  1. 2000. the DOE must also decide if the NWCF will  be closed or continue to be operated.
 If the DOE chooses to close the NWCF, a closure plan  must be submitted by June 1 +  180 days. If DOE
 chooses to continue NWCF operations. DOE must submit a schedule for submission of a permit
 application by July I, 2000.

      The PEW evaporator system separates liquid radioactive waste into  two fractions; one fraction is
 currently directed to the HLLW Tank Farm and the other fraction is directed to the Liquid Effluent
 Treatment and  Disposal Facility. The PEW evaporator is included in the RCRA interim status document
 (DOE-ID 1997c). which includes a closure and post-closure plan that defines the closure and post-closure
 requirements and performance standards.

      The WCF was taken out of service in 1981 after  18 years of operation. The WCF contains six units
 that are included in the 1NEEL RCRA Part-A permit application and are subject to the closure
 requirements for interim status treatment, storage, and disposal facilities (TSDFs). These units include
 four storage vessels, the WCF evaporator, and the high-efficiency paniculate air (HEPA) filter storage
 area. Surface and subsurface releases of radionuclide-contaminated solutions from the  WCF are
 addressed in the comprehensive OU 3-13 FS (DOE-ID  1997a), the Proposed Plan (DOE-ID 1998b). and
 this ROD. The  WCF is not included in the FFA CO and therefore, the disposition of the six RCRA units
and ancillary equipment will be performed in accordance with the WCF RCRA closure plan, which calls
 for closure of the WCF as a landfill with a RCRA-compliant cap.  The WCF RCRA closure plan was
approved in August 1997.  The closure consists of Hushing the lines,  isolating the structure, and uroutinu
the six RCRA units in place, followed by collapsing the aboveground structures into the WCF lower
 level?; and filling voids with concrete to act as a structural support for the cap.  A concrete cap extending
approximately 1.5 m (5 ft) beyond the WCF perimeter has been constructed.  Final closure construction"^
expected to be completed by September 1999.
11 I.elterliom the Stole ut'ld.iho'-.On.ilk-1) Green to Dun \V Ka-.ch. [)()i.-II>. on l-'ehruar> 13.1W5. Attached to the letter
*\.is the "Sloie nl Idaho Permit to Construct .in Air Pollution I'miumi: s.turee."-Pomw Number  ( oiiMriM Amendment Re^ueii i
                                              2-4

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  -^^
 nonsodmm-beanng waste has been processed.                                    rcspecmeiv  All

                        'mpaCtS °f disP°sition of the HLLW and calcined solids stored at INTEC will
the Waho HL\& FD E'S at'VeS ^   P°Siti°n °f facilities associated with HLW ™» also be included m

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                 3.
                      HIGHLIGHTS OF COMMUNITY PARTICIPATION
          In accordance with CERCLA $ I I3(k)P »RW_
    information and participation in the Rl FS and I  '  *      *      Series o/"°PP°rtunities tor public
    1994 through February' 999. The! p^fu ^  o ZHT "T ^^ WaS provid4d *™ OcTber
     k.ck-otf fact sheet, uh.ch briefly discussed the Sat of h  R!^" *"" """'^ mpUt mdlided a
    newsletter articles fa publication ofthe IVEEL ^Fnv         ^ D  ' numerous /A'^ *Wc>r
    Guide supplemental updates. Hve -^ tt hee  Xoo  ^T^0" '^^ '^Citizens'
    -nterested groups, and public meetings.                 °P°bed P'3n' bnetm8s an<* Presentations to


    individual? £ genial pubUctld
    list  Included in the fact sheet was a posp
    from tour members ofthe public The comments w,
   project w0rk plan. This fac't sheet als^ offered" chnica
   comprehensive investigation.  It was the initial
   how the investigation wou,d be condu  ed   Xo
   held later in the investigation process.
                                                     *'
                                                               R'/FS W3S S6nt tO about ^-200
                                                               C°mmUmty RelatIOns "™ -ailin,
                                                         ?0mment torm- Comments were received
                                                                   *"11 > the PreP-ation of the
                                                                   Interested in '»* WAG 3
                                                                      involved in d««™»m«
                                                                at the time- b"' briefings were"
                                  aa
  representatives from the DOE and the IXEEL dossed h'    B,°1Se'  Dunng these
  articles were generated as a result of these bdefin,s and  7'°^ ^ anSWered ^uestions- Ne
  The investigation was also highlighted in twoSes of a naZ 7* ^"^ ** the ^claled p
  and on an Idaho Falls radio talk show.                "atl°nal env'ronmental restoration newsletter
                                                                                    Cltizens
                and the second in Septembe  998  The  P      / Shert "^ dl"strib«ted in
 appraised of developments during the^l FS  to mdude  LSe  f^ d°CUmemS WM l°
 «he appro.xmiate dates when public meetmgs wo Id tat p ace TL  f TSt'gation' and to ann<^<*
 bnehngs to those interested in the WAG 3 investigation                   ^ a'S° °ffered technica'


                                                               <» b,monthly issues ofthe
                                                        ''f appeared in four ''«ues of a
                                                      suPPieme"t to the INEEL Reporter} in



recommendaiions to DOE. EPA. and the State of dah'/Pg ^ CItJZenS °ndaho- *«o make
early 1995. 1996. 1997. and 1998.
     , and
                          :r
                     national pub,,,a,io,K

                                          the Pocutdlo and Moscow areas the week of
                                          : Pubhc meetings and to see if a briefing uas desired.

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 A.i a result, public meetings were held with the Shoshone-Bannock tribes the morning of November 16.
 IWS.  Meetings were also held with stakeholder groups in Idaho Falls on the afternoon of November 16.
 Tw in Falls on November 17, Boise on November I S. and Moscow on November 19. A meeting was held
 with University of"Idaho students in Moscow on November 19. 199X.

      During the week of October 18, 1998, DOE-ID issued a news release to more than 100 media
 contacts concerning the beginning of a 30-day public comment period pertaining to the WAG 3 Proposed
 Plan.  Although the period began on October 23. 1998. it was automatically extended by the Agencies for
 an additional 30 da>s in anticipation of a large amount of public interest.  The initial comment period
 ended on December 22. 1998, but at the request of United States Congresswoman Chenoweth (Idaho
 District -1), the comment period was extended until February 12.  1999.  As a result of several news
 releases, a short note was placed in community calendar sections of newspapers and in public service
 announcements on radio stations. This note gave notice to the public that supportive WAG 3
 investigation documents were available in the Administrative Record of the INEEL Information
 Repositories located in the DOE Public Reading Room at the INEEL Technical Library in Idaho Falls, the
 Albertson Library on the campus of Boise State University, and the University of Idaho Library in
 Moscow.

      Display advertisements announcing the availability of the Proposed Plan, the locations of public
 meetings, and the comment period extension, appeared in six regional newspapers during the week of
 October 18,  1998 located in  Idaho Falls. Boise. Moscow. Fort Hall. Pocatello. and Twin Falls. Large
display advertisements appeared in the following newspapers:  Post Register (Idaho Falls), Sho-Ban News
(Fort Hall), Idaho State Journal (Pocatello), Times News (Twin Falls). Idaho Statesman (Boise), and
Daily News (Moscow).  A follow-up advertisement ran in newspapers approximately 2 days before the
public meetings in Idaho Falls, Twin Falls. Boise, and Moscow. Additionally, a post card was mailed to
about 6,200 citizens on the INEEL mailing list informing them of the availability of the Proposed Plan,
comment period, and upcoming public meetings. A note was also sent to all INEEL employees informing
them of the same.

      Copies of the Proposed Plan were mailed to about 700 members of the public on the INEEL
Community Relations Plan mailing list the week of October 18. 1998, urging citizens to comment on the
plan and to attend public meetings. Public meetings were held in Idaho Falls on  November 16, Twin
Falls on November 17. Boise on November 18. and Moscow on November 19, 1998. Prior to public
meetings in each location, an availability session took place from 4 to 7 p.m. The public meetings began
at 7 p.m.

      For the general public, participation in the decision-making process included receiving and
reviewing the Proposed Plan, attending the availability sessions before the public meetings to informally
discuss the issues, with the Agencies remedial  project managers and INEEL environmental restoration
technical personnel, and submitting verbal and written comments to the Agencies during the public
comment period.

      Written comment forms (including a postage-paid business-reply form) were available to those
attending the public meetings. The forms were used to submit written comments either at the meeting or
by mail. The reverse side of the meeting agenda contained a form for the public to use in evaluating the
 effectiveness of the meetings. A court reporter was present at each meeting to record transcripts of
 UitCUNSions and public comments. The meeting transcripts were placed in the Administrative Record for
 WAG 3 OL  3-13 m three INEEL  Information  Repositories. For those who could not attend the public
 meetings, but wanted to make formal written comment-., a postage-paid written comment form was
 attached to the Proponed Plan.

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                pd     ^                         "" »*"* ^""^ A"
                 ,n thls ROD are
                     vea c
receive are also     d d „ A               h  A'^   Pl""'C mMIi"gS '"" *" Wri"e"
                                                         as pan of this ROD •        -


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                  4.   SCOPE AND ROLE OF OPERABLE UNITS
                                  AND RESPONSE ACTIONS

        This comprehensive ROD addresses the known contaminant releases at WAG 3 resulting from
  SNF reprocessing storage and research, and ancillary activities except for those releases assoaated with
  the Tank Farm.  Closure of RCRA-regulated units and impacts associated with the closed RCRA units
  also ,s not included in this ROD. However, post-closure monitoring of closed units, such as the WCF
  and past releases of hazardous substances from RCRA-regulated units are addressed. Similarly closure
  or decontamination  and dismantlement (D&D) of HLW units is not included, but past releases of
  hazardous substances from these units are addressed.

       The  1NTEC is one of 10 WAGs at the INEEL. Each WAG contains a number of contaminant
  release sues grouped into OUs based on similarity of waste streams and projected remedial actions
  Fourteen OUs have been defined for WAG 3.< OU 3-01 through OU 3-13 are addressed in this ROD
  UL 3-14 will address the final action for the Tank Farm Soils and SRPA  inside the current INTEC
  rSf^ ^ °U ,3~'3 RI/BRA detemiined that 5' relea^ ^tes. including the perched water and
  the SRPA pose risks or threats to human health or the environment greater than allowable levels  Four
  new sites recently added to OU 3-13. were not evaluated in the RI/BRA but are presumed to pose a risk
  or threat because ot their origin and similar contaminants.  During the OU 3-13 FS evaluation the release
  sues and Obs were further categorized into seven groups relating to media, similar contamination or
  geographic  proximity. These groups are discussed and defined in the following sections.  Table 4-1  lists
  each WAG  3 site, site description, and site grouping. The DOE, EPA and the IDHW have selected "No
  Action,  ' No Further Act.on/'or a remedial alternative for each of the release site groups and the
  individual sues listed in the table, based on the comparative analyses of alternatives presented in the
 WAG 3 comprehensive RI/FS and other documents contained in the Administrative Record "  In addition
 four new sues recently added to OU 3-13  and their planned disposition are discussed in Section 4.9 and in
 Table 4-1.  Sect.on 4.10 describes six other sites that will be dispositioned under another WAG or other
 regulatory programs, but will be reviewed by the CERLCA program during the 5-year review process.

                         4.1    Tank Farm Soils  (Group  1)

 , ., ™e Tank Farm Soils (Figure 1-3) previously consisted of sites in OUs 3-06, 3-07 3-08 3-1 I  and
 -S-IJ. The sites are located in the area of the Tank Farm (Sites  CPP-16.-20 -^4  --»5 -26 -28* 30 '31
 -32, and-79) and adjacent to the PEW evaporator building (Sites CPP-15  -27 -33*and-58) are   '  " '
 consolidated into Site-96.  These sites consist of soil contaminat.on that resulted from spills and pipeline
 leaks ot radioactive liquids from plant liquid transfer operations.  Distributed throughout the Tank Farm
 soils outside of the previously identified release sites are low concentrations of contaminants at varvin-
 locations and depths.  New Site CPP-96 is a consolidation of all of the previously identified Tank Farm*
 So.ls sues and the intervening interstitial soils within the Sue CPP-96 boundary.' Contamination resultin-
 from releases from waste transfer lines and valve boxes in the Tank Farm area currently account for    =
 approximately 95% ot the known contaminant inventory, in total curies of radioactive material.


c   In addMu,,, lu -No Action Sues" uere uicnulled m .he l-'FA CO hut uere mn gnen an operable uni< number.  See
    Section 4 s lor jtldiiional Ji>cu*->ion
                                             4-1

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Table 4-1.  \VAG 3 CPP release sites and site grouping.
Site
CPP-Ol
CPP-02
CPP-03
CPP-04
CPP-05
CPP-06
CPP-07
CPP-08
CPP-09
CPP-IO
CPP- 1 1
CPP- 1 2
CPP- 1 3
CPP- 1 4
CPP- 1 5
CPP- 1 6
CPP- 1 7
CPP- IX
CPP- 1 9
CPP-20
CPP-2 1
CPP-22
CPP-2."
CTP-24
Op^able OU 3- 1 3 ROD
L'nit Description Site Group rwkinn
OU 3-09 Concrete settling basins and drv wells east 3
ofCPP-603
OU 3-09 French drain west of CPP-603 2
OU 3-09 Temporary storage area southeast of 1
CPP-603
OU 3-09 Contaminated soil area around CPP-603 3
settling tank
OU 3-09 Contaminated soil around CPP-603 settling 3
basin
OU 3-09 Trench east of CPP-603 fuel storage basin none
OU 3-02 Soil contamination northwest of CPP-642 none
OU 3-09 CPP-603 basin filter system line failure " 3
OU 3-09 Soil contamination at northeast corner of 3
CPP-603 south basin
OU3-09 CPP-603 plastic pipeline break 3
OU 3-09 CPP-603 sludge and water release 3
OU 3-02 Contaminated paint chips and pad south of none
CPP-603
OU 3-08 Pressurization of solid storage cyclone 3
northeast of CPP-633
OU 3-05 Old Sewage Treatment Plant west of 1
CPP-664
OU 3-08 Solvent burner east of CPP-605 1
OU 3-07 Contaminated soil from leak in line from 1
CPP WM-1 XI to PEW Evaporator
OU 3-09 Soil storage area south of CPP Peach none
Bottom fuel storage area
OU 3-02 Gas storage buildina. current location of none
CPP-66S
OU 3-09 CPP-603 to CPP-604 line leak 3
OU 3-07 CPP-604 radioactive waste unloading area 1
OU 3-02 Solid waste storage bin south of CPP-601 none
01 3-09 Paniculate air release south of CPP-603 none
Ol 3-02 CPP injection \\. ell (MAH-FE-PL-304) 5
OU 3-0- CPP Tank Farm area bucket >pill |
RD RA
RDRA
RD RA
RDRA
RD. RA
"No Further Action"
"No Action"
RD/RA
RD/RA
RD/RA
RD/RA
"No Action"
RD/RA
RD RA
RD/RA
RD.RA-OU 3-14J
"No Further Action"
"No Action"
RD RA
RD RA
"No Action"
"No Further Action"
RD RAh
RD RA-OU 3-14'
                                            4-2

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    Table 4-1.  (continued).
   CPP-27

   CPP-28

   CPP-29

   CPP-30
   I
   none
                                     Description
              OU 3-07  Contaminated soil in the Tank Farm area
                        north of CPP-604
   CPP-26     OU 3-07  Contaminated soil in the Tank Farm area
                        from steam Hushing
              OU 3-08  Contaminated soil in the Tank Farm area
                       east of CPP-604
              OU 3-07  Contaminated soil in the Tank Farm area
                       south of WM-181  by Valve Box A-6
              OU 3-08  Contaminated soil north and west of the
                       main stack (CPP-708)
              OU 3-07  Contaminated soil  in  the Tank Farm area     1
                       near Valve Box B-9
  CPP-3I     OU3-07 Contaminated soil in the Tank Farm area     1
                      south of Tank WM-183
  CPP-32     OU3-07  Contaminated soil in the Tank Farm area      1
                      southwest and northwest of Valve Box B-4
  CPP-33     OU3-06  Contaminated soil in the Tank Farm area      |
                      near WL-102, northeast of CPP-604
 CPP-34     OU3-06  Soil storage area (disposed trenches) in the   3
                      northeast corner of the ICPP
 CPP-35      OU3-08 CPP-633  decontamination spill
 CPP-36     OU 3-08 Transfer line leak from CPP-633 to
                     WL-102
 CPP-37a .   OU 3-02  Gravel pit—outside INTEC fence            3
 CPP-37b    Of 3-02  Gravel pit and debris landfill Inside INTEC   3
                     fence
 CPP }*{     Ol '  i n 1  rr • LI
    '"               -Wl"™SP~6()]ihr0^-™'  C—nderanotherprogram
CPP-39     OU 3-13  CPP HF storage tank (YDB-10S, and drv
                     well. OU 3-13  no Track I or Track 2.  '
C PP-40     OU 3-06  Lime pit at the base of the CPP-601 berm
                     and trench drain
                                                              3
                                                              3
    RD RA

    RDRA

    RD-RA

    RD.RA

   "No Action"

   RD/RA-OU3-!4J

   RD.RA

   RD/RA

  RD/RA

  RD/RA

  RD/RA
  RD/RA

  RD/RA
  RD.RA
                                                             none
                                                            none
C PP-41 a    OU 3-02  Fire training pits between CPP-666 and
                     CPP-663. under asphalt
CPP-41b    OU 3-02  Fire training pus between CPP-666 and
                     CPP-663
CPP-42      OL 3-IO  Drainage ditch \\estofCPP-63-
none
                                                            none
 "No Action"

 "No Action"

 RDRA

"No Action"

"No Action"

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Table 4-1. (continued).
Site
CPP-43
CPP-44
CPP-45
CPP-46
CPP-47
CPP-48
CPP-49
CPP-50
CPP-51
CPP-52'
CPP-53
CPP-54
CPP-55
CPP-56
CPP-57
CPP-5X
CPP-59
CPP-60
CPP-61
CPP-62
CPP-63
CPP-64
CPP-65
CPP-66
CPP-6"
CPP-6S
Operable
Unit
none
OL 3- ID
OL3-1I
OU3-IO
OU 3-06
OU3-13
OU3-OI
OL'3-Ol
OU3-0]
none
OU 3-02
OL 3-02
OU 3-02
OU3-IO
OU 3-02
OU3-H
OU 3-02
OU 3-02
OU3-OI
OU 3-02
OU 3-02
OU 3-02
OU 3-02
OU 3-02
OU 3-D3
OL 3-D2
Description
Grease pit south of CPP-(>3~
Grease pit south of CPP-60X
CPP-62 1 chemical storage area spills
CPP-637 courtyard pilot plant release
Pilot plant storage area uest of CPP-620
French drain south of CPP-633
PCB transformer yard (CPP-705)
PCB transformer yard (CPP-73 1 )
PCB staging area west of CPP-660
Pickling shed east of CPP-63 1
Paint and paint solvent area south of
CPP-697
Drum storage area west of CPP-660
Mercury-contaminated area south of
CPPT-'l5
Nitric acid contamination south of
CPP-734
Sulfuric acid spills east of CPP-606
CPP PEW evaporator overhead pipeline
spills
Kerosene tank overflow west of CPP-633
Paint shop at present location of CPP-645
PCB spill in CPP-718 transformer yard
Mercury-contaminated area near CPP TB-4
HexonespillbyCPP-710
Hexone spill uest of CPP-660
CPP Sewage Treatment Plant lagoons
CPP coal-fired steam generation facility
Fly Ash Pit
CPP Percolation Ponds =1 and =2
Abandoned uasoline tank
CPP VF.S-t TI-652
(North of Buildins: 6(161
Site Group
none
3
none
none •
none
3
none
none
none
none
none
none
3
none
none
1
none
•>
none
none
none
none
OU3-13 ROD
Decision
"No Action" per
FFA CO
RD.RA
"No Action"
"No Action"
"No Action"
RD-'RA
"No Action"
"No Action"
"No Action"
"No Action" per
FFACO
"No Action"
"No Action"
RD/RA
"No Action"
"No Action"
RDRA
"No Action"
RD.RA
OU3-14RLFSJ
"No Action"
"No Action"
"No Action"
Closure under another program
WAG 10
3
•>
RD RA
RD. RA
RD RA '
                                              4-4

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Table 4-1. (continued). 	
S~\ t i
^^k Site
/""D D AO
' ' 1
- — — 	
uperaoie
Unit n OL 3- 13 ROD
	 *- "ll 	 L/escrinhnn o-. /•-
~ 	 	 	 ' 	 	 	 	 Site Group Decision
^rr-ov UL J-uv Abandoned liquid radioactive waste storage 7
Tank CPP VES-SFE-20
CPP-70

CPP-71

CPP-72

CPP-73

CPP-74

CPP-75

CPP-76

CPP-77

4fe CPP-78
CPP-79
CPP-80
CPP-S 1
CPP-82
CPP-S3
CPP-84
CPP-S5
CPP-S6
CPP-S7
CPP-X.X

CPP-X9
CPP-90
_^**L
none

none

none

none

none

none

none

none

OL 3-09
OL 3-07
OL 3- 1 2
OL3-I2
OL3-I2
OL 3-08
OL3-13
OL3-I3
OL3-I3
OL3-I3
OL 3-13

Of 3- 1 3
OL3-I3
Septic tank east of CPP-655 none

Seepage pits west of CPP-656 none

CPP-758 cesspool east of CPP-65 1 none

Leaching cesspool east of CPP T- 1 5 none

Seepage pit and septic tank west of none
CPP-626

Septic tank and cesspool west of CPP-603 none

Septic tank and cesspool west of CPP-659 none

Seepage pit and cesspool north of CPP-662 none

Contaminated soil west of CPP-693, east of none
dry fuel storage area
Tank farm release near Valve Box A-2 1
CPP-601 vent tunnel drain leak 2
Abandoned CPP-637.CPP-601 VOG line none
Abandoned line (3.8 cm(1.5in.j) PLA-766 none
west of Beech Street
The entire perched water svstem at the 4
INTEC
Gas canisters (buried gas cylinders) 6
Waste Calcining Facility blower corridor 2
CPP-602 waste trench sump T
CPP-604 VOG blower cell sump and floor 2
drain
Radiologically contaminated soil none

CPP-604 -605 tunnel exeaxation ->
CPP-~09 ruthenium detection none
RD/RA
"No Action" per
FFA/CO
"No Action" per
FFACO
"No Action" per
FFA/CO
"No Action" per
FFA/CO
"No Action" per
FFA/CO
"No Action" per
FFA/CO
"No Action" per
FFA/CO
"No Action" per
FFA/CO
"No Action"
RD/RA
RD/RA
OL:3-I4RI/FSJ
OL3-l4RI/FSd
RD/RA
RD/RA
Part of WCF closure
RDRA
RD/RA
"No Further Action" -
Conduct 5-year review
RD-'RA •
"No Further Acrinn" -
                          Conduct 5-year revieu
4-5

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Table 4-1. (continued).
Operable
Site Unit Description
CPP-9 1 OU3-I3 CPP-633 blower pit drain
CPP-92 OU3-I3 Soil boxes west ofCPP- 16! 7
CPP-93 OL'3-13 Simulated calcine disposal trench
CPP-94 OU3-13 Gas canisters (buried gas cylinders)
CPP-95 OU 3-13 Airborne plume (also shown in 10-06)

CPP-96 OU3-13 Tank Farm interstitial soils
CPP-97 OU3-13 Tank Farm soil stockpile
CPP-98 OU3-13 Tank Farm shoring boxes
CPP-99 OU3-I3 Boxed soil
a. No action Mte-, withm the Tank Fann are consolidated MHO Site CPP-96. Because
will he -.uhieei to the tjroup 1 Interim Action and to the Ol' 3-14 Rl-FS.
C PP-_. i> j Mitircc lor Ol 3-13 (iroup 5 aquifer contamination outside the INTC
c= CPP-3X IN asbeMOs on rook and walls ofbuildings. The Mte will be closed under
d. Site mined to the OU 3-14 RI FS because not enoush data is available to make a
Site'G
3
3
T
6
None

I
3
3
3
: the sue*
E fence.
OU 3- 13 ROD
roup Decision
RD.RA
RD RA
RD RA
RDRA
"No Further Action" -
Conduct 5-year re\ ieu
RD-RA
RD/RA
RD/R.-\
RDRA
i are within the Tank Farm they
The source will be remediated
the INEEL Asbestos Abatement Program.
risk based decision. 	

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 -:: ::v !M l-.r. No ev.dence has been ;ound to md.cale ihas urn nt'ihc  lank harm tanks have 'e-i^v

  i-.vc, comammam. round m the mterstiual so.ls are hkelv ,he re.uit of aec.dental relea^ a " , „


          " f""? )        ^ l>'" "^ U"d Cr0^'" "™'™">" "^ "-v^on., and munvo- r
          s.  i,m,tcd sue nnestigauon, have been conducted at the Tank Farm sues became ,  r'  ,•


           "                                                                       '
                 RpRl> V                -                                     t, :o thc
                SRI A.  SRPA «rounduaior c.^nu.m.nated by Tank l-'arm so.N releases could be

vur.s;:iiiei: :i\ uiture grounduater u>ci'h.                       '
           4.2    Soils  Under Buildings  and Structures (Group 2)


      TheSo.ls I nder Buildmy, and Structures are comprised of release sues that occur beneath [\ i i-
.nu.hn.s or structures, and mclude Sues C'PP-,,2. -41a. -60. -08. -«0. -85. -*6. -87. and S9  "'-^ 4

                                        - Pil that was COVered b-v asPhalt du""S construction
           Site CPP-60 is the soils that were beneath the former pamtshop buildim?. CPP-64S „
           over this site.                                                  _         -  •
          Site CPP-68 is the former location of an abandoned. ! .892 L (500 gal) undereround tiasolme
          siOF3uc t*ink.                                                        w      *"



     *     r PP n?,1"80 reSU'ted 'ir°m a huzardous- radioactive liquid condensate leak from the Bundm-
          <- I r-oU-l  vent tunnel drain.                                                         ~



     •     Sue CPP-S5 is the WCF Blower Con'idor.  It has been closed m place as part of the \V< T

          under an approved H WMA closure plan. The WCF w,l! be mcluded w.th the Group 2 s«,U

          Lnder Buildings and Structures sites in the CHRCLA 5-year reviews.


          Sue CPP-S6 ,s a waste trench that runs beneath CPP-602. which collects liquid waste for
          transfer to the Rh\V  evaporator from various CPP-602 operations.



          Sue CPP-87 is located beneath the vapor off-gas blower cell of Building CPP-604.


          Site CPP-89 is a tunnel excavation located beneath  Buildings CPP-604 and -6U5.


    Sites CPP-87 and CPP-89 are integrally related: thcVoil and contamination removed from  ( TI


                " rpp-89- Comaminated ^ irom
    I ,ie major threats posed by Group 2 Mies are external exposure to contaminants if the bmldnv or

.tc ure is removed and potential leachmg and transport of soil eoniammants to the perched water or

I  A  1,, ...v.suns: hmldmg or sirueture a,:ren.I> prov:,!e^ an adequate rad.at.on protection hamer.,:-J

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  M.T\CS 10 limn infiltration into the contaminated soils. Group 2 >oils are not considered "principal threat'
  wastes became the lexels of radionuelide* pre.sent ha\e not been directly mea>ured.

                         4.3    Other Surface Soils (Group 3)

       The Other Surface Soils consist of release sites located in the following areas:

       •     Building CPP-603
             (Sites CPP-OI. -03. -04. -05. -OS. -09. -10. -11. and -19)

       •     Building CPP-633
             (Sites CPP-36 and-91)

       •     Calcined Solids Storage Bins
             (Sites CPP-13.-35. and-93)

       •     Disposal Trenches
             (SiteCPP-34)

       •      Old Sewage Treatment Plant (STP)
             (SiteCPP-14)

       •     Grease Pit
            (Site CPP-44)

       •     Near Building CPP-16!9
            (Site CPP-55)

       •     Near temporary Building TB-1

       •     Percolation Ponds that are situated south of the INTEC fence
            (SiteCPP-67).

      In addition. Group 3. also includes Sites CPP-37a. CPP-37b. and CPP-48. Site CPP-37a is a
former gravel pit located outside of the current INTEC security fence, that is used to collect storm uater
runoff from the Tank Farm. Site CPP-37b is a former gravel pit located inside the current INTEC
security fence that was pre\iously used for disposal of wastewaters from the old STP and subsequently
used for disposal of construction debris. Site CPP-4S is an excess chemical dump tank located south of
the old \VCF (CPP-633)  that was used as a trench drain from 1975 to 1981. Figure  1 -5 shows the
location of the Group 3 sites. These sites generally consist of «,oil contamination that resulted from
inadvertent spills and leaks of radioactive waste, decontamination solutions, spent fuel storage water.
Storage of radionuclide-contaminated equipment, and other plant-generated wastewaters.  Group 3 also
includes Site CPP-92. which consists of 648 boxes of radionuclide-contaminated soils that were generated
from a \ariety of INTEC activities.  In addition, the neu sites similar to Group 3 (CPP-97. -98. and -99)
di;«cus:icd in Section 4.9. consist of soils and other materials \\ili be remediated as Group 3 soils.

      The results of the Rl BRA (DOE-ID 199'b) indicate that the major threat posed by the Group 3
MIC.N i> external exposure to radionuclides. Additionally, throe MIC-, (CPP-35 -16 and -91 j pose a risk to
iheSRPA.
                                              4-S

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                       4.4   Perched Water (Group 4)
                                                             .
  the perched water at INTEC Perched wirVrrnn  ,   f   • u,          he aPProx'™te extent of

  ^^•K^^^













 ccor:=:s0:th7sTph:i^
 water recharge is the percolation ponds             P     Pnmaiy man*made S°UrCe °f Perched


                4.5  Snake River Plain Aquifer (Group  5)

                                                                - fr°m
inrcrim aaion. Th, actions Selec,ed for the    "
               associa,ed

-------
                        4.6    Buried Gas Cylinders (Group 6)

       Sites CPP-84 and CPP-94 comprise the Buried Gas Cylinders group. Site CPP-84 is located
 outside the current INTEC security fence, east of Lincoln Boulevard and south of the Big Lost River (see
 Figure 1-8).  The site consists of a buried trench where compressed gas cylinders were previously-
 disposed.  The cylinders at the burial site originated from INTEC and contain gases used for construction.
 The exact number and contents of the discarded cylinders is not known, but it Is believed that 40 to 100
 cylinders were disposed at the site.  The gases in the cylinders may include acetylene, compressed air.
 argon, carbon dioxide, helium, nitrogen, or oxygen. These gases do not pose a  human health risk but are
 considered a safety hazard because ruptures of the cylinders could lead to personal injury, fire, or
 explosion. DOE will  evaluate the safety concerns  of removing the cylinders versus capping them in
 place.

       Site CPP-94 includes an area about 2.4 km (1.5  mi) northeast of the  INTEC along the south side of
 a dirt security road (see Figure  1-8). Four exposed gas cylinders have been observed at the site and are
 believed to contain hydrofluoric acid.  The safety hazards associated with CPP-94 are similar to those at
 Site CPP-84. The potential for cylinder over-pressurization and bursting is considered the most serious
 hazard at CPP-94.  The buried gas cylinders pose a safety hazard to inadvertent  intruders (i.e.. back hoe
 operators or drillers).  Hydrofluoric acid is very corrosive, reacts violently with  moisture, and can
 generate explosive concentrations of hydrogen gas. Fluoride, a chemical residual of hydrofluoric acid
 reactions, is a potential human health and ecological hazard.

                4.7     SFE-20 Hot Waste Tank System (Group 7)

      The SFE-20  Hot Waste Tank System is also  known as. Site CPP-69, which consists of a concrete
 vault containing an abandoned radioactive liquid waste storage tank. The top of the tank vault is located
 about 3m (10 ft) below grade. The tank contains about 1.514 L (400 gal) of liquid and about 208  L
 (55 gal) of sludge (Figure 1-9).  The tank system consists of the tank contents, tank, and associated
 structures located east of Building CPP-603. The SFE-20 Hot Waste Tank  System was constructed m
 19>7 to collect liquid radioactive wastes from the south basin area of Building CPP-603  and the Fuel
 Receiving and Storage Facility.  In 1976. the SFE-20 Hot Waste Tank System was taken out of service
 and the inlet pipe was disconnected and capped. Contaminated soil may  have been used as backfill
 material for the excavation. The pump was also removed from the pump pit and the connections capped
 A preliminary investigation conducted  in 1984 indicated that the tank liquid and sludge contain elevated
 levels of Cs-137. Cs-134, Co-60, Sr-90. and isotopes of europium, plutonium. and uranium. The
 concentration  of plutonium indicates that the liquid is transuranic waste and that the sludge may be
 classified as transuranic waste. Previous spills w ithin the tank vault and pump pit contained similar
contaminants.  No data exists  to determine if contamination currently exists under SFE-20. however.
 when the vault is removed any contaminated soils w ill be excavated' and disposed in the ICDF in a
 manner consistent with the Group 3 soils remedy.

      The major threat posed by the SFE-20 Hot Waste Tank System is a potential release to the
underlying M)ils and subsequent leaching and transport  of soil contaminants to the perched water or
SRPA.

              4.8    "No Action" And "No Further Action" Sites

      The Agencies, have determined that "No Action" or "No Further Action" be taken under CERCLA
.it 40 Mie.s.  In all cases, the determination applies to the soils onlv and not to overlying man-made
•structures, A "No Action" MIC is a site  that has no contaminant source or has a mino/contaminant source
                                              4-10

-------
   with an acceptable risk level under a current residential exposure scenario, i.e. the risk is less than
                                             ^
            1 x 10  or HI >1 . (Radioactive decay will allow many sites that are currently unacceptaWe to
            decay to acceptable risk levels by the year 2095.)                  Currently unacceptable to

            The site has contamination that exists at depths greater than 1 0 ft bss and does not have an
            exposure route ava.lable under current site conditions.
                                                                       ' *« «* under a

                          sites- The technicai
       All "No Further Action" sites will be reviewed
          pro,ec,,veness of ,he rem«,ia, «i^ ^ Jen
^^^^^^^^^^^   - - ™* C -en,
4.8.1    "No Action/No Further Action" Sites Determined in OU 3-13 ROD
**'.*• ^    ?fPP-°6- CPp-°6 consists of a trench near the southern border of the INTEC that wi< i. ^H


                                                                       "
                                         - che Asencies have

                                            4-1

-------
 storage pad: feathering caused the paint to fall off and was wind dispersed outside of the control area.
 The contaminated paint chips and storage pad were both removed.  Subsequent surveys indicate that no
 contaminated surface soils exist at this site. The Agencies have determined that Site CPP-12 is a "No
 Action" site because the minor source was completely removed {WINCO 1992c).

 4.8.1.4    CPP-17.   CPP-17 consists of two areas near Building CPP-603. The site was used for
 storing piles of soil, asphalt, concrete, metal debris, and other items that reportedly came from a variety of
 construction and maintenance activities within the INTEC.  In addition, sludge and liquid generated
 during CPP-603 fuel storage basin maintenance activities may have been deposited in these areas
 resulting in contamination of the underlying soils.  The soil in CPP-17 was containerized in
 approximately 653 standard radioactive waste boxes. Three soil borings were sampled to characterize
 CPP-17. The results of the investigation and risk assessment, which are reported in Chapter 14 of the
 BRA, indicated that the risks to current onsite workers and hypothetical future residents is acceptable but
 the current residential risks are unacceptable. Therefore, the Agencies have determined that Site CPP-17
 is a "No Further Action" (LITCO  1995b).

 4.8.1.5     CPP-18. Site CPP-18 is an area that was used to store spent gas cylinders.  Building
 CPP-668 is presently located on this site.  In addition, excavation for, and construction of Building
 CPP-668 would have disturbed any minor contamination that may have existed at the site
 (WINCO I992d).  The Agencies have determined that Site CPP-18 is a "No Action" site because there is
 no documentation or other evidence of a release.

 4.8.1.6     CPP-21.  Site CPP-2I is an area south of CPP-601 that was used to store solid waste
 including paper, rags, and contaminated metal. The waste was contained in three dumpsters.  A
 radiological survey of the area revealed no evidence of contamination. The Agencies have determined
 that Site CPP-21 is a "No Action"  site because there is no evidence of a source or a release at this site
 (WINCO I993b).

 4.8.1.7     CPP-22.  Site CPP-22 is the location of surface contamination associated with a 1958 air
 release that resulted from the failure of a HEPA filter. The HEPA filter was associated with the Fuel
 Element Cutting Facility. Contamination from this airborne release has most likely been removed or
 covered over with soil during the period from 1958 to the present as a result of construction activities that
 have disturbed the area. The area was extensively surveyed and three boreholes were drilled within Site
 CPP-22 at the locations surveyed to have the highest radiation levels above background.  During the
 investigation, the peak concentration for Cs-137 was 14 pCi.-g. The Agencies have determined That Site
CPP-22 is a "No Further Action" site because the future risks are acceptable but the current residential
risks are not acceptable (LITCO 1995b).

 4.8.1.8     CPP-29.  Site CPP-29 is the result of a release of small quantities of radioactive liquid at the
 base of the original ICPP stack  in I974.  The original contaminated area  was estimated to be 0.7 nr (S frs
and no more than a few inches thick. Since the release, the Main Stack Refurbishment Project complcteK
excavated this site to a depth of 2.1 m (7 ft) (bis) and extended the concrete base of the new stack over the
area of the release.  The Agencies have determined that Site CPP-29 is a "No Action" site because the
original area of contamination was completely excavated and covered with concrete (WINCO 1993c.
 DOEetal. I994b).

 4.8.1.9     CPP-39.  Site CPP-39 consisted of a Indrofluoric acid storage tank, a concrete containment
 vault, and a 3S-m (125-ft) tile line  connected to the dry well.  The storage tank was used as a makeup tank
 to provide Indrofluonc acid to the  CPP-601 dissolution process.  The tank was also used to receive off-
 specifieauon hvdrofluone acid where it was cither adjusted to meet specifications or neutralized and
 discharged to a dry well. The dry well and vault both contained limestone  rock to neutrali/e the


                                               4-12

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                            r                              with this             -
    and subsequent risk analysis ind?«e Lmn^^M  ? 1"*,!™ remOVKl '" ' "3 Sam>>"n-a
    a« contaminants „ „, depths «vZ^^.1^r V^ xTo— ^'^ ""* *""
    Agencies have determined that Site CPP-39 is a °4 1 ,c Z,'    h        carcmogemc risk levels.  The
    acceptable! DOE-ID 1 997b).    reLKrJy'sa >™ Action  sue because the risks are considered
   plp'ng",, conssd-a I6'                a h'S10ric":id ""-tn-l^tion pi, and assoda.ed
   The drain pipe ,ed from a dr^






                                                ^
  .his *c33       Hte ccausc n° s°urce re™j-
  based concen.ra.ion (WINCO 1993d and DOETe Iwb"     ?   *      " "''^ Ihe ' X t0" risk-
      ! drip                                     T£'.«** -?«. were placed in

  been totally excavated and partially co'ered by Buildta CPP 66fi N  "° T*" '" "*'  CPP-4lb te
  therefore, no quantitative risk assessment was perfomed  nl A       T"   "*" talte" fr°m lhis sile:
  CPP-4,b is a -No Ac,ion- site because ,he ^'^'^ ""
 d'efig'n",,,

 been disposed to the surface soil at this site The A«^ h! Tf "°nr^loac"ve laboratory waste had
 Action" site because the emulated H, ^'^                            *" "^ " " "N°
                  .          e4 hi" operas ^CPP o'u"^ "T" ^ M
documented and other spills or releases were susr,er?,>H Tfc             '   ' releases were
asse                                    "
                                       susr,er,>           ,     M
 assessment indicated tha  the contaminan     "^ ^ Jel, e ^ Hl            """"  **
 dete,™^ ,ha, S,,e CPP-45 is . -N
                                                     '          '-700L
                                                          -
nonradioactive feed stock for process e   f Fo lloJI  ,h   ,     ! W"S'e ™K being used as a
contaminated soils were removed  Subseaum,rS,   '      ' "* WaS'e was ncu»alized and
removed. The h.ghes, C^^^S^^^^^' *??"" "^ *"*"
contaminated »as later entirely remnv,H A,n    "    S   -     • remam|ng soil that was clearly
tanks no, si,  The ^^^1^^%™^ ~ ^ «« ^- -he
              d and Ihc ra™» res"                                        beus     sourcc

                                           4-13

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 [2 gal]) \vas known to have occurred. The area was sampled and the analysis showed that although high
 fluoride concentrations were observed, but they were below risk-based levels. The Agencies have
 determined that Site CPP-47 is a "No Action" site because the calculated HI is much less than  1
 (XVISCO I992x).

 4.8.1.16   CPP-49. Site CPP-49 is the site of soils underneath an active transformer yard that
 contained three PCB transformers.  Visual evidence of leaks lead to sampling the concrete pads and
 surrounding soil.  Sampling results indicate that the soil contained less than O.I ppm PCBs: One concrete
 pad sample contained 29.1 ppm PCBs.  Subsequent sealing activities completed on the transformer pad
 ha\e resulted in encapsulation of the pad within a larger resultant concrete pad structure. The Agencies
 have determined that Site CPP-49 and the soils under the transformer pad is a "No Action" site because
 the PCB concentrations observed in the soil were less than the CERCLA cleanup criteria for PCBs. In
 addition, the concrete pad was sealed and incorporated into a larger concrete pad (WINCO I992a).

 4.8.1.17    CPP-50. Site CPP-50 is the location of soils beneath a PCB transformer pad. The
 transformer contained 874 L (231 gal) of 400 ppm PCB oil. Leakage was noted during an inspection of
 the transformer in 1985.  The leaked oil was isolated on the transformer concrete pad and did not impact
 the surrounding soil. The transformer was removed and disposed at an approved off-Site disposal facility.
 The Agencies have determined that Site CPP-50 is a "No Action" site because there is no evidence that
 contamination spread to the surrounding soil (WINCO 1992a).

 4.8.1.18    CPP-51.  Site CPP-51 is defined as the soil below a storage area for PCB-transformers,
 contaminated soil, debris, and concrete from the ICPP Utilities Replacement and Expansion Project. The
 storage area was unpaved:  During the upgrade project, two transformers leaked onto plastic sheeting.
 The sheeting, transformers, and debris have been removed from the site.  The PCB concentrations in the
 soil are less than the I ppm cleanup criteria specified by TSCA for unrestricted access areas (40 CFR
 761.125 (c)(4)(v). Of the eight samples collected, the maximum PCB concentration observed was
 O.I20 ppm.  The Agencies have determined that C'P-51 is a "No Action" site because the PCB
 contamination is below the TSCA cleanup standards (WINCO I992a).

 4.8.1.19   CPP-53.  Site CPP-53 was an area used by a painting subcontractor for the storage of
 approximately 30 to 40 drums of paint and paint solvents.  In 1983, the stored materials were removed to
 an EPA approved disposal facility and the area was covered with 61 to 76 cm (24 to 30 in.) of gravel.
 The area was subsequently used as a construction laydown area and vehicle parking. There are no
 documented releases at this site. Sample results did not indicate any contamination above detection
 limits.  The Agencies have determined that Site CPP-53 is a "No Action" site due to the lack of an
 apparent source (XVINCO 1992g).

 4.8.1.20   CPP-54. Site CPP-54 is an area that was used to store approximately 30 to 40 drums of
organic sohent and used oil.  There are no known releases from the drums.  Analysis of soil samples
collected did not reveal any contamination above risk-based levels. The Agencies have determined that
 Site CPP-54 is a "No Action" site due the lack of an apparent source (WINCO I992h).

4.8.1.21   CPP-56. Site CPP-56 is an area where a nitric acid leak occurred in a transfer line in 1968.
The nitric acid was neutralized prior to disposal and was nonradioactive.  In  1986-87, the site was
 e\ca\ated to support construction of CPP-796. Any residual contamination would have been blended
 with backfill soil as part of construction of CPP-796. The Agencies have determined that Site CPP-56 is
 a "No Action" >ite because the HI was qualitativelv determined to he less than 1. and the residual
 contamination was removed (LITCO I9l)4).
                                              4-14

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   4'8t\ V2 UCPP'57' Site CPP-57 is a sulfuric acid tank,  Approximated 189 L (50 aal) of sulfuric ici.l
   ^ on the ground in 1984  and I7J>34 L ,4.500 gal, spilled in 1985.  The so,, was ne tr Srf and
   removed; any residual acid that was not removed would have been naturally neutralized bv  he soi s  The
   Agenc.es have determined that Site CPP-57 ,s a "No Action" site because no source relL and  ne HI
   was qualitatively determined to be less than one ( W1NCO 19921).
  75*™? M         L  ^^ CPP"59 C°nSiStS °f S°'1S Withm a contai"^nt berm surrounding two
  75.708 L (0.000 gal) kerosene storage tanks.  Contamination of CPP-59 occurred in two separate
  kerosene releases that occurred ,n 1983; the combined release was 984 L (260 gal) of kerosene  There is

  mfi t^m'toT   f T? ^T?* '"' "" ^^ ^ ^^ ™*^ ™P™Jo
  m nitrated into the soil. Nme borehole samples were collected to characterize CPP-59  Xvlenes were the
  only volatile organic compounds (VOCs) detected in the soils at concentrations ran.ed between 1 and 11
  ugykg.  Risks were calculated to be less than 1 x 10'4 and an HI less than 1. The Agencies have
  determmed Site CPP-59 is a "No Action" site because the risk and His are less than 1 x 10'4 and one
  respectively. (W1NCO 1 992J, WINCO 1994a.)                                        ana one


  t£1'24 e,£PP*2' Ske SPP"62 'S a" 3rea Where paint solvents were ^carded to the soil.  In 198< a
  cleanup oi this area was conducted in which 28 drums of contaminated soil were removed and shipped to
  a commercial hazardous waste facility. Subsequently, in 1 987. the area was excavated for the
  construction of the 7* Calcined Solids Storage Vault. The Agencies have determined that Site CPP-6^ is

           °                 S°UrCe "^ rem°Ved 3nd addhi0nal  excavation has been             " "
 4.8.1.25   CPP-63.  Site CPP-63 is the site of a hexone spill in 1982. During excavation for cathodic
 protection mamtenance or repair, a hexone line was cut by a backhoe; approximately I89 L (50 g I) w
 released  There were no reports indicating if the soil was removed after the spill. Three soil samples
      '                                                                        "
 he  Theor                            -                           or      s  nc
 hexone. The V OC concentrations were less than the method detection limits. The Agencies have
 determmed that Sue CPP-63 is a "No Action" site because the HI is less than I ( WINCO 1 9930

 48. 1.26   CPP-64. Site CPP-64 is the site of a hexone spill in which a forklift operator punctured a
 £oTo° f th^T'    7 l° 8L (55 ga0 °f heX°ne lCaked °nt° the 3SPhait- VermicuL wasused to absorb
 were I  I   T^     ^f""'™'^ ™ collected and disposed. Soil samples from five boreholes
 uere analyzed and revealed  that no hexone was detected significantly below risk-based concentrations
 The other contammams detected were below an HI of I . The Agencies have determined that Site CPP^

                                                  he s°urce was removed' and the
4.8.1.27   CPP-78.  Site CPP-78 consists of a 2.3 nr (25 fr) area of potentially radioactivelv-
comaminated soil located west of building CPP-693 and east of the Dry Fuel Storage Area   '

D^t?^" um^h*800^ f r™* eXCaVati°n activities-  The origj" o^he contaminat.on is not kno.n
bu  ,> plumed to have resulted from a surface spill. Two soil borings were drilled and soil samples     .
collected and  analyzed. The analysis of the samples showed that the radiation levels barelv exceeded
background values and are below I  x iO'4 residential risk-based concentrations. The Auencies have
                                        "                                             "d the
™-1-*3   CPP:88- Site CPP-88 consists of the radioactively-contaminated soils withm the current
rpp vv^T1?' ,'nCe    l haVe "Ot been attribmed to anotlner sP«ific release site. Investigation of
virnu  INTrrt cxjcnsixe ^«nwnt reviews and analysis of samples collected from 16 boreholes from
%anou> INTEC. localion.s.  The maximum Cs-I37 concentration uas 36.6 pCi u and the <)^n UCL for
                                              4-15

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  Cs-137 was 14.1 PCi g. The Agencies have determined that Site CPP-88 is a "No Further Action" sue
  because it is above the current I x IO'4 residential risk range and below the vear 209S 1 x H/4 residential
  risk range (DOE-ID 1997b).                                         "

  4.8.1.29   CPP-90.  Site CPP-90 consists of soil contaminated by leaks  in sen-ice waste transfer lines
  ?olr?LnUlldlTg CPP-T and thC CPP'23 mjeCti0n WelL  The Ori^inal concrete PiP«"ne was replaced in
  1959-1960 with a vitnhed clay line.  The vitrified clay line  was replaced in 1969 with a stainless steel line
  that was partially replaced in I982 with another stainless steel line.  In 1986. the line was permanently
  taken put ot service and abandoned in place. Three soil borings were drilled to support the BRA  Soil
  analytical data trom those borings indicate a maximum Cs-l37 concentration of 7.5 pCi/a and a 95%
  LCL for Cs-137 of 7.5  pCi.g.  The Agencies have determined that Site CPP-90 is a "No Further Action"
  site because the future residential  risk is acceptable but the current residential risk is not acceptable
  (DOE-ID 1997b). This site will be reviewed under the CERCLA 5-year review to ensure that if this pipe
  is removed in the future, any contamination discovered will  be properly addressed.

 f:il'?°  . CPP'95-  Site CPP-95 is the wind-blown plume and consists of areas outside the current
 INTEC perimeter fence that are potentially contaminated as  a result-of wind dispersion of radionuclides
 from facility operations. The area delineated as Site CPP-95 (i.e., the WAG 3 AOC) is shown in
 Figure I-10. Surveys and soil sampling were conducted as part of the 10-06 RI and EE/CA  The 95%
 upper confidence level (UCL) 95% concentration for Cs-137 within the AOC is 5.9 pCi/e. Site CPP-95 is
 a "No Further Action" site . because it is above the current 1  x 10'4 residential risk range'and below the
 year 2095 I x 10" residential risk range (DOE-ID 1997b).

 4.8.2     "No Action" Sites Designated in the FFA/CO

 4.8.2.1    CPP-43-Grease Pit South of CPP-637. This pit was used for the disposal of an
 unknown quantity of oil and grease. The site occupies an area of 141 m2 (1,520 ft2)  The site was filled
 and  a building (CPP-651) was constructed on the site in the mid-1970s. A "No Action" decision
 documentation package was placed in the Administrative Record in September 1991; in December 1991
 the Agencies formally determined that this site is a "No Action" site in the FFA/CO (WINCO 1991 a).

 4-8.2.2    CPP-52.  Site CPP-52 was a pickling shed used to treat piping  and other structural materials
 with mineral acids during the original construction of the ICPP.  The  site involved an area of 13 4 m:
 (144 tf).  The building was a temporary structure located east of CPP-631.  Spent pickling solutions were
 disposed in liquid waste storage tanks: there are no records of spills or leaks. The building was
 demolished in 1954. A "No Action" decision documentation package was placed in the Administrative
 Record in September 1991; in December 1991, the Agencies  formally determined that this site is a "No
 Action" site in the FFA.CO (WINCO 199ib).

 4.8.2.3    CPP-70.  Site CPP-70 is a septic tank located east of CPP-655.  This septic tank was used to
 treat  sanitary waste generated at the craft shop and warehouse building Operations in the building
 included equipment maintenance and repair, welding, and carpentry.  There  are no drains located in the
 work areas and there is no evidence hazardous constituents were disposed in the septic system.  \ "No
 Action" decision documentation package was placed in the Administrative Record in September 199! • in
 December 1991. the  Agencies formally determined that this site is a "No Action" site in the FFA/CO
 (WINCO 199 lei.

 4.8.2.4    CPP-71. Site CPP-7] consists of the seepage pits west of CPP-656.  These pits were used in
conjunction with the septic tank located east of CPP-655 |CPP-0). There are  no records of hazardous
constituent releases.  A "No  Action" decision documentation  package was placed in the Administrative
                                              4-1A

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  Record in September 1991; in December 1991. the Agencies formally determined that this site is a "No
  Action  site in the FFA. CO (WINCO I991c).

  4.8.2.5    CPP-72. Site CPP-72 consists of the CPP-758 cesspool east of CPP-651  Site CPP-72 used
  to treat sanitary sewage from temporary office trailers. The trailers have been disconnected and the
  system is no longer in use. Because the septic system was only connected to office restrooms it is
  unlikely hazardous constituents were disposed in the system. A "No Action" decision documentation
  package was placed in the Administrative Record in September 1991; in December 1991, the Agencies
  formally determined that this site is a "No Action" site in the FFA/CO (WINCO 1 99 Id).

  ™24-6     CPP"73-  Site CPP-73 is a cesspool located east of and connected to temporary building
  LPP-T-5, which was used as a lunch/break room by a construction contractor.  No hazardous materials
  have been stored at this location, and no hazardous wastes are reported to have been disposed into the
  unit.  A ' No Action ' decision documentation package was placed in the Administrative Record in

                                                                      * site JS a "N° Acti°n" site
 4.8.2.7    CPP-74.  Site CPP-74 is a seepage pit and septic tank located west of Building CPP-626
 This septic system was constructed in the early 1970s and is used to treat sanitary waste from the fuel'
 receiving and storage building and storage basin change room. The building contains a cafeteria
 restroom. facilities, showers, and office space. No operations involving hazardous materials are known to
 have occurred in the building and it is unlikely hazardous wastes have entered the system. The Summary
 Assessment recommending "No Action" for this site was approved in 1988.  A "No Action" decision
 documentation package was placed in the Administrative Record in September 1991; in December 1991
 the Agencies formally determined that this site is a "No Action" site in the FFA/CO (WINCO 199 If).  '
 t"8'2'f  \^P'l5' Site CPP'75 c°nsists of the septic tank west of Building CPP-603. It was built in
 the early 1950s and received sanitary wastes before operation of CPP-74. The system was connected to a
 restroom facility, which was physically isolated from hazardous materials operations  The primary
 hazardous materials used in operations that might have been associated with this unit were mineral acids
 I he Summary Assessment recommending "No Action" for this site was approved in 1988 A "No
 Action" decision documentation package was placed in the Administrative Record in September 1991 • in
 December 1991, the Agencies formally determined that this site is a "No Action" site in the FFA/CO '
 (WINCO 1991g).

 4.8.2.9    CPP- 76.  Site CPP-76 consists of the septic tank and cesspool west of Building CPP-659
 which was used to treat sanitary wastewater from the old calcining facility, built in 1960   There are no
 records ot hazardous wastes entering the system. The septic tanks are currently being removed in support
 ot the NO, Abatement Facility construction. The Summary Assessment recommending "No Action" for
 trns sue was approved m 1988.  A "No Action" documentation package was placed in the Administrative
 Record in September 1991 : in December 1991, the Agencies formally determined that this site is a "No
 Action" site in the FFA/CO (WINCO 199lh).

 4.8.2. 10   CPP-77.  Site CPP-77 is a seepage pit and cesspool located north of Building CPP-66">
 There are no know n records that indicate hazardous materials ever entered this system The Summary
 Assessment recommending "No Action" for this site was approved in 1 988. A "No Action"
documentation package for this site was placed in the Administrative Record in September 1 991 • in
 December 1 99 1 . the Agencies formally determined that this site is a "No Action" site in the FFA/CO
(WINCO 1991 i).
                                              4-17

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                             4.9    New Soil Release Sites

        The Agencies have added four release sites e\en groups.  These sites were iinestitiated a.s
                                             4-IN

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   4.10.1   CPP-38— Asbestos in Nine INTEC Buildings

                               TK A Tsio;1 a ved io be/riabic
                   ^^^^

      e—
  with NESHAPS.                          SbeStOS manaSement is conducted in accordance

  be transferred to OU 3- 1 4 for further evaln^n h/    r Jgencie;> have determined that CPP-61 will


  that may rema.n under the concrete £2          ^ °f *' UnCertai" 3m°Unt °f PCB Contamination




  4.10.2  CPP-65-Sewage Treatment Plant Lagoon




      Site CPP-65 is the lagoons for the INTEC Sewage Treatment Planr ^STPI  TK   i

 waste from 3 1 FNTEC facilities  The STP hpoan oL T  • mf^  5 ( TP)' The plant trea
4.10.3  CPP-66~Steam Plant Fly Ash Pit
"sssr.'rjss.rssssr*?*"
(W.NCO .993h)  Sub        ar co     ri k
Rl RR A »-hi ^h      tqucHuv. an txoiogical risk screening was performed durin" the OU ^  n
                             ^^
                                   4-1

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 4.10.3.1   CPP-81. Site CPP-81 is an abandoned line from the 30-cm < 12-in.) Calciner Pilot Plant.
 The line, located approximately 0.6- to 0.9-m (2- to 3-ft) bis, contained simulated calcine that became
 plugged in the line following a test run. During the fall of 1993. the line was cleaned as part of a time-
 critical removal  action.  The line was flushed with hot acid to remove the simulated calcine. No leaks
 were observed during the removal action indicating that no previous release to the environment had
 occurred. The final water rinse was analyzed and found to not contain contaminants above toxicity
 characteristic leaching procedure (TCLP) limits. The Agencies  have determined the Site CPP-81 will be
 transferred to OU 3-I4 for further evaluation because of the lack of sufficient data to make a final
 decision.

 4.10.3.2   CPP-82. Site CPP-82 is the location of three waste water spills (designated Sites A. B. and
 C) caused by rupturing of previously abandoned underground lines. The lines were ruptured during
 excavation activities.  In the spill associated with Site A, an  estimated 9.4 L (2.5 gal) of low-level
 radioactive waste escaped; the abandoned line and contaminated soil associated with the leak were
 removed and disposed. Sites B and C are associated with spills of nonradioactive, nonhazardous waste
water;  these spills occurred during the repair activities associated with Site  A. The Agencies have
determined the Site CPP-82 will be transferred to OU 3-14 for further evaluation because of the lack of
sufficient data to make a final decision.
                                               4-20

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5.
                      SUMMARY OF SITE CHARACTERISTICS

                       Physiography,  Geology, and Hydrology
   volcanic p'a                  ^« *f — Sna.ce R,ver PWn (ESRP) .




                                                   ™
 "-1    Concep.ua, Mode, ., Water Sources ,„„ Hydrooeo.ogy „ WAG 3






Raver flowed dunng most of 1997 and 1998  At,and  'V^'^ ^ 3t INTEC- however the B.gfost
alluvmm ls composed of gravelly medium t«         °e' 3S much as 18-2 ™ (60 ft) of stuS
                                                                -
                        ^^^

                                  5-1

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                                     INTEC
                                   "i
             
       Legend
                                         I MX) Feel
                                                          D,iwDrj*n August 1*. !
Figure 5-1. 100-year floodplain map at [NTEC (L'SGS 1998).
                                      5-2

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   5000
  4900
  4800
 4700
  4600-
 4500 -
 4400 -
  4300
 4200-
4100 -
             A
                                           Percolation
                                             Ponds
	    Tank      Big LOS<
co    c          River
to    rsrm          OT
o
A

T"~
CM
                                                                                                    4175
                                                                                              K  7-  4163
                                                                                                             f-5000
                                                                                                             -4900
                                                                                                             -4800
                                                                                                            -4700
                                                                                                            ,_4600
                                                                                                            -4500
                                                                                                            -4400
                                                                                                           -4300
                                                                                                             4200
                                                                                                             4100
                                                                                                                                      A'
 Figure 5-2. Cross sect.on untie vadosc /one at the INTEC illustrating the generalized movement of vvaier from III,- -,ui foe to llic juuilcr WJ
 on AnJurson I99I.                                                                 '
                           Vertical exaggeration X 9.5
                               Saturn is sea level
                                     FEET
                        0        1000      2000     3000

                        0      250    500     750
                                     METERS

                        I ..  . 1 Basalt


                                Perched water

                                Contamination
                                 Inferred stratigraphy
                        Note: See Table 5-1 for the estimated
                        wciLii-s of recharge from ths different
                        sources.
                                                                                                                                                  5-3

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  based on drilling logs. Each modeled interbed zone consists of multiple noncontiguous sedimentary units
  that were lumped together to preserve total sediment thickness.                      caimentary un.ts

  5.1.1 1    Recharge Sources. Perched water bodies are known to exist beneath the INTEC
  Perched  water bodies are present beneath the percolation ponds and the INTEC plant facilities including
  the Tank Farm. The uppermost perched water zone identified at the INTEC occurs within the Big Lost
  nah™?TUm    A f  basalt.  The source of water creating these perched water zones include both

   re^ itad^TndThe Bi     eS>        ^'^ "** recharge sources at the INTEC ™^&

  ?mwvli0n P.°nd^ (SC7iCe WastewatCr P°nds)' W3ter System leakTse^^Sm ponds^lalScL
  .mgat.onunl.ned surface water drainage ditches, steam condensate, and CPP-603 basins  Table 5-1
  source  R "iT^n V°JUme f W3ter recharSinSthe Perched wa*r bodies at INTEC from the various
  sources.  F.gure 5-2 .llustrates the occurrence of the interbeds beneath the INTEC and the associated
  ondI   ^—-r-20nCS"          St perched water body in the southern INTEC results from
       The percolation ponds and the Big Lost River are the primary sources of recharge to perched water
 composing about 91% of the total recharge at the INTEC.  The percolation ponds conSbuteTbout 70%
 of the total perched water recharge. Percolation Ponds 1 and 2 are located outside the INTEC southern

               °eaStf C        "
                                                         U"Iined
                                                                                        of
            5.2    Conceptual Model of Contaminant Distribution
                                  and Transport at WAG 3

      Figure 5-3 is a conceptual drawing showing the main contaminant sources and transport
              T° 3> ,Wa? flltrating fr°m thC SUrfaCC t™^rt» contam,nanTs be'een
            surface soils and the SRPA. Contaminants present in the recharge water and perched water
 orioST      Va^ 2°ne ^ Primarily Sr-9° 3nd tritium'  Contam.nat.on in the lower
portion of the vadose zone is different m composition and concentration than the upper zone  The lower
S^t J°SS?^ Water Waf,influenced and Partia»y contaminated as a result of L events during
Ton'   h   ^H  ,  mjeCtr We" (CPP'23) C°"apSed and Service ^stewater was released mto the vaLe
zone above the lower sed.ment unit, Addit.onal contamination in the lower perched water zone 1S the
Source
Service wastewater (percolation ponds)
Sewage treatment ponds
Water system leaks'
Landscape irrigation1
Precipitation infiltration
Steam condensate
CPP-603 Basins
Big Lost River
Total
J Ostimaie based on past leaks and irrigation practices Actual loss
Volume
(gal/yr)
690,000.000
14,974,228
3,973,202
1,299,470
64.957.269
1,668.327
49.275
202.564.301
979,486.072
from piping leaks is noi known
nc.
Volume
Percent
70.4
1.5
0.4
0.1
6.6
02
<0 1
20.7
100

                                          5-4

-------
           INTEC
           Northern
           Edge
        Big Lost
         River
                                INTEC
                               Facilities
                        INTEC
                        Southern
                        Edge
Air Exposure
                                Tank
                                Vaults
                            Perched Water
Groundwater Exposure
    ~	
                                  Percolation
                                    Ponds
                                                   •Recharge
                                                        I ^     Ecological
                                                                 " "i Factors
                                                  Direct Contact  SurfldaJ Soils
                                                  	-.Route	-	
                                                                 Perched Water
                              Perched Wate
                                                       Perched Water
                                                                                      Fractured
                                                                                       Basalt
      Snake River
      Plain Aquifer
                            Groundwater Flow Direction
Figure 5-3. INTIiC'siicconcc;
conceptual model.
                                                                                                 GT990062

-------
 result of the transport of contaminants from the alluvial soils and upper perched water contamination
 The lower vadose zone contamination includes Cs-137, Sr-90, plutonium, 1-129 and mercury. Although
 contaminants are locally present in perched water, they are generally not available for consumption
 because of limited availability of that water. There are no water supply wells m the perched zone  Wells
 installed in the perched zone would not be capable of sustaining the pumping rates needed for future
 domestic water supplies. Furthermore, following this ROD's perched water remedies, the elimination and
 absence of man-made recharge will greatly reduce the primary recharge sources of perched water.  As
 such, the perched water does not pose a direct human health threat, but impacts aquifer groundwater
 quality because it is a contaminant transport pathway between the contaminated surface soils and the
 SRPA

       The SRPA has been contaminated by historical INTEC operational waste disposal activities.
 Release site CPP-23 (OU 3-02) consists of the  former INTEC injection well, which was the primary
 means of disposing of service wastewater from 1952 to 1984 and is the primary source of contamination
 in the SRPA at INTEC. In 1984, the well was removed from routine service and wastewater was
 subsequently discharged to the percolation ponds. After 1984, the well was used for emergency  purposes
 in 1986, and was permanently sealed in 1989.

      Radionuclides that were introduced into  the aquifer from the former injection well include Pu-23S.
 Pu-239, Pu-240, Sr-90,1-129, and  tritium. Of these, tritium was the most common, comprising about
 96% of the contaminant activity. At the time of injection, the radionuclides were generally below
 federally regulated levels. The injected wastewater also contained other (nonradioactive) chemicals
 including arsenic, chromium, mercury, and nitrates at concentrations below federal and state groundwater
 quality standards.  Mercury, however, is estimated to exceed groundwater quality standards in the
 immediate vicinity of the former injection well but has not been detected in downgradient wells.

      Subsequent migration of these contaminants has produced several overlapping groundwater
 contaminant plumes, containing tritium, Sr-90,  and 1-129 currently occurring in groundwater beneath
 INTEC and extending downgradient for several miles (Figures 5-4, 5-5, and 1-7).  Short-lived (<30 year
 half-life) radionuclides, such as tritium, do not pose a long-term risk. Strontium is predicted to persist in
 the aquifer beyond 2095 at levels above the MCL if no action is taken. 1-129 has a very long halt-life and
 is predicted to persist in the aquifer at concentrations exceeding  MCLs.

      Leaching and transport of Tank Farm soil contaminants poses an additional future risk to the
aquifer from Sr-90 and other contaminants (see Section 7). An evaluation of these risks and possible
remedial actions for the Tank Farm soils is the focus of the OU 3-14 RI/FS.

      The human health and environmental threat posed by the contaminated aquifer is groundwater
ingestion. Based on the groundwater simulations presented in the RI/FS, the contaminant plume  is not
expected to migrate beyond the INEEL boundary at concentrations exceeding MCLs The plume  does not
present a threat to off-INEEL drinking water users. The remedial action objectives will assure that the
aquifer meets MCLs within the INEEL boundary by 2095. As the plume gets further from INTEC. it
becomes more dilute, and by the time it reaches the INEEL boundary the MCLs are no longer exceeded.

      The aquifer beneath the INTEC fenceline will be evaluated in OU 3-14.  The focusofOU 3-14 will
address aquifer contaminants from  the injection well (CPP-23) and the Tank Farm. Other sources of
aquifer contamination inside the INTEC fence will also be investigated as part of OU 3-14, as necessary
                                              5-6

-------
                          Tritium concentrations (pCi/L)
  1 The ibuttwd 10 produce these
     i came JjrrcUy rmm UK
  Infnmuuon Sydcm (l-RIS)
      iver Man
      SWGtacic
     sfcral hy KM Amen.
Area covered by map
                                    1000  2CXX>  3000  4 5000 Fat
                                                                     2 Miles
Figure 5-4.  SRPA tritium plume (1995 data).
                                           5-7

-------
                   Strontium-90 concentrations  (pCi/L)

                                                                    Area covered by map
  Naa
  I nieMri.rcrSrJ«l»lliCifl.
     s one dtrcnly ^mm tfie
  Itnwnwnenul Roumum
  MmiuiKX S)Unn lERISI
     « js tuund in Uv
     Ri«r Pt«n A
                             I)    UXX)   2(KX)  .1000   4(XX)  5(XX)F«l
                                           I
                                                                      2 Miles
Figure 5-5. SRPA Sr-90 plume (1995 data).

-------
                     5.3    Nature and Extent of Contamination

        The nature and extent of contamination at the WAG 3 release sites determined to present an
  unacceptable risk or threat to human health or the environment are described below, by site group  These
  sites have actual or threatened releases of hazardous substances, which, if not addressed by implement
  the response actions selected in this ROD, may present imminent and/or substantial endangerment to   =
  public health, welfare, and/or the environment.  The detected contaminants of potential concern for each
  group or site are summarized.

  5.3.1    Tank Farm Soils (Group 1)

       Based on the results of drilling and sampling at previously identified release sites, the horizontal
  extent of contamination is generally localized at the site of the spill or leak, but, in some cases,
  contamination has been found to extend vertically to the soil/basalt interface at approximately 14 m
  (45 ft) bgs. Contamination has also been found along gravel lenses within the Tank Farm  Some spills
  and releases were cleaned up and excavated soils were replaced with contaminated backfill
  Contaminants released to the soils are suspected to have migrated into the underlying basalt and the
  SRPA. Because current information regarding the nature and extent of Tank Farm contamination is
  inadequate to support selection of a final remedy, a separate RI/FS for the Tank Farm is underway  The
 OU 3-14 RI/FS will further investigate contamination at the Tank Farm and develop alternatives for a
 final remedy. An mtenm action for the Tank Farm soils is presented in this ROD. Soil contaminat.on at
 the Tank Farm is summarized in Table 5-2 except data from sites CPP-16, CPP-24  and CPP-30 which are
 classified as "No Action" sites.  All the Tank Farm sites are shown in Figure 1-3. The Tank Farm soils
 are considered principal threat wastes.

       The major radionuclide contaminants in the Tank Farm soils are Am-241, Sr-90  Cs-137 Eu-154
 Pu-238, Pu-239/240, Pu-241, and U-235. Nonradionuclide contaminants include mercury and nitrate.

      Tank Farm sites with wastes derived from spills associated with the INTEC liquid waste treatment
 system wtil be assigned four EPA listed waste codes (F001, F002, F005,  and U134). The wastes will also
 be evaluated to determine  if they exhibit hazardous characteristics.  The results of the investigations
 performed to date indicate that the principal threats posed by the Tank Farm Soils sites are from external
 exposure to surface and near-surface radionuclides and from future ingestion risks from leaching and
 transport of radionuclides to the SRPA.  In addition, nonradionuclide constituents may be present m Tank
 Farm soils; the presence of such contamination will be addressed in the OU 3-14 RI/FS.  Known releases
 to the Tank Farm include a number of separate documented release sources as  follows:

 5.3.1.1    CPP-15.  The solvent burner at Site CPP-15 began operation in the late 1950s and was
dismantled m 1983. Before the solvent burner, a stack preheater was located at this site.  Waste solvent
primarily kerosene and tributyl phosphate degradation products contaminated with low levels of
radionuclides, were held in the tank and piped to the solvent burner for disposal.  Demolition of the
solvent burner occurred in  late 1983 including removal of the furnace/burner unit, furnace duct control
shed, pipmg, valves and controls within the shed, and piping penetrating the shed. In addition, an
unknown amount of contaminated soil was removed along with the solvent tank.  In September 1995
LMITCO construction personnel encountered elevated radiological readings while conducting an
excavation in the western half of the sue.  Six soil samples were collected in the area of the contaminated
footing. Based on this sampling, contaminants of potential concern (COPCs) identified for this site
include thallium, zirconium. Am-241. Cs-137, Eu-154. Np-237, Pu-238, Pu-239/240, Tc-99. and U-235.
                                             5-9

-------
Table 5-2. Summary sampling results statistics for Tank Farm (Group I) soil contaminants.
Soil Concentration
(nig/kg [nonradionuclide] orpCi/g [radionuclide])
C'onlaminanis
Ag
As
Ba
Be
Cd
Co
Cr
V C'u
5 »fr
I'b
Mn
Ni
Se
Sr
Th
V
Xn
/.r
Fluoride
NuiaiL-
Minimum
2.80E-01 B
2.80E+00 J
4.45E+01
2.43E-02
2.20E-01 B
1.86E+00
l.OOE+OOJ
7.38E+00
2.00E-02 J
4.80E+00
9.15E+OI
1.34E-OI J
5.10K-01 J
3.61E+03
4.85E+00
9.10E+OOB
3.20E-KH
5.I3K»00
5.30I--01
3.50I--UI
Maximum
1.15E+OOJ
6.80E+OOJ
I.93E+02J
4.50E-01
1.12E<-OI J
4.40EK)OB
!.13Ef02J
I.28E^01
4.44I-+00
3.17E<01 J
1.18E*05
1.94E+01 J
8.00E-01 B
3.61E+03
4.85E+00
I.85E+01
5.55EtOl
I.40E+OI
6.72E-IOOJ
8. 101- (00
Arithmetic
Mean
6.54E-01
4.25E+00
9.06E+01
2.84E-01
3.84E+00
3.33E+00
2.05E-KH
9.92 EiOO
3.03E-01
I.17E-»OI
5.08E+03
I.35E+01
6.97E-01
3.61E403
4.85E+00
I.47E»01
4.18E+OI
8.61 E <00
].70EiOO
l.681£<00
Standard
Deviation
I.78E-01
9.25E-OI
4.39E+01
1.49E-01
3.39E+00
6.47E-01
2.07E+01
1.81E+00
6.32E-01
6.82E+00
2.42E+04
4.03E+00
1.62E-01
NA
NA
2.77E+00
6.98E+00
3.55E+00
1.14E+00
1.541- +00
RMEb
1.01E+00
6.10E+00
1.78E+02
5.82E-01
1.06E-H)!
4.62E+00
6.19E+01
1.3SE+OI
1.57E+00
2.53E+01
5.35E+04
2.16E+01
1.02E+00
NA
NA
2.02E+01
5.58E+01
1.57E+01
3.98E-HX)
4.76E+00
Number
of
Samples
50
50
50
16
83
16
58
16
95
50
24
24
34
1
16
17
16
5
41
54
Number
of
Detects
35
47
50
15
53
16
58
16
59
50
24
24
3
1
1
17
16
5
40
51
Frequency
of
Detection
70%
94%
100%
94%
64%
100%
100%
100%
62%
100%
100%
100%
9%
100%
6%
100%
100%
100%
98%
94%
1NEEL
Background' .
(mg/kg or pCi/g) '
O.OOE+00
5.80E+00
3.00E+02
1.80E+00
2.20E+00
I.IOE-KH
3.30E+01
2.20E+01
5.00E-02
1.70E-KH
4.90E+02
3.50E+01
2.20E-01
NA
4.30E-01
4.50E+01
1.501-+02
NA
NA
NA
Number of
Samples
Greater than
Background
35
3
0
0
34
0
10
0
53
10
1
0
3
NA
1
0
0
'. NA
NA
NA

-------
Table 5-2. (continued).
Soil Concentration
(mg/kg (nonradionuciide) or pCi/g [radionuclide])
Contaminants
Methylene
Chloride
Toluene
Trichlorocthane
Am-241
Ce-144
C:o-60
Cs-134
Cs-137
E-u-154
11-3
Np-237
Pu-238
Pu-239/240
Pu-241
Pu-242
Ru-106
Sr-90
Tc-99 '
1 1-234
I I-23S
U-2.U)

Minimum

5.90E-03 JB
1.00E-03J
I.OOE-03J
6.00E-02
I.44E + 01
9.00E-02
1.30E-OI
4.78E-02
I.54E-01 J
2.49E+04
I.OOE-01 J
2.99E-02
2.58E-02
1.05E»06
3.20E*01
6.66E-02
1.60E-01
9.00E-OI
7.00E-02
2.031--02
7xSI:-OI

Maximum

9.10E-03JB
2.00E-03 J
4.60E-03J
1.66E+04J
I.44E+01
2.27E+04
7.55E+04
1.02E+08
5.65E+05
2.49E+04
1.63E+00
2.76E<05
I.26E+04
1.05E+06
3.20E+01
5.41E+01
5.68E+07
3.67E+OI
2.l2EiOI
(>.OOIit03
7.55I--01

Arithmetic
Mean

8.08E-03
I.14E-03
2.80E-03
6.25E+02
l.44Et01
1.81E+03
5.40E+03
I.31E+06
1.65E+04
2.49E+04
5.12E-01
8.25E+03
1.08E+03
1.05E*06
3.20Ei01
2.7 IE-* 01
7.02E+05
4.40E+00
9.85E-01
7.7()I-t02
7.55E-OI

Standard
Deviation

1.31E-03
3.78E-04
2.55E-03
3.08E+03
NA
6.28E+03
2.02E+04
1.02E+07
9.54E+04
NA
4.94E-01
4.73E+04
3.35E+03
NA
NA
3.82E+01
5.97E+06
1.02E+01
2.75E+00
2.17E*03
NA

RMEb

1.07E-02
1.90E-03
7.90E-03
6.79E+03
NA
I.44E+04
4.58E+04
2.17E+07
2.07E+05
NA
1.50E+00
1.03E+05
7.78E+03
NA
NA
1.04E+02
1.26E+07
2.48E+OI
6.49E-KH)
5.11E+03
NA
1> ^\
Number
of
Samples

5
22
6
64
12
41
41
119
45
1
46
64
70
1
1
31
93
12
63
53
i
i
Number
of
Detects

5
7
2
29
I
13
14
111
35
1
14
34
26
1
i
2
91
12
61
19


Frequency
of
Detection

100%
32%
33%
45%
8%
32%
34%
93%
78%
100%
30%
53%
37%
100%
100%
6%
98%
100%
97%
36%

1 00%
INEHl.
Background1
(mi>/ki> or oCi/o)
x o o r*- "£/
NA
NA
NA
1.IE-02
NA
NA
NA
8.2E-01
NA
NA
NA
4.90E-03
1. 001- -01
NA
NA
. NA
4.90E-01
NA
1.44E-IOO
NA

NA
Number of
Samples
Greater than
Rn(*K (>r/\t in/~l
ua\* R.JJI UUIiU
NA
NA
I '/»
NA
29
NA
NA
NA
99
NA
NA
NA
34
17
NA
NA
1 1/\
NA
85
NA
3
NA

NA

-------
Table 5-2.  (continued).
                                                 Soil Concentration

Contaminants
U-238
Gross Alpha
Gross Beta

Minimum
4.5IE-02
5.20E+00
3.60E+OI

Maximum
I.39E+00
I.20E+01
6.89E+02

Arithmetic
Mean
5.42E-OI
7.35E+00
1.62E402

Standard
Deviation
4.31E-01
2.19E+00
1.86E+02
— -
RMEb
1.40E+00
I.I7E+01
5.34E+02

Number
of
Samples
63
II
11

Number
of
Detects
58
11
11

Frequency
of
Detection
92%
100%
100%

1NEE1
Background'
(mg/kg or pCi/g)
I4E400
NA
NA
Number of
Samples
Greater than
Background
0
NA
MA
       NOTI-.
          Duplicate sample results were not included in the statistical analysis
                                                                           R'/FS Part A (DOE'ID'
                                                                                                          rouP ' Siles: ('pp-'5- -20. -25. -26. -27, -28. -Jl, -J2A, -32U. -JJ. -58A
                    ci;^^
      •   Samples rejected because ol'an unacceptable quality control parameter are not included in the table.
 b    The RM1-. concentration is lhe 95% upper value based on the empirical rule <95%of the measurements lie within two standard deviations of their mean)
U
J
NA
       I he INI-I-.I background concentrations represent the 95% upper confidence limit (Rood et al. 1 995)
       -   The analyte reported value is 
-------

   transferred to an underground storage tank before concentration m the PEW Evaporator  ItltoZ that
                                                                       of less than 2. It has been
                                                                         of leaks in the hoses. The

 though the fil, so,l 1S beueved to be %£££!£££?£
 containing trace quantities of radioactiV1ty during the 1 980s.
 ff m'^18 fl"te CPP"24 'V003^ '" thC Tank Farm and consists of a" ^ea of approximately

      The eastern portion of Sue CPP-25 overlaps the area of Sue CPP-20.  The transfer line that was
be,ng used to transfer hqu.d waste from VVC-1 19 to WL-102. ruptured on August 28 11960 conta^at.g
                                             5-13

-------
 the soil adjacent to the building. According to direct radiation readings at the time of the incident, the soil
 was initially contaminated to levels of 2 x I0~w R/hr. Approximately 7 m3 (9 yd3) of contaminated soil
 was removed and taken to the RWMC for disposal. No records exist to verify the effectiveness of these
 cleanup activities. However, during 1981 and 1983 the entire site was excavated during Phases I and II of
 the Fuel Processing Facility Upgrade Project. This excavation included the eastern portion of sites
 CPP-20 and CPP-25 as discussed above. Fill materials placed back into the excavation consisted of 3 mR
 material in the bottom of the excavation and clean soils in the upper 9.1 m (30 ft).

       Contaminated soils at Site CPP-25 are believed to be confined to soil with gross radiation readings
 of 3 to 5 mR placed at depths between 9.1 to 12.2 m (30 to 40 ft) during upgrade projects in the 1980's.
 Soil above a depth of 9.1 m (30 ft) was reportedly clean fill.  Because of the lack of confirmatory soil
 sampling in the area, sample results from previously excavated Tank Farm soil will be assumed, for the
 purposes of the BRA, to be representative of the soil beneath both sites CPP-20 and CPP-25.

 5.3.1.6     CPP-26. CPP-26 consists  of soil potentially contaminated by a 1964 release of radioactive
 steam that was inadvertently released to the air through a faulty hose coupling on the decontamination
 header. The volume of radioactively-contaminated steam that was released at Site CPP-26 is unknown.
 The release is assumed to have contaminated the land surface of approximately 13 acres to the northeast
 of building CPP-635.  However, in an approved Track 2 NFA recommendation, the scope of the
 CERCLA investigation was limited to that portion of the site inside the Tank Farm. The original land
 surface at the time of the release (prior to membrane installation) is now located at a depth of 0.7 m
 (2.5 ft) bgs.

 5.3.1.7    CPP-27 and CPP-33. Sites CPP-27  and CPP-33 consist of contaminated soil associated
 with subsurface releases of HLLW from the Tank Farm transfer system near the northeast comer of
 building CPP-604.  These sites were determined to be related to releases from the same source and,
 therefore, are being addressed as a single release site. Following cleanup, it was estimated that 25  mCi of
 radioactivity in soil remained in place (WINCO 1993i).

      In 1983, additional contaminated soil was discovered.  This additional contamination, thought to be
 the result of a separate release from the same transfer line, was designated CPP-33. Cleanup efforts in
 1983 removed approximately 10,710 m3 (14,000 yd3) of contaminated soil. Of this total, approximately
 1,530 m3 (2,000 yd3) exceeding 30 mR/hr of beta-gamma radiation was removed and placed in trenches.
The soil in these trenches is addressed separately as Site CPP-34 (Section  18). After the 1983 excavation.
 the CPP-33 area was backfilled and trace amounts of radioactively contaminated soils were reportedly left
 in place below, and lateral to the excavated area (WINCO 1993i).  It appears that the majority of
contamination is located in the southwest portion, of the site where levels as high as 30 mR/hr were
measured below a depth of 6.1 m (20 ft).

 5.3.1.8    CPP-28.  The contamination at Site CPP-28 was discovered in 1974 during the installation
of a cathodic protection electrode in the Tank Farm area. Soil with radioactive contamination up to
40 R/hr was encountered at a depth of about 1.8 m (6 ft) bgs.  The leak was later determined to be from a
0.3 cm (1/8 in.) diameter hole inadvertently drilled through one side of the 7.6-cm (3-in.) diameter
stainless steel pipe during original construction in 1953. The HLLW consisting of first-cycle raffinate
most likely leaked through secondary containment to the surrounding soil.  In late 1974, approximately
45 m3(56 yd3) of contaminated soil having an estimated 3,000 Ci of gross radioactivity was removed
 from the area above the pipeline leak. No contaminated soil was removed from below the pipe
encasement due to high levels of radioactivity in the soil. The excavated area was subsequently
backfilled.
                                              5-14

-------
   "                         '" "'      '     <20 ' 20 ft> '"* »f =«ice so.l contam,M,,on
                                     ^
                    1 8 !°a!8
                                                                                   ae
  5.3. If f   CPP-32. Site CPP-32E is an area of contaminated soil southwest of valve bnx R d  Th,c













  o n , to a depth of about 0.3 m ( 1 ft). The contaminated material apparently originated from a 5 I cm
                               ^^^
5.3.2   Soils Under Buildings or Structures (Group 2)
















.he  o,l>. ,nou,c. thc> be ava,!ab!e tor exposure and contmued leachmg of contaminants to the SRPA.  The
                                           5-15

-------
 c\: currcntlx an' :ncomp:e:c patinxax and :he leachmu is bcum controlled bv the
 P^CKCC 01 ihohutldiny.uhich limits miiliraiiun.                        "                    '

 ,  ,  The Soils Lnder Bu'IdinJ?s or Structures group is comprised of release sites in OUs 3-09. 3-1 .t and
 .'-I.' that occur beneath INTEC buildings or structures, and includes Sites CPP-02. -41 A. -60, -68. -SO.
 -N>. -S6. -s~. and -S9 (Figure 1-5). These sites consist of soil contamination that resulted from past
 h.i/ardou-, ur radioactive liquid spills. leaks, and plain operations and are considered low-level tlux-it
 \\a>ies.

       I he individual release sites comprising Ciroup 2 include:

 5.3.2.1     CPP-02, French Drain West of Building CPP-603:  14.000.000 L (3.698.408 »al) of
 hasm xxater \\as disposed per year. An estimated 493 Ci was released with the major isotope beinii
 tritium. The Graphite fuel storage building was constructed over this site.  The site has not been sampled
 If not for the depth of release and the presence of the graphite fuel storage buildinc. this site  would pose -i
 threat due to external exposure. Modeling performed during the Rl FS  indicated that this site presents -i *
 grmmdxxater risk. Currently the leaching of contamination is being controlled by the building limiting '
 inllllralion.  Should the building be removed this contamination will present a direct exposure risk and
 increased groundsater risk.

 5.3.2.2    CPP-41A.  Site CTP-41A is one of two pits where oils and organic materials were placed in
 metal drip pans and ignited for fire brigade practice. The training pits are no longer in use. CPP-41A is a
 pit that has been covered with asphalt and. because it is close to building CPP-663, it is suspected of
 having been excavated and removed during construction of CPP-663.

 5.3.2.3    CPP-60. Site CPP-60 is a small cinder block building commonly referred to as  a paint shop
 Inn xxa* actually used to house hazardous materials.  It was suspected that during paintbrush cleaning
 Mihents were discharged to the surrounding soil. The building \\as removed in*the I970's and .CPP^645
.in office building, is nou located oxer the area. No samples xxere collected to confirm the existence or
.licence of contamination at this site (WINC'O 19920.

5.3.2.4    CPP-68. Site CPP-68 is the former location of an abandoned 1.892 L (500 gal) under»round
gasoline storage tank. Use of the tank xvas discontinued in 198? and the tank was removed  in 1986=
During exhumation of the tank, there xvas no visual evidence to suggest that the tank leaked. There arc no
opcuting records prior to 19S3 or records of -pills associated \x nh the operation of this tank.  A smJle
>.impie oi the tank bed soil xxas analyxed and found to contain only traces of gasoline ran»e onianic"
cor.-.::u;c:il< th.it did not exceed risk-based !c\c!s.  hi addition, \ >ual examination of the Tank  bed soil du1
 I'.oJ «.:.:geM tank lc.ik.iuc i \V1NV()  199?gi.

 5.3.2.5    CPP-80, Building CPP-601 Vent Tunnel Drain Leak:  Soil contamination  resulted
 Iroin leakage of corrosive condensate from a cast iron underground line.  No soil sampling xvas performed
 due to the  inaccessibility of the site. Approximately 397.468 I. (105.000 gal) of condensate containinu
 550 d of radionuchdes xvere estimated to haxx* been released to the soil  betxveen 1983 and 1989. The"'
 leaked contaminants haxx> been observed in the 34 m (110 ft I perched water.  Due to the depth of the
 rolea^ and the presence of Building CPP-601  this sue only presents risks via'the uroundxvater exposure
 pathxxax. Modeling performed during the RI  FS indicated that this site presents a^minor siroundxxaier
 -:-k  Jn»r p-.irpo.cs .if^mnJ^awr modeling. :i'.e :«.venior>- for tins .«M:.V!. -.he :ii!ild::ig be reir.oxx-d. ;h;s co:v,am;r.at:on «ill present a direct exposure risk and
 •r.c:oa>v\! jroundwater risk. Should the bi;:;dmg be remoxed ihi- contamination would pose an external
 expo>ure risk and a minor increased groundxxater r-^k.

-------

  S.J   A A  u TT   7.     excavatl<>n included an area immediately south of CPP-604 as well as


                                       '                        -  Soils       "8 - ™
            in Tab,c „.

 5.3.3   Other Surface Soils (Group 3)

                                                                               cpp-
radionucluie-contaminated soils that were generated as a result of a vanery o  MTEC ^a^v^es
the rKultSof dr,iBH, " T S"CS'h'™ deK™'"1:d *E ««"' of soil conaminatran.  B,Scd .on
                  -
                                           5-17

-------
'" S°" C°ntaminants at Sile CPP-89 (excavated so,! was placed ,n«o boxes that are currently
Soil Concentration
(mg/kg Inonradionuclide] or pCi/g [radionuclide])
Number
Standard of
Contaminants Minimum Maximum Mean Deviation RMEb Samples
As l.60E-tOOB 5.90E+00 4.11E+00 1.25E+00 6.61E+00 15
Hg 6.00E-02B 1.04E+01 1.49E+00 2.90E-tOO 7.29E+00 17
Sc 2.IOE-01B .IOE-01B 3.20E-01 l.OOE-OI 5.20E-01 16
Am-241 2.00E-02 2.36E+01 2.83E+00 6.58E+00 1.60E+01 14
Co-60 3.90E+00 3.90E+00 3.90E+00 NA NA 1
Cs-134 2.30IitOO 2.30E+00 2.30E+00 NA NA 1
Cs-137 1.40K-OI 7.73E+03 1.25E+03 2.70E-I-03 6.65E+03 14
1-129 3.1 OF. tOO 3.IOE+00 3.10E+00 NA NA |
Np-237 I.50E-01 I.50E-01 1.50E-01 NA NA 1
l>u-238 2.00E-02 ' 2.59E+02 3.83E+01 8.86E+01 2.16E+02 14
I'u-239/240 O.OOE'OO 2.47E+01 3.30E+00 7.57E+00 1.84E+01 14
Sb-125 1.30E+01 1.30E+01 1.30E+01 NA NA 1
Sr-90 3.00E-01 1.08E+04 1.48E+03 3.02E+03 7.52E+03 14
U-234 S.lOF.tOO 5.10E-tOO 5.10E+00 NA NA 1
U-235 2.301--01 2.30E-01 2.30E-01 NA NA i

a NOIli:
• Duplicate sample results were not included in the statistical analysis
— ^ .
Number
of
Detects
15
15
4
14
1
I
14
1
1
14
14
I
14
1
1



	 . 	 , —
	
Number of
INEE1. amples Greater
Frequency Background0 than
of Detection (mg/kg or pCi/g) Background
100% s soK+nn
88%
25%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
ioo%
100%


• Analytical results used in this table are samples collected from boxed soil from the 1991 -1 992 emergency fire exit excavation at building 604/605 ((
5.00E-02
2.20E-OI
1.IOE-02
NA
NA
8.20E-01
NA
NA
4.90E-03
1E-OI
NA
4.90E-01
1 .44E+00
NA


TH-89)
. Samples were analysed lor VOCs, morgamcs, and rad.onuchdes Only those constituents identified ,n Appendix 0 of the OU 3-13 RI/HS Part A (IX)K-ID l'W7b) are show,, ,„
• Samples rejected because of an unacceptable quality control parameter are not included in this table
t
1


NA
i I/A
| i
i i
NA
tin
NA
IN/\

NA
i*tf\
n
i j
NA



this table
h The RMI- cuncciiiiaiHm is Ihe 95% upper value based on the empirical rule (95%of.he measurements lie within two standard deviations of their mean)
c Hie INhl-.l backgrouiul concentrations represent the 95% upper confidence limit (Rood et al. 1995)
H - The analylc reported value is *-RI)l., but >IDI..
1 1 he anal)tc «ah uleiililied in ihe .sample but the numerical resuli may not be accurate
NA Not Applicable
KMi Kca.stiiuhlc NtuMinuin I'XMOMIIC





















-------
  rr^ Because of the general]y small area and contaminant mass of most of these sites, the quantities of
  COCs present at most sites do not pose a threat to groundwater.  However, several sites have significant
  sources at or near the soil basalt interface.  For those sites there is a minor threat to groundwateflhe
  COCs at these sites include both radionuclide and nonradionuclide contaminants.

  5.3.3. 1    CPP-35 (Building 633 Decontamination Spill).  Site CPP-35 resulted from a spill of
  decontamination fluid that entered the WCF air transport system and was released to soil  Th,s release
  was estimated to have a contaminated area of 1 1 1 m2 (1200 ft2).  The release was approximately 38 L
  (10 gal) of solution containing nitric acid, mercuric nitrate, heavy metals, fluoride, nitrates, and as much
  as iU u of total activity. Contaminated soil and gravel were removed and shipped to the RWMC for
  disposal.  Sampling results data from the Track 2 investigation are summarized for CPP-35 in Table 5-4
  No contaminants were detected below 2 m (7 ft).
  Stem ™°T36 ^ontemmaterf Soil Southeast of the INTEC Stack). The contamination at
  Site CPP-36 is the result of the three separate releases, which are described below:

        1 .     In 1 970, the calciner offgas lines between the WCF and the stack were excavated  Highly
             contaminated soil (up to 20 R/hr) was encountered at a depth of 1.8 m (6 ft) beneath Olive
             Avenue.  The exact location of the release source is unknown. According to records  the
             contaminated soil was excavated and disposed at the RWMC. Clean fill was used as
             backfill.

       2.     In October 1 974. contamination was encountered under Olive Avenue during excavation for
             installation of lines. This contamination apparently was the result of waste that flowed out
             of an onficecorroded by nitric acid. The waste was probably from liquids being transferred
             from  Tank WC-1 19 (sump tank at the WCF) and Tank WC-102 (PEW evaporator).

       3.     In November 1974. 2,840 L (750 gal) of solution containing an estimated 4 Ci of total
            activity leaked into Valve Pit MAH-OGF-P-04.

 i 074 IW° quant,ltatlve sar"Pling events were undertaken at this site before the Track 2 investigation  In
 1 974, three samples were collected from the excavation under Olive Avenue and analyzed for
 radionuc ides  The depths from which the samples were collected cannot be established from available
 reports. In 1 99 1 , samples were collected from four boreholes (Colder Associates 1 992)  The boreholes
 were drilled to amaximum depth of 1.8 m (6 ft). The samples were analyzed for VOCs, metals and
 radionuchdes. The VOCs were not measured above detection levels.

      The Track 2 investigation involved installing seven "observation wells" to measure  subsurface
 radiation levels and the drilling and sampling of two boreholes.  Samples from the boreholes were
 analyzed for selected metals, nitrate and nitrite, fluoride, PH, and radionuclides. Summary sampling
 results statistics for data from CPP-36 is provided in Table 5-5.  Based on the result of investigation's
 conducted at Site CPP-36. the zone of contamination is assumed to extend from the ground surface  to the
 soil/basalt interface at about 12.8 m (42 ft).  This depth is based on high activity levels measured  m the
deepest samples collected from borings CPP-36-1 and CPP-36-2. Results from the "observation wells"
show elevated radiation levels to at least 7.6 m (25 ft) below ground surface (bgs).

      The area of CPP-36 is shown in Figure 1-5.  The initial area was expanded because "observation
wells located at the boundaries of the area indicate radiation levels above background.  In addition  the
CPP-36 area has been extended to the southeast to incorporate Site CPP-91. Investigative r-ults  indicate
contamination at CPP-91 to be indistinguishable from CPP-36.  The rev.sed area of Stte CPP-36 ,s about
 /4s m" (8.052 ft").
                                             5-19

-------
Table 5-4. Summary sampling results statistics for soil contaminants at Site CPP-35 '
Soil Concentration
(ing/kg Inonradionuclide] or pCi/g [radionuclidej)

Contaminants
Mercury
Cadmium
Am-241
Cs-137
Eu-154
Pu-238
Pu-239/240
Sr-90
1 1-234
1C l1'235
0 1 1-238
(iross Alpha
dross Beta

Minimum
5E-02 B
1.40E+00
I.38E-02
2.14E-01
3.18E-01
7.93E-01
5.24E-02
7.52E+00
9.59E-OI J
5.20H-02
l.OlK-rOO
3.65I-+00
2.04EKH

Maximum
7.20E+00
1.40E+00
1.2IE+00
8.64E+03
II.80E+00
1.32E+01
7.25E-01
3.24E+03
1.02E+OOJ
7.20E-02
1.14E+00
2.02E+02
1.21 1- +04

Arithmetic
Mean
1.66E+00
1.40E+00
5.17E-01
6.63E+02
3.37E+00
5.44E+00
3.21E-01
5.77E+02
9.82E-01
6.03E-02
1.07E+00
2.76E+01
1.I4E+03

Standard
Deviation
2.49E+00
NA
6.01E-01
2.14E+03
4.81E+00
6.77E+00
NA
I.10E+03
3.32E-02
1.03E-02
6.51E-02
5.21E+01
3.19E+03

RMEb
6.64E+00
NA
1.72E+00
4.94E+03
1.30E+01
1.90E+01
NA
2.78E+03
1.05E+00
8.09E-02
1.20E+00
1.32E+02
7.52E+03

Number
of
. Samples
14
14
3
14
5
3
3
8
3
3
3
14
14

Number.
of
Detects
12
1
3
14
14
3
3
8
3
3
3
14
14

Frequency
of
Detection
86%
7%
100%
100%
36%
100%
100%
100%
100%
100%
100%
100%
inn%

1NEEI.
Background1
(mg/kg or pCi/g)
5E-02
2.20E»00
1.10E-02
8.20E-01
NA
4.90E-03
IE-01
4.90E-01
1.44E+00
NA
1.40E+00
NA
MA
Number of
Samples Greater
than
1 1

T
q
MA
7
2

o
NA
0
NA

M
J
NA
RMI
 •   I >uphcate sample re^ulls were not included in the sialislical analysis.
 .   Analyneal results used in diu, table are from samples colleced from two borings installed dunng the OU 3-08 Track II invesl.gaUon (WINCO I
 .   Samples were also analyzed for fluonde, pH. nitrate, nitrite, and K-40  These constituents are no, shown in this table because they are no, present a, hazardous concen.rat.ons
 •   Samples rejected because of an unacceptable quality control parameter are not included in this table.
The KMH concentration is the 95% upper value based on the empirical rule <95%ofthe measurements lie within two standard deviates of,heir mean).
 The INI-.lil background concentrations represent the 95% upper confidence limit (Rood et al.  1995)
  -  The analyte reported value is IDL.
  -  The analyle was, identified in Ihe sample but the numerical result may nol be accurate.
  -  Not Applicable
     Reasonable Maximum I'xpnsure

-------
T?.bJl5.-5. Jjummaiyjampling results statistics for soil contaminants at Site CPP-36.'
Soil Concentration
(mg/kgjmmradionuclide] or pCi/g Iradionuclide])

Contaminants
As
Ba
Cd
Cr
"g
Pb
Am-241
Cs-137
l:u- 1 54
1-129
Np-237

l'u-238
Pu-239/240
Sr-90
U-234
U-235
1 1-238
(iross Alpha
Gross Beta

Minimum
3.20E+00
6.76Ef01
8.10E-01B
9.60HiOO
I.20E-OI
7.20E*00
1.03EfOO
2.04E+01
8.75E-02
I.23E+00
4.00E-02

1.70E-01
7.00E-02
2.90E-01
l.OOE-OI
4.44E-02
I.20E-01
5.46EiOOJ
7.48HK)1

Maximum
4.10E+00
8.92EKH
8.40E-OI.B
I.49E+OI
1.66E+01
3.22E+02 J
7.63E+02
4.08E+05
4.74E+03
2.43E»02
I.90E+00

8.18E+03
3.24E-J02
5.13E+04
2.81E+00
9.95E-02
I.S4EiOO.-
2.751- *04J
2.51E«05
Arithmetic
Mean
3.69E+00
7.69E+01
8.25E-01
I.21E+01
I.43E+00
4.74E+OI
2.29E^02
2.93E+04
5.91E+02
6.33E+OI
8.90E-OI

I.82E+03
7.41E+01
2.8IE+03
6.54E-01
7.I9E-02
6.48E-01
3.73E-t03
4.50E<04
Standard
Deviation
•
2.59E-01
7.43 E^OO
2.12E-02
1.76EtOO
3.78E+00
1.IIE+02
3.63E+02
9.71E+04
l.SOE-t-03
1.20E+02
6.99E-01

3.58E+03
1.4IE+02
1.14E+04
7.95E-01
2.26E-02
5.94E-01
8.831: +03
9.85E+04

RMEb
— 	 	 -. 	
4.21E+00
9.18E+01
8.67E-01
I.56E+01
8.99E+00
2.69E+02
9.55E+02
2.24E+05
3.59E+03
3.03E+02
2.29E+00

8.98E+03
3.56E+02
2.56E+04
2.24E+00
1.17E-OI
1.84Ef-00
2.I4E+04
2.42E+05
Number
Samples
8
8
19
8
19
8
13
20
11
9
9

13
13
20
13
13
13
ll
11
Number
of
Detects
8
8
2
8
19
8
4
20
10
4
s
•J
5
5
20
13
5
13
11
11
Frequency
of
Detection
— — 	 	 	 „
100%
100%
11%
100%
100%
100%
31%
100%
91%
44%
c/;o/
->O7o
38%
38%
100%
100%
38%
100%
100%
100%
INEEL
Background'
(mg/kg or pCi/K)
5.80E+00
3EK»2
2.20E*00
3.30E+01
5E-02
I.70E+01
1.10E-02
8.20E-01
NA
NA
1 1/*
NA
4.90E-03
1E-01
4.90E-01
I.44E400
NA •
11/1.
1 40Fffl()
» .~V/l— I \J\I
K] A
IN/\
NA
Number of
Samples Greater
than Background

0
V7
o
\J
o
\J
10
1 f
1
1
70
&\)
K( A
NA
MA
INA

•
10
1 7
HI A
NA
K.I A
NA
NA

-------
Table 5-5. (continued)
                                Soil Concentration
                 [nig/kg jnonradionuclide] orpCi/g [radionuclide])
                                                  .     „   .  _,                Number   Number   Frequency        INEEl.           Number of
                                          Arithmetic    Standard                   of         of          of         Background'     S     ,1
H!!«:J.m!najy?..  Mjnimum,  Maximum     Mean __Dgvjajion     RME"     Samples   Detects   Detection    (mg/kg or pCiM   thanBa^kground
 a      NOII-                                                                              ~                    ~	—	
       •    I hiplicalc sample results were not included in the statistical analysis

       '    on firs1! ^sstsiKSSr(oar bonnss inslalleddurin8 thc )W! asse™ (Guldcr Assodates wi *and rrom tw° adi""unai *«»insiaiicd*™« ^
       .    sampling results from an investigation m 1974 are not included in this table because the locauon of one of the samples and depths ofall of the samples could not be esuMuhed
       •    fhesanipleslrornthel991investigalionwereanalyzedforV(K"s.MetalsandRadiologicalConstituents No VOC"s were measured above detection hm.t- ™t   i  ,1,
            and radiological constituents that were identified with concentrations greater than detection limits are shown in the table                                  X 'h°Se meta'S
       .    I he 0113-08 Track II Investigation samples were also analyzed for lluonde, pit. nitrate, nitrite and K-40  These constituents are not shown m the table because thev are noi r^en,
            at ha/ardous concentrations                                                                                               ^^UMS*. me/ !!)!..
 I      -   I lie analyie was identified m the sample but the numerical result may not be accurate.
NA    -   Not Applicable                                               •
KMI-      Reasonable Maximum Exposure

-------

                                                            S.teCPP-91
    WCF (CPP-633). The blower pt contom  d2n th <   I ^ T P" l<>Cated °n the nOrth Slde of *c    '
    below the blower pit floor, which s pp"ox ™a"lt m ( U fti!" f tof ^ tO the Sed'™
    revealed elevated radiation levels on the blowe ph walTs and floof  nt   ^ ' ^ °f the bI°Wer p«
    and snowmelt had entered the blower p,t and was observed to h?J"      § theu°IeanuP' water fr™ ram
    sample of the dirt on the blower plt fl^ £^ ^etatedleve                               A
   d-scovery of the water anTd anfn ?992 TheaL tnTh? ""^ ^ WCF beCame °Pera^nal  Upon
              sa.phng results ^^^^^      TO **
   settling basin (CPP-740),                 K^^^T^ Z™1** h°n'20nlal
   MAH-SFE-SW-048) east of CPP-603  The Pnl 1  (C.fP:301>' ^ ^ ^ wells (CPP-303 and
   backwash slurry of filter aS material rd,^         ^ JS" Clea"UP SUpP°rt System rece'v^ a
   filter system.^ ^^^^l^^ ^ ^ ™ R*CeiVin* and Stora8e F-^
                                                           ^
 manho,, Ms syn, sc    to e«            SS^ ™mP«™="« - - access
                              atuutoiw
 •he supernatant ,„ waste s.orage  S SFM??Ste 'cpr"^,^0™? ?"lJ1;ttin8 W°S UScd '» ™sf»
 Expenmental Breeder Reactof (EBR) No 2 fill ™  ,      OU 3-09). In March 1969, several
                                               **>"     '                   These s.tes
re!ease.  S,,e CPP-04 *l™*tt?a« » »™ resulKd *»


an,n,emona, leases
                                          5-23

-------
Table 5-6. Summary sampling results statistics for soil contaminants in CPP-91 soil borings.'
Soil Concentration
(mg/kg [nonradionuclidej or pCi/g (radionuclide])
Arithmetic Standard
Contaminants Minimum Maximum Mean Deviation
As
Ha
Be
Cd
Co
Cr
Cu
MB
Ul
to Mn
-p.
- Ni
Pb
Sb
So
Tli
V
/n
Cs-137
Pu-238 .
l'u-239
Sr-'X)
1 L- w
3.60E+00 P
7.81EKMP
3.70E-01 P
4.3E-01 BP
4.80E+00 BP
l.52E»01 JP
1.25E+01 P
7.00E-02B
1.67E*02P
1.81E+01 P
5.60EiOOP
5.80E-01 BP
2.00E+00 P
1.80E+OOBP
2.34E+01 P
4.73E+01 P
l.OOE-Oi
3.20E-01
6.00E-02
2. 001: <-0 1
2. 3 2 !•: 'GO
I.03E-»01 P
I.86E+02P
1.20E+00 P
3.30E+00 P
I.22E+01 P
3.73E+01 JP
3.28E+01 P
5.40E-01
5.34E+02 P
3.80E+01 P
1.72E+0! P
1.20E+OOBP
2.00E+00 P
I.80E+OOBP
4.34E+01 P
1.07E+02P
I.40E+02
3.20E-01
6.00E-02
7.58E*03
232E»00
6.17E<00
1.11E+02
5.90E-01
1.27E+00
7.05E^O
2.397E+01
1.768E+OI
2.70E-01
2.616E+02
2.472E+01
9.74E+00
8.50E-0!
2.00E+00
1.80EI-00
3.083E+01
6.716E^01
3.081EtOl
3.20E-OI
6E-02
2.287EHB
2.32H* 00
2.20E+00
3.12E+01
0.28E-01
8.90E-01
2.72E+00
7.49E-KH)
6.78E+00
1.50E-01
1.28E+02
6.85E+00
3.79E+00
2.30E-01
NA
NA
7.70E+00
2.03E+01
4.59E+01
NA
NA
3.60Et03
NA
RMEb
1.06E+01
1.73E+02
6.46E-01
3.05E+00
1.25E+01
3.90E+01
3.12E+01
5.70E-01
5.18E+02
3.84E+01
1.73E+01
1.31E+00
NA
NA
4.62E+01
1.08E+02
1.23E+02
NA
NA
9.49E+03
NA
Number
of
Samples
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
1
1
4
1
Number
of
Detects
10
10
10
10
10
10
10
8
10
10
10
9
1
1
10
10
8
1
1
4
1
Frequency
of
Detection
100%
100%
100%
100%
100%
100%
100%
80%
100%
100%
100%
90%
10%
10%
100%
100%
80%
100%
100%
100%
100%
INEEL
Background'
(mg/kg or pCi/g)
5.80E+00
3Et02
1.80E+00
2.20E<00
1.10E+01
3.30E+01
2.20E+01
5.00E-02
4.90E+02
3.50E+01
1.70E+01
4.80E+00
2.20E-01
4.30E-01
4.50Et01
1.50E+02
8.20E-01
4.90E-03
IE-01
4.90E-01
NA
Number of
Samples Greater
than Background
6
0
0
1
2
2
2
8
1
2
1
0
1
1
0
0
6
1
0
4
NA

-------
  Table 5-6.  (continued).
                                       Soil Concentration
                        (mg/kg [nonradionuclide] or pCi/g (radionuclidel)
                                                                                Number   Number  Frequency
                                                                                   °f         of         of
                                                                                Samples   Detects
                                                                                    1
                                                                                                                                  INEHl.
                                                                                                                               Background1"
   Number of
Samples Greater
than Background
  (iross Alpha
  Ciross Beta
        NOT!-:
             Duplicate sample results were not included in the statistical analysis
                                                            ^^
                                                                                                            A,.c,Ft,Ml!.K.N,mdIonls,.
j
j
M
i>
NA
KMI'
 be an estimated quam.ty
I he analyte reported value is < RDl., bul > 11)1.
Sample analyse by inductively coupled plasna atomic emission spectroscopy
Not applicable
Reasonable Maximum l:\posure

-------
       Table 5-7. Summary sampling results statistics for soil contaminants at Site CPP-01.'
to

Soil Concentration
(pCi/g [radionuclide])
Number
Arithmetic Standard of
Contaminants Minimum Maximum Mean Deviation RMEb Samples
Am-24 1
Co-57
Co-60
Cs-137
Hu-152
l-u-154
En- 155
l'u-239
Sr-l)0
U-235
1 1-238
(iross Alpha
dross Beta
a NOTI:
.
1.78E+OOJ 1.78E+OOJ 1.78E+00 NA NA 3
1.02E+00 1.02E+00 I.02E-KH) NA NA 19
1.38E+00 3.32E+02 7.12E+01 1.46E+02 3.63E+02 19
1.29E+00 4.60E+04 4.64E+03 1.20E+04 2.86E+04 19
2.23E+00 1.04E+02 5.37E+01 5.75E-I-01 1.69E-H)2 19
4E+00 7.97E+01 5.03E+01 4.06E-r01 1.32E+02 19
8.81E+00 8.81E+00 8.81E+00 NA NA 19
5.30E+OOJ 1.20E+OIJ 8.83E+00 3.36E+00 1.56E+01 11
1.11E+01 4.85E+03 9.43Et02 1.46E+03 3.86E+03 16
9.34E-03 3.94E-02 2.40E-02 8.55E-03 4.11E-02 11
I.I2E-OI 2.50E-01 2.01E-01 4.26E-02 2.86E-01 11
4.30E-KK) 3.32E*03 4.47E+02 8.61 £+02 2.17E+03 19
7.46E+00 4.32E+04 4.99E+03 1.01E+04 2.52E+04 19

Duplicate sample results were not included in the statistical analysis
Number of
Number Frequency 1NEEL Samples
of of Background' Greater than
Detects Detection (mg/kg or pCi/g) Background
1 33%
1 5%
5 26%
15 79%
4 21%
3 16%
1 5%
3 27%
16 100%
1 1 100%
11 100%
14 74%
19 100%

• Analytical results are from samples collected from three bonngs and from the bonom of dry well SW-048 during the Oil 3-09 Track 2 Investigation
Preliminary Scoping Track 2 Summary Report For Operable Unit OU 3-09 (LITCO I995b) and Appendix G of the OU3-I3 Rl/FS Part A (DOU-II)
1.10E-02
NA
NA
8.20E-01
NA
NA
NA
l.OOE-01
4.90E-01
NA
1.4
NA
NA

Results arc provided in
1997b).
1
NA
NA
15
NA
NA
NA
3
16
NA
0
NA
NA

the I-inal
• Selected samples were also analyzed for Cd, K-40, Np-237, Pu-238 and U-234. This data is nol shown because concentrations were below detection limits.
•
Samples rejected because of an unacceptable quality control parameter were not included in the table.



h The RMI- concciuration is the 95% upper value based on the empirical rule (95%of the measurements lie within two standard deviations of their mean)
c The INI-
l-l background concentrations represent the 95% upper confidence limit (Rood et al. 1995}



J Questionable 1 I'S recovery or analytical yield
NA NIII applicable
UMI KI-J
snmihli: Maximum l-xptmire




-------
                                                                                                      1
        TheCOPGs for CPP-04/05 include Ce- 144, Co-60. Cs- 134, Cs-137, Eu-152 Eu-154 Eu-155 and
   U-235. The areal extent of contammation is est.mated at 408 m2 (4,422 fr)  Assuming an
   of contamination of 0.6 m (2.0 ft), the total volume of contammated soil is Lfmated a? 245
  5.3.3.6    CPP-08/09 (Contaminated Soil Area Around CPP-603 Basin Filter
  ™^im^rt ber se they were detemimed to have resuited ^
  carbon steel filter system line due to corros.on. Approximately 25 1 m3 (2,700 ft3) of soil were
                                     L (21-000 gal) *^™^^^        *•
  remnv^f ^ iocatl°" of the leak was nev^ determined. The leaking line section was replaced and
  removed from serv.ce.  Contaminated soil resulting from the leak was apparently encountered by
  construction crews on the east side of CPP-603, where a section of the line was located  T^e area of
  contamination was delmeated by radiolog,cal survey instruments, however no soil samples were

                      -
                                                             T
                                                                assumed
                                                                       imated contammated
 53.3.7   CPP-10 (Contaminated Soil Area around CPP-603 Plastic Pipeline Break)

     65         a rel
                                       3000 L (800 gal) of radionuclide-conmmecPPO
          tc  3w3             ,     «? as a result of fa'lu- of a PVC line ,n Decemben976.
 Approximately 34 m (366 ft ) of asphalt and soil outside the building were contaminated Aooarentlv no
 remed.al actions were performed at the s.te, other than placing several inches of ckan oU oter the  '
 contammated area. Table 5-10 provides summary sampling results statistics for CPP 10

      Radionuclide contaminants include Co-60, Cs-137, Eu-152. -154 and -155 Sr-90 and I J 7is  Th*

        d
ctntfnf  t HT^ 1 (CAPP'603e **«*• and Water Release). This site resulted from a release of
(3oTSlnUnf
-------
       Table 5-8. Summary sampling results statistics for radionuclides at Sites CPP-04/OS.'
NJ
00
Soil Concentration
(nig/kg InonradionucliJeJ or pCi/g [radionuclide])
Conlammants Minimum Maximum
(VI 44
Co-60
Cs-134
Cs-137
Hu-152
liu-154
liu-155
U-235

2.00E-01 2.39E+03
1.05E-02 1.45E+03
7.50E-02 2.26E+02
2.19E-01 2.65E+04
2.00E-01 3.50E+04
4.73E-01 3.22Ef04
5.38E-03 7.60E+03
4.75E-02 3.02E-01

Arithmetic Standard
Mean Deviation
1.20E+02 3.28E+02
4.62E+01 1.57E+02
1.81E+01 3.77E+01
9.60E+02 3.27E+03
9.32E+02 3.49E+03
9.31E+02 3.34E+03
2.27E+02 7.96E+02
7.0IE-02 3.62E-02
RMEb
7.76E+02
3.60E+02
9.35E+01
7.50E+03
7.91E+03
7.61E+03
I.82E+03
1.43E-01



Number of
Number Frequency INEEL Samples
of Number of Background1 Greater than
Samples of Detects Detection (nm/ku ornCi/e) naelcimiimrf
204 133
204 172
204 89
204 204
204 199
204 187
204 178
120 120
65%
84%
44%
100%
98%
92%
87%
100%
NA NA
NA
NA
8.20E-OI
NA
NA
NA
NA
NA
NA
196
NA
NA
NA
NA
a NOII-
• Duplicate sample results were not included in the statistical analysis.
' ^V™* «sulls are from samples collected from 51 bonngs installed to charactenze the CPP-740 horizontal settlmg basin hi 1981. Results are prov.ded in the Rad.oactive Was.,
( haracteruation o. CPP-603 Cleanup Basm-CPP-740 (EG«i 1 982) and in Appendix E of the Preliminary Scopmg f rack 2 Summary Report For Operable UnU SfSwn^bl
h 1 he
c The
NA
KMI: =
KMI- concentration is the 95% upper value based on the empirical rule (95%of the measurements lie within two standard deviations of their mean).
INI'l-.l. background concentrations represent the 95% upper confidence limn (Rood el al. 1995).
Not applicable
Reasonable Maximum Hxposure.













-------
 Jjbje5j._Summaiy sampling results statistics forjojlcrmt^ntc at Site CpP.08/09 •
                                                 "~~~~"""	                    '
                                Soil Concentration
                _.	(pCi/g (radionuclide))
  (Joniiiminaiits
  Cs-137
  liu-15:
  I-u-15.4
 .Sr-90
  U-235
JL'-?-H-
 Gross Alpha
 Gross Beta
         Minimum   Maximum
Arithmetic
  Mean
  I.49E+01
  4.38E+00
  7.78E-01
2.52E+01 J
  1.93E-02
  1.56E-01
 5.10E+00
 9.88E+01
 1.08E+03
 4.38E+00
 2.95E+00
 1.40E+02
 2.61E-02
 1.61E-01
7.99E+01
9.36E+02
      NO) I:
 5.32E+02
 4.38E+00
 1.86E+00
 8.53E+01
 2.27E-02
 1.59E-01
-•
2.91E+01
5.19E+02
 5.83E+02
      NA
 1.54E+00
 5.76E+OI
 4.81E-03
 3.54E-03
  ' ' '     .—
3.48E+01
4.34E+02
  RMEb
 I.70E+03
      NA
 4.94E+00
 2.01E+02
 3.23E-02
 1.66E-01
————•!•„__
9.87E+01
1.39E+03
                                                           Number   Number   Frequency
                                                              °f        of         of
                                                           Samples   Detects   Detection
  4
  4
  4
  3
 2
_2_
 4
 4
                                                                                4
                                                                                I
                                                                                2
                                                                                3
                                                                                2
             I )uplicale sample results were not included in Ihe statistical analysis.
                                                         100%
                                                          25%
                                                          50%
                                                         100%
                                                         100%
                                                         100%
                                                         100%
                                                         100%
    INEEL
  Background1
(mg/kg or pCi/K)
    8.20E-01
         NA
         NA
    4.90E-OI
         NA
    1.40EjM30
        NA
        NA
 Number of
  Samples
Greater than
Background
   4
 NA
 NA
   3
 NA
                                           ^^^
                                                                                                  the Final Preliminary Scoping I rack 2
c
1
NA
KMI
yueslionahle I.CS recovery or analytical yield
Nol applicable
Kcasonahlc Maximum lixposure

-------
Table 5-10.  Summary sampling results statistics for soil contaminants at Site CPP-IO.*
Soil Concentration
(pC'i/g [radionuclide])
( 'oiuaminants
C'o-60
Cs-137
hu- ! 52
Iui-154
l-u-155
Sr-90
U-235
U-238
(MOSS Alpha
(iross Beta
a N( ) 1 1-
Minimum
3.18E+00
2.I5E+00
9.16E+00
5.701-400
1.48E+00
4.17E»01
1.13E-02
1.76K-01
2.78H+00
1.42K*02

Maximum
3.I8E+00
1.I9E+03
9.16E+00
5.70E+00
I.48E+00
5.83E401 J
1.42E-02
2.IOE-01
1.38E+02
5. 45 E* 03

Arilhmeti
c Mean
3.18E+00
4.91E+02
9.16E-HX)
5.70E+00
1.48E+00
5.00E+01
1.28E-02
1.88E-OI
4.97E+01
1.48E+03
Standard
Deviation
NA
5.36E+02
NA
NA
NA
I.17E+01
1.46E-03
1.88E-02
5.65E+01
2.05E+03
RME"
NA
1.56E+03
NA
NA
NA
7.34E+01
1.57E-02
2.26E-01
1.63E+02
5.58E+03
Number
of
Samples
6
6
6
6
6
2
3
3
6
6
Number
of
Detects
1
&
1
1
1
2
3
3
5
6
Frequenc
yof
Detection
17%
100%
17%
17%
17%
100%
100%
100%
83%
100%
INEEL
background'
(mg/kg or pCi/g)
NA
8.20E-01
NA
NA
NA
4.90E-01
NA
1.4
NA
NA
Number of
Samples
Greater than
Background
NA
6
NA
NA
NA
2
NA
0
NA
NA
h
c
J
NA
KM I
 •       Duplicate sample results were not included in the statistical analysis.
 •       Analytical results are from samples collected from one boring installed during the OU 3-09 Track 2 Investigation  Results are provided in the Final Preliminary Scoping Track ">
         Summary Report For Operable Unit OU 3-09 (I.ITtt) I995b) and Appendix G of the OU3-13 Rl/FS Part A (DOE-ID 1997b).
 •       Selected samples were also analyzed for Co-57. K-40, U-234, Np-237, Pu-238. Pu-239 and Am-241. This data is not shown because concentrations were below detection limits
 •       Samples rejected because of an unacceptable quality control parameter were not included in the table.
'I he RMI: concentration is the 95% upper value based on the empirical rule (95%of the measurements lie within two standard deviations of their mean).
'I he INl-hl background concentrations  represent the 95% upper confidence limit (Rood el al. 1995)
-  Questionable I X'S recovery ur analytical yield.                                                                                                              .
   Not applicable
   Reasonable Maximum I-xpnwiic

-------
l l^&mirnary C
results statistics for soil contaminants at Site CPP-
Soil Concentration
(mg/kg [nonradionuclide] orpCi/g (radionuclidel)

Contaminants
As
Ha
Be
Cd
Co
Cr
Cu
£ Mg
Mn
Ni
Pb
Sb
Se
'111
V
Xn
Co-60
Cs-137
lui-154
Np-237
Si -00



Minimum
2.80E+00
6.34E+01 P
2.50E-01 P
4.30E-OI P
3.50E+00 B P
1.32E+01JP
7.80E+OOP
5.00E-02 B
1.32E+02P
1.16E+01 P
5.30E+00 P
4.40E-01 B P
8.50E-01 B P
1.30E+OOBP
1.83E+01
3.29E+01
1 10E+OI
2.90E-01
360E-OI
1 501--01
I.UKiOl J



Maximum
6.40E+00
1.22E+02P
5E-01 P
1.70E+OOP
6.30E+00 B P
2.37E+OI P
1.54E+01 P
5.00E-02 B
2.58E+02 NJ P
2.06E+01 P
8.80E+00 P
8.30E-01 B P
8.50E-01 B P
1.30E+OOB
2.81E+01
6.42E+01
6.10E-01
7.27E+01
1.80EIOO
1.50H-01
1 3H-;i()l J



Arithmetic
Mean
4.77E+00
9.76E+01
4.23E-01
1.12E+00
5.13E+00
1.85E+01
1.3IE+01
5.00E-02
I.97E+02
1.73Ef01
6.96EfOO
6.06E-01
8.50E-01
1.30E+00
2.50E+01
5.04E+01
2.93E-01
2.56E+01
7.53E-01
1.50H-01
1.311^01



Standard
Deviation
-•" 	 ....,.-. i i _
1.27E+00
1.96E+01
7.32E-02
5.00E-01
7.83E-01
3.07E+00
2.26E+00
NA
4.44E+01
2.78E+00
1.11E+00
1.56E-01
NA
NA
3.14E+00
8.44E+00
2.75E-01
2.64E+01
5.64E-01
NA
NA



RMEb
7.31E+00
1.37E+02
5.69E-01
2.I2E+00
6.70E+00
2.46E+01
1.76E+01
NA
2.86E+02
2.29E+01
9.18E+00
9.18E-01
NA
NA
3.13E+01
6.73E+01
8.43E-01
7.84E+01
1.88E*00
NA
NA
IN /\


Number
of
Samples
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
1
i
i


Number
of
Detects
10
10
10
10
10
10
10
1
10
10
10
9
1
1
10
10
3
10
6
1

1


Frequency
of Detection
100%
100%
100%
100%
100%
100%
100%
10%
100%
100%
100%
90%
10%
10%
100%
100%
30%
100%
60%
100%

100%


1NEEL
Background'
(mg/kg or pCi/g)

3.00E+02
1.80E+00
2.20E+00
1.10E+01
3.30E+01
2.20E+01
5.00E-02
4.90E+02
3.50E+01
1.70E-KH
4.80E+00
2.200-01
4.30E-OI
4.50E+01
1.50E+02
NA
8.20E-01
NA
NA

4TOI-:-OI

Number of
Samples
Greater than
Mni'L' urfiiitifi
U«L Ivgl (JUIIU
2
0
0
0
o
0
0
0
0
0
0
o
1 ''•*'•
1
0
0
NA .:
9
\l A
IN A .
MA
t*f\
1
*•* i

-------
  Table 5-11.
                                               Sllll ( UlkClllUllOII
                             (inu ku InomadiouueluleJ en pCij; |uuhctmielidej]_


Arithmetic Standard
Contaminant:, Minimum Maximum Mean Deviation
1 1-234
I I-23S
tiioss Alpha
(iio.ss Ik-la
.1 Mill
•
•

1.201*00 . 1. 201- KM) 1 .201:400 NA
1. 001; K)() l.OOl-i 00 I.OOK+OO NA
4.(.()1-.K)0 2. 301: 1 01 UlEfOI 5.1 (if-! 100
. 2.40HKH 	 .2/WJi'03..l 3.741*02 9.171:102

1 liiplicjlc sample lesull.s vveie nol ineliided in the siali.slical analysis

RMHh
NA
NA
2.141*01
2.211*03


Aiialvlical u-Mills aie Irnni samples i-ollecled Iron) three borings iiiblalled during the Oil j-13 R| Rei
Samples vveie analy/ed hu t 1 1' Metals and Radiological I onslilneiils Only those e
omliluenls that \v
Numhei nl
Numhei Numhei |Nhl;I. Samples
"' °' l-"iei|ueney HacknuuuuT (iieatei than
Samples Detects (,ri)f*if»rhni, (I,,H>L*I. >tT-n/-^. ., i> i i
	 i.vii t:vlii,. . ul i^itcuon ( mu KJJ t)r p\ j/jy Hyckunnmil
1 1 100% 1.441-100 ()
1 1 100" ii 1 JflK ifU) a
10 10 100% NA NA
10 10 100% NA NA


lilts aiepiovuled in Appendix (iol iheOIH \) M I s I'aii A (l)()l II) l')')7|,);1,,,| ,|lt.
eie identified above detection hmib in lite samples aie shown in the table ex. cm 1.. 	
         •        Sample:, leveled because ul'an iin.iccepl.ihk- quality coiiliol paiamclci  weie not included in tile table.
I-       I lu- KMI , ,,,,ce,il,al,,,n is .he W.. up|v, value based on the en.pineal rule ('K-,.,1 H,e ,11,-asuren,enl> he wilhm Hvo sla,,,l.ml deviaiu.t.s ,,l ihe.r meant
c       I lie IM-1 I  h.ii'kj:ii,iind IUIICL-IIIIJIIKIIS u-pieseiil Ihe')>"„ uppn ciinl'ideiice Innil (Koudelal. l<)')5)
I   i Nun U.i.11 Ihcjiialue vvaMileiinlieil in ilie .sample bill the nunieiical le.sull nia>  mil heaccuiale
.1   (K.id I I he u Mill is Mati.stieally positive at the "y:,, eunlidence level and b eon.sideial lo he an estimated quantity.
H   Ihe.inalvle lepmleil value is-  KDI  , hut  -11)1
N   Spiked s.iinple,eiiivei>  not vvilhin coiiliol Innil

I'   Sample .mjlvsis by indiietively coupled plasma atomic emission spectioscopy
NA   Kol .ipplu.ihle
KMI    Ke.ison.ihle Maximum l:\posure

-------
        Radionuclide activities were still above background Ie%'els at that depth; however COPC activities
  decrease with depth. The areal extent of the site is 208 nr (2,240 ft2). The total estimated contaminated
  soil volume is 1,140 m (40,390 ft3).

  5.3.3.9     CPP-03 (Temporary Storage Area Southeast of CPP-603).  Site CPP-03 is a
  temporary storage area southeast of CPP-603 that was used to store old and abandoned equipment, most
  ot which was radioactively contaminated.  The area was decommissioned in the late 1970s and all stored
  material was boxed and sent to the RWMC for disposal. Contaminated soil was removed, boxed and sent
  to the RWMC, and the area was covered with 28 cm (11 in.) of "cold" soil. Subsequently, 9.175 m3
  (12,000 yd ) of contaminated soil excavated from the Tank Farm was stockpiled at the site before burial
  in three trenches located in the northeast corner of the INTEC.

       Radiological field surveys in the area have indicated surface activity levels above background at
  various locations at the site. Three boreholes in the area were drilled to 3.0 m (10 ft) bgs in locations
  where high surface activities were observed. Samples were collected and submitted for radionuclide
  analysis.  Summary sampling results statistics are provided in Table 5-12. The COPCs include Cs-137
 and Sr-90. Cesium-137 is the primary COC, with contamination detected from the surface to about 1 2 m
 (4 ft) bgs.  The areal extent of contamination is estimated at 6,970 m2 (75,000 ft2), and the estimated
 volume of contaminated soil is 8,364 m3 (300,000 ft3).

 5.3.3.10   CPP-67 (CPP Percolation Ponds #1 and #2). Site CPP-67 consists of two unlined
 service waste percolation ponds.  The ponds receive service wastewater consisting primarily  of cooling
 water and condensed steam generated by various INTEC operations.  INTEC wastewater that contains
 only traces of radioactivity (or none at all) passes through the service waste system. The waste consists
 primarily of cooling water and steam condensates.  This waste activity is monitored before being
 discharged to SWP-1 or SWP-2.  There are three main service waste systems at INTEC- (1) the eastside
 system, (2) the westside system, and (3) the CPP-604 PEW process condensate monitor/shutdown system
 Figure 1-5 shows the relative location of the ponds, which are fenced to exclude entry of large wildlife
 and unauthorized personnel.  Table 5-13 shows summary sampling results statistics for CPP-67.

      S WP-1 is located outside the south INTEC security fence, southeast of CPP-603 and was
 established in 1984. The pond is  approximately 125.0-m (410-ft) long in the east-west direction and
 146.3 m (480 ft) in the north-south direction and approximately  5.5-m (18-ft) deep. The pond was
 excavated in gravelly alluvium that is approximately 7.6- to 9.1-m (25- to 30-ft) thick and is underlain by
 basalt, which locally outcrops in the pond.

      The SWP-2 is located outside the south INTEC security fence, southeast of CPP-603. The SWP-?
 was established in 1985 when it became apparent that the infiltration capacity of SWP-1 had decreased "
 and water levels began to rise. The pit bottom is approximately  152.4-m (500-ft) square and 3 to 4 m
 (12 to 14 ft) deep. The pit was excavated in gravelly alluvium approximately 6 to 11 m (20 to 35 ft)
 thick, underlain with basalt. Basalt outcrops in the comer of SWP-2. The pond is designed to
 accommodate continuous disposal of approximately 11.4 M L (3 M gal) of water per day.

      RCRA clean-closure equivalency was achieved for metals contamination in Pond SWP-1 in April
 1994 and Pond SWP-2 in May 1995: therefore, only radionuclide contamination was assessed as part of
the WAG 3 RI/BRA. Site CPP-67 is considered to be a significant source of the perched water beneath
the southern portion of the INTEC.
                                             5-33

-------
 Table 5-12. Summary sampling results statistics for soil contaminants at Site CPP-03.1
Soil Concentration
(pCi/g [radionuclide])

Containinunts
Cs-137
Sr-90
(iross Alpha
( iross Beta

Minimum
2.53E-01
1.60E+01
O.OOEiOO
3.02E+00

Maximum
6.I6E+01
4.39E+01 J
7.24E+00
1.67E+02

Arithmetic
Mean
I.89EKH
3.00E+01
3.57E+00
4.68E+01

Standard
Deviation
2.46E+01
1.97E+01
3.25E+00
6.76E+01

RMEb
6.81E+01
6.94E+01
1.01E+01
1.82E+02

Number
of
Samples
9
2
9
9

Number
• of
Detects
7
2
4
6

Frequency
of Detection
78%
100%
44%
67%

INEEl.
Background'
(mg/kg or pCi/g)
8.20E-OI
4.90E-01
NA
NA
Number of
Samples
Greater than
Background
7
3
NA
MA
       NO 11:.
        •       Duplicate sample results were not included in the statistical analysis.
                Analytical results are from samples collected from three borings installed during the OU 3-09 Track 2 Invesl.gation. Results are provided in the Final Preliminary Scomn* Track 7
                Summary Report l-or Operable Unit OU 3-0') (I.ITCO I995b) and Appendix 0 of the OU3-13 RI/FS Part A (DOE-ID I997b).                     rrel.m.nary Scoping I rack 2
                Selected samples were also analysed for Co-57. Co-60, Hu-152, Eu-l 54. BU-I55 and K-40. Th.s dau, is not shown because concentrations were below detection limits
        •       Samples rejected because of an unacceptable quality control parameter were not included in the table.
h      The KM!-: concentration is the 95% upper value based on the empirical rule (95%ofthe measurements lie within two standard deviations oftheir mean).
c      The INI-J-I. background concentrations represent the 95% upper confidence limit (Rood el  at. 1995).
J - Questionable I.CS recovery or analytical yield.
NA - Nut applicable
KMI-  -      Reasonable Maximum Exposure.

-------
Table 5-13.  Summary sampling results statistics for soil contaminant at site CPP-67.'
uv/n v_.uin,ciiu*iuun 	 — 	 — • " 	 • — •
(mg/kg (nonradionuclidej or pCi/g [radionuclideh
Contaminants
Ag
As
Bu
Be
Cd
Co
Cr
Cu
E »«
Pb
Mn
Ni
Sb
Se
Th
V
Zn
Cyanide
Sulfide
2-Butanone
Acetone
Ben/ene
bis(2-
I'lliylhe.xyl).
Minimum
2.IOE-OI BJ
1 .20E+00 B
3.21E+01
3.00E-01 J
4.20E-01 B
I.70E+OOB
3.60E+OONJ
8.60E+OOJ
9.00E-02
3.90E+OOJ
3.86E+01 EJ
6.90E + 00
3.60E-01 B
l.OOE-01 BJ
2.10E-01 B
5.60E*00
2.44Ef01 NJ
1.20E-01 B
5.40E-OI
7.00E-03 J
5.00H-03 J
1 .<)OI-;-03 J

3. ()()!•: -02 J
Maximum
I.80E+01 J
1.38E+01
4.00E+02
8.30E-01
I.I2E+OI
l.OOE+01
1.08E+02
1.49E+02J
1.26E+02J
1.95E+OU
3.59E+02 EJ
2.83E+OI
6.90E+00 B
8.00E-01 J
2.10E-01 B
3.63E+OI N
1.02E+02J
5.20E-01 J
1.57E-J01
9.00E-03 J
9.10E-02B
1. OOIi-03 J

3.70EfOO
Arithmetic
Mean
— — — 	 —
2.91E+00
4.52E+00
1.44E+02
5.61 E-01
1.8'2E+00
4.82E+00
2.35E+01
2.43E+01
1.26E+01
8.49E+00
1.23E+02
1.51E+OI
1.42E+00
3.88E-01
2.10E-01
1.53E+01
4.77E+01
2.90E-01
8.10E+00
8.00E-03
2.39E-02
l.OOE-03

1.311-^00
Standard
Deviation
- — • — ' 	 — —
3.84E+00
2.17E+00
8.40E+01
1.62E-01
2.14E+00
I.83E+00
1.90E+01
2.06E+01
2.76E+OI
3.33E+00
7.12E+01
5.37E+00
2.42E+00
2.71 E-01
O.OOE+00
5.66E+00
1.74E+01
2.07E-01
5.20E+00
1.41E-03
2.99E-02
NA


RMEb
• — — 	 	
I.06E+01
8.86E+00
3.12E+02
8.85E-01
6.IOE+00
6.I5E+01
6.55E+01
6.78E+01
1.52E+01
2.65E+02
2.58E+01
6.26E+00
9.30E-01
2.10E-01
2.66E+01
8.25E+01
7.04E-OI
1.85E+01
1.08E-02
8.37E-02
MA
IN A

Number
of
Samples
87
99
92
ft!
u /
100
66
UU
99
66
81
98
59
67
S6
j\j
100
1 \J\J
S7
-f /
67
67
65
10
33
7
1 -j
33

Number
of
Detects
	 	 	 __
34
98
92
65
AS
46
95
66
66
88
59
67
8'

67
67
3
10
2
33
1

Frequency
of
Detection
39%
99%
100%
12%
65%
70%
96%
100%
81%
90%
100%
100%
13%
8%
2%
100%
100%
5%
100%
6%
21%
3%

INEEL
Background'
(mg/kg or
PCi/g)
O.OOE+00
5.80E+00
3.00E+02
1.80E-tOO
2.20EHH)
1.10E+01
3.30E+01
2.20E+01
5.00E-02
1.70E+01
4.90E+02 •
3.50E+01
4.80E+00
2.20E-01
4.30E-01
4.50E + 01
1.50E+02
NA
NA
NA
NA
NA

Number of
Samples
Greater than
Background
34
24
4
0
9
0
15
22
66
I
o-
0
1
4
0
0
0
NA
NA
NA
NA
NA

                                                                  4.83E »00
                                                                               29
                                                                                                  17%
                                                                                                               NA
                                                                                                                             NA

-------
Table 5-13. (continued).
Soil Concentration
(nig/kg [nonradionuelide] orpCi/g [radionuchde])

Contaminants
phthalate
Butylbenzyl-
phthalate
Carbon Disulfide
Chlorobenzene
Di-n-
butylphthalate
Diethyl-phthalate
Methylene
Chloride
^ I'cnlachloro-
°^ phenol
Toluene
Trichloroethane
Am-241
Ce-144
Co-60
Cs-134
Cs-13?
Hu-154
H-3
1-129
Np-237
l'u-23S
1V2.W.240
KM- 100

Minimum


4.00E-02 J
1.40E-02
l.OOE-03 J

3.80E-02 J
4.10E-02 J

2.00E-03 J

3.70E-01 J
l.OOE-03 J
l.OOE-03 J
8.00E-02 J
4.00E-01
1.60E-01
1.50E-01
l.OOE-01
2.80E-01
6.10E-01 J
I.46EMDO
6.30E-OI
9.00H-02
5.00H-02 ,
1 401: MX)

Maximum


1.40EHX)
1.40E-02
l.OOE-03 J

I.30E-01 J
4.10E-02J

2.40E-02 J

3.70E-01 J
l.OOE-03 J
l.OOE-03 J
7.80E+00
1.50E+00
2.35E+00
3.50E+00
1.80E+02
4.00EHH)
6.10E-OI J
3.70E+00 i
I.63E+00
3.04H+01
2. 07 F. tOO
5.971:' UK)

Arithmetic
Mean


6.12E-01
I.40E-02
l.OOE-03

8.92E-02
4.10E-02

9.63E-03

3.70E-01
l.OOE-03
l.OOE-03
6.31E-01
9.23E-01
5.99E-01
1.50E+00
4.06E+01
1.63E+00
6.10E-01
2.50E+00
1.12E+00
6.10E*00
5.49E-01
3.451: 1 00

Standard
Deviation


6.75E-01
NA
NA

4.74E-02
NA

7.44E-03

NA
NA
NA
1.46E+00
5.52E-01
6.43E-01
9.23E-01
4.67E+01
1.26E+00
NA
9.67E-01
2.90E-01
7.50EM30
5.43E-01
1 91 Hi 00

RMEb


1.96E+00
NA
NA

1.84E-01
NA

2.45E-02

NA
NA
NA
3.55E+00
2.03E+00
1.89E^OO
3.35E+00
1.34E+02
4.15E+00
NA
4.43EiOO
1.70EMJO
2.11F>OI
1.641itOO
7.27E-fOO

Number
of
Samples


29
33
33

29
29

33

29
33
33
53
58
58
58
58
38
10
20
10
53
53
58

Number
of
Detects


4
1
1

5
1

8

1
1
1
27
3
12
23
43
7
1
4
10
36
22
7

Frequency
of
Detection


14%
3%
3%

17%
3%

24%

3%
3%
3%
51%
5%
21%
40%
74%
18%
10%
20%
100%
68%
42%
12%
INEKl.
Background1
(mg/kgor
pCi/g)
r o/

NA
NA
NA

NA
NA

NA

NA
NA
NA
1.1E-02
NA
NA
NA
8.2E-01
NA
NA
NA
NA
4.90E-03
I.OOE-01
NA
<
Number of
Samples
Greater than
Background


NA
NA
NA

NA
NA

NA

NA
NA
NA
27
NA
NA
NA
35
NA
NA
NA
NA
36
21
NA
1

-------
t
able 5-13. (continued).
                                        Soil Concentralion
                        _Jmg/kg [nonradionuclidel orpCi/g [radionuclidel)
               !^ __    Minimum
  Sb-l25
  Sr-90
  U-234
  U-235
  U-235/236
  H-238
  Y-90
 Gross Alpha
 Gross Beta
                   3.IOE-01
                   1.20E-OI
                   O.OOE+00
                   7.00E-02
                   l.OOE-Ol
                   9.00E-02
                   I.IOE-OI
                  ~"	''    .—
                  7.70E+00
                  U9E+01
       NOTl::
 Maximum
     -—-
 5.IOEKX)
 1.63E+OI
 2.75E+00
 7.00E-02
 l.OOE-01
2.60E+00
1.20E-K)0
7.30E+01
1.63E+02
 Arithmetic
    Mean
     ii   —
  1.76E+00
 2.07E+00
 9.98E-01
 7.00E-02
 l.OOE-01
 8.92E-01
 4.04E-01
""
 2.85E+01
 4.80E+01
  Standard
  Deviation
 —
  1.73E+00
  3.73E+00
  5.12E-OI
    NA
    NA
 4.37E-01
 4.05E-01
	'  .-	.
 I.78E+01
 3.27E+01
   RMEb
  5.22E+00
  9.53E+00
  2.02E+00
    NA
    NA
  I.77E+00
 1.21E+00
—     i
 6.41E+01
 1.13E+02
Number
of
Samples
58
54
53
43
10
54
11
— 	 _
34
44
Number
of
Detects
8
24
53
1
1
50
7
~-- i 	
34
44
Frequency
of
Detection
14%
44%
100%
2%
10%
93%
64%
1 " '
100%
100%
INEEL
Background'
(mg/kg or
pCi/g)
NA
4.90E-OI
1 .44E+00
NA
NA
I.4E+00
NA
	 ' 	 • 	 _.
NA
NA
Number of
Samples
Greater than
Background
NA .
20
6
NA .
NA
4
NA
NA
NA
              Huphcwe sample results were no. mcluded m the statistical analysis
                                                                                                                                       Decision Docuinent
I- • The reported value is es.m.a.ed because of the presence of m.erference
N* S^r.   T' ldt'm"led '" 'hC SamP'C bU' 'he nUmenCa' resu" ™y «« >- accurate
N- Spiked sample recovery was no. wiihm Ihe control limits
S - The reponcd value was dc,em,med by ,he meihod ofsUndard adduions
NA  Not applicable                                      '
                                             '/-w

-------
   i 9          !!-1^ '™esti8atl've results« the zone of contamination for SWP-1 is estimated to be about
   iw?   J    ?    ^  C     S     thC SUrfaCC t0 ' '8-m (6'°-ft) b§s' Based on the dimensions of
   bWP-1, the volume of contaminated soil beneath SWP-1 was estimated to be 32,922 m3 (1,1 80,800 ft').
  //: n e ^,u °n ?C inve,sti|ative results< the 2<>ne of contamination for SWP-2 is assumed to be 1 8-m
  (6.0-ft) thick  and extends from the surface to 1.8-m (6.0-ft) bgs. This depth is based on the decrease in
  radionuchde COPCs with depth, and the low activities measured in deeper samples. Based on the
  7i^nnSnnnSf£   Plt> the V°lume °f contammated soil beneath the pit was estimated to be 14,8 14 m3
  (1,500,000 ft ).
  f££11f* °™™r *£ - This sue resulted from a 1978 release of 7.570 L
       gal) of radionuchde-contaminated liquid that leaked from an underground waste transfer line
between CPP-603 and WL-102 in CPP-604. The waste transfer line was constructed of 304 stainless steel
that reduced from a 3.81- to 3.18-cm (1-1/2- to 1-1/4-m.) diameter line and ran for 530 m (0.33 mi) at a
depth of approximately 1.5 m (5 ft) bgs.  The major area of contamination was estimated at the time to be
approximately 1 0 m- ( 1 08 ft-) on the surface. The waste transfer line was abandoned m place after the
leak was discovered.  Table 5-16 shows summary sampling results statistics for soil contaminants for


      Numerous radionuclides were identified as COPCs for Site CPP- 19. Cesium- 137, Sr-90 and
isotopes of europium are the most widespread and are found at the  highest activity levels  These COPCs
range irr activity as high as 408.000 pCi/g for Cs-137 at boring CPP- 19-2 drilled at the site of the release
                                             5-38

-------
Soil ( oiici-niiuiuin 	 	 	
(1111; ku [noniailioiuicluk-J 01 p( Vjj [rai
Contaminants
AL-
As

Ki
Ik
( \\

Ci
Co
Cu
I' 1(101 idi-
":-'
Mn

Ni
I'll
1 II
Sc
Sul fide
V
/.it
ms(2-cihylhexl)
pluilate
CN 137
Np 2*7
Minimum
1 90HiOO
1 501: 1 00
x2.SI-.i01
5. 001 -01

600H-01
9 lOHiOO
3.60l-:i()()
1 271-JOI
1 301:100
I.OOH-OI
1.191:102
1.3 II: lOl
3.001: 1 00
7.00E-OI
2.I8HI01
1.721-1 01
3.71 Hi 01
4.60H-OI
1 101: 1 00
7 OOl-.-OI
Maximum
2.501-100
7. lOHi 00
2.39l:i02
5.00l-:-()l

I.OOl-iOO
7.601:100
1.7II-JOI
2.60l-:tOO
6,o()i-;-oi
2.691:102
2.60H.IOI
1.32HK)2
7.00H-OI
8.I4H101
2.2IHfOl
8.95HiOI
6.20H-OI
2 OOI-. 1 03
7.00I--OI
Arithmetic
Mean
2.20I-IOO
3.%l-iOO
I.07H102
5.00l-:-OI

7..SOI--01
I.53I-;»()|
'5.601-100
i.49|.;toi
'3.50E-0!
I 94 Hi 02
I.96H.O!
l.4IH(OI
7.00H-OJ
3.95H101
1.971-101
6.331- ) 01
5.401--01
3901;, 02
VOOI-.-OI
lionuclidejj 	
Standard
Deviation
4.24H-01
I.86E100
4.87H10I
NA

2.05H-OI
4.I2H+00
2.83H100
3.1IH100
3.72H-01
3.54E-01
I.06E(02
9.12I-IOO
O.OOH1-00
2.46EtOl
3.46EHK)
3.7IEK)!
I.I3H-OI
6. 1 3 1: 1 02
NA

RMhh
3.051-100
7.68F.IOO
2. 04 Hi 02
NA

1. 1 9 1- 1()()
2.35H101
2.1 IHK)1
2. 67 Hi 00
1 .061: 1 00
4.061- H)2
3.78H+01
7.03 Hi 01
7.00H-01
8.87H101
2.66H101
1.38H402
7.66H-01
1.621-103
NA

Number
of
>;i ill r\ I »>c
*.JUlll|)ICo
20
20
20
•^
20
20
T
£,
T
£,
1 5
20
2
2
20
20
5
2
2
20
20
20

Number
ol hequency
._iM.ocl!! . of Detection
2 10%
~)t\ I /i/\|) •
^" 1 U(J/u
20 loo1;;,
1 50%

211 100%
2 1 00%
2 1 00%
15 100%
2 10%
T 1 /WUJ/
- 1 00%
2 100%
20 100'H,
1 
-------
 Table 5-14.
                                               Still ('cilKvllll.llliHI
                             (ins; kg Liiiimadiiwucliijk'J 01 ji( '[_» [iiuliniiuduiij]

( 'oniamiiKini.s
I'll -MX
Si W
1 --I <4
I -MX
a N( ) 1 1

Mininuim

5 IOI-.M10
1 (.01- ' 00
1 10I-.00
I ()()!• MM)


Maximum

5.1 OH MM)
6.001: M)3
2.501: M)0
...2-MH '«<>_.


Arithmetic
Mean
5.1 (Hi MM)
K.I3I:M)2
1 .471-: 1 00
1.7 II: MM)


Slaiuiaid
Deviation
NA
l.40KM)3
4.40H-01
6.45I-.-01


JIM,.*
NA "
3.701-103
2.351: MM)
3.001: MM)


Number
of
Samples
20
20
20
20


Numhei
of
De!eel:s
1
10
8
0


l-ieqtiency
"1" Detection
5'!,,
05%
40%
45%


INI-I-.L
Umrkijoi 'pl'i/ji) •
4 O01'-0^
4 90I--0 1
1.44
1.4

N'miihi-i ol
Samples
(iieatei than
liuckuiiiuiiil
1
17
2
/

                 Diiplu.iir simple u-Mills \\i-icmit incluilal in the Nlulislic
                                                             .
A^^.Hl.lU•^u-|l,l.lJll,llll.\|l|H•lllll\(i..^lll•()IM•l.»K|•|•SI•anA(l«)l•-ll)l«W7h)
                                                 i mtugtHM-.. ladhi.iiiclulcs. a lull -.uilL-ol' V()CS. SV()(\.
                                                        • in ihc bMe oxcci ** ** (
         "U


Miculo l'( I
                                                                                                                                           .-\sMiujlis I > H»
                                                                                                                                                                    ,,        .....
                                                                                                                                                                    aic |ii.m,k-.l in llu- 1 mlilu uiu!
        •        Sjnipk^ i.-ii-, k-il IVI.IUM ul .1	uai-pl.ililc i|iialil> omlitil pjiamek-i were mil mdmk-.l HI llic tahk-

I-       II.,- KMI c.-,,a-n.,.,,,,m ,, UK- «jv-. „,„,,, ljUlL. ha:,,,! »„ U.cnnpmcal n,lc WM the iiMMiicnieni!, lie unit,,, ,«„ ,,all(b,,| .k-Man,,,,, ,,i ,!„,, i,KUi

1        I hl  IM  I I  l>ai-k;jninii,l KIIU.-II	ion-, i.-pa-^iil the MS",, nppei ennliili-nci- liinil (KiHid L-I ul
KMI
                              I  \jmsim

-------
	 	 	 : — • 	 : i 	 c- ' ' 	 ••"" "i»-.i iv'i .lull lUUlUIIIIIIUIltS ai OIIC I 1 1 - | ^
Soil ( imceiiiiaium ~" ' "
(nit! ku hionnuiiiimiclidoj o_r_p< -i jjjnidioiuiclidcjj
( 'oniammaiiis
As
Ha
He

( it
(•
i
( 'u
III!
Mn
V,
IN 1
I'lt

Se
\ •
\
/,,
f -it
/.i
Co (>0

Cs- 1 *4
Cs-IW
1 .,, i «. i
1 It- 1 . '-4
S| ')(!
1 • <1O

Minimum

5.30li*OOHP
7.581-:* 01 p
3.80I--01 HP

4. 1 01-: 1 00 HP
I.I6EHII P
1 20I:M)I JP
I.30K-OI
I.391-J02JP
1.41 1:1 01 P
6.MII-.IOOP
(>.SOI:-Oi HP
1. 691-1 01 P
3.S41:*OI P
7.501-MOOP
4.90I--01

.6.00I--01
8.00I-.02
2.201:H)1
4.701-:tOO
_
9.00I-..OI
Maxuiuim
8.301:. OOP
I.I 31: K)2 P
5.30I--01 HP

5.601: -00 HP
I.7II;'0| P
I.74I-.IOI JP
2.57l-:'i02 JP
I.97l-i01 P
1.39|:< 01 P
9.60l-:-()| HP
2. 65I-J 01 P

1. 231: 101 P
9.00E-OI

6.00K-01
4.63EI03
3.IOI-IOI
4 181i*03

2. 701-j 00
Arithmetic
	 Mean
6.301-100
4.361--OI

4.6 11: 1 00
1.37EiOI
4.40E-OI
l.82l-*02
1.571-tOl
8.46EiOO
8.40H-01
2.111:101

I.06E+OI
6.95E-OI

6.00E-01
1.2IH103
2.651: »OI
1. 371-:. 03

1. (.71: KM)
Standard
Deviation
1.02 Hi 00
5.I3I-X)2

5.70h-OI
2.251: 1 00
2.011:100
4.14H-OI
4.07EK)!
2.231:100
2.5 IE fOO
I.24E-OI
3.341-100

1.57EfOO
2.9()[>()1

NA
2.04E+03'
6.36I-+00
1.931-103

9.29I.:,,,
RMH"
8. 34 E U)()
l.l7E*02
5.39E-01

5.75EUM)
1.82E10I
I.82E-*OI
I.27H*00
2.63E*02
2.02E101
1.35Ki01
1.09E<00
2.78E+01

8.27E-KH
1.37E*Ol
1.28EfOO

' NA
5.29E+03
3.92E-K)!
5.23E*03

3.53l-;iOO
Number
of
Samples
7
7
7

7
7
7
7
7
7
7
7
7

7
7
7

7
7
7
5

4
Number
of
Delects
7
7
7

7
7
7
7
7
7
4
7

7
7
2

l
i
7
7
*^

3
1'icqiieiicy
of
1 Jt'tt'C t ll 111
i '*• Ik. L t HJI I
100%

100".;,
100%
100%
43" (i
100%
100%
100%
57%
100%

100%
100%
70"
^ / /(,

loo1;;,
_
29%
1 /Win
HH) ,,
75",,
IM:lil.
5.801- 1 0()
3.001: 1 02
1 .801: lOO

3 301: i ()|
2.2(11:101
4. 901: i 02
3.501: .01
1 7()lM()l
2.20I-.-01
4.50I-.I (I]

1.501: <02

f\I A
i ^ / \
NA
8.20E-01

NA
4 9oi-:-oi
NA
Numbei of
Samples
Greater lluii
Hack^iotnul
.
0

0

0
3
0
0

4
0

0
N.
A
NA
A
NA
6

NA
c
\A

-------
       Table 5-15. (continued).
Soil Concentration
(mg/kg (nonradionuclide] orpCi/g (radionuclidej)

Contaminants
(iross Alpha
(iross Beta

Minimum
4
27

Maximum
15
7950

Arithmetic
Mean
8.03E+00
1.99E+03

Standard
Deviation
3.72E+00
3.35E+03

RMEb
1.55EHH
8.69E+03

Number
of
Samples
7
7

Number
of
Detects
7
7

Frequency
of
Detection
100%
100%

INEEL
Background1"
(mg/kg or pCi/g)
NA
NA
Number of
Samples
Greater than
Background
NA
MA
                       Duplicate sample results were not included in the statistical analysts
              NOTI:
                                                                                                                               in Appendix G of the OU3-13 RI/FS Part A (IX)Iv-ll) 1997b) and the
                       Samples were analysed for CLP Metals, zirconium and rad.olog.cal constituents  Only those constituents that were identified above detection l.mils are shown in the table excem li.r th.
                       following constituents which were delected but are not considered to be present at hazardous concentrations: Al. Ca, Fe, Mg. K and Na
               •       Samples rejected because of an unacceptable quality control parameter were not included in the table
^     h      I he RMl: concentration is the 95% upper value based on the empirical rule (95%of the measurements lie within two standard deviations of their mean)
*j     c      IhclNM:!  background concentrations represent the 95% upper confidence limit (Rood etal. 1995).
       J - (Non-Kud) The analyte was identified in the sample but the numerical result may not be accurate.
       II •  I'hc analyte reported value is < KOI., but > 11)1..
       I' - Sample analysis by inductively coupled plasma atomic emission spectroscopy
       NA - Not applicable
       KMI' -  Reasonable Maximum Exposure,

-------
Tab.je 5-16.S
•* • 	
— » 	 '. 	 L

iiiiuiiiiinanis
at Mtci ri'-M
)



Sinl ( cmcciiiration "" 	
mi; kg InoiiiacliomidiileJ t.i p(j/j. [ladiomiclidcj)
Niiinhft
Contaminants Minimum
As 3.101-iOOJP
B-' 4.45F10I P
(';l 2.18i;»03P
('<> l.90i;t()OHP
(l 5.ioi-:ioo.ip
r" 6.00I-. i OOP
.. I.-1M
N''i l>. II lit Oil'
N'' s.4oi-:ioop
l>h 3.S01-.IOOJP
•sh 5.30i;-01 HP
v 6.50F. IOOHP
/•» 2.211; (01 NJP
Am-241 1 .971-: 100
Co 60 I.90F-01
Cvl34 5.00l-:-02
<-l.<7 6.00I-.-02
1 II- 1^2 | S7|. ,()()

1 " i vi i '.'oi-.-oi

Maximum
7.001-1 00 JP
! 84F.I02P
2.321:105 P
9.60I-.-01 HP
8 201 vi 00 HP
2.63F,i 01 P
1.671- i()l P
'••""Ol-.-OI
2.94l-.i02 NJP
2. 641-101 P
I.OII-iOI P
8.30F.-OI HP
3. 641: (01 P
8.6()1-:(01 P
I.97F.100
2. 1 fili i 04
6.00I--02
4.0X1-105
....
, ./()!. M)4
5.351-'i()4

Arithmetic
Mean
4.65FiOO
1.03 Ft 02
4. 08 1:-0 1
3. 531-;. 04
' 4.77FJOO
1.541:101
1.50I-.-OI
I.80H(02
1.651- 101
6.861-100
7.I2F-OI
4.751: K)l
1.971: (00
1. OS Ft 04
5.50F-02
3.40F 104

- '-'' '"4 •
1. 34l-i 04

Standard
Deviation
1.23 Hi 00
I.56F.-01
6.97H104
2.92H-01
2.00F.IOO
7.45HIOO
3.85FiOO
O.OOFtOO
6.77Ht()l
5.761- tOO
I.80H100
1.04Ft01
2.00H101
NA'
1.531--104
7.07i;-03
1.1 Slit 05

5.061-104
2.671: K)4

RMl;h
7.IIF.IOO
I.96HI02
7.20F-OI
1.75Ht05
I.02F(00
8.77F.iO()
3.03E101
2.02F»01
1.50F-OI
3.15F.+02
2.80F+01
1.05EK)!
9.38F-01
4.02E(01
8.75F-+OI
NA

6.91F-02
2.70FtOS

1 .301: t OS
6. OS HI 04

of
10
10
10
10
21
10
10
10
10
10
10
10
10
10
10
1
71
10
7|

1 1
21

Number
it:> 	 01 Detects
10
10
10
10
10
10
10
10
1
10
10
10
6
10
10

1
1 •)

,
4

Frequency
(>l deteeiion
100-;;,
100%
100",,
100%
100%
100",,
100%
"
100%
100%
1 00".;,
60",,
loo11;,
100%
1 00%
10%
— 0 t.
57 „



Nuiuln/i til
Background1 (iu-atei liian
5.80EKM) |
3.00lit02 o
1. SOli 1 00 o
2.401-:i04 i
2.20FiOO o
l-IOl-JOl o
3.301; 1 01 o
l. 201; ioi o

5.00I:-02 |
4.9()l:i02 o
3.501-1 01 ()
1. 701-101 o
4.80i;K)0 o
4.50i;ioi o
1. 501: 102 o
1.I01--02 |
NA NA
NA NA
s2oi-:-oi K,

NA NA
NA NA

-------
Table 5-16.
Soil CuiKiiili.ilinn
iiu1 ku [nunuiiliniiiiclidcj in pt'i'jj [luduniuclidcj)

( 'onlainin.iiiis
lui-155
Nh-95
l'u-239 240
Si -90
1 1-235
l'-23X
(iioss Alpha
( iioss Ik-la
.1 Mill

Minimtim
1 (iOh.-()I
o OOI--02
1 4 Ih. i02
1X5 hi 01
1 73I--02
1 S(>h-OI
1 S7I-MJO
2 Slh.iOO


Maxinuini
9.621-,. ,3
9.00I--02
1.4 II: '02
1.251:i05
2.3()I-iOO
4.53I-.-OI
I.hlhi04
5-4 X I-M) 5

Arithmetic
Mean
3.21 1: K»
7.33H-02
1.4 11: (02
2.h8Hi04
X.nii-01
2.5XI--01
1. 5()li i03
3.531: « 04

Standard
Deviation
5.551-103
1.53I--02
NA
5.02H-I04
1.341:100
1.69F.-OI
4.50f:i03
1.251- 105

Nuinbei

RMI:k }•
1.431:t04
1.04H-01
NA
1.271--I05
3.501-iOt)
5.96I--01
1.051-104
2.X5lit05

of
iamples
21
10
1
10
5
5
21
21


l-icquency
Tdeleclion
14%
30'«,
100'!,,
X0%
dO%
hO%
100%
90%
IN! hi
(Illl! kl! ill Jll'lrjj)
NA
NA
I.OOh-0]
4 901: 01
NA
1. 4()|-i 00
NA
NA
Ntimlii-i i>l
(iK-Jlcl lll.lll
Hack".i niinil
NA
NA
1
X
NA
0
NA
NA
                        .iii' >jni|ili- icMilb \\cii; nut meliuU.I in ihi- Malislical analysi
                                                                                                                                 19

                                                                                                                                 11
                 A,uK lu-jl ivsulis aic Hum samples roll* .,-,1 !„„„ |fto hmnj* installed dunnj- ihc ( )l I 3-0-> Track 2 lnvnii?aii.ni uiul ivv,,lh.i U,L>.S niMalluJ ilurini: .lu- ( )l M . |  i |<|  «..,..,,  .
                 I ,.»!  l-K-l,M,,»;,,y Scop,,,, hack 2 Sun.m.ns l<,p,,,, l-o, tlpcmblc linn O.I 3-,W(l.l ICO  |W5b,. Appends < i ,„ ,l,c (.1 ,.-..» KI/I-S !>.,. A (I)OI -II, 1,,7I,, ',n!l ,|J I ! £

                 Samplo ««o analy/cd Inr H.I' MclaK ami Kiuln.kigical lon.s.nucnls Only Un.sc vimMiluiiils Ihu. »«« idcnuiic.1 jhnu- ilctccli.ni Innih .» Ihc samples  nc sl,,,«i, ,„ ,h, u.l .
                 lolkm mp L-,.i.Miu,ciib "Inch wc,c tlclcclal h,,i a.c no. cun^Jcrcd hi he present a. ha/a.dous c.mcent.atmns  Al. I c. Mg. K. NJ ami K-JO       '

        •        Sample-, u-jci-lcil IICCJIIM- of an tinuccejxulile i|iialily conliol paramelei aie not included in  Ihc lahlc

        Ihc KMI- coitcciilialitHi ^ the ';.V,. upper value based on Hie enlpiiical mlc C>.S%oCi|,e  nieasu.eincnlb he \\tllnn  I«o biaiulaul de» i. ..... n-, ul ihen mean)

>•'       I In.' INI I I  li.ick(!iiiiindciiiicciilialioiiMcpieNetil the 'J.v1,. uppci con fulenci: limit (Rood et al  IW5)

I   I he anaKle was ulentilied in Ihc sample hut ihc munciical icMilt may nol he aeeurale.

li   Hie aiulsie icpiiiled \aluc is-- Kl)l . hut '• 11)1

N   Spiked sample icemcix  nut \Mllllil conliol limits

I'   .Sjmple an.il\sis In uiiliMixcly coupled plaMiual ...... t CIIIISMOII .•.pcetinscupy

N\  'Nolapplicahle

KMI    Ke.iMin.ihK- M.IMIIIIIIII I \POMIIC_ _
                                                                                                                                                                                             ,    „
                                                                                                                                                                                              '"
                                                                                                                                                                                     .v . .„. ,   „
                                                                                                                                                                                         '        '
 l>

-------
                                                                                                            1

  taed test O^P2!^0^ "*?? CPP^1917>' ™s ** « a group of 648 boxes of soil
  located wes  ot CPP-1617 ha contain soils and debns with low levels of rad.oact.ve contamination. The
  (075 n Vn,     i  X,  X , .h) and L2 * !-2 * 2-4 m (4 x 4 x 8 ft) boxes are constructed of I 9-cm
  (0.75-,n.) plywood and are Imed with a polyethylene membrane.  The soils were generated during vanous
  INTEC acnvrties. including the Tank Farm upgrade, CERCLA remedial projects  the CPP-603 cleanuD
  excavation tor the hre exit from building 604/605 and miscellaneous excavations' at INTEC ' wh  e soT
                  ^^^
            are                                                                        6°4/6°5
     -ss                                 f°T the Various Cation activities are arsenic,
 U234 and U ?s  vnr      '   ^ EU'154> ^^^ Np'237' Pu'238> P"-239/240, Sr-90, Sb-125
 U-234, and U-235. VOCs were not detected in the samples. The only inorganics detected above
 Ren n           ,                            '        '          was   ow  e
 Region III nsk-based soil concentration of 23 mg/kg residential, noncarcmogemc soil screening level
 These contaminants are consistent with the types of contaminants contamed in the servS^SLtS

 ™
                  deb?S u^6 contained in Polyethylene-lined boxes that have not deteriorated
           and eaf   ! ******* ^^ of contaminated soil have not leaked from the boxes and
 h!  IK        ono  contaminant migration from the box staging area have not occurred  Assumme
 that the boxes are 80% tail, there is a total of approximately 1,000 m' (37,000 ft') of so^ln the "

 :o m^?96off d"93 ^"^ Ca/f  Tt^ '" ^ ^^ ^ *™h W2S aPP™-™ately 61 m (200  ft, ,n
length and  4 m  * tt) m vv.dth at the bottom, sloping to 4.9 m ( 16 ft) in width at the top.  The trench
contamed 1 I to 1 .2 m (3.3  to 4 ft) of nonrad.oactive calcine before being backfilled to grade with
          Cy  1-2.m<4ftI)?ft°P»il-  Based °» Photographs and operator logs, the trench was used for
         calcine disposal from  1964 through 1966.
                                            5-45

-------
Table 5-17. Summary sampling results statistics soil contaminants for Site CPP-93/
Soil Concentration
(mg/kg [nonradionuclide])
Coiiliiminunis
Al
11(5
Nitrate/Nitrite
Na
Minimum
6.!!E*03
2.80E+00
l.OOE+00
4.29E*02 B
Maximum
1.20E+05
1.40E+02
7.49E+01
4.29E+02 B
Arithmetic
Mean
3.97E1-04
4.43EKH
1.66E+01
4.29E+02
Standard
Deviation
4.48E-r04
5.19E+OI
2.77E+01
NA
RMEb
1.29E+05
1.48E+02
7.20E+01
NA
Number
of
Samples
8
8
8
8
Number
of Detects
8
8
8
1
Frequency
of Detection
100%
100%
100%
13%
INEE1.
Background*
(mg/kg or pCi/g)
1.60E404
5.00E-02
NA
5.20E+02
Number of
Samples
Greater than
Background
3
8
NA
0
       NOTI-:
               Duplicate sample results were not included in the statistical analysis.
        «       Analytical icsults are from samples collected from four borings installed during the OU 3-13 Rl.  Results are provided in Appendix U of the OU3-I3 RI/I:S Pan A (DO1:-II> I Wb) and
               the i-RIS Database.
h      1 he KM!- concentration is the ')5% upper value based on the empincal rule (95%of the measurements lie within two standard deviations of their mean).
c      I lie INl-.hl. background concentrations represent the 95% upper confidence limit (Rood el al. 1995)
U   I he analyte reported value is  •; RDl., but > IDL
NA - Not applicable
KMI- = Reasonable Maximum lixposure

-------
   TW»,,  T8 ,  mvestlgatlon more than 60 bo™gs were dnlled to define the simulated calcine
   Because the calcine was easily identified visually only a few samples were collected for laboratory
   analysis The analytical results from borings CPP-93-1 through CPP-93-4 confirm the p esence oTth,
   layers of simulated calcine material in the vicinity of a trench located southeast oTbuScPP 603
   PJTenC,!L? SmTted calcme material is supported by visual observations in the borings and elevated
   S^torm°[SSUiyi     mUm' mtrate/nitrite< and S°dlum- T** °bs<™d calcii was only 3 t
                 H the.slmu!*ed cal<='"e contain elevated concentrations of mercury, aluminum.
  w     n    r h         Concentrates of sodium, nitrate/nitrite, and aluminum appear to decrease
  the d!P V  the,b°nng,S to b^kground levels but mercury concentrations are still above backed at
  but £ ^n TtmP, HS m    ^""u85-  ^ fU" CXtent °f merCUry above Background has not beenSed
  30 m ( 1 0 ftf^     Su 8gf lhat ^^ concentrat'°"s w^d continue to decrease with depth be ow
  31 fi  f?;   ?       of additional borings drilled outside of the area of the trench indicate that
  s^ficam lateral m.grat.on of mercury and aluminum from the buried calcine has not ocoSed

        The contaminated zone for this site is assumed to be from 0.8 to 7.6 m (2 5 to 25 ft)  A
  contaminated soil of 2,039 m> (72,000 ft') was estimated based on the reported dimensions rt

                     ^ ? } ^ t0 ^ °/7'6 m (25 ft) ^ ^ t
                     This site is being addressed as an ecological risk site.
  5.3.3. 16   CPP-14 (Decommissioned Sewage Treatment Plant).  Site CPP-14 ,s the site of a
  decommissioned sewage treatment plant that operated from 1951 through 1982. The Jm^ent pTant
  processed sanitary wastes from nine facilities at the INTEC.  Site CPP-14 is located inThe north renLl
  portion of the INTEC, south of Cypress Avenue, east of Beech Street, and north S '£ SfS? Tank FaL
  as shown on Figure M.  Site CPP-14 was determined in the RI/BRA (Dol-ID T^^e solely an
 ecol0g,cal concern due to the presence of mercury at a depth greater than 9 feet.                X

                                     *mo"dled as part of the ™i* ^placement and Expansion
                                         Dem°lition Was comPleted in September 1983 and


            Removing the wastewater treatment facilities and associated equipment to a depth of 1 5-m
            p- tt) belowgrade


      •     Rerno.v«ng and disposing of all remaining sludge in the drying beds

            Removing all buried piping, except the 0.3-m (12-m.) infiuent line and the 0. 15-m (6-m )
            etiluent lines from the chlorine contact basin to the drain field.

      The excavated area was backfilled and graded to match the surrounding ground surface.
H.en            r                Jt- Imh°ff UnkS' final tank' and chlorination tank extended to as
deep as 6.1 m (20 tt) belowgrade. The lower port.ons of these facilities were left abandoned in place.
                                            5-47

-------
 Demolition planning documents stated that drainage holes approximately 0.09 m: (1 ft2) would be cut in
 the bottoms of all abandoned structures to prevent accumulation of infiltrating surface water.  Also left in
 place were the 0.3 m (12 in.) diameter influent line, the 0.15 m (6 in.) effluent line to the drain field, and
 the drain field distribution piping.

       The extent of contamination at the former sewage treatment plant was evaluated based on the
 results of sampling. The zone of contamination in the area of the Imhoff Tanks is assumed to be 0.9 m
 (3.0 ft) thick, and extends from 2.4 to 3.4 m (8 to 11-ft) bgs. This thickness is based on the initial depth at
 which sludge was encountered in sampling, and the depth of the base of the tanks. The area of the tanks
 is 18.6 m' (200 ft2). Radionuclide COPCs at this site include Cs-137, Np-237, U-235, and Sr-90. Of
 these, Cs-137, Np-237, and Sr-90 were detected at activities above 1.0 pCi/g. Cs-137 activity ranged as
 high as 6.21 pCi/g.

       The zone of contamination at CPP-14 Plant site was assumed to be 8.2 m (27 ft) thick.  This zone
 extends from 1.5 to 9.7 m (5.0 to 32.0 ft) bgs. The area of CPP-14 Plant site measures 900 m3 (9.860 ft2).
 Numerous radiological COPCs were detected in multiple plant site area samples. These include Cs-137.
 U-234. U-238. and Np-237.  Of these, U-234 and U-238 were detected at the highest activities, 6.89 and
 52.1, respectively. Cs-137 and Sr-90 detections were also common, but at lower activities. Table 5-18
 provides summary sampling results statistics for soil samples collected at CPP-14.

       The zone of contamination at the drain  field is assumed to extend from 4.3 to 7.6 m (25 ft) bgs.
 The top of this interval is based on the depth of the drain field piping. The area of CPP-14 drain field is
 estimated to be 306 m2 (3,300 ft2). Radiological COPCs at the drain field are Np-237 and Sr-90. Of these
 COPCs, only Np-237 was detected above 1 pCi/g. Np-237 was detected at a maximum activity of
 1.4pCi/g.

 5.3.3.17  CPP-37A (Gravel Pit #1). Site CPP-37A (Pit #1) is located outside of the INTEC security
.fence and measures approximately 43 m (140  ft) in  width 64 m (210 ft) in length and is 4.3 m (14 ft) in
 depth. No information is available on the date pit usage began; however, Pit #1 was used for
 decontamination of radiolonuclide-contaminated construction equipment during July and October 1983.
 In addition, during 1982 and 1983, the pit was used as a percolation pond for INTEC service wastewater
 while the injection well was being refitted. This pit currently receives stormwater runoff from the
 INTEC.

     Soil samples were collected from Pit #1  in 1991. Analytical results are summarized in Table 5-19.
 Based on the contaminant screening, COPCs identified for Pit #1 were arsenic, Co-60, Am-241, Cs-137,
 Np-237. Pu-238. Sr-90, U-235, and U-238. The Track 2 investigation for Site CPP-37 (WINCO 1994a)
 Pit #1 indicated that arsenic was detected above background in eight out of 14 samples collected.
 However, the maximum arsenic concentration was only 8.7 mg/kg relative to the background value for
 arsenic of 5.8 mg/kg.

     Radionuclides detected above background in soil samples collected in Pit #1 were Am-241. Cs-137.
 Pu-238, Sr-90, and U-238. Other radionuclides that do not have a background value were detected at low
 concentrations including (maximum concentrations in parentheses): Co-60 (0.55 pCi/g), Np-237
 (1.07 pCi/g) and U-235 (0.05 pCi/g). No radionuclides were detected in the 0- to 0.3-m (0- to 0.5-ft)
 samples except for Sr-90 at 0.69±0.12 pCi/g in the southwestern portion of the pit. Radionuclides were
 not detected above background in the deep borehole below 4.6 m (15 ft).

     The contaminated zone at Pit #1 is assumed to extend from 0 to 3.0 m (10 ft). The area of Pit # 1 is
 2.731 m: (29.400  ft2) and 9,179 m2 (98,800 ft2) based on the dimensions reported in the Track 2
 (WINCO I994a).
                                              5-48

-------
Table 5-18.  Summary sampling results statistics for soil contaminants at Site CPP-14.'
Soil Concentration ~ 	 —
(mg/kg [nonradionuclidel or pCi/R fradmnnrljdpl)
< 'oMluminuiils
Imhoff Tanks
As
Ua
Be
'.Cr
HB
Mn
Ni
Pb
Th
V
Zn
Acetone
Di-n-octyl Phthalate
Bis(2-hthylhexy!)
Phthalate "
Toluene
Total Xylencs
Phenol
Minimum
1.22E+01
4.60E+00
1.75E+02
5.30E-OI B
5.12E+01
9.63E+01
L20E+00
2.07E+02
2.40E+01
3.56E+01
2.40E-01 B
3.10E+01
1.35E+02
I.30E-02
2.90E-01 J

9.80E-01
6.00E-03 J
5.00I--03 J
2.201--01 J
Maximum
4.89E-I01
4.90E+00
2.07E+02
5.60E-01 B
6.07E+01
9.63E+01
4.00E+00
2.48E+02
2.62E+01
2.1IE+02
2.40E-01 B
3.49E+01
4.75E-*02
2.10E-02
2.90E-01 J

1.70E+00
2.90E-02
2.70E-02
2.30E«0()
Arithmetic
Mean
3.06E^01
4.75E+00
1.91E+02
5.45E-01
5.60E+OI
9.63E+OI
2.60E+00
2.28E+02
2.51E+01
1.23E+02
2.40E-01
3.30E+01
3.05E+02
1 70E-02
2.90E-01

1 .34E+00
1.75E-02
1 .60M-02
1.261-!iOO
Standard
Deviation
2.60E+01
2.12E-01
2.26E+01
2.12E-02
6.72E-KH)
NA
1.98E+00
2.90E+01
1.56E+00
1.24E+02
NA
2.76E+00
2.40E+02
5.66E-03
NA

5.09E-01
I.63E-02
1.56E-02
1.471HOO
Number Number
of Of
RME Samples Detects
8.26E+OI 2 2
S.17E+00 2 2
2.36E+02 2 2
5.87E-01 2 2
6.94E+01 2 2
NA - ? i
6.56E+00 2 2
2.86E+02 2 2
2.82E-H)! 2 2
3.71E+02 2 2
NA J i
3.85E+01 2 •>
~* £•
7.85E+02 2 2
2.83E-02 2 2
NA ~> \

2.36E+00 2 2
5.01E-02 2 2
4.72E-02 2 •>
4.20E+00 2 2
l-'requency
of
Detection
100%
100%
100%
100%
100%
50%
100%
100%
100%
100%
50%
100%
100%
100%
50%

100%
100%
100%
100%
1NEEL
Background"
(mg/kg or pCi/g)
O.OOE+00
5.80E<00
3.00Ei02
1.80E+00
3.30E-KM
2.20E+01
5.00E-02
4.90E+02
3.50E+OI
I.70E+01
4.30E-01
4.50E+OI
1.50E+02
NA
NA

NA
NA
NA
NA
Number of
Samples
Greater than
Background
2
0
0
0
2
1
2
0
0
2
0
0
1
NA
NA

NA ,
NA
NA
NA

-------
       Table 5-18. (continued).
Ui
o
Soil Concentration
(mg/kg Inonradionuclide] or pCi/g [radionuclide])
('oMlumiiiants
4-Mcthylplienol
l,2-I)ichloroethane
1 ,4-Dichlorobenzene
Ben/.oic Acid
Methylene Chloride
Naphthalene
4-Chloroaniline
Phcnanthrene
Fluoranthene
I'yrene
Bcn/.o(u)unthraccnc
Chryscne
Ben/.o(b)fluoranthene
Ben/o( k ) lluoranthene
Benzol a jpyrene
Aroc lor- 1260
(VI 37
Np-237 .
Sr-90
1 1-234
I '-235
I -.M.X
Minimum
7.60E-01 J
3E-03 J
3.10E-01 J
2.30E-01 J
1.20E-01 B
1.70E-OI J
6.40E-01 J
1.50E-01 J
2.40E-OI J
3.00E-01 J
1.50E-01 J
3.80E-01 J
3.20E-01 J
2.70E-01 J
3.40E-01 J
6EH)0 X
4.94E+00
I.70E»00
7.10H-01
7.00L-01
5.00E-02
5 ioi-:-oi
Maximum
7.60E-01 J
3E-03 J
3.10E-01J
3.20E-01 J
1.20E-01 B
1.30E+00
1.10E+OOJ
3.70E-01 J
7.20E-01 J
6.60E-01 J
3.80E-01 J
3.80E-01 J
3.20E-01 J
2.70E-01 J
3.40E-01 J
2.30E+01 X
6.21E+00
1.98E-<00
1.07E«-00
1.15EHK)
5.00E-02
.V301i-()l
Arithmetic
Mean
7.60E-01
3E-03
3.10E-OI
2.75E-01
1.20E-01
7.35E-01
8.70E-01
2.60E-01
4.80E-01
4.80E-01
2.65E-01
3.80E-01
3.20E-01
2.70E-01
3.40E-OI
1.45E+01
5.58EtOO
1.84E+00
8.90E-01
9.70I--01
5.00I--02
5 201-.- 01
Standard
Deviation
NA
NA
NA
6.36E-02
NA
7.99E-01
3.25E-01
1.56E-01
3:39E-01
2.55E-01
1.63E-01
NA
NA
NA
NA
1.20E+01
8.98E-01
1.98E-01
2.55E-01
2.55E-01
NA
I.4IH-02
RMEb
' NA
NA
NA
4.02E-01
NA
2.33E+00
1.52E+00
5.72E-01
U6E+00
9.90E-01
5.91E-01
NA
NA
NA
NA
3.85E+01
7.38E+00
2.24E+00
1.40E+00
1.48EKK)
NA
5.481--OI
Number
of
Samples
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Number
of
Detects
1
1
1
2
1
2
2
2
2
2
2
1
1
I
1
2
2
2
2
2
I
2
Frequency
of
Detection
50%
50%
50%
100%
50%
100%
100%
100%
100%
100%
100%
50%
50%
50%
50%
100%
100%
100%
100%
100%
50%
100%
INEE1.
Background'
(mg/kg or.pCi/g)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
8.20E-01
NA
4.90E-OI
1.44E+00
NA
1 .40H > 00
Number of
Samples
Greater than
Background
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2
NA
2
0
NA
0

-------
Table 5-18. (continued).
Soil Concentration
	 _ (n^kgjnpnradionuclidej ot pCi/g [radionuclidel)

( 'iiiiuiminani.s
Y-90
Plant
Ag
As
Ba
Be
( d
( o
r
u
Hg
Mn
Ni
I'b
Sb


/n
2-Buianone
4-Nitrophenol
Di-n-octyl Phlhalate
MfiliylencChloiulc

Minimum
7.00E-01
8.00E-01 B
2.40EHH)
4.96E+OI
2.40E-01 B
4.00E-OI B
3.70E+00 B
7.30E+00 J
9.40E»00
4E-02
1.02E + 02 J
I.05E-KH
4.60E + OOJ
1.23E+OI B

1.04E+01
2.31E+01
I.OOE-03J
2.60E-OI J
2.40H-0] J
2.50E-U2 B

Maximum
UOE'OO
8.30E+OOJ
4.10E+OOJ
I.49E+02
6.30E-OI B
6.60E-01 B
6.60E+00 B
3.04E+OI
3.11E+OI
1.10E-01
2.92E+02 J
2.65E+OI
6.22E-t01
I.23E+01 B

3.04E + 01
1.00E-03J
2.60E-01 J
2.40E-01 J
I.20K-01 B

Arithmetic
Mean
9.00E-01
4.12E+00
3.50E+00
8.54E+01
4.09E-01
5.25E-01
4.72E+00
1.60E+01
1.50E+OI
7.50E-02
1.69E+02
1.61E+01
I.68F,t01
1.23E+01

1.82E+OI
4.20E+01
l.OOE-03
2.60E-01
2.401--01
7.33I--02

Standard
Deviation
2.83E-OI
2.77E+00
7.30E-01
3.16E+01
1.44E-01
1.1IE-01
1.16E+00
6.44E+00
8.34E+00
4.95E-02
5.93E+01
5.57E+00
1.95E+01
NA

6.42E+00
1.91E+01
NA
NA
NA
4.42E-02

RMEb
I.47E+00
9.66E+00
4.96E+00
1.49E+02
6.97E-01
7.47E-01
7.04E+00
2.89E+OI
1.74E-01
2.72E+01
5.58E+01
NA

3.10E+01
8.02E+01
NA
NA
NA
I.62E-01

Number
of
Samples
2
11
11
11
11
11
11
11
11
11
11
11
11
t 1

11
11
1 1
10
1 A
11

Number
of
Detects
2
5
7
11
10
4
6
11
6
2
11
11
8

11
8
i

4

Frequency
of
Detection
100%
45%
64%
100%
91%
36%
55%
100%
55%
18%
100%
100%
73%
9%
100%
73%
9%
10%
1 0%
36%



INEE1.
Background'
(nig/kgorpCi/g)
NA
OH+00
5.80E»00
3.00E + 02
1 80E*00
2 20E+00
1 lOEfOl
3 30E+01
2.20E+01
5.00E-02
4.90E*02
3.50E«01
1.70Et01
4.80E*00

1.50E+02
NA
NA
NA
NA


Number of
Samples
(ireaterthan
Background
NA

0
0 .
0,


0'
1
I
0
0
2
I

.
0
NA
NA
NA
NA

-------
       Table 5-18. (continued).
Ul
I


NJ
Soil Concentration
(nig/kg [nonradionuclidej orpCi/g [radionuclide])

Contaminants
Bis(2-Lilliylhexyl)
Fhllialatc
Toluene
Total Xylenes
Ben/oic Acid
Tetrachloroethylene
Penlachlorophenol
Aroclor-1254
Aroclor-1260
Am-241
Cs-137
Np-237
Sb-125
Sr-90
1 1-234
U-235
U-238
Y-90
Drain Field
Ag
As
I):i

Minimum

4.30E-02 J
4E-03 J
4.40E-02
2.00E-01 J
1E-03J
3.80E-01 J
2.10E-02JX
l.OOE-01 JX
1.15E+00
3.10E-01
4.05E-OI
l.OOE-01 J
7.00E-02
9.00E-02 J
5.00E-02
l.OOE-01 J
I.OOE+OI J

3.30IHOOJ
l.lOEiOOJ
7 121-tOl

Maximum

4.30E-02 J
4E-03 J
4.40E-02
2.00E-01 J
IE-03J
3.80E-01 J
1.20E-01 JX
5.70E-01 DJX
1.I5E+00
3.89E+00
S.SOEiOO
I:OOE-OI J
5.70E-01
6.89E+00
6.80E-01
5.21E*01
4.00E-01

3.30E
-------
Table 5-18. d minimal).


< •..nu.miM.iMK
Me
.
( \l
( 'o
(•
i
('u

l!
\ 1
Mil
Ni
1.1
n
Se
1 1)
V
•/
/n
l)i-ii-hiii\l I'lnlialaie
Naphthalene
I'heiiaiithiene
Autcloi-1260
(VI 37
Np-237
Si-'W
1 ' ") M
I -.'>!
1 ' MS



I"1;: ku [

Minimum
4.30H-OI H

8.IOH-OI M
4.401-1 00 M
l.57lii()|
I.S'M-JOI

3.SOI:'-()1 J

8 I31it()l
I.33I-H01
9.401-1 00 J
4.30I-.-OI H
2.101i-()l It
I.47I-+01
4. 501-101
9.0()l-:-02 J
I.20I--OI J
8.70I-:-02 .1
7.20li-OI DJX
3. 15 1- 100
5.90I--OI
vlnl'-OI
2 'OI--OI

— .- 	
Soil Ctwu
iiuiii jihoiuielulej

Maximum
4.30I--OI H

S.10I-.-OI M
9.00!-;iOOB
2 52 lit 01
l.94l-:t()|

3 S()|i-OI J

4.l3|-!i02J
2.201-:. oi
1. 551;. t 01 J
<-.'>oii-oi j
2.40I-.-OI H
•2.97I-..OI
S SOli 1 01
9 OOIi-02 J
I.SOIi-0] J
8.70I--02 J
7.2oi:-orr>jx
3.I5H-MH)
1. 401: '00
S.XOI-.-01
-1 20I-.-01
* 9<)|- .01







"Till: li^hoiuk-lulej)

Arithmetic
	 Mean
4.30I--01

S.IOI:-OI
6.001: *00
l.WI-iOl
l-921-i 01

3.80I--OI

2.38I- + 02
I.75LK)!
1. 271: +01
5.60K-OI
2.25H-OI
2.24Ht()l
6.78F.IOI
9.00L-02
I.50H-01
8.70K-02
7.20I--OI
3. 151; tOO
1.04 lit 00
5.00I--0]
3.73J-OI
2.90I;-0|


Slundarti
Deviation
NA

NA
2.00LiM)0
' 5.371- » 00
3.54H-OI

NA

I.671-I02"
4.711->00
3.081; +00
' I.X4E-01
2.I2H-02
7.5 IH tOO
2.. 9E*01
4.24l:tOO
NA
NA
NA
4.I21--OI
5.69li-02
.S.72I--02


RMHb
NA

NA
I. I2I-M)!
2.971-:. OJ
1 991-' 1 01
.
NA
1 N f \
5.721it()2
2.691-: + 01
1.89Iit()|
9.28I--01
2.67I--OI
3.741- »01
1.121: 1 02
NA
8.63 1:.iOO
NA
NA
NA
1 N/\
1. 861- i.OO
1.291- MM)
4.871-i-Ol
4 641-' 01
'

Number Numhei l-iei|iiene\
"' <>!' of
1 ** * 'ClCC IS I'CtCCllOll
3 I TV

1 33'},,
•l 3 100".,.
3 loo11,,
"1 -) , -7,.
-s 2 07";,
^
I 33",,
3 100%
3 100",,
•; 3 1 00%
" •' . 2 07'!,, '.
; •>
•! 3 loo1!-;,
•; 3 100%
'i i i >ii
* .I.>/K
^ 9 /»-?"
*- \t l U
3 1 •! •»!-
1 .V^ ',,
1 .^.'.11
\ 1 » 1 1
1 1 33 „
•' 3 loo11,,
'' 3 loo",,
5 3 loo-.,
\ 1 i.i
3 |()(l",,

Maekgnniiul'
«»'S'!'£.4L£LL/IS.)
1. SOI: tOO
2201-JOO
I.IOIitOI


2.201-101

5.00I--02
4.901: 1 02
3. 501- 1 01
1.701-1 01
2.20I:-OI

4. 501: 1 0|
.I.50hi02
NA
NA
NA
NA
8.20H-OI
NA
1.441-1 00

1 ,40l-.t 00
Niniil
Sam
Maekf
(l
0
(i
o

o

1
0
0
o


0
f)
1)
NA
NA
NA
NA
1
NA
0

n
                                                                                                                                iluui

-------
Table 5-18.  (continued).
Soil Concentration
(mg/kg Inonradionuclide] or pCi/g [radionuclide])

( 'lllll.llllllKllllS
Y-90
a NO II-.

Arithmetic
Minimum Maximum Mean
9.00E-02 9.00E-OI 4.95E-01


Standard
Deviation RMI:b
5.73E-01 1.64E+00


Number
of
2


Number
of
2


Frequency
of
100%


INEEL
Background1
(nig/kgor pOYg)
NA

Number of
Samples
Greater than
Background
NA

        »       Duplicate sample results were not included in the statistical analysis.
        •       Analytical results are from 17 soil samples collected from five pipe excavation locations and 10 boreholes installed under the OU 3-05 Track 2 investigation.  Results are provided in The Track 2
                Summary Report, Waste Area Croup 3, Operable Unit 3-05. Old Sewage Treatment Plant West of CPP-664 (WINCO 1993j) and Appendix G of the OU3-I3 RI/KS Part A (OOIMD 1997b).
                Selected maniples were analyzed for metals, radionuclidcs. VOCs. SVOCs, PCBs, pesticides/herbicides and dioxin/furans  Only those constituents that were identified above detection limits are
                shown in the table except for the following constituents which were detected but are not considered to be present at hazardous concentrations: Al, Ca, He, Mg, K and Na
        •       Samples rejected because of an unacceptable quality control parameter are not included in the table
h       flic RM1: concentration is the 95% upper value based on the empirical rule (95%of the measurements lie within two standard deviations of their mean).
i'       flic INI-I-I  background concentrations represent the 95% upper confidence limit (Rood et al. 1995).
J   I lit; anulyle was identified in the sample but the numerical result may not be accurate.
H   I lie unalyle reported value is <('RD1., but > 11)1..
J.\ - I lie icporled value is an estimate quantity manually entered onto the results form.
I)J.\ =- I he compound was analy/ed at a secondary dilution factor and was an estimated quantity that was manually entered onto the results form.
NA - Not Applicable
KMI:  -  Reasonable Maximum Lxposure.	

-------
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VN VN »;,x | -|

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vx VN VN f VN
1 Ki-:i(ir7 «i,(M)i fi M
1 l(|r-HlZ. i « ;,(io | f, N
*" ro-'-inos" ",,r.r t- t.,
HOC f f|
" i<)-:-ii)f f ",,0111 f | f |
0 IHi'-IOct ",,(l()| f| ^i
0 r(i'-iin)-»- »„„„, _ M t,|
S mi'-'IOSV ".,(l(l| f| f|
uuii^ir[j i|pij|~" "(1iT)iI in IM TuiJ"" ~T~"i — " 	 	
|oi.i.|uinN' ' H'INI"'" nil;illhnj-l ^^.1^ ^^.10^

r'\n n,| l-^Anjo'v/r-,

OOt4V/.c 00»H()0-| HKIiCi •
VN VN ro-;ioo\-

1" 'it. I I l()-;h'> k
io-;i80'z. 10-360 1 io-:-io/. f

lO'.-ISk 1 c()-3IM KK-IOI 1

- ' •''<• ' '
OO'liS'V (MHHcc'l OIHMVI 1
VN VN \()-W
Id ) ^IK' in ^Hinillllininoi nm.- riu {.-1II...III,

OOi-166'V t(l-.-H)()i
cOvlOO'S tO--l(H) V

lo-'iorz. uK-iorr
I/.-,,,,.,, in-'i/i/'i
'" '"'4 '
in~'.in-"i iH~*ifv/i
. .
no ' ,-iz.o i M)":ior i
-.•(M)':If8'f 10: :•!()(-• |
I()-:1()!,"C lO'i-IOs S
io--io6'(> i()--iov r
r vo-i-joo'c rw-ioiic
r vo-:-ioo i rviMniii

H io-:-iorf rii io-:-ionr
IOK-IU I 00 1 -101 L
1 1\ "tim
lot-jio'v lof-iror

00»H()S'I fl III- HIS f
t '<- c lOi-liX L
OOiHOi'8 (HM-IOI I-
(tinunxp[/^ iiiiuuiuiiv
^pllOIHIOIpI'lllollI ,IN ,1m)
ilio ) |iov;
	 	 ^ 	 1 	 ,___ • ,
>,|iln,| .
	 ~ 	 4,H'-.i[
a-0

h'r-ji

Of,- IS

^vr-'M
M"-ii\
",H., ,
"lI'MM
'i:;:
OM.||p|||.rri
.ni.i|\i|P|M
•>S

•Ml
i )

I1 )
''II
••v
siiiiuiiuiriiiii )



-------
 5.3.3.18   CPP-37b, Gravel Pit and Debris Disposal Pit #2. Site CPP-37b is located inside the
 INTEC security fence. Before being backfilled, the site was approximately 79 m (260 ft) in width,
 116 m (380 ft) in length and was 7.9-m (26-ft) deep and area of approximately 9,179 m: (98,800 ft2).
 Prior to 1982. this pit was often  used for the disposal of waters released from the sludge dewatering pit of
 the old STP (CPP-715). After 1982, the pit was used to dispose of construction debris, some of which
 may have been radionuclide contaminated.  Anecdotal information suggests that the Pit may also have
 been used for the disposal of chemical wastes. Additionally, the CPP-37b was open in 1964 when the
 release of radioactive steam associated with Site CPP-26 occurred.  Radioactive steam containing Cs-137
 was released from a decontamination header in the HLLW Tank Farm. The year this pit was backfilled is
 unknown, but it is believed to have been backfilled to grade shortly after its use as a construction debns
 landfill was discontinued. Modeling and sampling of the site indicated the site is not a significant
 contributor to groundwater risk or surface exposure risk. However, since the pit was previously used as a
 landfill, characterization is considered insufficient to recommend no further action at the site.  Table 5-20
 provides summary sampling results statistics for soil samples from Site CPP-37B.

 5.3.3.19    CPP-48 (French Drain South  of CPP633).  Site CPP-48 was an excess chemical dump
 tank located south of the old WCF (CPP-633) that was used as a french drain from 1975 to 1981 (herein
 referred to as "dump tank"). The dump tank was made of steel and measured approximately 1.5 m (5 ft)
 m diameter and 3.7 m (12 ft) long, with a lid and no bottom.  The top of the dump tank stood
 approximately 0.6 m (2 ft) above the ground surface, with the tank bottom at 3 m (10 ft) bgs. As part of
 the calcining process, nitric acid  and other chemicals consisting primarily of aluminum nitrate and
 calcium nitrate used in the calcining process were disposed into CPP-48. The chemicals and
 radionuclides released to the dump tank were not treated or neutralized before percolating into the soil
 matrix through the bottom of the tank. A portable above ground disposal line was used to discharge
 effluent to the dump tank. Table 5-21 provides summary sampling results statistics for soils collected at
 CPP-48.

      Prior to the installation of an excess chemical dump tank (CPP-48), in 1975, waste chemicals were
 disposed directly to the soil in  a trench-like depression located at the dump tank site. The trench is
 approximately 3 x 1.5 x 0.3 m (10 x 5 x 1 ft) in size.  From 1975 to 1981, chemicals from the calcining
 process were disposed directly to the CPP-48 dump tank. The above ground piping used to move
 calcining effluent from CPP-633  to CPP-48 was a flexible hose that, when not in use, was "rolled up" and
 stored in CPP-633. In August  1993, the dump tank was dismantled, packaged, and removed to the Waste
 Experimental Reduction Facility  (WERF).

      Records indicate that the chemical disposal to CPP-48 was in low quantities (several gallons at a
 time). Through the years of operation, however, site personnel  indicate thousands of gallons of waste
effluent may have been disposed. No records were kept regarding the volume of effluent disposed or the
constituents in the waste stream,  but it is suspected the mercury, Cs-137, Sb-125, and Eu-155 may have
been introduced to this site via waste chemicals from the calcining process.

      In March 1991. a RCRA sampling program was conducted to characterize possible soil
contaminants in the vicinity of the dump tank.  Samples were collected from a boring drilled to 14 m
(46.5 ft) bgs and analyzed for RCRA metals, pH, nitrite, and nitrate. Analysis indicated soil samples
contained no detectable levels  of the VOCs, semiVOCs. pesticides, dioxin/furan, or herbicides.
                                             5-56

-------
_Table 5-20  Smniiu
iix
results su
. — . - ' -
'MIIIIIUII \ .Til Mill
MIIL: it .-M.III.I nu
IIIM1LA 11)1 ,S()||
loiiiuniiiui
m*ai Mict
IT-37H.. 101-02.1
4001-01
3.501-01
2.201-01 J
2.101-01 J

720i;-02J
1. 101-01 J
2.401- 01 .1
2 '01 -01

Maximum

8. 501; tOO
I.141-. 101 J
4.6SI-:t()2
3201-iiOO
4.261:. 01
1.201-01 .1
2.261: Mil J
6.50I-.-01 li

?9()|.,()|
VOOI- 02 J
.« 7()1- 02 .1
<>. 1 01-02 J
4 001-01
< 501-01
2.201-0] .1
2.101-01 .1

72(11- '-02 .1
1 101-01 .1
.' 401 III 1
.' ;H| 01

Arithmetic
Mean

4.191; UK)
4.42IOOO
1.261-;) 02
1.221: UK)
1.851:1 01
1.201-0!
9.(,0i;.00
2.8 11-01

1 201 •;-()!
7 00i;-02 -
3.701-02
6.101-02
4.001-01
.3 501-:-01
2.20I:-01
2.IOI--01

7.201--02
i.ioi;-oi
2401-01
2 501-01

Standard
Deviation

4. 01 lit 00
1.84litOO
7.73liK)|
6.551-01
7.061: 1 00
.NA
4.561:100
1.321-01

1.04 li-0 1
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA

RM1:'1

I.22HIOI
8.101-iOO
2.81HK12
2. 531: (00
3.261; t ()|
NA
l.871:.to]
5.45I--OI

3.28H-OI
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA

Numhei
of
Samples
28
28
28
28
28
28
28
28

NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
avcl Pit 112."


Numhei hcquency
of of
Deteets Detection
3 11",,
28 |()0%
28 100'!,,
22 79
28 100%
1 3'},,
28 100%
15 54'.',,

7 NA
1 . NA
1 NA
! NA
1 NA
1 NA
1 NA
1 NA

1 NA
1 NA
1 NA
1 NA



INI-.I-.I.
Hackinomur
(Illli/ku 01 p('| i;)
Ol-.tOO
5.801: t()()
3.001; -02
2.201: 1 00
3.301-!i01
5.0()l-:-02
1 701- .01
2.201-01

NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA


Numhei ol
Samples
(ireater than
•J"
;
1
I
1
1

4

NA
NA
NA
NA
NA
NA
NA
NA
i^/\
NA
NA
NA
NA

-------
Table 5-20.  (continued).
Soil Concentration
(nig/kg [nonradionuclidej or pCi/g [radionuclide])
Ciini.imiiMiih
.•\mclm-l2M)
Am-241
Cs-I37
1-12')
Np-237
I>u-238
Sr-90
1 1-234
y U-235
00 1 1-238
a NOU--
Minimum
4.20E-OI
2.1E-01
1.40E-01
1.57E+00
3.20E-01
6.00E-02
8.00E-02
1.50E-OI
5.00E-I02
1.60E-013

Maximum
420E-01
3.89E+00
6.3 IE-* 00
I.57E+00
8.60E-01
5.00E-01
4.31E+00
I.21E400
7.00E-02
7.44E+00

Arithmetic
Mean
4.20H-01
I.18E+00
2.04E+00
1.57E+00
5.13E-01
1.99E-01
9.30E-01
3.12E-01
5.75E-02
7.87E-01
Standard
Deviation
NA
1.40E+00
1.67E+00
NA
1.26E-01
1.57E-01
1.06E+00
2.14E-01
9.57E-03
1.46E+00
RMEb
NA
3.98E+00
5.38E+00
NA
7.65E-01
5.13E-01
3.05E-rOO
7.40E-01
7.66E-02
3.71E+00
Number
of
Samples
NA
26
26
26
26
26
26
26
26
26
Number
of
Delects
1
6
17
1
26
8
21
26
4
26
Frequency
of
Detection
NA
26%
65%
4%
100%
31%
81%
100%
15%
100%
1NEEL
Background1
(mg/kgorpCi/g)
NA
1.10E-02
8.20E-01
NA
NA
4.90E-03
4.90E-01
I.44E+00
NA
I.40E+00
Number of
Samples
(Jreater than
Background
NA
6
11
NA
NA
8
12
0
NA
3
        •       Duplicate sample results were nut included in the statistical analysis
        •       Analytical results are from samples collected from four borings installed under the OU 3-02 Track 2 Preliminary Scoping Package for CPP-37 by Ciolder Associates. Ine  Results are
                provided in the Draft Report for the Idaho Chemical Processing Plant Drilling & Sampling Program at Und Disposal Unit CPP-37 (Oolder Associates I'W2) and Appendix (i of the
                OU3-U RI/I;S Part A (DOL-ID I997b).
        .       Selected samples were analyzed for metals, radionuclides, V(X's, SVOCs, PCBs and pesticides/herbicides. Only those constituents that were identified above detection limits are
                shown in the table
        •       Samples rejected because of an  unacceptable quality control parameter are not included in the table
li       The RMI: concentration is the '>5% upper value based on the empirical rule (95%of the measurements lie wilhm two standard deviations of their mean)
c       the INhl-.l  background concentrations represent the 95% upper confidence limit (Rood et al. 1995).
j   I lie unulyte was identified in the sample but the numerical result may not be accurate.
H  - The analyse reported value is < RD1 , but •* IDI.
NA   Not applicable 01 not available
KMI-  •  Reasonable Maximum l-.xpusure '

-------
Table 5-21.  Summary sampling results statistics for soil contaminants at Site CPP-48."
Soil Concentration
(mg/kg]nonradionuciide] or pCi/g [radionuclidel)

< 'iinKiimnanis
As
Ha
Cr
Cu
Ug
Ni
<-/i
6, v
vO
X.n

Niliale
Nitrite
Niirale/Nitrite
Chloride
Fluoride
Sul fate
Sulfide

Tin

Cs-137
1- u-lf>5
. -i if
Sh I2~i

Minimum
2.70EK)0
3.70E+01 B
7.70EHOO
I.05EK31 J
5.10E-01
I.89E»01
4.60E+00
I.SOEiOl
4.52E+01

7.05E-01
5.29E-01
9.60E-01
I.20E-KJOJ
5.20E+00
2.21E+OI
1.56E+00

3. OOE-02

3.30EKJO
5.201--01
6.00E-02
2-10l:.()0

Maximum
1.32EKM
J.14E-KH
3.96EKM
1.05E-K)! J
9.50E-01
1.89E+01
2.39E+01
I.80E+OI
4.52E+OI

5.71E+00
5.90E-01
5.40E+00
3.30E^OOJ
2.64E+02
1.31E+02
1.56E^OO

3. OOE-02

6.50E+OI
(>.7()l-:-OI
''.OOE-02
.\30lMOO

Aiiihmeiic
Mean
5.45EKJO
9.92Ef01
1.79E+01
I.05Et01
7.87E-01
1.89E+01
9.51E+00
1.80E+01
4.52Et01

2.58E400
5.72E-01
2.88E + 00
2.42EiOO
1.91E+02
5.18E-t01
1.56F^OO

3. OOE-02

4.13E1-01
5.95E-OI
7.50I--02
3.2Xl:i 00

Standard
Deviation
2.92E+00
7.51E+01
8.10EHX)
NA
2.41E-01
NA
6.05E-tOO
NA
NA

2.42E+00
2.91E-02
2.I2E+00
8.92E-01
I.24E+02
5.31E+01
NA

NA

2.4IEKH
1.06E-01
l.2'JI-:-{)2
1.3 81: KM)

RMHb
1.13EHM
2.49E(02
3.41E+01
NA
I.27E-HW
NA
2.16E+01
NA
NA
i vf\
7.42E+00
6.30E-01
7.12E+00
4.20E+00
4.39E+02
1.58E+02
NA
i *f\
NA
1 vf\
8.95E+01
8.07E-01
l.OIE-OI
6.04E.OO

Number
ol'
Samples
11
11
1!
1
11
1
8
1
i
i
7
7
4
4
4
4
i
i
i
i
11
4
4
11

Number
of
Deieels
11
11
11
1
3
1
8
1
1'

5
4
4
4
4
4




5
2
4
4

l;requency
of
1 'election
100%
100%
100%
100%
27%
100%
100%
100%

100%
71%
57%
100%
100%
100%
100%

100%

100%
45%
50%
100%
36",,

INEEl.
Haekgiouiul l
(mg/kgoi pCi/g)
5.80EKJO
3.00E+02
3.30EfOI
2.20E*01
5. OOE-02
3.50E+OI
I.70E+OI
4.50E-f01

1.50E+02
NA
NA
NA
NA
NA
NA

NA

NA
8.20E-01
NA
4.90ii-03
NA
Number of
Samples
(iiejtei tliun
HackiitiHind

"
1
1
• 0
3
o
I
o

0
MA
j if\
MA
IN A
MA
IN/V
MA
IN A
MA
JN/V

NA
I 't /\
NA
1> f\
'
4
NA

-------
Table 5-21.  (continued).
L/l
I
o
Soil Concentration
(nig/kg [nonradionuclide]
( 'i>Hi.imm,mls
Si ')()
U-234
U-238
(iross Alpha
Gross Beta
Miniinuin
I.20I--OI
I lOE+00
I.IOE-tOO
9.00E-*00
U2IM02
Maxinuim
2.60E-OI
2.50E+00
2.70E+00
1.40E+01
1.22E+02
or pOi/g {radionuclide])
Arithmetic
Mean
I.K7IJ-OI
l.58EtOO
1.68E+00
1.I5E+01
1.18E+02
Standard
Deviation
7.02E-U2
6.29E-01
7.04E-01
3.54E+00
4.32E+00
RMEb
3.27E-01
2.84E+00
3.09E+00
1.86E+01
I.27E+02
Number
of
Sample-.
8
4
4
4
4
Number
of
Detects
3
4
4
2
4
Frequency
of
Detection
38%
100%
100%
50%
100%
INEEI.
Background c
(mg/kgorpfi/g)-
4.<;t)h-OI
1.44E-KH)
I.40E100
NA
NA
Number of
Samples
Greater than
Backunnmil
0
1
2
NA
NA
a.    NO'I I:
      •    Duplicate sample results were not included in Ihe statistical analysis.
      •    Analytical results are from samples collected from I boring installed m 1991 and from three boreholes and excavated soil in 1993  Results are provided in the Closure Plan for I and
           UnitO'P-48(INI-:i  1991) and the I-RIS database.                                                                                                                '
      •    Selected samples were analy/cd lor inorganics, radionuclides, V(X's, SVCK's, pesticides/herbicides, and dioxins/furans Only those constituents that were identified above detection limits are
           shown in the table
      •    Samples rejected because of an  unacceptable quality control parameter are not included in the table.
h      I he RMI- concentration is the 95%  upper value based on the empirical rule (95%of the measurements lie within two standard deviations of their mean)
c      The INfchl. background concentrations represent the 95% upper confidence limit (Rood el al. 1995).
J   I he analylc was identified in the sample but the numerical result may not be accurate.
H •--The analyte leportcd value is < RDI., but > IDL,
NA - Not applicable or not available.	

-------
       In August 1993. the dump tank was removed, cut into sections, packaged, and delivered to WERF
 for disposal. Four soil samples were taken at the bottom of the dump tank excavation (3 m [10 ft] bgs)
 and at (3.7 m [12 ft] bgs), to determine possible soil contamination in the underlying soil. Samples were
 analyzed for kerosene. VOCs, semiVOCs, RCRA metals, and radionuclides.  Kerosene, VOC, and
 semiVOC constituents were not detected. Analysis for radionuclide contamination showed a Cs-137
 concentration highest at 3.7 m (12 ft) bgs with 65±1 pCi/g, an Sb-125 concentration of 5.3±0.2 pCi/g at 3
 m (10 ft), and the highest Eu-155 concentration of 0.67±0.10 pCi/g at 3.7 m (12 ft).

 5.3.3.20   CPP-44.  A grease pit south of CPP-608 has an ecological HI greater than 1.0 from exposure
 to cadmium, chromium III, chromium VI, lead, mercury, nickel, and decanal. Cadmium and nickel are
 native metals that are eliminated as COPCs when compared to 10X background (Rood et al. 1995).
 Table 5-22 provides summary sampling results statistics for soils collected at CPP-44.

 5.3.3.21   CPP-55. An area contaminated with paint solvents, has an ecological HI  greater than 1.0
 from exposure to metals (arsenic, chromium III, chromium VI, lead, mercury, nickel, selenium, and
 silver). Arsenic, chromium III, lead, and nickel are native metals that are eliminated as COPCs when
 compared to 10X background (Rood et al. 1995). Chromium is not expected to persist in the environment
 in the chromium VI form (Bartlett and Kimble 1976, Rai  et al.  1989). Mercury remains a concern after
 this initial screening with a maximum concentration of 5.2 mg/kg. The next highest was 0.62.  It is highly
 probable that the one sample having the high hit was a small hotspot that would not contribute that greatly
 to average exposure. Table 5-23 provides summary sampling results statistics for soils collected at CPP-


 5.3.4   Perched Water (Group 4)

       Perched water consists of water in the vadose zone  that is saturating sediments or basalts above the
 regional aquifer (Figure 5-2 and 5-3).  The perched water  is discussed in Sections 5.1 and 5.2.
 Contaminants already in the perched water are a potential source of SRPA contamination.  Contaminants
 of concern (Sr-90) were selected based on transport of the contaminant to the SRPA, and future ingestion
 of SRPA ground water post 2095. Other contaminants are summarized in the following paragraphs. The
 Perched Water (Group 4) is identified as containing low-level threat wastes. As noted in Section 5.2,
 Table 5-1, the perched water is a result of recharge from man-made sources at INTEC.  When INTEC
 operations cease  the recharge sources will stop and the perched water bodies will not yield sufficient
 water to be usable to future users.

      As part of the WAG 3 RI, a complete round of groundwater samples were collected during May
and June 1995 from all perched water wells having sufficient water for sample collection. These data are
summarized in Table 5-24. The results of previous groundwater sampling efforts have been described in
the WAG 3 Comprehensive RI/FS Work Plan (LITCO 1995c).  Figure 5-6 shows well locations where
perched water has been observed at INTEC and Figure 5-7 shows measured Sr-90 activities in the
perched water.

      The only chemical constituent in the upper perched  groundwater zone beneath the northern portion
of INTEC detected above either a Federal primary or secondary MCL was nitrate. The MCL  for nitrate is
 10 mg/'L. The highest nitrate/nitrite concentrations (35.4 mg/'L in well CPP 55-06 and 26.8 mg/L in
well MW-10) were measured in the southeastern portion of the northern perched groundwater.
                                             5-61

-------
Table 5-22.  Sunninux Man.stic.s l>n _soij cn»iaminanu> al Site C TI'-44.J
	 * . •-"•-• »-»P —  Minimum Maximum Mean Devi;iti,i|, R(vn:h
As
Me


("i
Cu
1 It!
Ni
l'l>
Sh
Se
III
/n
I.I.I hi
cllianc
Imlmxy
Decanal
Oil ami (
.1 Mill
•
•
•
•
b NIC
i Ilk-
2.11-NOOJ 7JI-.OOJ 4.061-100 2.321*00 9.30HtOO
8.XOH-OI lOOhMJO 1.171*00 3.50I--OI 1.87E-KX)

I.OIMOOJ 8.40I*0()J 4.951-100 2.581*00 l.OIRiOl
2.931*01 J I.54I-.-03J 5.171*02 5.991-102 1.721*03
1 . 091-1 01 J 4.781-.. ()|J 2.7IK-I01 1.171*01 5.05l*-01
2.00I--OI 5.00I-.IOO 2.431-100 I.74I-..00 5.911-100
3.51-M)] J 3,441-102.1 1.541*02 1. 101*02 3.741*02
S.91*0()J 2..SII-.02J 8.09I-H01 1.121*02 3. Ill-* 02
OOI--OIIJJ I.9I-.IOOH.I 1.091*00 7.(M)l-.-()| 2.491*00
1.5I--OI UJ 2.20I:KIOJ 1.181*00 1.451*00 4.081*00
1.II--01UJ 4.701-01 ItJ 3.401i-()l 2.00I-.-01 7.4()h-()l
4.031-MJIJ 1.221-;. 02.1 0.791*01 2.901*01 1.261*02
i liliui)
5.00I--03J 5.ooi-;-o3 .1 5.ooi-;-o3 NA • NA
4-melhyl 7.801*00 J 9.501-JOOJ 8.051*00 1.201*00 1.111*01
9.00I-.-03 J 9.001M)3J 9.001-;-03 NA NA
iiea.se 2.581* 03J 3.831*1)3 J 3.2 Hi 1 03 8.84Iit02 .4.981*03
Duplicate sample results were nut included in the slalislieal analysis.
Analytical lemlts are Ironi soil samples collected from the surface soil overlying the pad grease pit
1 inal Scoping Summary Repon OU .1-10, Reference 10, Analytical Data Report, CPI'-44 Grease 1


Numhei
of
.Samples
5
0

0
0
0
0
6
6
6
6
6
6
0
6
0
6

Si"1'5


Numbei
of
Delecls
5
4

6
0
6
6
6
()
3
2
•^
6
1
2
1
2

iunip beneath
lilmv dOX Nin
Selected .samples were analysed lor rnetals, V(X 's. SVOCs, 1'1'Bs, ami TPM Only those consiuueiib that weie ,dem,.kd abmc
Sjinples teiecleil because ol an unacceptable qualily control paramelei are noi included in ihe table
KMI c.mccniialiou is (he 'JV,. upper value bused on Hie t-tnpuieal rule |VS'!u,,filie ineasincmenis he with
IM 1 1 b.it ki'ioiind iuiii.eiili:i|iiiiis icpicscul ihe 'JS11,. unpei conllilcnce limn iko.i.l ,•! .,1 ImKi
in tuo stamhid
tlev laiions ot
— 	 ,.

hcquency
ol"
I ^ctcciioti
100",,
(>7 , n

loo1];,
100%
100%
100%
100%
100%
50%
33%
50%
100%
17%
33%
no/
/(I
33%

^rr^nrcnc,
detection hums arc
Ilien nicjn)
	 _

I XI -1:1
Background '
5.80l:t()()

1 .801: 1 00
2. 201: (00
3.301*01
2.201*01
5.00I--02
3.501*01
1.701*01
4.801*00
2.20I--OI
4 3()i;.()|
1.501: K)2
NA
NA
N«
A
NA

, KcsulK.ep,,,,,,
( O 1 ')')•! )
sluiun in Ihe table

	 _. 	

Nuinliei til
Sample.sd'iea
L_.lhaiiHackuioti
"•



S

s

^
i
1
i
1
0
NA
v \
i\A
NA
NA

d ill (he Hack 2 Diali


         v u	kmilk-.l in ihi-.sjinple Inn llieniinieiical ii-Mill nuv nul Iv aeriuale
                          Kill.bul  -11)1

-------
Table 5-23. Summary statistics for soil contaminants
at Site CPP-55.'
Soil Concentration,
(ing/kg [nonradionuclidej orpCVg [radionuclide])

( 'onluininuiils
AB
As
Da
Cd
Cr
Hg
Ni
1'b
i/i
6s Sr-')0


Minimum
1. 90li tOO
3.80EKH)
7.00E-rOI
9.40E-01
1.33E+OI
5.00E-02
1.38E-t01
4.10E+00
4.30Et03


Maximum
6.10Et-00
1.34Et01
6.09E+02
1.40E+00
6.47E+01
5.20E+00
1.21E+02
3.20E+01
4.80E+03

Mean
3.00E100
6.34E+00
1.59E+02
1.16E+00
2.54E+01
4.30E-OI
2.70E+01
9.59E+00
4.55E+03

Standard
Deviation
1.31 1- +00
1.78E+00
I..01E+02
1.90E-01
9.09E+00
1.03E+00
2.04E+01
5.13E+00
3.54E+02

RMHb
5.62E+00
9.90E+00
3.60E+02
1.54E+00
4.35E+01
2.49E+00
6.77E+01
1.99E+01
5.26E-f03
Number
of
Samples
49
- 49
49
49
49
49
49
49
5
Number
of
Detects
16
49
49
4
48
24
49
49
2
Frequency
of
Detection
33%
100%
100%
8%
98%
49%
100%
100%
40%
INEEL
Background '
(mg/kg or p(Vg)
O.OOI-tOO
5.80E+00
3.QOE+02
2.20E+00
3.30E+01
5.00E-02
3.50E+01
I.70E-KH
4.90E-01
Number of
Samples (iiealer
16
30
4
0
6
22
7
2
2
Duplicate sample results were not included in the statistical analysis.

Analytical results are from samples collected from 1 1 boreholes drilled during the
taken from the Closure Report for tTP-SS.' Mercury ConUmm J \£l "wE
Mercury Contaminated Area South of CH> T-15 (WINCO 1993).
      SS ,nv^i,»»i, «, h  <* 1 1  »
** n^ided  n?h  W^Vo V  t     *"
    provided in the W1NC O Track
                                                                                                                                                          '° devel°P 'h'S table
                                                                                                                                      Document Package OU 3-02, Site CPP-55,
                Selected samples were analyzed lor VOC's, metals and radionuclides as well as the full 40 CFR 264 Anrv»nrt,, « ,n t r    , t-
                ^™*^™-*^^^
                Samples rejected because of an unacceptable quality control parameter were not included in the table.

I'      The KMI: concentrate ,s the 95% upper value based on the empirical rule (95%of the measurements lie wiihm .wo standard dev.ations of their mean)
c      I he INI-.I-I  background concentrations represent the l)5% upper confidence limit (Rood ct al. 1995)
H - The iinalyte icported value is «• RDI , hut •• 11)1.
NA •  Nol applicable

-------
Table 5-24.  .Siimnuu   ^i
results Muiistics loi contaminants
\Vaici ciiiiccntMlhiii. niu I  oip(VI.
'JJ'J.lln.1 JL>«.Tch»:il \\;iler wcl|sj[May-Jiine IW5) *
( uiii.mim.mis
A,!
As
H.I
Itc
( "Itlomle
( 0
Ci
t'n
1 lumule
Mn
Ni
NO, NO,- N
I'll
Sh
Si-
Sul laic
11)
\'
/n
Ani-241
I'u 23S
I'll 239 240
M ''D
Mininniii)
7.701-04 BNJ
3.401-03 It
7 141-02 B
1.201-04
2 lil-.'Ol
.1 701-04
4 301-03 It
1.301-03 It
1 .001-01
N .101-04 It
2,501-03 It
3 5|)| MX)
2.001-03 111
2.001-03 H
3.001-03 It
2.021'JOI
3.3()1:-03 It
I.501--03 ItJ
2.60I--03 It
3.00]-:-02
0 001- iOO
II 001 MIO
Dill III
Maximum
1.40H-03B
4.90I-.-03 B
3.941-01
I.20I--04
1 .251: 1 02
1.3()l-:-03
l.llli-02
I.49I--02H
3.6oi-o r
1. 801-0 1
7.50I--03 It
6.%l-..01
2.001-03 ItJ
6.40I-.-03 B
4.0()l-:-()3 B
6.181-iOi
5.00H-03 B
6.701--03 B
6.93K-02 HJ
1.601 l-OI
o.ooi-: .00
O.OOI- • 1)0
3 201- -us
Aiithnietic
Mean
1 091-03
4 1 71-, 1 00
I95K-OI
1.2()!-:-04
5.491- 1 01
7.801--04
6.05l-:-03
3.75I-.-03
2.51 li-OI
2.111-02
4.63I--03
1.991:101
2.001--03
3.60H-03
3.331--03
4.03H101
4. 15 1- -03
3.56H-03
2.15L-02
9.5011-02
0.001-. 1 00
o.ooi-: too
4 061- '04
Slynd.iiil
Dcvialiiin
4.45I--04
7.5I1-.-OI
9.141--02
NA
2.781: -01
2.521-04
2.52l-:-03
4.531-03
4.681 -.-02
5.l5l-:-02
2.58I--03
1.691:i(ll
' NA
I.67I--O.V
5.77I-.-04
•1.271- K)l
1.20K-03
1.8II--03
2.06F-02
9.19H-02
0.001: ' 00
O.OOI: 1 00
S.(i()i-;.04
RMHh
1.981--03
5 671: MM)
3.78H-01
NA
l.lll-H)2
1.28I--03
1.IIH-02
1.28I--02
3.45I-.-01
1.241- -01
9.791--03
5.37IiU)l
NA
6.94li-()3
.'4.48I--03
6.571-1 01
6.551--03
7.18H-03
6.27I--02
2.791i-0|
O.OOI-: 1 00
O.OOI: '00
2. 131: 'Oi
Numhi-i of
Suniplc.s
"io
H.
16
10
16
10
16
16
16
10
10
10
10
10
10
10
10
16
16
16
10
10
10
Numhci ol
Delects
2
3
16
1
16
S
6
X
16
13
3
16
1
5
3
16
2
II
10
2
2
2
14
Detection
1 V',,
19",,
100",,
6",.
100",,
50",,
IS",.
50",,
100",,
S 1 ".,
19",,
100",,
0",,
31",,
19",,
100",,
13",,
69%
63V n
13",,
13",,
13",,
NX11,,

-------
  Table 5-24.  (continued).
Water concentration, mg/L or pCi/L
Contaminunls
k <><>
1 nliiim
II-..M4
1 1-2.<8
(iross Alpha
(iross Heta
a NOTI-;
Minimum
400E-01
6.21 Hi 02
l.WKtOOJ
8.00E-01 J
2.30E+00
5.20E*00

Maximum
7.36l-t02J
7JOIM04
I.ISIifOl
2.70E+OOJ
I.I4E*03
5.89E+05
Arithmetic
Mean
8.96Et()l
2.00F.<<)4
4.70E(00
1.94E+00
1.88E+02
7.00E+04
Standard
Deviation
1.91E+02
2.35E<04
3.24EIOO
6.08E-01
3.68E+02
I.51E+05
RMEb
4.72E+02
6.7()Ki{)4
I.I2EI01
3.16E+00
9.24E-f02
3.72E+05
Number of
Samples
16
l(>
16
16
16
16
Number of
Detects
14
14
7
7
9
16
Frequency of
88%
88%
44%
44%
56%
100%
                Duplicate and QC sample results were not included in the statistical analysis
                                  ^
                                                                                                      ~«« -, -re .ent.Hed above detect.on „.„ ,„ ,he samp,e5 are
                Carbonate. TKN and Ammonia-N                                      °' conslderc<1 lo ^ Pre«nt at hazardous concemrat.ons. Ci. He, Mg. K. Na, Alkalinity. B.c Alkalme

                Samples rejected because of an unacccpuble quality control parameter were not included in the table

h       I he RMh concentration ,s the 95% upper value based on the ernpmca, rule <95%of the measurement he w.thm two standard dev.ations of the.r mean)
II   ( onla'niinanl in associated blank
!•  - I'he reported value is an estimate because of interference
J  l-slimatedconcenlration
N   Spiked sample recovery was not within control limits
NA  Nol applicable

-------
  V
  A,>
 /
\r
i:  ii »!;:-i J:  ^^?£O^o^^-v~^^
H-jrl—-^  * rf.^--teS^r^i;:.0.^^,;^^ sr^f^
.....><
                                                                                 ,  !  I I  !
                                                                         j Jill t   IIP1

                                                                        llllliil! llllHfi
                                                                                  «  -  $.  -
                                                                   $b~..;
             AV*""" ••—"••-. ™.. <«™--* ^ *>"W(^*"»f *.^ ----- •*•*..      ^t j, __,  -«». ••  «.               •    *'*'•  i-f-f- it\ *.*» .   ^1 •





               %.  ''•-  \            "I  il    "vl  i /          :    ' ''•-, a-      """'• ii"
                \V 	           _ .V):     -v : •'           '       -. ?  \        :s
                                            1     i    J  ': *  '  'i
                                             J     *    i    s     S

-------
                                        CPP-033-04E
                                   - .--'.l.qt-pCtXL-—
              MW.'
              0.7
	 0.7 pCi/L
 -  i                     i  MW-020
~  :       '                25800  pCi/L
~  j	
 CPP-033-02~  .  MW-010
 102  pCi/L    ,j. 17200  pCi/L

                          20000 pCi/L
                                                                    CPP-0_37-04  |:
                                                                  '5
                                                              Mll-
                                                                          004
       I  -1
                                                                        I
                                         'l04000^0t/L   :.  &CPP-055-06 I
                                            "^—"'        \  66300  '
                                         .,-1
              	j	j
                                                       I I
               MW-017
              ' 1.6 pCi/L
               MW-015
               22100' pCrrtr--
                                                •. 0 - 200 pCi/L

                                                «  10.000  - 30,000 pCi/L

                                                O  30.000  - 300.000  pCi/L

                                               © >  300.300  pCi/L
                                                                           March S.
Figure 5-7. Sr-W concentration in the upper perched groundwater (May-June 1995).
                                            5-67

-------

         ea«
 55-06 fFimirP s M TV,    P°njon 01 INTEC, particularly associated with wells MW-2 MW-5 and TPP

                                         °s                                 '
                                          o
            42 m ( 140 ft) the maxrm™ «     ,'   P?  re$Pecllvel>'' ln we" MW-2. At a depth of
                       ^^^^^^^
l=ve,s

                                     ^
detected in all we! s                              ^^^ C°nSM °f H'3' Stronti^-90 was

                s^^P^^^^s^^
   MW-5.       concentration detected in the upper perched groundwater zone was 1 05±2 pCi/L in


                                   5-68

-------
   exceeded e  17  P H      '"   C UPPCT PerChed water zone   Manganese concentrations exceeded the Federal
  5.3.4.3    Deep Perched Groundwater. Contamination in the lower portion of the vadose zone is
  different in composition from the upper perched zone. The lower vadose z^e ^hed water





                               ^^^^^
     rounds o groundwater samples have been collected from MW-U one round o
           Ct°!IeCted. T MW'17 and MW-1*. a"d a substantial database concern ng
                        WL-22i^

        wa  r     e      f ^f ^ ^ ^ ^ *** *" *" H 3 Concentrations inwov  "
        water bodies, the source of this contamination is either from a historical release where the
 contaminants have moved through the system or waste water disposal to the ICP^ec Jn wel.
 INTECome JuneQ       r    ***** **"*** ""*" ^ "^ the CaStem b°undarv of 
-------
      From the May 1995 water sampling of USGS-50, the concentrations of all chemical contaminants
except nitrate/nitrite were below Federal primary or secondary MCLs.  Nitrate/nitrite concentration was
measured at 31.3 mg/L. compared to the Federal primary MCL of 10 mg/L. Radionuclides in the
groundwater that were detected include H-3 (61,900±700 pCi/L), Sr-90 (151±2 pCi/L), and Tc-99
(63±1J pCi/L).  The concentrations for H-3 and Sr-90 are within the expected values based on the
historical sampling conducted by the USGS.

      Well M W-17 is  the only deep perched water monitoring well located in the southern portion of the
INTEC. This well has been constructed to monitor three perched water bodies:  an upper zone from 55.4
to 58.4 m (181.7 to 191.7 ft) bis, a middle zone from 80.4 to 83.5 m (263.8 to 273.8 ft) bis, and a lower
zone from 110 to 116 m (360 to 381 ft) bis. During the May 1995 sampling event, water was only present
m the upper and lower zones. None of the chemical constituents detected in the groundwater exceeded
either a Federal primary or secondary MCL.  Only two radionuclides (H-3 and Tc-99) were detected in
groundwater samples collected from MW-17. The concentrations of these two radionuclides were similar
between the upper and lower perched water zones. H-3 concentrations varied from 25,1001400 to
25,700±400 pCi/L and Tc-99 concentrations varied from 5.9±0.6 to 6.4±0.6 pCi/L.

5.3.5    Snake River Plain Aquifer (Group 5)

      The water quality in the SRPA  at and downgradient from the ICPP has been adversely impacted
due to past  facility operations.  The SRPA (Group 5) is identified as containing  low-level threat wastes.
The majority of INTEC-related SRPA contamination is due to the disposal of wastes through the ICPP
injection well.  Contamination in the aquifer is also due to downward migration of contaminants from
surface soils and perched groundwater zones. The injection well was the primary source for waste
disposal from 1952 through February  1984 and used intermittently for emergency situations until 1986.
The average discharge to the well during this period was approximately 1.4 B L/yr (363 M gal/yr) or
about 3.8 M L'day (1 M gal/day) (DOE-ID I997b). It has been estimated a total of 22,000 Ci of
radioactive  contaminants have been released in 4.2 x 1019 L (1.1 x 1010 gal) of water (WINCO 1994c).
Table 5-25 is a summary of the total curies discharged to the injection well for each radionuclide and
includes the curies remaining after radioactive decay (DOE-ID 1997b). The vast majority of this
radioactivity is attributed to H-3 (approximately 96%) with minor components of Am-241, Tc-99. Sr-90.
Cs-137, Co-60.1-129. and Pu.  The remedy selection for the SRPA was based on groundwater transport
modeling used to predict the activities/concentrations of contaminants in groundwater at the time of
exposure (post 2095).  This section presents data on the current water quality in the SRPA.

      Since the 1950's, the USGS has installed 33 monitoring wells around the ICPP to characterize the
occurrence, movement, and quality of the water in the SRPA.  The location of the wells completed in the
SRPA and the frequency of groundwater sample collection by the USGS are provided in Figure 4-12 of
the OU 3-13 RI  (DOE-ID 1997b). The ICPP has a groundwater sampling program of selected SRPA
wells to satisfy the groundwater monitoring requirements for the RCRA and DOE Order 5400.1.  This
sampling program, implemented in October 1991, uses selected USGS wells and collects samples on a
quarterly basis to be analyzed for the RCRA groundwater contamination parameters, RCRA drinking
water parameters. RCRA groundwater quality parameters, and selected radionuclides. The results from
this sampling program  are provided in the WAG 3 RI/FS Work Plan (LITCO 1995c).

      In Ma\ and June 1995. a complete round of groundwater samples were collected from the aquifer
wells located near and  downgradient from the ICPP (Figure 5-8). The results from this sampling effort
are provided in Table 5-26. The aquifer data summarized in the RI are discussed in the following
paragraphs. An isopleth map of 1995 1-129 concentrations is shown in Figure 1-7 to identify the extent of
Group 5. A vnap of the 1995 Tritium  plume is shown in Figure 5-4 and the Sr-90 plume is shown in
Figure 5-5.
                                             5-70

-------
Raduaucfidc
A|.ilOm
Arn-241
8*- 140
C-I4
Ce-141
Ce- 141/144
Co- 144
Co-37
Co-60
Cr-JI
C»-134
C»-I37
CM38
Eo-132
£»154
Eu-133
H-3
Hi-203
[-129
1-130
K-40
La- 140
Mn-34
Nb-93
Np-237
Pr-144
Po-238
Po-239
P9-239/Z40
P»-2JO
Rt»-I0«
Ra-103
R u-106
Sb-124.
Sb-125
Sr-SJ
St-S9
Sr-89/90
Sr-90
U-234
U-235
U-236
U-231
Y-90
Za-65
Zr-95
Z^Nb-95
Uiudomfiri Alpha
UtudmnTied Beta-Gamma
Qtixa—

Ha* Lift
4.SOE-01
4J2E*02
3.49E-02
5.73E*03
190E-02
7JOE-01
T.SOE-01
7.40E-01
3.27E«00
7J9E-02
IME^OO
3.02E-rOI
i.lOE-05
1J«E«OI
LSOEtOO
l.23E'*OI
1.3E-OI
1J7EWJ7
2.21E-02
1.2aE>09
4.60E-03
8.30E-01
9J5E-02
i!4E*06
3.3E-05
I.73E*01
2.44E+04
2.44£*04
6J7EWJ3
9.4IE-07
l.lOE-Ot
I.OOE»00
I.45E-OI
2.77E«00
1.7SE-01
l.JOE^JI
156E-OI
2.JiE*OI
143E'rOi
T.O*E*03
2J4E*O7
4.«7E«09
7J2E-03
6^SE4I
1.T8E-01
I.TSE-Ol
_
-

Total
Total AcriruT
Injccud
(cn
8-34E-05
1.1TE-Q4
5.03E-04
1.27E-01
USE-04
l.UE-OI
l.73E*Ol
SJ4E-03
I.49E-OI
5J7E-03
IJOEfOO
1Q5E«01
ZJOE-Ol
8.12E-02
• USE42
122E-02
113E-H04
7J3E-03
2.7SE-01
198Ei-01
24IE-12
6J2E-04
6.55E-01
4.63E-OI
5.AIE-03
4.47E-01
IJ2E-OI
I.05E-02
3.74Emi
I.14E-03
4.IIE*00
1.4JE-OI
1.70E*OI
Z41E-04
1.86E*OO
9.I4E-05
5J9E->00
1JI£*00
I.60E-M31
22SE-02
I.94E-03
4.Q9E-04
6.I1E-03
I-32E«OO
4^JE-04
2J4E-01
XOSE«01
5J6E-OI
3.nE-^)l •
6.33E^32
2J2E->44
Total Aomry
araauuoc*
	 (CD 	
1.34E-12
3.08E-04
8.S6E-1J6 .
1.27E-01
3.19E-61
142E-14
2.07E-06
8.91E-09
J.77E-03
2.91E-67
2.03E-03
1.19E*01
O.OOE*00
4J«E-02
193E-02
3.43E-03
3J9E*03
3.10E-42
2.7IE-OI
-UJE-152
2.31E-12
O.OOE*00
7.02E-OI
•1.17E-33
3.4SE-03
O.OOE*OD
I.15E-OI
I.04E-02
3.74&02
I.14E-03
O.OOE-MX5
4.39E-J7
S.S5E-04
5.02E-36
1.22E-02
1.7IE-23
-tJiE-27
6 JOE-01
8.75E-MX
123E-02
I.94E-03
4.09E-04
6.J1E-03
O.OOEWX
U9E-II
U3E-23
IJ8E-43

-
-
3JCEWH
Fcrtfaioftkt
Injocud Aomty
0.0
97.2
0.0
99J
0.0
0.0
0.0
0.0
5.9
0.0
0.1
S7J
0.0
33.7
33i
IS ^
0.0
100.0
0.0
100.0
0.0
0.0
0.0
100.0
0.0
17.1
99.9
99.9
99.1
0.0
0.0
0.0
0.0
0.7
0.0
0.0

34.S
100.0
100.0
100.0
100.0
0.0
0.0
0.0
0.0

-
-

feraatoftb*
0.00
0.00
0.00
0.00

0.00
0.00
0.00
0.00
0.00
n ffi
U.UU
QJO
0.00
0.00
0.00
0.00
OQ ' *
W.1**
0.00
0.01
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0,00
0,00
0.00
0.00
0,00
0.00
0.00
0.00
0.00
0.00
0.02
0.22
0.00
0.00
0.00
0.00
0.00
0.00
0,00
0.00

_
-
100.0
• Dteayed to January 1.1995
" Einmateof odionuctideiotter t&aa H-3 from 1957to l962[»wimta|9SJ%of the aaimncta H-3. Ban*cloi|t)( 1966)1
                                                                  5-71

-------
             LM-10
                 UF3-04
                 IM-O8
LF2-1S
          Legend
                                         0     IflW)    ilWI)  3000 teei
Figure 5-8. SRPA sampling \\ells location map.
                                                 5-72

-------
 (it-
 dt-
 OL

 IT
                                                                        .,iot:-isn
                                                                         frO i HZ
                                                                         00+H8
                                                                          VN
                       (M)'.|0|  I
                       001:109  t
                                                                                              ooc-irs't
                                                                                            U tO-:-!
     III- 100'S
     IO--IOOY
    lO'-ns's;
    ",,(101
III \.'tl.1lllv>l.l
                             oi
                             01
it-
it-
it-
  CO-H9

   VN  •

 to-?!:
oo+nvi
 io-;u
  VN

 001-12
 t ()-;•! c
 ,io-:-u
                                                                                             lO-i-ltO'c
                                                                                           H cO'-ISO'l
                                                                                          I'NJI  H1--IOS
  H ;0--lO(ri
 r.\\u 5"o--Ku:'i
  SI i'0--l()i"t-
  H HC'IO^S
  !| MI--IOO I
 I'H !()- I09'|


 H HI--IOS t-
 M tO-'-lOO'C
 H t'o-'iort
I'N'H H)-':IOV"9
•Mil
 "X
u IV

-------
 Table 5-26.  t
                                                   W.iu-1  iMikvnii.iiinii  iiiL1 I  in p(  11
                                                                                                                                                                                        1 lt't|llflU \  III
                                                                                                                        NumbiM ol  Samples      Nuinhci  nl l)i-UM%            IH-ialinn
                                                                                                                                   4'J                           21)                         -11"..
                                                                                                                                   4')                           4«>                         I III)",.
        Mill
         •         I iii|ilK,ik .mil 1.11  sample ICMllls vveie nul iiulntlcil in tile, slalisliciil anal v sis
         •         \nalviii.il lesnlls aie liom (!rniniihvalei samples enllci'leil  linm (he SKI'A ilnnn;.' Mas and June I')'H as pull nl llie ()l I  '  I I Kl  Kesnlts ,ue pmv nkil m  lalik I -I ul tin-1 H -1  I ' Kl I s
                   I'.nl  \il)ii|  ID lw7h)aiulllic I UK Dalahase
         •         s.nnpli-s \veie .in.ilv/cil Ini  I Al  iniiii'.inics anil lailinnncliiles  Onlv tlinse ennsliliielils that were ulenlilieil ahnvc ilcleelinn linuls in (lie s.nnplos .IK sh,,un in  the l.ililc e\ii|il Im tin
                   lulliiuin;1 onnsliliKnts vvlnel) vveic ileleelcil lint aic nut cniisulcicil In he pioscnl al ha/aiilnus enncentialiiiiis ( a.  I e. M;'  K, ami Na
( utii. mini. nits
t H«IS. Alpli.i
dinss Mcl.i
Mininiuni
2 .U)l: 1 1)()
2.4(H-JO()
M.tMiiuiin
1 ()()!• idl
4.(i'H-.i02
TKci'__
1 SI-iOl"
4inU/yrh
         •        N.nii|iliv n.|i\loil ln\.iiiM-iil an nli.iiVi-|il.llik' i|li;illl> i-i)iiliiil puiuinclt-i wi'ii- unl UK Imlfil 111 tlw lahlo
I,     |  |,r |'|- li i nil llu- I'niiKiiy ( nn-.liliK-nl Mjuil.ilils luhlc ill ID.-M'A I (ill I  II _'mi(u) mili^s MlhauiM- liniliinU.1
.      III. I'Hi i tiuiifhli.il inns It M  m.iir'.iik-M-  sihi-i, jiul /me .iic liuni Ilk' SiYoiul.ii) (  inisliluail M.imlanK  in IDAI'A  I Ml I  11  Jim ih)
,1     |  in- I'Ki i >iiiitviili.ilinii> l"i  Ain-.MI. l-IJ'J.aml lo Wan- oaknlalal \;iliiushj!>c.'ll 'I  'ti nns
>•     S,ii i nh.il \ s.iinpliif.' il.ila IKI  I-IJ'< \\ai lakon litiiililjU iulluck-(l illlllllj; ihc I'Nil ''I I I.Sd.S sampling cvcnl (USdS I')')-!)   UK- ,l;i|;i sluiuu in I In.- lulilo is uiiK limn llmsc Molls .s.niipkil Imlli ,l,n nr- |i.
      |'i'm.«i| I .si i>, s.nii|iliii!' IM-III an.l llu- \\ Ad ' Kl I-S. Ma\  Juno I')'>.•>, nuniplini!  cvcnl
I      I  lu- I'Kt 11 UIIK nil.limns l« H  '• .''•' .mil I1-?'X.IK- limn Sivlinn S. lahlc S-^orilns KOI)
      I  IK- I'Ki i iunK-iili.iliini l"i ;'iu-.s .ilph.i iiu'luilcs i.uliuiil .Vli hnl cvchuk's latliin mill niaininn
11     I  In I'Ki i Kincciilialiiiii l"i I'lnsilWu u-iiinhinal liclii plinlnn cniitlciM is 4 nil<.\i 'cltcclivc ilusc cquivalcill
It    I i.hi.nn.n.ii.I in jsvioulcil III.ink
I     Ih. ii'puiii-il \.iliii- iscsiun.ik-il lu..uiso oi ilio pii-scncc nl micilcii'iioc
I   I -.11111.11, ,I i.iliii-llll.lllllll                                                             ;
N   S|>il..,l  s.llllplc IvVtlVi'lV \VJS lltll vvillllll Killlltll Illlll^                   '
\\    I'.ixl tlii-'isliiin spike liir (il-AAS .nuUsis is nut nl cnnlinl limits, while sample ahsnilunee. is less Ilian 5(l"mil spike iiliMiiluiice
N \   \ui .ipplualilc
I'Ki t   I'liliiiim.nv  JxVjiicilialtnn (iii.il

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  levek L, ^ o«T   ^i ^od'ng l° Bartholomay H997), Cs-137 has been detected above reporting
   eyds through 1985 m wells USGS-40 and USGS-47 at the ICPP due to liquid-waste discharge to L
  ICPP injection well.  Dunng 1982 to 1985, maximum concentrations ,n wells USGS-40 and USGS 47
                  2°°±5° pCi/L' re*«**ly- Dunng 1986 to 1988, Cs-137 was not detected in these
                                             37 was detected '" one sam'
  roo  rvi
   992f ?  n7°n      ^   '  ,90) 3nd °nC Sample fr°m Wel1 USGS'47 <70±3° PC^ on April 29
  for Cs-n? L 3oT7S vr°s.        " ^ °f *" ^^ ^ ^^ dUn°g the WAG 3
  tt'^DD A- P/t/f°n/"/"'  M<>n'toring the quantities of Pu-238 and Pu-239/-240 (undivided) discharged to
  was not sets  L  ^ "V^  ^ '° *" time' 3'Pha actJV1^ from Plut— dismtegraS
  was not separable from the monitored,  undifferentiated alpha activity.  During 1 974 through 1 985 about
  aiSCi of Pu-238 and 0.05 C, of Pu-239/-240 (undivided) were discharged tc ^theVcPP ± ion well
       According to Orr and Cecil (1991), plutonium has been detected in the SRPA near the ICPP in

            '4?^ U/p°S;47' B°th °f *** WdlS are located near the ICPP Action weH  n we.
 0 47+0 16 oG/L I'd 5 £T?n ^^ TO ^ ^^ '" ^^ I98? at Concentrations of
 a47±0 16 pd/L and 5.5±0.4 pd/L. respectively.  In well USGS-47, Pu-238 was last detected m October
 1983* a concentrate of 0.5±0.06 PCi^. Since the 1986 to 1988 period reported by Orr and Cecf


       Pu-238 was only detected in a single water sample collected from well USGS-48   The samole was
 coHected ,n October 1 990 and had a concentration near the MDL at 0.05±0.02 PCi/L. Be^e^i a7d
 1995, all plutonium measurements at the INEEL were below the reporting leveH
 Plutonium was not detected m any of the aqutfer wells sampled during thf WAG
                            Ame™"m'241 is a decay product of Pu-241 and has a half-life of

        and TAN  Smce,       ^ ^ ^^ *» ^ ^ detCCted » the SRPA «* *c
        and TAN.  Since 1988, however, Am-241 was detected in well USGS-44 during July 1992 at
 concentrations of 0.07±0.03 and 0.08±0.03 pCi/L, in well USGS-37 during October 1992 at a

                  9±0-03 Cl/L ^             -         June ^91  at concentrations of
         at a concentration of 0.54±0.14 pCi/L.

5.3.5.4    lodine-129. From 1953 to 1983, an estimated 0.01 to 0.136 Ci/yr (0.56 to 1 18 Ci) of 1-129
were contamed m the wastewater d.scharged to the disposal well (Mann et al. 1988). For 1984 to  986

                        "                                                              '
0
rh Ir^V°Und"fD^OUndwatersamPlesn^  1981' 1986- 1990, and 1991) have been collected bv
 1994) -In X   ^ ^ thC ICPP (Mann 3nd BeaSiCy 1994)- AcCOrdin^ to Mann »d Beasiey
(1994).  In 1990 and 1991 concentrations of 1-129 in water samples from wells that obtain water from the
Snake River P!am aqu.fer ranged from 6.00E-7±2.00E-7 to 3.82±0.19 pCi/L. The mean concentration ,n
water from 1;, wdis was 0.81±0.19 as compared to 1.3±0.26 in 1986." Mann et al. (1988) reported a
                                           5-75

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                                                                                                          1
similar decrease in 1-129 groundwater concentrations between the 1981 and 1986 sampling events. The
distribution of I-129 in the SRPA for 1990-91 is provided in Figure 1-7.

      During the WAG 3 RI, 1-129 was detected in wells USGS-67, LF2-12, and LF3-08 at
concentrations of 1±0.3 pCi/L, 1.2±0.3 pCi/L, and 0.9±0.3 pCi/L, respectively.  Two of these wells are
located several miles downgradient from the ICPP. The limited amount of 1-129 contamination m the
aquifer is consistent with the observations made by Mann et al. (1988) where decreasing 1-129
concentrations were attributed to decreasing 1-129 disposal and the change in disposal techniques. The
half-life of 1-129 is 1.57E+07 years.

5.3.5.5    Tritium. A H-3 plume has developed in the SRPA from disposal of liquid wastes at the
INEL. The principle sources of H-3 in the aquifer have been through injection of liquid wastes through
the disposal well at the ICPP and discharge of waste water to the infiltration ponds at the ICPP and the
TRA. It  is estimated approximately 30,900 Ci of H-3 have been discharged to the SRPA at the ICPP
since 1952 (Orr and Cecil 1991). Of this amount, approximately 22,200 Ci were discharged via the
disposal well at the ICPP. The remainder of the H-3 was discharged to the aquifer via the ICPP
percolation ponds.

      According to Orr and Cecil (Page 30, 1991), "Tritium concentrations in water from the Snake
River Plain aquifer decreased by as much as 39,000 pCi/L during 1986-1988. By October 1988, tritium
concentrations ranged from 700±200 pCi/L to 6l,600±l,100 pCi/L and the tritium plume extended
southwcstward in the general direction of ground-water flow. The size of the plume in which tritium
concentrations exceeded 500 pCi/L decreased from about 51 mi2  in October 1985 to about 45 mi2 in
October 1988.  The area of the plume containing tritium concentrations in excess of the MCL of
20,000 pCi/L (EPA 1989, p. 551) decreased from 4.4 to 2.8 mi2.' The reduced concentrations of H-3
were attributed to radioactive decay processes, overall reduction in H-3 disposal rates, dilution from
recharge, and changes in the disposal methods

      The distribution of H-3 in the SRPA for May 1995 is shown in Figure 5-4. The size of the plume
that exceeds the federal drinking water standard of 20,000 pCi/L  is approximately 3.3 km2 (1.3 mi'),
significantly smaller than the 7.3 km" (2.8 mi2) reported in October 1988.

5.3.5.6    Strontium-90. A plume of Sr-90  has formed downgradient from the ICPP primarily in
response to the ICPP disposal well. According to Orr and Cecil (page 32,  1991), "in October 1985, the
size of the strontium-90 plume where concentration exceeded 6 pCi/L was about 2 mi2 (Pittman et al.
1988, p. 53): the concentrations of strontium-90 in wells 57 and 47 were 74±5 and 63±5 pCi/L,
respectively. Strontium concentrations decreased as much as 33 pCi/L during 1986-1988.  By October
1988, strontium-90 concentrations ranged from  8±2 to 48±3  pCi/L. and the area of the strontium-90
plume had decreased to approximately 0.8 mi2.  The strontium-90 concentrations in wells 57 and 47, both
within the plume, decreased to 41±3 and 48±3 pCi/L. respectively."  They attributed the reduced areal
extent and concentration of Sr-90 to the diversion of liquid radioactive wastes from the disposal well to
the infiltration ponds in addition to radioactive decay, diffusion, dispersion, and dilution from natural
recharge.  Since 1989. concentrations of Sr-90 in water  samples from most wells have remained relatively
constant.

      The distribution of Sr-90 in the SRPA for May 1995 is provided in Figure 5-5. The areal extent of
the Sr-90 plume has decreased between October 1988 and May 1995. consistent with the previous trend.
The maximum Sr-90 concentration detected in the aquifer was 84 pCt/L in well MW-18.  Historical Sr-90
concentrations for the USGS and CPP aquifer wells were provided in the WAG 3 RI/FS Work Plan
(LITCO  19950.
                                             5-76

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  5.3.5.7    Technetium-99. Tc-99 was identified in 32 of the 44 wells sampled during the WAG 3 RI.
  The highest concentrations of Tc-99 were identified in the north central portion of the ICPP in wells
  MW-18, USGS-47, and USGS-52 having concentrations of 448±4 pCi/L, 235±3 pCi/L, and 174±2 pCi/L
  respectively. The Tc-99 plume extends to the southwest of the ICPP and includes wells USGS-123,
  USGS-57, and USGS-39.  The maximum Tc-99 concentration outside the ICPP security perimeter fence
  is 49 pCi/L in well USGS-123.

       Chemical constituents detected in SRPA at the INEEL have in the past included total chromium,
  sodium, chloride, and nitrate. During the WAG 3 RI, water samples were collected from all aquifer wells
  and analyzed for CLP metals plus zirconium.  From the 44 wells tested, only the water sample from well
  LF2-11 exceeded a federal primary or secondary MCL. The magnesium concentration in LF2-11 was
  measured at 62.8 ug/L, compared to a federal secondary MCL of 50 ug/L. This well is located
  approximately three miles downgradient from ICPP and since magnesium was not measured in other
  wells above the federal  secondary MCL, this contamination is not likely associated with the ICPP.

  5.3.6    Buried Gas  Cylinders (Group 6)

       Site CPP-94 includes an area about 2.4 km (1.5 mi) northeast of the INTEC along the south side of
 a dirt security road.  Four exposed gas cylinders have been observed at the site and are believed to contain
 hydrofluoric acid. Site CPP-84 is located outside the INTEC fence line, east of Lincoln Boulevard and
 south of the Big Lost River. An estimated 40 to  100 cylinders were disposed in a trench  at Site CPP-84
 The safety hazards associated with CPP-94 and CPP-84 are similar.  The potential for cylinder
 over-pressunzation and  bursting is considered to be the most serious hazard at both sites.  Hydrofluoric
 acid is very corrosive, reacts violently with moisture, and can generate explosive concentrations of
 hydrogen gas. Fluoride, a chemical residual of hydrofluoric acid reactions, is a potential  health and
 ecological hazard. No known release of the cylinder contents has occurred.  As no sampling activities
 have been conducted at these sites, no sample results or sampling statistics are available.  The buried gas
 cylinders (Group 6) are considered to contain low-level threat wastes.

 5.3.7    SFE-20 Hot Waste Tank System (Group 7)

      A preliminary  investigation conducted in 1984 indicated that the tank liquid and sludge contain
 elevated levels of Cs-137, Cs-134, Co-60, Sr-90, and isotopes of europium, plutonium, and uranium.
 Previous spills within the tank vault and  pump pit contained similar contaminants.  Site CPP-69  soil
 contamination is associated with CPP-VES-SFE-20.  Soils beneath the tank vault have not been sampled
 due to inaccessibility. There is no evidence that the vault has leaked. The soils were not included as a
 source in the vadose zone and groundwater models used  for risk assessment. The SFE-20 Hot Waste
 Tank System (Group  7) is identified as containing principal threat wastes.

      In February 1984,  liquid and sediment samples were taken from the tank interior, vault floor  and
 pump pit (Table 5-27). The  analysis consisted of only Co-60, Cs-137, Cs-134, Eu-152, Eu-154. Eu-155.
 Sb-125, total strontium, and  plutonium and uranium isotopes. The  reported concentrations of Cs-137.
 total strontium, and plutonium isotopes in the single tank liquid sample  were 2,050,000" 9 700 OOo'and
 17.600.000 pCi/L. respectively (WINCO 1984).  For the  same radionuclides, the concentrations m'the
 tank sediment sample were reported at 55,400,000,000; 4,700,000,000;  and 93,500,000 pCi/L,
 respectively.  Three samples were collected from the floor (two liquids and one sediment). Trie reported
concentrations in the two liquid floor samples for Cs-137 (analysis  for total strontium and  plutonium
 isotopes was not requested) taken from the south and center vault floor locations  were 905.000 and
248.000.000 pCi  I., respectively. The reported concentrations of Cs-137, total strontium, and piuton-um
 isotopes in the sediment sample collected on the north end of the vault were 8,920,000: 1.720,000: and
                                             5-77

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79.200 pCi/g. respectively. For the same radionuclides, the concentrations in the pump pit sediment
sample were 2.290.000; 5,890,000; and 3,010 pCi/'g, respectively.  Only Cs-137 at a concentration of
76,000 pCi/L was reported for the pump pit liquid sampling (WINCO 1984).

      There are no data available for nonradioactive constituents; however, the tank contents may contain
inorganic and organic constituents that were associated with the operation of the CPP-603 spent fuel
storage pool filtration system. It should be noted that generally, longer lived radionuclides (i.e.. those
having half-lives greater than 10 years) are of most concern and thus, those with shorter half lives were
not summarized in this section.
                                              5-78

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Table 5-27. Summary analytical results for the SFH-20 hot waste tank system.
  Identification Number and
         I oGilion
              Co-60
                         Cs-137      Cs-134      Eu-IS2      Eu-154
                                                                                                     Eu-155
                                                                                      Sb-I25
 Uadioisotopic content of tim-ars and samples of SFK-20 area (Sample concentration (pCi/smear jsear samples), pCi/g |solids| orp('i/nil. (liquids!)
  I    l'i|ii.-> (cMcnors) ;IIK!
      u.ilK (inlciiiu) in
           |>il   midway
      and pit floor
 2    I'ipes and walls in
      pump pa  I ID 2 ft
      from bottom
 11    Floor-north end of
      vault.
 12    Bottom 6 ni:-tank
      interior.
 13    Bottom of pump pit.
 14    I'ump pit-sump
  Sincai
                         7 681'M)2
* Walls, tloor, and
ceiling of access
tunnel.
4 Representative areas
of vault walls.
<-/. 5 SFL-20 tank
-^ (exterior).
7 A teas of apparent
seepage on walls
8 Floor-south end of
vault.
') Floor-center section.
10 SFH-20 tank interior.
Smear

Smear
Smear

Smear
Liquid
Liquid
Liquid
  Smear         --'      897E+03       -"         —*          —»

             5.54E+OI    I.39EKM    5.92E+OI    5.84E+02     5.70E+02     I.21E+02

                        2.19E+03

             I.5IE+00    5.84E-KM    9.84E+OI    1.20E+03     7.70E+02     204E+02

             9.5IE+OI    4.I6E+04      —'         —•          _•          _•

             5.83E+00    9.05E+02    I.35E+00       —*          —'          —•

             I.OSE+02    2.48E+05    I.55E+00       —"          —*          _'
             7.43E*-OI    2.05E+03    7.76E+00       —•          —*          .._•
Dry Solids    2.I5E+04    8.92E+06    I.06E+04    I.50E+05     I.3IE+05     4.73E+04

Wei Solids    3.27E+05    5.54E+07    I.62E+05    I.38E+05     I.2IE+05       —'
                                                                                                                                           Pu
                                                                                                 I.7IE405     I.02E+02
                                                                                     7.32E+OI     9.70E+03     l.76Et(M
                                                                                        -a       I.72E+06    7.92E+04
                                                                                                                                                   - 1.60E-04
                                                                                                                                                   ()6    9.35E+04    I 9IE-03
Wet Solids   238E+04    229E^06    I.33E+04    5.65E+04     4.62E+04     2.05EKM     4.73E+04    5.89H^06    3.0IEf03
  Liquid
                           76

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     Table 5-27. (continued).
            Sample Numbci                 ,,1"±]-H_           .         Jl'f!?	Ra-226        __  _       Th-232                       Alpha
           lws Tor SKK-20 surface soil samples (Sample concentration lp('i/g|)
                   I                        22WKMII                    I7KI-..OI                    122KUHI                    2031-..(HI                                             2..WJOI                    3171:1(11
                   5                        3431-101                    29IEiOI
      *    I lie mm i>riiKUMii<::> lor IJunium (U) was rcptmcd in g/I.
      j    iMiinpc lu-lou ilcteciion limn
      b    Aiulyii^ \>.as mil icqucilcd  IK-cibiun was bused on earlier Alpha Scan results
      c    Anal\M.s nut pL'rloniK'il Analy/ud only ianiplcs expected to show highest concentrations
oo
O

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6.
 CURRENT AND POTENTIAL SITE AND RESOURCE USES
            6.1   Current Land Uses
































,DOE)
  6.2   Reasonably Anticipated Future Land Use
                           ^^
                   6-1

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  Shoshone-Bannoek Tribes, the BLM. DOE. U.S. Forest Sen-ice. U.S. National Park Service, Idaho
  Department of Transportation. Idaho Fish and Game, and emht business, education, and citizen
  organizations. In addition, the EPA. and IDHW participated"in an ex-officio capacity.  Following review
  and comment by the public participation forum, the document underwent a 30-day public comment period
  and was subsequently submitted to the CAB for review and recommendations. No recommendations for
  residential use of any portions of the INEEL until at least year 2095 have been received to date.

       Areas of the INEEL are expected to be either industrial or non-industrial for the next 100 years  In
  the northern area of the INEEL. potential industrial use of the land for a spaceport is being considered
  The non-industrial areas are expected to involve grazing and similar activities. In addition  the INEEL is
  currently a National Environmental Research Park and is expected to remain so for the foreseeable  future
  This future use is expected to last until at least 2095.

       The reasonably anticipated future use for WAG 3 until 2095 is as a government-controlled
  industrial  facility.  The industrial area is expected to involve activities such as national laboratory research
 and development or handling, treatment, and disposal of radioactive materials.  The industrial operations
 assumptions  include a 10-ft basement scenario. Section 11 of this document discusses institutional
 controls to be implemented at OU 3-13 CERCLA sites. An Institutional Control Plan for specific sites
 will be developed during RD. Section 21. lof the FFA/CO provides EPA site access with or without prior
 notification.  The Institutional Control Plan will include provisions that any lease or privatization effort
 by DOE will  include EPA access.

                 6.3    Basis for Future  Land Use Assumptions

      The projection for future land use at INTEC is based upon:

      •     DOE projections for the future of its national laboratory research and development activities
            and nuclear reactor programs

      •    The presence of active industrial and research  facilities

      •    The presence of an industrial infrastructure

      •    No apparent non-industrial uses, other than grazing within the  INEEL

      •    Recommendations from the INEEL CAB and other stakeholders regarding future use
           assumptions.

                               6.4   Groundwater Uses

      Current SRPA groundwater use at INTEC is for drinkirm and irrigation.  Groundwater is extracted
Irom several production wells, which are located upgradient of WAG 3 groundwater contamination
There is no current water usage from regions of the aquifer that have been contaminated above MCLs
immediately downgradient of INTEC. Future groundwater  use from contaminated portions of the SRPA
outside ot the  current INTEC security fence will be restricted by institutional controls until 2095
Follow ing 2095. it is anticipated that groundwater in  the SRPA'will be available for all use/
Groundwater contamination from INTEC is not expected to migrate past INEEL boundaries. Water use
restrictions during the restoration time frame will apply onK inside the INEEL boundaries.
                                             6-2

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       There is no current or future planned groundwater use from the perched water zones  The nerched
 water zones are trans.ent and are not capable of producing sufficient w'ater for domes^othe,u'sef

                  6.5    Groundwater Classification and Basis


aquifj^bv*" SSS^'Sl' Thr^T ^ °^ **** ™ ^ S°'e *>urc"
unrW M  h    ' i           uctooer /. ivvi.  Three categories of aquifer protectiveness are applied
no orev    regulatlons:  (' > Sensitive Resources. (2) General Resources, and (3) Other Resources. Since
-r-lL i  oS a°    l° categonze the SRPA under state regulations has occurred, the aquifer defaults to the
cuaHt     HSTeS  Categ0ry' Genera! ReS°UrCe a"uifers are Protected to ^sure that groundwater
Oual tv R^rS! ^ruf"^', State W3ter quality standards are specified by the Idaho Groundwater
Vuai.ty KUIC. the Idaho Water Quality Standards, and Wastewater Treatment Requirements  Idaho's
groundwater standards mcorporate  10 CFR 20 Appendix B, Table 2 and 40 CFR 14lTnd  43
                                         6-3

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                                                                                                         1
                           7.    SUMMARY OF SITE RISKS

                       7.1    Human Health Risk Evaluation

       The purpose of a human health risk assessment (HHRA) is to evaluate potential adverse impacts to
 human health resulting from exposure to site-related radioactive and nonradioactive contamination  The
 HHRA approach and results are summarized in this section.  First, Section 7. 1 I summarizes the
 conservative screenmgs performed to identify sites or sources of contamination and COPCs by media
 Contaminated media evaluated in the HHRA at OU 3- 1 3 include soil, groundwater, and air  The release
 sites sources, COPCs, and COPC concentrations for each of these med.a were evaluated independently
 primarily due to the complexity of the groundwater evaluation and the number of soil sites  These
 uuDAm?J VCre Summarized and lhe results were '"en used as input in the performance of the baseline
 HHRA. This assessment is summarized in Section 7.1.2.  A somewhat different grouping of sites was
7.1.1    Derivation of Exposure-Point Concentrations

      Generally, the analytical results of the field investigations conducted since 1 99 1 were used to
est.mate exposure point concentrations for each site-related chemical. This was accomplished bv
implementing the measures below for each retained site:

           Extract (by site) contaminant of potential concern (COPC) concentration data from the
           Environmental Restoration Information System (ERIS) or from appropriate information


     •     Eliminate data that were rejected per the method validation

     •     Eliminate data that indicated probable blank contamination

     •     Segregate quality control data (e.g., blanks, duplicates)

     •     Average duplicate results

     •     Assume nondetects are one-half the reported sample quantitative limit

     •     Aggregate data by individual COPC


           Aggregate COPC data by select depths, i.e.. surface and surface - subsurface (see Table 7- 1

           Calculate the 95% upper confidence level (UCL) of the arithmetic mean for each COPC bv
           select depths (EPA 1 992a)                                                       '

     •      Assess appropriateness of the 95°,, UCL  versus maximum concentration (EPA  I992a)

     •      Select appropriate concentration estimate

     •     Calculate contaminant concentration and or contaminant mass.

-------
 Table 7-1. Results of the site and chemical screening processes.
                              OLVSite
                                                                           COPCs
  3-01 CPP-61
  PCB Spill in CPP-7I8 Transformer Yard-Radiological contamination

  3-02/CPP-23
  CPP Injection Well
 3-02/CPP-37A
 CPP Gravel Pits'I
 3-02/CPP-37B
 CPP Gravel Pit tf2
3-02.CPP-65
Sewage Treatment Plant
3-03CPP-67
CPP Percolation Ponds #\ and ^2—Sediments
  Cesium-137
  Strontium-90
  Technicium-99

  Osmiuma
  Cesium-137
  Europium-152
  Europium-154
  Strontium-90
  Arsenic
  Americium-24l
  Cesium-137
  Cobait-60
  Neptunium-237
  Plutonium-238
 Strontium-90
 Uranium-235
 Uranium-238

 Aroclor-1260
 Keponea
 Arsenic
 Americium-241
 Cesium-137
 Iodine-129
 N'eptunium-237
 Plutonium-238
 Strontium-90
 Uranium-235
 L'ranium-23S

 Will be evaluated
 only as a source of"
 recharge to perched
 zones and SRPA.

 Americium-241
 Cerium-144
Cobalt-60
Cesium-134
Cesium-137
 Iodine-129
Neptunium-237
 PIutonium-23S
Plutonium-239 -240
 Ruthenium-106
Antimony-125
Strontium-90

-------
  Table 7-1. (continued).
   3-05/CPP-14
   ImhoffTanks
  3-05/CPP-14
  Plant Site
 3-05/CPP-14
 Drain Field
 3-06/CPP-33
 Contaminated Soil in the Tank Farm Area NE of CPP-604
 3-06.CPP-34
 Soil Storage Area in the NE Corner of the ICPP
3-06 CPP-40
Lime Pit at the Base of the CPP-601 Berm and French Dram-
RadiologicalContamination

3-07.CPP-20
CPP-604 Radioactive Waste Unloading Area
   Tritium
   L'ranium-234
   Uranium-235
   Uranium-238

   Aroclor-1260
   Benzo(a)pyrene
   Phenanthrene3
   Cadmium
   Cesium-137
   Neptunium-237
   Strontium-90
   Uranium-235

   Aroclor-1260
   Americium-241
  Cesium-137
  Neptunium-237
  Antimony-125
  Strontium-90
  Uranium-234
  Uranium-235
  Uranium-238

  Phenanthrene3
  Arsenic
  Neptunium-237
  Strontium-90
  Arsenic
  Americium-241
 Cesium-137
 Neptunium-237
 Plutonium-238
 Plutonium-239/240
 Strontium-90
 Arsenic
 Cesium-137
 Neptunium-237
 Plutonium-238
 Strontium-90
 Uranium-234
 Uranium-238
 Cesium-137
Americium-241
Cesium-134
Cesium-137

-------
 Table 7-1.  (continued).
                              OU-Site
                                                                           COPCs
 3-07CPP-25
 Contaminated Soil in Tank Farm Area North of CPP-604
 3-07/CPP-26
 Contaminated Soil in Tank Farm Area Steam Flushing—Operation
 inside the Tank Farm perimeter
 3-07CPP-28
 Contaminated Soil in the Tank Farm Area South of WM-I81 by
 Valve Box A-6
3-07CPP-31
Contaminated Soil in Tank Farm Area South of Tank WM-1X3
  Cobalt-60
  Europium-154
  Neptunium-237
  Plutonium-238
  Strontium-90
  Technicium-99

  Americium-24l
  Cesium-134
  Cesium-137
  Cobalt-60
  Europium-154
  Neptunium-237
  Plutonium-238  •
 Strontium-90
 Technicium-99

 Americium-241
 Cesium-137
 Europium-154
 Plutonium-238
 Plutonium-239
 Strontium-90
 Uranium-234
 Uranium-235
 Cerium-144
 Cesium-134
 Cesium-137
 Cobalt-60
 Europium-154
 Neptunium-237
 Plutonium-239
 Plutonium-240
 Plutonium-241
 Plutonium-242
 Ruthenium-106
 Strontium-90
 Tritium
 Uranium-234
 L'ranium-235
 Uranium-236

 Cesium-134
 Cesium-137
 Cobalt-60
 Europium-154
 Plutonium-239'-240
 Ruthenium-106
Strontium-90
                                          "-4

-------
                                                                                                        1
   Table 7-1. (continued).
                                 Of. Site
                                                                             COPCs
    3-07CPP-32W,E
    Contaminated soil in the Tank Farm area of Valve Box B-4

    3-07/CPP-79
    Tank Farm Release Near Valve Box A-2
   3-07/CPP-83
   Perched Water
   3-08/CPP-13
   Pressurization of the Solid Storage Cyclone NE of CPP-13
   3-08.'CPP-l5
   Solvent Burner East of CPP-605—Radiological Contamination
' . 3-08.CPP-27
  Contaminated Soil in Tank Farm Area East of CPP-604 and CPP-33
  3-ns CPP-35
  Uranium-235

  Cesium-137
  Europium-154
  Strontium-90

  Americium-24l
  Cesium-137
  Plutonium-238
  Strontium-90
  Uranium-234
  Uranium-235
  Arsenic
  Chromium
  Americium-24l
  Strontium-90
  Technicium-99
  Tritium
  Uranium-234
  Uranium-238
 Arsenic
 Zirconium"
 Cobalt-60
 Cesium-134
 Cesium-137
 Europium-154
 Strontium-90
 Technicium-99

 Thallium3
 Zirconium1
 Americium-241
 Cesium-137
 Europium-154
 Neptunium-237
 Plutonium-238
 Plutonium-239/-240
 Tecnicium-99
 Uranium-235

 Americium-241
 Cesium-137
 Europium-154
 Neptunium-237

 Plutonium-238
 Plutonium-239 -240
Strontium-90
Uranium-235

Americium-241

-------
 Table 7-1. (continued).
                               OU Site
                                                                           COPCs
  CPP-633 Decontamination Spill
 3-08.CPP-36
 Transfer Line Leak from CPP-633 to Wl-102
 3-09.CPP-OI
 Horizontal Settling Basin, and Vertical Settling Pit and Soil Adjacent
 to SVV-048 Dry Well and CPP-303 Dry Well—Environmental Release.
3-09CPP-02
French Drain
     of CPP-603
3-09 CPP-03
Temporary Storage Area SE of CPP-603 Stockpiled Soil


3-09 CPP-Q4 and CPP-05 Contaminated Soil Around CPP-603
Settling Tank
3-09 CPP-06
Trench En^t ol'CPP-f>u3 Fuel Storage BIIMI
  Cesium-137
  Europium-154
  Plutonium-238
  Plutonium-239
  Strontium-90
  Uranium-235

  Americium-241
  Cesium-134
  Cesium-137
  Europium-154
  Plutonium-238
  Plutonium-239
  Potassium-40
 Strontium-90
 Uranium-234
 Uranium-235
 Uranium-238

 Americium-241
 Cobalt-57
 Cobalt-60
 Cesium-137
 Europium-152
 Europium-154
 Europium-155
 Plutonium-239
 Strontium-90
 Uranium-235

 Suspected Cesium-
 137
 Suspected
 Strontium-90
 Suspected Tritium

 Cesium-137
 Europium-152
 Strontium-90

 Cerium-144
 Cobalt-60
 Cesium-134
 Cesium-137
 Europium-152
 Europium-154

 Europium-155
 Uranilim-235

Cesium-137
Strontium-90

-------
 Table 7-1.  (continued).
                               OUSite
                                                                           COPCs
  3-09/CPP-08 and CPP-09 CPP-603
  Basin Filter System Line Failure and Soil Contamination Near NE
  Corner of CPP-603 South Basin
  3-09/CPP-lO
  CPP-603 Plastic Pipeline Break
 3-09/CPP-1 I
 CPP-603 Sludge and Water Release
 3-09/CPP-17a
 Soil Storage Area South of CPP Peach Bottom Fuel Storage Area
 3-09/CPP-17b
 Soil Storage Area South of CPP Peach Bottom Fuel Storage Area
 3-09/CPP-19
 CPP-603 to CPP-604 Line Leak
  Cesium-137
  Europium-152
  Europium-154
  Strontium-90
  L'ranium-235

  Cobalt-60
  Cesium-137
  Europium-152
  Europium-154
  Europium-155
  Strontium-90
  L'ranium-235

  Arsenic
  Thallium3
  Cesium-137
  Cobalt-60
  Europium-154
  Neptunium-237
  Strontium-90
 Cesium-137
 Europium-152
 Europium-154
 Strontium-90
 Cobalt-57
 Cesium-137

 Arsenic
 Calcium1*5
 Americium-241
 Cobalt-60
 Cesium-134
 Cesium-137
 Europium-152
 Europium-154
 Europium-155
 Niobium-95
 Plutonium-239
 Strontium-90
 Uranium-235
3-09 CPP-22
Paniculate Air Release South of CPP-603
Abandoned Liquid Radioactive Waste Storage Tank CPP VES-SFE-20
Cesium-137
Strontium-90
Techrticium-99

Cobalt-60
Cesium-134

-------
Table 7-1. (continued).
                              OU Site
                                                                          COPCs
 3-09CPP-78
 Contaminated Soil West of CPP-693, East of Dry Fuel Storage Area
 3-IO.CPP-46
 CPP-637 Courtyard Pilot Plant Release—Radiological Contamination
 3-U/CPP-58W/E
 Subsurface release of contaminants associated with PEW spills
 and CPP PEW Evaporator Overhead Pipeline Spills
3-12/CPP-80
CPP-60I Vent Tunnel Drain Leak (VT-300)
3-13.CPP-85
WCF Blower Corridor
3-13CPP-87
VOG Blower Cell Floor Drain. Sump and PEW Evaporator Feed
Pump Cell
 Cesium-137
 Europium-152
 Europium-154
 Europium-155
 Plutonium-239 -240
 Antimony-125
 Strontium-90

 Strontium-90
 Cesium-134
 Cesium-137
 Strontium-90
 Technicium-99

 Americium-24l
 Cesium-137
 Europium-154
 Plutonium-238
 Plutonium-239
 Strontium-90
 Uranium-235

 Chloride3
 Suifate3    ,
 Zirconium3
 Cerium-144
 Cesium-134
 Cesium-137
 Europium-154
 Europium-155
 Plutonium-238
 Plutonium-239/-240
 Ruthenium-106
 Antimony-125
 Strontium-90

Cobalt-60
Cesium-134
Cesium-137
 Europium-154
Strontium-90

Arsenic
 Barium
Cadmium
Chromium
 Lead'
Mercury
Cobalt-60
Cesium-134

-------
                                                                                                       1
  Table 7-1. (continued).
   3-13CPP-88
   Radiologically Contaminated Soils Map
  3-13/CPP-89
  CPP-604/605 Tunnel Excavation
 3-13/CPP-90
 CPP-709 Ruthenium Detection
 3-13/CPP-9!
 CPP-633 Blower Pit Drain
3-13-CPP-92
Soil Boxes West ofCPP-1617
       COPCs
             lm
    Cesium-137

    Arsenic
    Thallium3
    Cesium-137
    Strontium-90

    Americium-241
    Cesium-134
   Cesium-137
   Cobalt-60
   Iodine-129
   Neprunium-237
   Plutonium-238
   Plutonium-239.240
   Strontium-90
   Antimony-125
   Uranium-234
   Uranium-235

   Benzo(a)pyrene
   Phenanthrene3
  Arsenic
  Thallium3
  Cobalt-58
  Cesium-134
  Cesium-137
  Europium-155
  N'iobium-95
  Strontium-90  .
  Arsenic
  Manganese
 Thallium3
 Cesium-137
 Strontium-90

 Americium-241
 Cesium-134
 Cesium-137
 Cobalt-60
 Europium-152
 Europium-154
 Iodine-129
 Neptunium-237
 Plutonium-238
 Plutonium-239/240
 Stronfium-90
Antimony-125
Uranium-234
L'ranium-235

-------
 Table 7-1. (continued).
                                 OL' Site	-              COPCs
  3-13 CPP-93 Simulated Calcine Trench                                        Aluminum
                                                                             Mercury
  3-l3,Windbloun Area 
-------
  7.1.2    Site/Source and Contaminant Identification

  7.1.2.1    Soil.  This section summarizes the identification of sites and COPCs assessed in the HHRA
  tor soil contamination.  First, the sites that were designated "No Action" or "No Further Action" in the
  Track I, Track 2, or Rl/BRA were eliminated based on whether the soil concentration exceeded the
  PRGs.  These sites either: (a) contain no source of contamination, either through process knowledge or as
  a result of sampling activity; or, (b) contain no source of contamination because of remediation  All
  signed and pending decision statements were reviewed during the RI/BRA to ensure that the assumptions
  on which these recommendations were based remain valid (see Section 4.8). The second step of the site
  screening process was based on the results of previous risk evaluations. All sites for which preliminary
  risk evaluations using Track I or Track 2 methods have shown cancer risk or hazard levels to be less than
  I * 10-  or an HI< I.0, respectively, were eliminated from further evaluation. The contamination
  screening process was performed for each of the retained WAG 3 release sites.  Historical sampling data
  were used to identify COPCs present in soils at the WAG 3 sites. The list of contaminants was reduced
  by eliminating contaminants with observed concentrations  less than INEEL background concentrations
  by eliminating contaminants with detection frequencies less than 5% (i.e.. one detect in 20 samples equals
  a 3% frequency of detection) and without evidence of release at the site, and by consideration of whether
  or not the contaminant is an essential nutrient. Because substances that are essential nutrients can be toxic
  at high concentrations, the latter screening step was only applied at sites where essential nutrient
 concentrations are less than  10 times the background concentration.  The results of the site and 3
 contaminant screening are presented in Table 7-1.  Soil concentrations for assessment were then
 calculated for sites of concern as discussed in Section 7.1.3 of the RI/BRA (DOE-ID  I997b).

 7.1.2.2     Groundwater.  This section summarizes the  identification of COPCs and sources, and the
 modeling to determine groundwater contaminant concentrations. Groundwater COPCs were identified
 using three steps. First, an initial set of contaminants was identified by comparing the maximum
 concentrations measured in the aquifer and perched water to the limiting concentration defined bv either
 the water concentration based on a  IE-06 risk level, an HI of I, or the applicable MCL.  The seco'nd
 identification step designed and applied a screening process to evaluate the potential for groundwater
 contamination from contaminated soils. Soil contaminants were evaluated for their maximum risk in the
 alluvium pore-water, their propensity to infiltrate through the alluvium, and the predicted reduction in
 activity due to radioactive decay. These first two steps used field data presented in Section 5.1 of
 Appendix F of the OU 3-13 RI/BRA. including maximum observed concentrations of individual chemical
 species and the associated risk. The field data included:  (I) sampling and analysis of aquifer and perched
 water, (2) service wastewater source logs, and (3) sampling and analysis of soil contamination.
 Contaminants of concern based on other factors such as water sample information and soil contamination
 screens, were identified in the third  step.  As a result, three nonradionuclides and IO radionuclides were
 identified as COPCs in groundwater as shown in Table 7-2.  The identification and evaluation of the
 contaminant sources for the groundwater pathway are discussed in Section 5.2 of Appendix F of the
 OU 3-13  RI/BRA (DOE-ID 1997b).

      The contaminant transport modeling was limited to three  nonradionuclides (arsenic, chromium  and
 mercury-) and 10 radionuclides (Am-241. Co-60. Cs-137. H-3. 1-129. Np-237, Total Pu, Sr-90. Tc-99 and
combined uranium). Each COPC was incorporated in the model using the mass (radionuclide activity is
converted to mass units) defined from the known  releases, service waste, soil contamination, or TRA
discharge to the aquifer.  These contaminant mass sources were  modeled as either a uniform'release over
a known time frame, a variable release over a known time frame, or a one-time release at a particular
time. For the  simulations, the plutonium isotopes were combined into a Total Pu run and the uranium
isotopes arc combined into a Total L run.

-------
  Table 7-2.  Summary- ofthe identified .uroundwater COPC
COPCs Based on Waier Samples
Additional COPCs
Aquifer Based Based on Perched
COPCs Water
Am-241 None
H-3
I- 129
Np-237
Sr-90
Tc-99
u-234
U-238






Additional COPCs Additional COPCs
Based on Soil Based on Other
Contamination 	 Considerations
Arsenic Cs- 1 37
Chromium Mercurv
Co-60
U-235
Pu-238
Pu-239
Pu-240







Final List of the
COPCs for the
Groundwater
Pathway
Arsenic
Chromium
Mercury
Am-241
Co-60
Cs-137
H-3

1-129
Np-237
Total Pu
Sr-90
Tc-99
Total U 	
       The total mass or activity ofthe contaminants at the general source location was divided into more
 specific locations and given the best estimate of time during which the releases occurred  Table 6-1 and
 Figure 6-1 of Appendix F ofthe OU 3-13 RI/BRA report summarize source locations and simulation time
 frames tor each ofthe contaminant sources.  Section 7 of Appendix F ofthe OU 3-13 RI/BRA presents
 the vadose zone and aquifer simulation results. Table 6-4 ofthe OU 3-13 RI/BRA (DOE-ID I997b)
 presents a summary ofthe results by COPC.

       The aquifer transport simulation results consist of contour plots ofthe peak concentration at eiuht
 ditferent time frames centered about the MCL. contours of either the HI or risk number, depending on
 applicability, for eight time frames centered on the 10'" risk (or HI = 1), and the time history of the peak
 concentration and corresponding risk for the entire aquifer, for the Test Reactor Area footprint and the
 INTEC footprint. (TRA is an upgradient source of tritium and chromium to INTEC.) Tables 6-5 to 6-8
 ofthe Rl-BRA present result summaries by COPC.

      Concentrations for each contaminant were calculated as maximum values to coincide with the
 100-year future residential scenario time frame over the entire WAG 3 and therefore is the same
 regardless of location within the INTEC. This was the only scenario for which aroundwater was
 considered a pathway. The risk calculated for the SRPA are on-Site risks. There are no projected
 off-lNEEL impacts to downgradient SRPA users.

 7.1.2.3    Air. Area-weighted concentrations were calculated tisinn  the soil concentration terms
 prepared for each group and site within INTEC that are  presented in Sections 8 through 26 ofthe
 Of 3-13 Rl BRA (see Table 7-3 of this ROD). For the  oriMte worker scenarios. COPC concentrations in
 the 0- to l>cm  (0- to 0.5-ft) depth range were used.  For the future residential scenario CQPC
concentrations in *oil in the 0- to 3.05-m (0- to lO-ft) depth range were used. The individual site
concentrations were then used to estimate the contaminant air concentrations due to emissions that may
 result from multiple sues of concern within WAG 3.  Tin-, methodology j., presented in Section 7 \ T>"
and 2- 2 of the OU 3-13  Rl BRA (DOE-ID I WHit. Huch U)PC concentration term was calculated a> an

-------
                                                                                                          1
Table 7-3. COPC exposure-point concentrations in air
COPCs
Aroclor-1260
Benzo(a)pyrene
Aluminum
Arsenic
Manganese
Mercury-
Uranium
Am-241
Ce-144
Co-57
Co-58
Co-60
Cs-134
Cs-137
Eu-152
Eu-154
Eu-155
H-3
1-129
K-40
Nb-95
Np-237
Pu-238
Pu-239/240
Pu-241
Pu-242
Ru.Rh-106
Sb-125
Sr-90
Tc-99
U-234
U-235
U-236
U-23S
Current Onsite Worker
Fugitive Dust Volatiles
(mg/nr or pCi-nr'l (nm nv )
• — ' - —
1.5E-I2 8.4E-16
— - __
1 .2E-09 —
3.2E-09 —
— —
5.1E-09 —
4.5E-06 —
4.6E-07 _
4.4E-10 —
— . —
5.1 E-06 —
1.5E-06 —
• 5.0E-04 —
1.3E-04 —
1 .OE-04 —
1 .4E-05 —
2.7E-07 —
3.1 E-06 —
— —
4.4E-12 —
1.3 E-06 —
5.5E-06 —
! .7E-06 —
— . . _
— - —
2.9E-07 —
1 .7E-07
2.1E-04 —
6.4E-07 _..
2. 1 E-06 —
5.6E-08 —
• — '
I.T.-H6 ' --
Future Onsite Worker
Fugitive Dust Volatiles
( nm nr or pCi. nr' ) ( me/m3)
— —
I.5E-12 8.4E-16
— —
1.2E-09 — -
3.2E-09 —
— •• — •
5.1E-09 —
3.9E-06 —
9.5E-46 —
1.2E-50 - . — '
•• — • _
l.OE-11 —
3.6E-2I —
5.0E-05 —
8.1E-07 —
3.9E-08 —
• 1.2E-1I —
9.7E-10 —
3.1E-06 —
— • —
	 • 	 .
1.3E-06 —
2.5E-06 — -
I.7E-06 —
— .... — -.
— - —
4.6E-37 —
2.3E-1S —
1 .9E-05 —
6.4E-07 —
2.1 E-06 —
5.6E-OS —
— —
1 T-D6
Future Qnsite Resident
Fugitive Dust Volatiles
(mg/nr orpCi/nr') (mem')
1.9E-11 1.6E-13
I.6E-12 5.7E-16
7.1E-07 _
7.4E-08 —
3.4E-09 —
8.3E-10 —
4.3E-09 —
1.1E-05 —
I.3E-45 —
1.7E-50 —

7.4E-II —
8.5E-21 	
2.3E-03 —
2.4E-06 —
l.OE-07 —
2.2E-11 —
5.4E-09 —
I.2E-06 —
3.0E-07 —
. _ _
1.4E-06 —
4.2E-06 -
3.2E-06 —
5.4E-07 —
3.8E-09 —
L8E-37 —
I.SE-18
6.3E-04
1 .6E-06
1.5E-06 —
5.8E-08 —
9.0E-1I
I.4E-06

-------
  7.1.2.4    average v alue over the entire WAG 3 are and therefore, the same value is .used regardless of
  location within INTEC.

  7.1.3    Human Health Risk Assessment

        The OU 3-13 HHRA methodology is presented in Section 7 of the OL' 3-13 RI/BRA
  (DOE-ID I997b).  This methodology was applied consistently for all retained sites within WAG 3  The
  HHRA evaluated risks due to exposure to COPCs through soil ingestion. fugitive dust inhalation  VOC
  inhalation, external radiat.on exposure, groundwater ingestion, ingestion of homegrown produce  dermal
  absorption of groundwater, and inhalation of water vapors during indoor water use.  The approach is
  described in the following sections.

  7.1.3.1    Exposure Assessment.  The exposure assessment stage of the human health risk
  evaluation process estimates the exposure route, magnitude, frequency, and duration of exposures that
  receptors may experience due to contact with contaminants at a specific site or group of sites.  The
  primary purpose of the exposure assessment is to estimate total dose for a receptor that can later be
 compared with chemical-specific dose response data to estimate cancer risk and the likelihood of other
 noncancer adverse health effects. A conceptual site model (CSM) was prepared to identify receptors and
 exposure routes under current and future land use conditions (Figure 7-1).  The CSM  illustrates the
 contaminant sources, primary release mechanisms, secondary sources and release mechanisms exposure
 pathways  exposure routes, and receptors specific to WAG 3.  Aspects of the exposure assessment process
 are described m more detail below.

 7.1.3.2    Identification of Potentially Exposed Receptor Populations. The identification of
 potentially exposed receptor populations includes consideration of applicable current and future land use
 T^f'  A discussion of these scenarios at the INEEL  is found in Section 7 of the BRA  As shown by
 the CSM, potential receptor populations include occupational site workers and hypothetical future
 residents  The current land use includes continued  use of operating facilities. Access to these facilities is
 controlled: therefore, the only potential receptor is an occupational worker during the current land use
 seennrin
scenario.
      Because current industrial uses at WAG 3 are expected to continue in the future, the future land use
scenario included occupational workers. Also, for the purposes of the WAG 3 HHRA it was assumed
that residential development may occur and thus, exposures to hypothetical future on-Site residents mav
occur and were evaluated.  The residential receptor is assumed to be an adult for all potentially complete
pathways: additionally, a child receptor was included in the soil ingestion pathway assessment  For this
pathway, the child and adult parameters were averaged on a time-weighted basis.  Child exposures were
evaluated specifically for the soil ingestion exposure route because children  have the potential for much
greater exposure via this route. The timing for the future land use exposure scenarios was assumed to be
100 years in the future for both receptor populations.

7.1.3.3    Identification of Potential Exposure Pathways. The CSM  for WAG 3 includes
sex eral exposure pathways and associated routes that vv ere selected for further  evaluation based on
process and release history. The completeness of exposure pathways and routes are expected to varv
between release sites according to the presence or absence of site-related  chemicals or the presence of
engineering features or artifacts that prevent exposure from taking place.  Exposure pathwavs evaluated at
each Mie of concern are summarized in Table 7-4.  Site-specific  features that influenced the"completeness
01  pathway and evpOMire routes are described separately for each site in  Sections S through 26 of the
OL 3-13 Rl BRA.
                                              "-I4

-------
G
                                         or BTBJM gigac
                                 occoifiuiniai suinaa usa
                                 M TtC PCW CVAMMATOI FACUH
                                    T-7/AC  3  conceptual  site model.
          Figure 7-1  WAG 3 conceptual s.temodd
                                                                                                                                                                                                     7-15

-------
                                                                                                       1
                                  «posure pathways quawjtaively CTataed for WAO 3
    Potentially Exposed
         Receptor
    Occupational
    worker
   Residential
                        Scenario

                  Current land use
                  Future land use
   Occupational
   worker
                 Future land use
  Potentially Complete Exposure Pathways and Soil Depths by
 __ _ . _ Exposure Route _

 Inhalation of VOCs (0- 1 5 cm [0-6 in.])'
 Inhalation of airborne particulates (0-15 cm [0-6 in.]?
 Ingestion of surface soil (0-15 cm [0-6 in.])'
 External radiation (0- 1 .22 m [0-4 ft])b

 Inhalation of VOCs (0-3.05 m [0-10 ft])c
 Inhalation of airborne particulates (0-3.05 m [0-10 (Of
 Ingestion of surface soil (0-3.05 m [0-10 ft])'
 Ingestion of homegrown produce (0-3.05 m [0-10 ft])*
 Ingestion of groundwater
 External radiation (0-3.05 m [0-10 ft])c
 Inhalation of VOCs (0-15 cm [0-6 in.])'
 Inhalation of airborne particulates (0- 1 5 cm [0-6 in.])*
 Ingestion of surface soil (0-15 cm [0-6 in.])*
External radiation (0-L22 m [0-4 ft])*
                                                                    -

     ExposureisassumedtobelimitedtosuifecesoiL Surfaced is considered as the top 0-1 Scm((Win.>
                                                                         .

subs                                                       Contamination betew todepthi,



                        *'          * """^ ***** **«** to become *"*«* «>« *™ allowing exposure
  tooccur to the
  7.1.4   Toxfcity Assessment
 and reference dose values are presented in Section 7.2 of the OU 3-13 RI/BRA (DOE-ID 1997b).

 7.1.5    Human Health Risk Characterization
 to a ootiarnP    *?****** is f**«* « both cancer risk and noncarcinogenic hazard
 to a potential receptor. Potential concern for noncarcinogenic effects of a single contaminant in a sinele
              1**     ***• WWch * *" rad° °™< «timated intake dJUdSSJSSSS
                                ?e COntaminant>s refe™* ^se (RfD). A RfD is defmed^ddly
                                         * WJU "Ot prOduCe delcterious effects durin8 a Iife^- ^
ny be rhlv e                           ^ °f aCn)SS a" media to *hich a S^n Population
                         '    HI  3" bC calculated- ^ HI expresses noncarcinogenic eflS-ts of
                                          mCdiUm °r across media-  Potential carcinogenic risks are
                                          dividual might devel°P cancer in *eir life^e fr°»
                                   Er°JeCted intakeS and Che™^-specif5c, dose-response data called
                                d *" eS'imated daily intake °f a comP°URd' ^eraged over a lifetime
devdop cc                      'nc«™ntal risk that an individual exposed to that compound may
                                            7-16

-------
                                                                                                            1
   calculate the Z         T  "?"? **" ^ '° S°/V *&>»""• The intake equations used to
   Rl BtS mOF 1CH'Q™  rl       J°m Ttammated S°ilS 3re PreSemed in Sectlon 7 of the °U 3-<^
   Jct-m^ h         /   ''     SC mtakeS 3nd the aV3ilable t0xidty inf°™^ion were then used to
   riS^S f,'nCreaSed can«r madence and noncarcinogenic hazards.  The results of the soil exposure
   nsk calculations are presented by site in Sections 8 through 26 of the OU 3-13 RI/BRA (DOE-ID 1997b)
   mrtTnToo^tr™   C fiSkS WerC eVa'Uated cumu|a ^ Air Exposures.  The intake equations used to
  calculate the! scenano-specific mtakes from the inhalation of fugitive dust and volatilized contaminants
  are presented ,„ Section 7 of the OU 3-13 RI/BRA.  These intakes and the available to^i^Son
  were used to estimate the increased cancer incidence and  noncarcinogenic hazards (Tab  ^7-5 anT77)
  2  Sn  ^ tender a!,' h6 "1CreMed.can^ Hsk from exP— » area-weighted air concentrations if"
  we 1 below a HI ofl  fn  ^T SCena"°S-     "°ncarcin°genic hazard for this pathway was found to be
  mtction 27 of the OU f, wiSS""*' ^^^ M°W'theSe "** WCK CVaIuated
  in section 21 ot the OU 3-13 RI/BRA report (DOE-ID I997b).
 7.1.5.4    Cumulative Risk Presentation. Cumulative cancer risks and noncarcinogenic hazards
 associated w.th WAG 3 were estimated by summing all risk contributions across all paZ^y and
 exposure routes tor all contaminants. Risk contributions from the groundwater and air pathways were
 added to nsk contributes from the soil pathway at each group and site within WAG 3   The resuUs are
 anirrweT"31^ '" SeCt'°n 27 of theOU 3-13 RI/BRA (DOE-ID I997b).  From these results Tables 7-7
 cannce"r r^^^^l^^^^^^^y ^ HHRA a"d the Corresponding

 7.1.6    Human Health Risk Uncertainty

       Many sources of uncertainty are introduced during the risk assessment process, beginning with site
 investigations and samphng and analysis through risk characterization. Site-specific uncertainty is
 discussed separately for each release site in Sections 8 through 26 of the OU 3-13 RI/BRA  A summary
 of uncertamty sources and their potential effects on the risk evaluation is given in the following
 paragraphs.                                                      w                 fe


Or f n R • Rp1°S"re f*thWayS- Generally, pathways and exposure routes were evaluated in the
OU 3-13 RI BRA according to their potential risk contribution.  Exclusion of less significant pathways
may underestimate the total nsk to human  health. However, those pathways not quantified were        '
decisions l° rePreSCm Sma" S0urces °f exP°sure and were not expected to influence risk management

-------
       ^Many of the sites are rarely, if ever, visited by onsite workers.  The actual exposure time is
  significantly lower than the values used in human health risk assessments (i.e.. 10 hr d) and therefore risk
  calculations likely represent an overestimate of the actual risk.

  7.7.6.2     Contaminant Fate and Transport. With the exception of radionuclides. the evaluation
  of human health risks assumed that environmental media concentrations determined from sampling will
  remain at the same levels over the assumed periods of exposure. This assumption is likely to result in an
  overestimation of risk, since concentrations are expected to decline over the long-term as natural
  processes degrade, dilute, or remove site contaminants.  The rate of the these natural processes in the
  contaminated media are unknown, therefore, the magnitude of the overestimate is difficult to determine.

  7.1.6.3    Exposure-Point Concentration. The exposure-point concentrations used for assessing
  risks associated with the reasonable maximum exposure case were  either the maximum detected value or
 the upper 95th percentile of the mean value (whichever is less). Nondetected values were treated as
 concentrations equal to half the detection limit.  This procedure would overestimate the risk except in
 cases where the actual concentration of the chemicals is below the detection limits.

 7.1.6.4    Exposure Levels.  The amount of exposure that an individual receives is highly dependent
 on their activity patterns.  There is considerable variability regarding the values assumed in calculating
 human intake factors.  For instance, estimates of soil ingestion rates for all populations  are subject to
 ongoing debate. This may again result in overestimating or underestimating the risk on an individual
 basis.  Additionally, exposure levels estimated for this project did not take into account the fact that
 individuals such as onsite workers would be required to wear personal protective equipment (PPE) when
 working in contaminated areas. This results in an overestimation of risk for these potential receptors.

 7.1.6.5    Cancer-Risk Estimates.  The predicted cancer risk in  humans due to chemical exposure
 (i.e.. nonradiological) is often based on cancer dose-response data in animals. There is  a long-standing
 controversy in the scientific community as  to the best way by which cancer-dose response data obtained
 from animal studies should be extrapolated to humans. In general, the EPA follows a conservative
 procedure in deriving slope factors, so cancer risk estimates due to chemical exposure based on these
 values are likely considerably higher than the true risks.

 7.1.6.6     Computer Modeling.  A computer model  was used to estimate exposure concentrations of
Site-related chemicals in groundwater. These values were subsequently used to estimate chronic daily
intakes, and subsequent total cancer risk and noncarcinogenic hazard.  Numerical predictions of
contaminant fate and transport in the vadose zone and the aquifer were based on:  {I) hydroueoloeic data
forming the conceptual models for both zones:  (2) contaminant release source term estimates: and"
(3) estimates of the contaminam-soil-basalt chemical interactions. The uncertainty in the conceptual
model and its parameterization was qualitatively assessed. This uncertainty may have lead to either an
over estimation  or underestimation of risk.  Uncertainty in source term estimates,  including the volume.
mass and content: and in the interaction of the contaminant with the  soil and basalt, parameterized as the
distribution coefficient or Kd; cannot be quantified accurately. The predicted contaminant concentrations
are much more sensitive to these latter two  parameter values than the first. The uncertainty associated
with the UNO of a computer model to estimate groundwater exposure  concentrations is discussed in detail
in Section (•> of die OL' 3-13 RI  BRA.

-------

COPCs
Aroclor-1260

Benzo(a)pyrene
Aluminum

Arsenic
Manganese
Mercury

Uranium
Am-241
Ce-144
Co-57
Co-58
Co-60
Cs-134
Cs-137
Eu-152
Eu-154
Eu-155
H-3
I- 129
K-40

Nb-95
Np-237
Pu-238
Pu-239240
Pu-241

Pu-242

Ru Rh-106
Sb-I25
Sr-90
Tc-99
L'-234
U-235
L'-236

L-23S
Total Cancer Risk
Indicate" that the c.c
\ 1 1) indicate" that >",
Current Onsite Worker
Inhalation of Inhalation of
Fugitive Dust Volatiles


2E-14 1E-17
	

IE-15 —
NTD _


NTD —
4E-15 _
IE-IS _
3E-23 _
	 	
8E-18 —
IE-18 _
2E-I6 —
2E-16 —
2E-16 —
3E-18 —
6E-22 —
9E-18 —


3E-25 _
IE-15 _
3E-15 —
IE-15 — .




SE-19 _
2E-20 —
3E-16 —
4E-20 —
7E-16 —
2E-P —


5H-I6 _
3FM4 IE-IT •
'iM.iMiitunt ;- not a c 1 )('( m the medium IT
Kit1. Jala i^ not a\ai.'ahle
UlULl^lU HI Ull .
	 Future Onsite Worker
Inhalation of Inhalation of
Fugitive Dust V'olatiles

— — ;
2E-14 IE-17

—
IE-15 _
NTD _

• 	
NTD —
3E-15 _
2E-57 _
8E-64 _
	 _
2E-23 —
2E-33 —
2E-17 _
IE-18 —
8E-20 —
3E-24 _
2E-24 _
9E-18 —

	 ; • „ —
	 . 	
IE-15 —
2E-15 —
IE-15 —

: 	

	 	
1 E-48 —
3E.-31 —
3E-I7 _
4E-20 —
~E-16 —
2E-1? —

	 	 . -
5E-I6
.3E-I4 IE-17
.it the N,K-

Future Onsil
Inhalation of
Fugitive Dust

NTD
2E-14

NTD
1E-13
NTD

NTD
NTD
IE-14
3E-57
IE-63

1E-22
6E-33
IE-15
4E-I8
2E-19
5E-24
1E-23
3E-18

5E-20

IE-15
3E-15
2E-15

5E-16

2E-18
5E-49
2E-3I
IE-15
1E-I9
5E-16
2E-17

3E-20
4E-16
n


:e Resident
Inhalation of
V'olatiles

NTD
8E-18

	



	














	





	

	







	
	

SE-l,s


-------
  Table 7-6. Noncarcinouenic hazards due to COPC concentrations in air.
                     JTurrent Onsite Worker
                                Future Onsite Worker
      COPCs
Inhalation of
Fugitive Dust
                                 Inhalation of
                                   Volatiles
                                                                               Future Onsite Re
Inhalation of
Fugitive Dust
Inhalation of
 Volatile*
Inhalation of
Fugitive Dust
Inhalation of
 Volatiles
  Aroclor-1260
  Ben/o(ajpvrene
  Aluminum
  Arsenic
  Manganese
  Mercurv
  Uranium
  Am-24]
  Ce-144
  Co-57
  Co-58
 Co-6t)
 Cs-134
 Cs-137
 Eu-152
 Eu-154
 Eu-155
 H-3
 1-129
 K-40
 Nb-95
 Np-237
 Pu-23X
 Pu-23^ 240
 Pu-241
 Pu-242
RuRh-106
Sb-125
   NTD
    —
   NTD
   4E-06
    —
   STD
                                     NTD
                                                   NTD

                                                   NTD
                                                  5E-07

                                                   NTD
                  NTD
                 NTD
                 NTD
                 NTD
                 NTD
                 5E-07
                 1E-07
                 NTD
                  NTD
                  NTD
 Tc-'W
 l'-234
 L-235
 I -2.V>
   In.: «.j
.VII lhi
                                                               n|.;-oo
                                                                                           Oli-dO

-------
 Table 7-7. S

     (iroup Site
ry.l?LK'/»!JA concjusionsand recommendations for groups andsile^f mnr.»rn_
 CojiilamiiKuiis Identified
Sues ,,f I M-lusix e      CPP-02: Kad.onuclidcs  CH'-02: Unknown
(iiouiulwaiei Concern
                               site included in'me gmundwa'ter modd*"1" C°IlUimillalioni   J'hcsc sites|we"; e^»^ i" the RI/BRA u.
                                                                                        I HO i?\liMll lh:il tl\j»t( .»»-.. 	_ __..**.  i
                   '   C'PP-23: Radionuchdes  CI'l'-23: Significant potential source of groundwater
                                             contamination, site included in the groun.dwater model.
                     Cl>l>-o5: Low levels of   CPP-65: Significant source of water, i
                                                                       -
                                                                                          source
                     Kudioiuielidcs
                                             C;iM'-W|: Unknown potential for groundwater coniammalion
                                             site included in the groundwater model.

                     C -IM'-XJ: Kadi<,nuclule.s   fPI>-83: Signitlcant potcnlial source of groundwater
                     a'ul mcli'ls              contamination, site included in the groundwater model.

                     U'l'-*7: Radionuclidcs   CPP-K7: No identified route for contamination transport to
                                             the aquifer, site not included in the groundwater model

                                                                                 al- con,amin.,ion.
                                                                                                  *
      and metals

      Kiulionuclidcs at all
-28,   siles
                                       -. f---•••• i iu • t\Jt KIVJU||VJW

                       site. Included in the groundwater model.
                                            Current occupational:  surface risk >IE-04 due to external
                                            radiation exposure (Cs-137)

                                            Future occupational:  surface risk >1 E-04 due to external
                                            radiation exposure (Cs-137)

                                            Future residential: surface risk >1 E-04 due to external
                                            radiation exposure (Cs-137)
                                                                                                                         0
                                                                                  Ihe extent that they are a source of recharge
                                                                                  and/or contamination to the SRPA and will he
                                                                                  evaluated further in the Oil .1-13 l-easibility
                                                                                  Study.
                                                                                 The potential increased cancer risk is
                                                                                 unacceptable regardless of land use
                                                                                 assumptions. Alternatives protective of future
                                                                                 residents should be evaluated during the Oil
                                                                                 3-13 Feasibility Study for this group.

-------
         Table 7-7.  {continued)..
 I

I J
        lank I .inn South
        ldT-15.-27 \.\.
        s.xU'l )
        \Vaste Calcine
        I-acihtv (CI'l'-35.
OldSloiaiie I'ool
(CIM'-UI  (1-1 U.S. .
US II1). -III. -II)
Stoiaue Vatd l.asl of
(IT-olM (Cl'l'-03. -
I7A.-I7H)
                       Contaminants Itlenlilled

                       Radionuclidesat all
                       .Mies
                       (TP-35: Uadionuclides

                       (TI'-36.-«M:
                       kadionticlidcs

                       CIT-X5: Nti release
                       idcnlilled

                       Kadionuclidcs for nil
                       sites
                              Kadionuclidcs for the 3
                              siles
                  Risk Assessment Results'*

 Current occupational: surface risk >1H-04 due to external
 radiation exposure (Cs-137)

 Future occupational:  surface risk --II--04 due to external
 radiation exposure (C's-137)

 l-'uture residential: surface risk -'II--04 due to external
 radiation exposure (Cs-137) and ingestion of homegrown
 produce
 (Cs-137)

 Current occupational:  surface risk •> I li-04 due to external
 radiation exposure (Cs-137) Future occupational:  surface
 risk > Ili-(l4 due to external radiation exposure (Cs-137)

 Fulurc residential:  surface risk > 1 li-04 due to soil ingeslion
 (Am-241, Cs- 137, Sr-W), homegrown produce ingestion
 (C's-137 and Sr-90), and external radiation exposure (Cs-137)

 Current occupational:  surface risk > I [{-04 due to external
 radiation exposure (Co-60, Cs-134, Cs-137, Lu-152, liu-154)

 Future occupational:  surface risk >  IL-04 due to external
 radiation exposure (Cs-137, Liu-152)

 l-'uture residential:  surface risk > I li-04 due to external
 radiation exposure (Cs-137, Fu-152,  Hu-154)

Current occupational: surface risk > I  li-04 due to external
radiation exposure (Cs-137)

l-'uture occupational:  I li-04- surface  risk  •- IF.-OISduelo
radiation exposure (Cs-137)

Future residential:  surface risk > I li-04 due to external
radiation exposure (Cs-137)
	      Conclusions andJRecomniciulations

   The potential increased cancer risk is
   unacceptable regardless of land use
   assumptions. Remedial alternatives
   protective of future residents should  lie
   evaluated during the Oil 3-13 Feasihility
   Study for this group.
   The potential increased cancer risk is
   unacceptable regardless of land use
   assumptions. Remedial alternatives
   protective of future residents should he
   evaluated during the OH 3-13 Feasibility
   Study for this group.

   The potential increased cancer risk is
   unacceptable regardless of land use
   assumptions. Remedial alternatives
   protective of future residents should he
   evaluated during the ()t) 3-13 Feasibility
   Study for this group.


   '['he potential increased cancer risk is sliglulv
   greater than I li-04 under current occupational
   and future residential assumptions. Only site
   CTIMJ3 should be evaluated further in the ()l I
   3-13 Feasibility Study.

-------
   Table 7-7.  (continued).

       < iroup.Sile      ..<>?»

  l"IT-.17A U            Radionuelides and
                        arsenic
 CIT-(i7
                       Kadionuclide
CIT-14
                       Kadionuclides
CIT-34
                      Radioiuielidcs
Risl< Assessment Results'1
  Current occupational: I H-04 > surface risk > I H-06 due to
  external radiation exposure (Cs-137)

  Future occupational:  I H-04 > surface risk > I H-06 from
  external radiation exposure (Cs-l37, Np-237)

  Future residential: 1 H-04 > surface risk >  I H-06 due to soil
  mgcslmn (arsenic) and external radiation exposure (Cs-137,


  Current occupational: surface  risk >l H-04 due to external
  radiation exposure (Cs-137)

  Future occupational: I H-04> surface risk > I H-06 due to
 external radiation exposure (Cs-137, Np-237)

 Future residential: surface risk >1E-04 due to external
 radiation exposure (Cs-137)

 Current occupational:  I H-04>surface risk > I H-06 due to
 external radiation exposure (Cs-137, Np-237)

 Future occupational:  I H-04> surface risk > I H-06 due to
 external  radiation exposure (Cs-137,  Np-237)

 Future residential: I H-{)4> surface risk > I H-06 due to
 external radiation exposure (Cs-137,  Np-237)

 Current occupational:  1 H-04> surface risk >  1 H-06 external
 radiation exposure (Cs-137)

 Future occupational:  1 H-04> surface risk > I H-06 due to
external radiation exposure (Cs-137)

Future residential: surface risk > I H-04 due to homegrown
produce inges.ion (Sr-90) and external radiation exposure
                                          The potential increased cancer incidence at
                                          this release site is less than I H-(M under all
                                          land use assumptions; therefore, further
                                          evaluation in the OU 3-13 Feasibility Study is
                                          not warranted.
                                         The potential increased cancer risk i.s
                                         unacceptable under future residential  land use
                                         assumptions. Remedial alternatives
                                         protective of future residents should he
                                         evaluated during the OU 3-13 Feasibility
                                         Study for this site.


                                         The potential increased cancer incidence al
                                         this release site is less than I H-04 under all
                                         land use assumptions; therefore, further
                                         evaluation in the OU 3-13 Feasibility Study is
                                         not warranted.
                                                                                                         The potential increased cancer risk is
                                                                                                         unacceptable under future residential land use
                                                                                                         assumptions. Remedial alternatives
                                                                                                         protective of future residents should be
                                                                                                         evaluated during the OU 3-13 Feasibility
                                                                                                         Study for this site.

-------
 Table 7-7.  (continued).

     dump Site      Con
(Tl'-l 3               Riulionuelides
 Cl'l'-on
                      Radionudides
                       Radionucliiles
ci-i1-::
                      Kndionuclidcs
      .._.._..     Kisk Assessment Results'*

 Current occupational:  surface risk > I H-04 due to external
 radiation exposure (Cs-137, Hu-154)

 Future occupational:  surface risk > I H-04 due to external
 radiation exposure (Cs-137)

 Future residential:  surface risk > I H-04 due to homegrown
 produce ingestion (Sr-90) and external radiation exposure
 (Cs-137)

 Current occupational:  surface risk > I li-04 due to external
 radiation exposure (Cs-137)

 Future occupational:  I H-04 > surface risk - 1 li-06 due to
 external radiation exposure (Cs-137)

 Future residential:  I li-04 > surface risk > 1 H-06 due to
 external radiation exposure (Cs-137)

 Current occupational:  surface risk > 1 H-04 due to external
 radiation exposure (Cs-137)

 Future occupational:  I H-04 > surface risk >  I H-06 due to
 external radiation exposure (Cs-137)

 Future residential:  surface risk >  I H-04 due to soil digestion
 (Cs-137, Sr-90), homegrown produce ingestion (Cs-137,
 Sr-'JO) and external radiation exposure (Cs-137, Hu-152
 Hu-154)

 Current occupational:  surface risk > I li-04 due to external
 radiation exposure (Cs-137)

 Future occupational:  1 H-04 > surface risk >  1 H-06 due to
external radiation exposure (Cs-137)

 Future residential:  1 H-04 > surface risk > I H-06 due to
external radiation exposure (Cs-137)
                                                                                                        ——   tV'iielusmns and JKa:oniniendations

                                                                                                          The potential increased cancer risk is
                                                                                                          unacceptable under all land use assumptions
                                                                                                          evaluated. Remedial alternatives protective of
                                                                                                          future residents should be evaluated during
                                                                                                          the OU 3-13 Feasibility Study for tins site"
The potential increased cancer incidence at
this release site is greater than I H-04 under
current land use but less than I H-04 under
future occupational and residential land use
assumptions; therefore, further evaluation of
this site in the FS is not warranted.


The potential increased cancer incidence at
this release site is greater than 1 li-04 under
current and future residential land use
assumptions but less than  I li-04 under future
occupational  land use. Remedial alternatives
protective of future residents should be
evaluated during the  OU 3-13 Feasibility
Study  for this site.


The potential increased cancer incidence at
this release site is greater than I li-04 under
current land use but less than 1 H-04 under
future occupational and residential land use
assumptions; therefore, further evaluation of
this site in the OU 3-13 Feasibility Study is
not warranted.

-------
          7-7.  (continued).
          nip /Site
jCj>ntjiininaiits Men tilled

 Kadionudidc.s
                                                   	  Risk Assessment Results'1
 UT-XN
                        Radiomiclidcs
                       Radionuclides


                       Mercury
                                                Current occupational:  I E-04> surface risk > 1 |£-()6 due to
                                                radiation exposure (Cs- 137)
                         Future occupational:  I K-04> surface risk
                         radiation exposure (Cs-137)
                                                                                          I li-06 due to
.1  I llC tlsk
         •issoV.nu-111 io;.iilis in Ihis milk- tin inn intflmltf llie air and
 Future residential:   I L-()4> surface risk '> 11-:-06 due to
 external radiation exposure (Cs-137)

 Current occupational: I K-04> surface risk > I li-06 due to
 radiation exposure (Cs-137)

 Future occupational:   1l>04> surface risk > I f>06 due to
 radiation exposure (Cs-137)

 Future residential:  I E-04> surface risk > IL-06 due to
 external radiation exposure (Cs-137)

 The waste boxes that contain radioactive soil were not
 evaluated quantitatively in the RI/BRA Report.
 Current occupational: 111 > I

 Future occupational: III > |

Future residential:  non-carcinogenic hazard > I due to
ingestion of home grown produce
—	Conclusions and Recommendations

 The potential increased cancer incidence at
 this release site is less than IH-04 under all
 land use assumptions; therefore, further
 evaluation of this site in the OU3-I3
 l-easibiliiy Study is not warranted.
                                                                                                           The potential increased cancer incidence at
                                                                                                           this release site is less than I H-04 under all
                                                                                                           land use assumptions; therefore, further
                                                                                                           evaluation of this site in the OU3-I3
                                                                                                           Feasibility Study is not warranted.
                                                                                    The disposition of these boxes will be
                                                                                    deferred to the OU 3-13 Feasibility Study.
                                                                                    The noncarcinogenic ha/ard under future
                                                                                    residential assumptions is > 1; therefore,
                                                                                    further evaluation of this site in the OU 3- \ 3
                                                                                    FS is warranted.

-------
                                                                                                                                                    1
 Table  7-8. Human health baseline risk assessment summary for WAG 3 sites ofconcern.
                                                                                                 Exposure Scenario
                                                                                         Excess Risk of Incurring Cancer
Group
Group 1— INTECTank Farm1


Group 2 — Soils Under Buildings and
Structures
Group 3— Other Surface Soils



Group 4 — Perched Water

Group 5 - Snake River Plain Aquifer1-'




Group 6 — Buried Gas Cylinders
Group 7— SFE-20 Hot Waste Tank
System8"1

* Half-life ten \carsl used in modeling lor Ol ' 3
COC
Cs-137"
Sr-90***
U-235
NSR'
Cs-137
Eu-i52
Eu-154
Sr-90
Total Pu
Sr-90
Am-24 !
Cs-137
[-129
Np-237
Sr-9()
—
Pu •
U
•13 risk assessment.
Half-
life*
30
29
10"

30
13.3
8.8
29
104
29
432
30
1.57x10"
2.1x10"
29

2xl04
10"
Current
Worker
6 in 10
5 in 1 0.000
5 in 1 0.000
NSR-"
5 in 1 00
2 in 1 .000
2 in 1 .000
1 in 100
NRd
NRd
NR
NR
NR
NR
NR
NRCr
NRCh
NRCh
Future Worker
(in 2095)
6 in 100
5 in 100.000
5 in 10.000
NSR"'
5 in 1 ,000
1 in 100,000
Sin 10.000.000
1 in 1.000
NRJ
NRd
NRJ
NRJ
NRJ
NRJ
NRJ
NRCf
NRCh
NRCh
Future Resident
(in 2095)
3 in 10
2 in 10.000
2 in 1 .000
\SRC
2 in 100
6 in 100.000
4 in 1 .000.000
4 in 1 .000
NRd
NRd
4 in 2.000.0001-'
4 in l.OOO.OOO1-'
2 in IOO.OOO'
8 in l.OOO.OOO'
9 in l.OOO.OOO'
NRC'
NRCh
NRCh
** Os-13? contributes to risk only MJ direct exposure.
*•* Sr-*) contributes to risk \ ta groundwaler. soil
a Pu. which prtmariK originates Irom the Tank
direct exposure, and
Farm soils, is predici
ingest ion.
led to exceed

SRPA MCLs and i

3ose a i»round\vat«?r mut*

<;tinn rikL in fhr* vmr
                    •            	    	—~ i—' - — 	 — •  -   •--.•••»....^mv« i \ti\jj\. uibuikiivMia UP (vi 11.1 MVU lauvjii, 11 nciv: 33411 v. i\ in uu
     addressed in the Ol. 3-14 Rl FS.

b    Ke\ OOCs and  their concentration-; are assumed to he the same as tor (jroup .' soils

C    No suruce risks tNSRl due to incomplete exposure pathway, while buildings arc m place.  No risk to future residential receptor it'huildings are
     lell in place, or  removed with subsequent capping or removal ofunderK mg soil  Release sues pose a potential risk to groundwatcr \ la -.oil
     contaminant leaching and transport. Risks to grounjwatcr are presented under Group 5  Hie contaminants from soils are not a significant
     I'uturc impact to grounduater

J    Nil risk because perched water is not capable ot\ustaimng a pumping rate needed I'or t'uture domestic water supplies, therelore. it :s not a
     Miurce ol'potable uater.  However, perched water is a  source of contamination I'or the SRPA  Risk calculations on future impacts -A ill he
     rellned underthe Tank Farm Rl FS (OL 3-14)

c    Thove i allies are predicted risk to luture residential in  :i«5 and he>ond  I'umulatue groundwater risk to future residential in :V>5 jnd bejond
     i> 5 in i'lll.niHI ouKide the current 1STEC •iecunn  tencc  Ri>k calculation^ on I'ulure impacts inside the current INTf-X  seeuniv fence «ill be
     refined under the Tank Farm RI FS i Ol  .'-I4i.

i    No n-.k-. vsere calculated i NRO tor these Mies  1 hcsc sues prescni .1 %aiet>  r^k and threaten t'uture release of contaminants
^    High coiKentration> <i unuinJw.iier :l a 'ele.i-,e oc>.ur-

i    MlhiMi^h «nrkcr> .Innk -sRP \, ihe Jrinkin.: water well- d.i IM: -nierse^t the plunie/
'    No ;i«k to i.iluie .>»-ri>ct il' iisiii.ifiMi.ii ^.-ii'.-.-k retnam -;i p!.n.e "f waier 'reairiient •- inipie-inenied	
                                                             '-26

-------
                            7.2    Ecological Evaluation
  .o cause undesirable eel, aTef ec s  The ^T""!"1""' "T " WA° 3 thal have "«
.  associa,ed con^n^s also proeo

  7.2.1    Site and Contaminant Screening

       As discussed in Section 28.2.2 of the OU 3- 1 3 RI/BRA (DOE-ID I997hj fnr „ t  ,- n




 at these sites was initially screened from concern iS                 ' a"y contaminant identified
 than the 95V5% upper tolerancHevd omTS h  t     IT""1 COntaminant concentrations was less
 (Roodeta,. I^S)^^^^^                                         .
 of concern remained to be evaluated in the ERA.         screening levels (EBSLs). As a result 27 s.tes
      Contaminant concentrations in water at CPP-65 and TPP f,i „.» ^       j
                       '
                                       ,
 concern, and sensi,,ve species ,ha, may be fourfd
7.2.2   Exposure Assessment
      As discussed in 28.3 in the OU 3-13 RI/BRA fDOF rn iQ07K\ *u      •  •
site of concern were then evaluated to de term nZ V     u       }<  he remaming contaminants at each


   •£.z±T^^
         ERA ,he maxin,um value                                "" Perf0™ed ^ ** "*
7.2.3   Toxicity Assessment

-------
   Table 7-9.  Screening of liquid effluent concentrations at the Sewage Treatment Plant. CPP-65.
COPC
As
Ba
Cd
Cl
Cr
Cu
Pb
Hg
Mo
Ni
Se
Ag
Zn
Nitrate
Total phosphorous
Plutonium-239/240
Strontium-90
Liquid Effluent
Concentration
(nm:L)J
l.OE-03
8.4E-02
5.0E-03
9.5E-01
6.0E-03
1.7E-02
2.8E-03
l.OE-04
1.7E-02
I.5E-02
2.0E-03
l.OE-03
2.7E-02
I.2IE-K)]
2.9E+00
1.9E-031'
3.6E-011'
Toxicological
Benchmark
(me/LorpCi.L)h
1.6E-01
1.56E+01
2.3E-02
2.3E^05':
9.36E-HX)
4.7E-01
I.01E-01
9, 1 E-02
3.3E-01
1.14E+02
9.6E-02
NA
3.04Et-02
1 .9E+03
NA
NA
NA
Water Concentration of
	 ConcenUmg/'L^
X
X
X
X
• • x
X
X
X
X
X
x
j.OE-03d
X
X
2.9E-H)Oe
X
X
 "J^1 CmC™™t0ns aretmean concentrations, except Cl. nitrate, and total phosphorous are maximum observed
 concentrations,  I nits are mg-L. except tor radionuclides. which are pCi-L.


          ^ IOVICOl0!?!cal benchmarks for wildlife exposure through dnnking water from Opresko et al  < 199<> unless othenv.se

                                      d beiK-hmark ™

d. S.l\ er toxicity .s related to water hardness.  At water hardnesses of 50. 1 00 and 200 mgAL ' as CaCo-  the t ' S ' F.P A 1 1 980 »


SErlJ ed.lhiatI^.5I0"CemratIon "f »ial recoverable silver not exceed 1 .2. 4.1 and 1 3~ugAL-'. respec'tivelv.'at'anv t.me ' The


C, u ,t   ^h,n he        a ^rr °' 5?° mg "- Thert-'tbre l°XICIty "°UW be 10Wer' A|S° the concentration m the
citluem ,» « ,ihm Ihe range seen as background nationally.  Kopp < 1964, found silver in 6.6". of 1 .577 surface waters sampled

u.th a mean detected concentration of 2.6 ug L (range: 0.1E 38 ug D. For 1 -TUB 1 979. according to U S  surface uiater

^.nplmg data .mm UFA'S STORE! database, the annual mean le>el> ranged from 1 to 9 u. L and annual max'mun
c,  Phospl«>roU> ,> .m e^ennal component of the annual hodv and eliminated as a concern at this lex el.  Excess phos

exacted ,n the unnc t\AS. I9.SO.  Th,s contaminant «,ll he eliminated as a concern based on this rationale   Ph0:>



f  Rjdnmuclidc IcieN acccpuble as dnnkmg water tor human receptors should he acceptable for ecolomcal receptors as

.1 hoc voni.iniin.inis u ill he eliminated Kised on this criterion                                         ^i-piors J>
                                                      "-2X

-------
Table 7-10.  Screening
^^^^                                               Ponds.
	 COPC
Al
As
Ba
Be
Cd
Cl
Cr
Co
Cu
Fe
Pb
Mn
Hg
Ni
Se
Ag
Tl
V
Zn
Cyanide
Fluoride
Nitrate
Nitrite
Phosphate
Sulfate
Sulfide
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Bis(2-ethylhexyl)phthalate
Chrysene
Huoramhene
Mothylene chloride
Phenanthrene
P^ rene

j |. |-|iucil, . .
i n» jr.. maximu
Liquid Effluent Sediment
ND{4E-02) v

1.04E-01
X
NDflE-03)
6.30E-02
X
6.30E-03
5.70E-02
ND(I.5E-02)
1 .60E-03
ND(2.5E-04)
4.50E-03
ND(1E-03)
ND(2E-03)
X
X
X
X
ND(5.4E-OI)
5.58E-00 '
ND(8E-0)
5.22E-00
,
X
X
X
X
X
X
X
X
X
X
X

m observed concemraiu.
*
X
5.00E-01
X
X
X
4.60E-00
V
*\
x
X
X
X
V
.\
X
X
2.10E-01
I.88E+OI
4.58E+OI
1.20E-01
X
V
A
x
x

X
1.57E-01
2.40E-OI
6.20E-01
3.50E-0!
4.40E-OI
2.50E-01
6.00E-OI
1.50E-00
1.10E-02
8JOE-01
9.30E-01
ns. ND = not deli

x
250
X
X
X
55

X
X
X
X
X
3.300
1,000
18
0.0000
X
X
.
X
0.0000
0.0000
0.0000
0.0000
0.0000
18.0000
0.0000
0.0000
0.0000
0.0000
100
eieJ. detec
Calculated
water Toxicological
x
X
3.3E-03
X
2.98E-1-02
X
8.33E-02
X
X
X
X
X
X
X
6.36E-05
1.88E-02
2.51E-K)0
5.63E-01
X
X
X
X
X
7.34E+01
1.I3E+00
2.91E+00
1 .64E+00
2.06E+00
I.37E-02
2.81E-00
' 7.03E+00
5.I6E-02
3.80Et-00
8.08E-00
ton limit is in oaren
ha*JCS^^^^ ! n * ''f" cx~.lhrilu^ Jnnk.ng *a,cr from Opresko et al. , | w<,
observed or • il ••' -d v ° Ct J '''r'1 tljljhasc lorc"nw'rvl"1 ••-•••••••" 	 	 	 '-

•.onceniraiinns :n the micnial iiieestkin
••• 1 he A. \ .ilue, are '\i%ej .MI a ci'inp.
Mi.mu.it \Mieiin.i.N \.ilue -,.i\ nl ihle
.1 1 1 hlllllMU- \H .;. :,,.„. .!„„ ,rl V
lion e coed*, the lo\i 'ol
fouio il exposure \-V
u[|on (-jx li( u . i •
TI i, nn^erv'iiiie.v ^
evtvoi!-, hv.VK-nni.irk
r . , ,
T 1. _ •
tlllL. fJUIpubtb. LO
2.45E+00
1.56E-I-OI
1.88E-00
2.3E-02
NA
9.36E-HK)
NA
4.7E-1-OI
NA
i.OIE-01
2.51E+02
9.1E-02
1.14E-f-02
9.6E-02
NA
2.1E-02
5.4E-01
3.04E-K)2
1.8E+02
7.48E+OI
I.9E-KJ3
NA
NA
NA
NA
NA
NA
1.27E-KX)
NA
l.OE+01
NA
NA
1.67E*OI
NA
NA

The lowest applicable
ncentralions are i>uen
E
E
E
E
NB
E
NB
E
NB
E
E
E
E
E
NB
1 "• I_>
E
E
E
E
E
E
NB
NB
NB
NB
NB
NB
X
NB
E
NB
NB
E
NB
NB

NOAHL
if the
fc\ ' r , ™rk ' nc rcsullini? 'inal concentrations are used as the uaicr
' * H J\ 
-------
Table 7-11.  Threatened and endangered species, special species of concern, and sensitive species that
mav be found on the INEEL.*
        Common Names
                     Scientific Name
                             Federal
                             Siaiush.c
             State
            Statusc
            BLM
           Statusc
            L'SFSf     ISPS
           Statusc    Statusc
 Plants
 l.emhi mi lk\ etch
 I'umiedmilkv etch-
 Plains niilk\ctch
 Winged-seed evening primrose
 Nipple cactus'"
 Spreading gilia
 King's bladdcrpod
 Tree-like oxuheca"
 Inconspicuous phucelia^
 Puzzling hahmolobos
 l,'te=s ladies tresses'"
 Birds
 Peregrine falcon
 Merlin
 Gyrlhlcon
 Bald eagle
 Ferruginous hawk
 Black tern
 Northern pygmy o«.la
 Burrowing owl
 Common loon
 American white pelican
 (Jrejtegrei
 \\ bite-faced ibis
 Long-billed curleu
 Loggerhead shrike
 Northern goshank
 Swjinson'i ha\vk
Trumpeter swan
Sharptailed grouse
 Boreal o\\ I
 1-lanmuilatcdiml
 MammaK
 \\olt
       rabbit
bijj-
                    u.'i t'craniii'iix var jpus
            Astragalus gilvilliirux
            Ctiiiii.\siinit] ptcnu-pcnna
            Cor\phaniha nn
                 pMX tCiiliiti pnlycladon
            Li.'Mjiii.'1'L'lla kingii iw ctihrcnxi.'i
            On t/ii-cn denJrnitica
            Phacclia incon.\f)icua
                     tH pcrplcxa \ur. pcrplcxa
            Falco pcivgrinux
            Falcii culumhariut
            Falco msticolus
            Haliaeetus leucocephalus
            Buteo regalis
            Chlidonias niger
            Glaiicitlium gnmna
           Athene cunicularia
            (javia immer
           Pi'licumis t'n ihrorhynchos
           Casincrodius alhuA
           Plegatlis chilli
           \umcnius amttricanus
           Lanius ludovicianu*
           Accipiler /•entiiis
           Buicn MI amount
           Cygnus buccinator
                 lti/>n\
 X

 NL
 NL
 NL
 NL
 X
 NL
 C2
 X
 LT

 LE
 NL
 NL
 LT
 C2
 C2
 X
C2
 X
X
X
C2

C2
C2
X
C2
Tuuniend'
carud but
                                        Hi (Sytvilagu*)
* (oirn\i'itdii
1.I-. XN
C2

C 2
 X
 X
 X
 X
 X
 X
 X
 X
 ssc
 X
 X

 E
 X
 ssc
 T
 SSC
 X
 ssc
 X
 ssc
 ssc
ssc
X
 X
 M.
s
X
ssc
X
ssc
ssc

 L:
ssc

ssc
 s
 X
 s
 X
 X
 s
 X
 R
 s
 X
 X

 X
 s
 s
 X
 s
 X
 \
 s
 X
 X
 X
 X
 s
 s
 X
s
s
s
s
 X

 X
s
  s
  X
  s
  X
  X
  X
  X
  X
  s
  s
  X

  X
  X
  X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 s
 X
 s
 s
 s
 s

 X
'x
                                                                    s
                                                                    R
                                                                    I
                                                                    S
                                                                    R
                                                                    T
                                                                    M
                                                                    R

                                                                    M
                                                                    X

-------
 Table 7-11.  (continued).
         Common Names
  Nferriam's shrew
  Long-eared myotis
  Small-footed myoeis
  Western pipistrel!ej
  Fringed myotisd
 California myot.sj
 Reptiles and Amphibians
 Northern sagebrush lizard
 Rtngneck snakej
 Night snake1'
 Insects
 Idaho potntheaded
grasshopper11
Fish
Shorthead sculpinj
                                            Scientific Name
                                   Son:* mcrrianu
                                   Myotis evotis
                                   Myotis subulatus
                                   Pipistrellus hespcna
                                   Myotis thysanodfs
                                   Myotis californicus

                                  Sceloporus graciosus
                                  Dtadophis ptiiictaius
                                  Hypsiglena torqttara

                                 Acrolopliiius punchellus


                                 Coitus confiuus
Federal
Siaiusb.c
X
C2
C2
NL
X
X
C2
C2
X
State
Statusc
— —
S
X
X
ssc
ssc
ssc
X
ssc
X
BLM
Statusc
X
X
X
X
X
X
X
S
R
L'SFSf
Statusc
X
X
X
X
X
X
X
X
X
/\PS
Siatusc









C2
                                                                    X
  T^l'laTc113re IhOSe T'E and Ca'e80r> 2 -LSFS»  (INPS 1^5:

-------
                                                                           in
    and, therefore, are not necessarily representam e of loci/
    underestimation of potential heal'th impacts.

    7.2.4    Risk Characterization

          As discussed in Section 28.4 of the
    is divided by the TRV to calculate a HQ
    at each site. Any contaminant with a HQ s,caicr inan me ,
    tor rad.onucl.de) was presented in the risk characterization
                                                             * '
                                                                                    at the 1N'EEL
                                                               Th'S "*y rCSult in °*«*'imai,on
                                                                                              or
                                           "    '
                                                            ,
                                                       §
                                                                       *"
                                                                  * ° H°S f
                                                                                          °-
                                                                 Have nonradio.og.ca,
includes CPP-13. -14 (Imhoff tanks,   rea I? T T?7a
-93. Old Storage Pool Group (CPP-01  -04  05  08  09  1 On  ^c    ' ~55' '^ ^ '84< '88- -90-
 for loggerhead shrike, peregrine facon and  e
 low overal, rating for bats wal g iv n at'cPP-l
 rating at site CPP-34.  Sites rated ov^alUs 4w" are
 therefore potential for incidental use by vi dl ?e  These  es
Significantly to chronic wildlife contaminant exposure? ™,
of WAG sites of concern in an ecoiogkal comext Th  H
                                                       °"

                                                          T
                                                             §
 adequate to verify presence or          0««     The r
 professional opinion supported by liml ^e7obse"at!on            "

 7.2.5    Additional Screening
                                                                             Overail site rati"g
                                                                 l° "^ CPP'34 3nd CPP-37a' A
                                                                 ^ als° 8iVe" & '°W °Veral1
                                                               °     P,°S"iVe a"ributes and
                                                                     dlSCOUnted as Contributing
                                                             W3S conduct^ to allow evaluation
                                                                ' °f *** surv^w™ "°t
                                                                        SUbJeCtive' based °"
 currently within the fenced area that
 the activities ^ocl^
 less than that modeled in the ERA  Addj ,'on- k  u  h '
 sources]) most of these sitesare ^axei anZn ui'tlhl
 any special attraction to
                                                           lhat
                                                            er- n^nv of the sites of concern are
                                                                the 'NTEC-  B°th the fence and
                                                               eXp°SUre of recePtors to niuch
                                                     eXC,eptlOns [particularly sites with water
                                                     "    ^^ ""^ a"d XV°U'd "Ot provide
ofcxtrapolaunu to multiple species  TRV
    e metals, ^.ch               ™
                                                                                      «o be
                                                                       e a"d ^ uncertainty
                                                                  This is particularly true for

-------
        Based on this rationale, an additional screening was determined appropriate for the WAG 3 sites as
  agreed on in an October 20, 1997 conference call between DOE-iD, EPA. and 1DHW.

        This screening was composed of two steps:

        1.     As a risk management decision, it was decided to eliminate ecological contaminants as a
              concern if the exposure point concentration was less than 1 Ox the background value
              (Roodetal.  1995). For those contaminants that have no site-specific background the mean
              for the western United States presented in Shacklette and Boemgen (1984) or other sources
             was considered acceptable.

       2.    For those sites that initially used the maximum values, if possible, the 95% UCLs were
             calculated (see Table 7-12) for each contaminant that was not eliminated in the HQ
             evaluation of the ERA.  This value was also eliminated if the 95% UCL was less than the
              I Ox background.

       This screening resulted in eliminating Sites CPP-37A, -39, -40, -42, -84, -88, and -90 as sites of
 concern. The sites and COCs remaining after the screening are listed in Table 7-13. Four sites pose
 solely an ecological risk, CPP-14 (the imhoff Tank), CPP-44, -55, and -66.

       Because Sites CPP-14, -44, and -55 presented an unacceptable risk for ecological receptors only
 these sites were added to the Other Surface Soils Sites (Group 3) for alternative evaluation. The
 ecological risk screening approach resulted in establishing conservative risk assumptions  Actions
 undertaken at sites CPP-44, -14, and -55 are based on the small volume of COC contaminated material
 and the cost benefit of action now rather than further study. Final assessment  for site CPP-66 will be
 conducted under OU  10-04.  For sites that pose a potential threat to both human and ecological receptors
 it is assumed that remedial alternatives developed to address human health risks will also be designed to '
 adequately address ecological concerns. This WAG ERA represents the second phase of the three-phased
 approach to ERA.  The first phase is the "preassessment" performed at the WAG level. This screen is
 performed to reduce the number of sites and  contaminants to be addressed in subsequent assessments
 This screen for WAG  3 is presented in Section 28 of the RI/BRA (DOE-ID 1997b).

      In phase two, the WAG sites and COCs identified by the initial screening are assessed for potential
 risks to ecological receptors using an approach that parallels the human health  risk assessment
 methodology.

      The third phase of the ERA process is  the OU 10-04 (INEEL Site-wide) ERA, which is performed
 to integrate the results of the WAG ERAs to evaluate risk to OU 10-04 ecological resources The
 OU  10-04 ERA will integrate the results of the WAG ERAs for all INEEL WAGs to determine whether
 contamination at the WAGs contributes to potential risk to populations and communities on an
 ecosystem-wide basis. Those sites previously screened at the WAG level based on either lOx background
 or lOx HQ will be reevaluated at a population level at this time. If the OU 10-04 ERA determines That
 those WAG 3 sites screened at less than lOx background or HW less than 10. require further action that
action will be determined during the WAG 3  5-year reviews.

                              7.3    Basis for Response

     Forty-nine sites  within  WAG 3 have actual or threatened releases of hazardous substances that if
not addressed by implementing the response actions selected in this ROD. may pose unacceptable risks to
human health or the environment. For analysis of remedial alternatives, release sites were combined into

-------
Table 7-12. Results of additional .site.-coniaminant evaluation and screenim
Site
CPP-I3
CPP-I4
Area 1
Area 2


CPP-19
CPP-34
CPP-37A
CPP-39

CPP-40
CPP-42
CPP-44





CPP-53




CPP.()f>

CI'P-Xs

CPP-90

I'l'P-'J?

DM
Mi»r.it!o
COC
Arsenic
Mercury

<'hromium III
Lead
Mercury

Silver
Arsenic
Arsenic
Mercury-
Mercury
Barium
Di-2-ethv Ihexy Iphthalate
Fluoride
Mercury
Silver
Chromium III
Fluoride
Lead
Barium
Cadmium
Chromium III
Chromium VI
Decano)
Lead
Mercurv
Nickel "
Arsenic
Chromium III
Chromium VI
1 J
Lead
Mercurv
Nickel '
Selenium
Silver

Boron
Fluoride
Selenium
Siromium
Arsenic
Mercur>
Nickel
\niimonv
\ricmc
Mercurv
Mumimim
Mercurv
\riCIUC
Mereiirv
Maximum
Concentration
•S.30E-00
5.95E-OI '

5.I2E-01
3.56E-OI
1 .20E---00

I.22E-OI
6.30E-00
7.IOE-00
6.00E-01
9.60E-OI
UOE-03
1.40E-OI
9.29E-02
1 70E-OI
1 S^E-01
'.20E-OI
UOE-M)!
6.00E-OI
UOE-03
8.40E-00
I.54E-03
1.54E+OI
9.00E-03
2.81E-02
5.00E-00
3. 44 E -02
I.34E-OI
6.50E-OI
6.50E-01
3,20ET01
5.20E+00
6.50E-OI
6.40E-OI
300E-00

3.10E-02
I.65E-02
I.60E-00
6.90E-02
~ IOE-00
I.OOE-00
1.63E-02
9.50E-00
2.95E-01
1 MOE-flO
1 201: -i)5
I.4nl:-ij2
5 >)n|: -nn
5 5:i:.-nl
IOX
1'5",, I'CL Backs-round
5.80E-0!
4.'OE-OI 5.00E.OI

5.80E-01
1.70E-02
5.00E-01

3.7E-01
5.80E-OOI
5.80E-01
2.80E-01 5.00E-OI
4.40E-OI 5.00E-OI
3.00E-03
2.80E~03J
5.00E-OI
3.7E-01
3.30E-02
2.80E-03J
1 .70E-02
3.00E+03
' 3.30E-02
NA
NA
1.70E+02
5.00E-01
3.50E-02
5.80E-01
3.30E-02
8.70E-00 NA
I.70E-02
6JOE-01 5.00E-OI
3.50E-02
2.20E-00
3.7E-OI

2.30E-02
2.80E-03a
2.20E-00
2.00E-03J
5.80E-01
3.00E-01 5.00E-01
3.50E-02
4.80E-01
5.SOE-01
4.5"I:-OI 5.00E:-OI
1.NJH-05
ii Mil: -HI 5.00F.-OI
5 Mlt:-lJ|
2.2"li-ul 5,iKiF:-n|
	 	 Elimination Rationale 	
Below IOX background
95" n L'CL beiow"i OX background

Below IOX background
Below IOX background
Sample was taken at approximately 9
ft bgs
Below IOX background
Below IOX background
Below IOX background
95% L'CL belowr!OX background
95% UCL below IOX background
Below 10X Background
Contaminant below 1 5 ft
Below IOX background
Below IOX background
Below IOX background
Below IOX background
Below IOX background
Below IOX background
Below IOX background
Below 10 X background
Retain
Retain
Retain
Retain
Retain
Below I OX background
Below IOX background
Below 1 OX background
Not expected to exist as Chromium
VI in the environment
Below IOX background
Retain
Below 1 OX background
Below 1 OX background
Below IOX background •
Retain
Below IOX background
Below IOX background
Below IOX background
Below IOX background
95% UCL below IOX background
Below IOX background
Below 1 OX background
Below IOX background
95% UCL below IOX background
Below IOX background
Retain
Below luX background
95% I'd. helovv~10X backuroumi

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 Table 7-12.  (continued).
Site

Storage
Yard"
Tank Farm
Tank Farm
WCF


coc
Nickel
Arsenic
Mercury
Nickel '
Mercury
Arsenic
Cadmium
Mercury
Nickel "
Arsenic
Mercury
Nickel

Ma.ximum
Concentration
y.-IE-OI-
5.90E-00
5.52E-01
5.5IE-OI
2.30E-OI
5.90E-00
3.42E-H30
I.51E-00
5.51E-01
7.50E-00
2.80E-02

IOX
95",, L'CL Backerounc
3.50E-02
5.80E-01
3.30E-01 5.00E-01
3.50E-02
5.00E-OI
5.80E-01
2.60E-01 5.00E-OI
3.50E-02
5.80E-01
1.50E-00 5.00E-01
3.50E-02
	 Elimination Rationale
Below IOX background
Below 1 OX background
95% UCL below IOX background
Below IOX background
Below IOX background
Below IOX background
Below IOX background
95% L'CL below"] OX background
Below IOX background
Below I OX background
Retain
Below IOX background
J. Background from Shackleue and Boemgen II9S4).

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   Table 7-13. Sites and COCs which mav
                     ""  —               -• —
                           N'onradionuclides
present an unacceptable risk to ecological receptors.
          Radionuclide
 CPP-13
 CPP-14
 (ImholT Tanks)
 Area I
 CPP-19


CPP-34

CPP-44
  CPP-55

  CPP-66

  CPP-67



 CPP-93
 Old Storage Pool
 (CPP-01.-04.-05.
 •08.-09.-10.-II.
 -88)

 Tank Farm
 fCPP-20. -25. -26.
 •28.-3I.-32E W.
 -79. excavated
 soil)

 Tank Farm South
(CPP-I5.-27.-33.
-58. -88)
                       Mercury

                       Mercury
                       Chromium III.
                       Chromium VI. Lead.
                       mercury

                       Chromium VI
                      Boron
                      Metals and organics
                      Mercurv
  (CPP-35. -36. -X5.
  -S8. -91)
                     Mercury
     Sr-l>0
                                               Cs-137. Eu-I52. Eu-154.
                                               Sr-90, Co-60
                                               Sr-90
   Am-241. Np-237.
   Pu-238-239. U-234.and
   U-238
                                             Cs-137, Eu-152. Eu-154.
                                             Co-60. and Sr-90
                                             Am-137. Cs-137. Eu-154.
                                             Pu-239. and Sr-90
                                             Cs-137
  Am-241. Cs-134. and Cs-
  137
                                                                                   Comments
                                                                         Solely an ecological concern.
                                                                         Approximately 105 nr of soil.
                                                                    Solely an ecological concern.
                                                                    Approximately 88 nr of soil.


                                                                    Solely an ecological concern.
                                                                    Approximately 325.5 nr of soil.

                                                                    Solely an ecological concern.
                                                                    Approximately 79,800 m3 of soil.

                                                                    This site will be remediated based
                                                                    on the HHRA, an assessment
                                                                    beyond the screening level was
                                                                    not deemed necessary.
       he SRpfg ?R    T; S°r\ S°iIS Lnder BU"dinSS and StrUCtUr"' ^er Surface Soils. Perched
        r.               'ed GaS Cylmder Sites' Indiv idual sites include «he SFE-20 Hot Waste Tank
b > em. The response act.ons selected in this ROD are designed to reduce the potential threat"  o human
health and or the em ironment to acceptable lex els.

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                      8.   REMEDIAL ACTION OBJECTIVES


 «*c!!rS£S
 pathways, and remediat.on goals. Remediation goals establish acceptable exposuretveL that are



 Agencies (1UHW, EPA. and DOE). The RAOs are primarily based on the results of the baseline ri«fc-
 assessment and applicable or relevant and appropriate requirements (ARARs)
 remedvT?orChieKe * reaS°fnable de§ree ^ Protection at the WAG 3 sites, the Agencies have selected
 remedy tor each group of sites that meet the RAOs. These remedies protect human health and the
 environment and meet regulatory requirements. The WAG 3 RAOs were d veloped f ^^ spec, fie

                                     The applicable *** for a
                    d*le]°pSd f°r ecol°8ical receptors, based on a screening-level ERA For release
                    :s^^^
developed for S,,es ,ha, solely pose a Uuea, ,o ecological receptors For ecoTogical recep,* te

            lTfEnnpdlity Wl11 bC USCd aS a" industrial facility "P to the year 2095.  During the
          period of DOE operates, expected to last to at least 2045, this area is a radiological control




          Only the contaminated groundwater present in the SRPA outside of the current INTEC

          security fence ,s addressed in this ROD. The selected remedy is expected to fully address

          h , coniammanon. However, this action does not address groundwater inside the cuS
          INTEC security fence, which will be addressed under OU 3-14.
    J-    r^LS! time Per'od 2095^d bey°nd- ^ is assumed that the SRPA located outside the current
          INTEC security fence will be used as a drinking water supply.
    5.
JlevZn31 Ca^cin^enic;iskia' INTEC from natural background radiation due to surface

UNEP°985      gr°    S°  radlol°2ical contamination is 10"1 (EPA 1994, NEA 1997.



Permanent land use restrictions will be placed on those release site source areas and the

 CDF complex  *h,ch u ill be closed in place, for as long as land use and access restrictions
are required to be protective of human health and the environment
                                         X-l

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The human health RAOs developed for soils and groundwater at OU 3-13 include:

  1.    Groundwater

        a.    For INTEC-impacted groundwater (located in the groundwater contaminant plume
              outside of the current INTEC security fence) restore the aquifer for use by 2095
              and beyond, so that the risk will not exceed a cumulative carcinogenic risk of
              1  x 10"1  for groundwater ingestion.                                     .

        b.    For INTEC-impacted groundwater (located in the groundwater contaminant plume
              outside of the current INTEC security fence) restore the aquifer to drinking water
              quality (below MCLs) for use by 2095 and beyond.

        c.     For INTEC-impacted groundwater (located in the groundwater contaminant plume
              outside of the  current INTEC security fence) restore the aquifer to so that the non-
              carcinogenic risk will not exceed a total  HI of 1  for groundwater ingestion.

        d.     For INTEC-impacted groundwater (located in the groundwater contaminant plume
              outside of the current INTEC security fence), prevent groundwater consumption by
              the public until Objectives a, b, and c, listed above, are met.

        e.     Maintain caps  placed over contaminated soil or debris areas that are contained in
              place and the closed ICDF-complex, to prevent the release of leachate to
              underlying groundwater which would result in exceeding a cumulative
             carcinogenic risk of I x 10'4, a total HI of 1; or applicable State of Idaho
             groundwater quality standards (i.e., MCLs) in the SRPA.
      Surface Soils

       a.
Prevent exposure to contaminated surface soils at each release site such that for all
surface exposure pathways, a cumulative carcinogenic risk of ! x 10'4 and a total
HI of 1 is not exceeded at each release site.  These RAOs also address "No Further
Action" Sites where the current radiological contaminant levels will meet
residential risk-based concentration on or before year 2095. The RAOs will be
achieved as follows:

(I)    DOE Operational Phase,  expected until year 2045:

      (a)    Implement Institutional Controls to limit  access and exposure
            duration at each source area to achieve a cumulative carcinogenic risk
            of 1 x  IO"1 and a total HI of 1.

      (b)    Remove contaminated soil at each source area, sufficient to achieve a
            cumulative carcinogenic risk of I x 10'4 and a total HI of 1 to a future
            residential user: or cap in place contaminated soil or debris areas
            presenting a cumulative carcinogenic risk of 1 x 10"4 and a total
            HI of I.

 (2)   Go\ernment Control Phase:  expected between year 2045 and 2095

       (a)    Implement Institutional Controls to limit the duration and frequenc>
             of exposure to non-cupped contaminated .soil areas by the public to

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                         achieve a cumulative carcinogenic risk of 1 x i Q'4 and a total
                         HI of 1.

                    (b)   Maintain caps for contaminated soil areas which are contained in
                         place, to prevent exposure of the public to a cumulative
                         carcinogenic risk of i x ] 0'4 and a total HI of 1.

                    (O   Maintain the closed and capped ICDF complex to prevent exposure
                         oMhe public to a cumulative carcinogenic risk of I x 10'4 and a total


              (3)   »^^^*;s^^t^£:r
                   .cumulative carcinogenic risk of 1 x 10'4 and a total HI of 1.
3.    Perched Water
a.
           •Prevent migration of radionuclides from perched water in concentrations thar
            would cause SRPA groundwater outside ihe current INTEC ^7"^ f^  to

            S  ra,HCTU'atiVe,CarCin08eniC Hsk °f '  X 10"  a total HI of I : or applicable
            State of Idaho groundwater quality standards (i.e., MCLs) in 2095 and beyond
                                    drilling through the contaminated earth materials
                                    :on of the perched water to prevent exposure of the
                              carcmogemc risk of 1 x 10'4, a total HI of 1; and protection
                         neet Objective 3a listed above.

                         (INTEC-derived groundwater contaminant plume outside current


           CDDA      j      .          "    Corkers and general public from ingesting
           SRPA groundwater that exceeds a cumulative carcinogenic risk of 1 x 10* • a total
           HI of 1; or applicable State of Idaho groundwater quality standards (i.e., MCLs)

     b.    In 2095 and beyond ensure that SRPA groundwater does not exceed a cumulative
           carcinogenic risk of 1 x KT4; a total Hf of 1; or apphcable State of Idaho
           groundwater quality standards (i.e.. MCLs).

  Other Areas


     a.     For other source areas that either pose a safety hazard, a threat of release to
           groundwater. or an ecological hazard, the RAOs include:

                                        posed by buried compressed ga
                 Wa"te            °freleaSe IO the SRPA Posed by the SFE-20 Hot
           ( 3 )    Pre% ent ecological receptor exposure to surface soil COCs with a
                 concentration greater than 10 times background concentrations that may
                 cause adverse effects to resident populations of flora or fauna as
                 determined h\ the screening level ERA.

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                                8.1    Remediation Goals

   b^°-'oi, radiological coma^a^s
           Risk-based soi, concen,ra,L co^pld™ H??*'' a"d ««« "»*« and
  COCs are presented ,n Table 8- 1. If more , ban one 00^        nsk o™ HI of .I for individual soil
            C°"CemraIi°"s ""I ^ modified so ,ta .hclul^T" ",' .Pa'tiC'"a: releKC site- "«'
 Table 8-1.  Soil
     Contaminant
 Radionuclides
    Am-24l
    Cs-I37
    Eu-152
   Eu-154
   Pu-238
   Pu-239240
   Pu-2-Jl
   Sr-90
Nonradionuclides6
 -Mercury (human health)
 Soil Risk-Based
Remediation Goal3
For Single COCs"
       290
        23
       270
     5200
      670
      250
   56.000
      223
                                                                    23
                                        X-4

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                                 11 Soals that correspond to the concentration- or activity-based soil
               n    sou

    Dfied in  0 CFR 83502 T      ^ ^^ "^ DOE-workers- the occupational dose limit is

   eaua to 5 rem , A M I  >  P       '"""'I °CCUPatlonal dose limit « a total effective dose equ.valent

   aS, J, T Th   I  ')- F°r "P°sure of the Senera! Public prior to the Year 2095, land use is projected

   for ±     ,     a/TC rerTd?°n goals combined with institutional controls are considered p'rSve
   for mdustnai use of the area by the general public prior to the Year 2095.                    p««ecuve



        Nonradionuclide remediation goals for mercury, lead, and chromium were also estimated for

  ecological receptors. The ecological receptor remediation goals estimated for these consSts aVe o 5


                              *"
  ud bec                                                                         gs «
  used because of the small volume of the sites and the cost effectiveness of taking remedial act, on versus

  addmonal study to refine the estimate. An evaluation of whether additional soil excavation is


                                                                                  "
  comrpleetedeCOl0gICal '~~pl"'° "'" uc tu"uut;ica a»er me WAU  iu plant uptake treatability study is
                   cge°are tesedln^hl?'^ C°CS PreSCnt'" ^ SR?A groundwater outside the cu^nt
  /FDA PA i Am "mi ->nn\  T-i.  r-r,^. -^^-.        state of Idaho groundwater quality standards
  UUAFA 16.01.011.200).  The SRPA COCs consist of tritium, Sr-90 and daughters, 1-129 Np-237


  heTrTure"* T1117 Pri°r %n°o9<5 ^ Sr-9°' M29< NP'237< P'^onmm and uranium isotopes and
  ineir uaugnters. and mercurv tn /oo^ anH K»»«/<-.n^  TU« cr>r>»       i           .           v   »••«»»

  COCs are presented in Tabk 8-2           y             * gr°Undwater remed.ation goals for these




                      goal for INTEC-derived alpha-emitting radionuclides (i.e., Np-237, Pu is
 cu   ntTEC             '                                         gtounvude
 current INTEC security fence corresponds to a cumulative alpha-activity of 1 5 PCi/L in the year 2095 and

 beyond  Modelmg has shown that alpha-emitting radionuclides are not expected * «SS ^ ^pCi/r

 standard ,n the SRPA inside the current INTEC security fence until the year 2750 with a ^
      '  Remediatio"' * necessary. of   Tank Fa™ insde the current

' tO       * lhe
                        .NTPr                      alpha-emi«ing radionuclide impacts in the
    uLd    /,                    '            tl°n g°als f°r Chromium and mercu±
    ug, L and 2 ug/L. respectively, for individual constituent VICLs.



8.1.1    Tank Farm Soils Interim Action (Group 1)
nn,  r Tn ^^ ^ 3t ** Tank Farm Soils rdease sites are extemal exposure to radiation and

uo    b  nrSFnamtrasTrt °f CO"taminantS tO lhe Perc^d -ter or the SR'PA.  The rendition
goals ror the I ank Farm Soils interim action are:
      I -     Preventing intrusion into soil contaminants by the general public




      2'    tRheds"te  PreCipitati°n inflltratio" b>- approximately K0»o of the average annual'precipitation at




      3.    Maximize run-off and minimize surface ^ ator ponding on the Tank Farm
                                             X-5

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       4.    Prevent surface water run-on from a I in 25 vear. 24 hour storm event
       5.     Minimize infiltration and subsequent contaminant leaching due to external building drainage
             and run-on.

       These remediation goals support groundwater RAOs la through Id; surface soil RAO 2A(1 )(a)
 perched water RAO 3a. and SRPA RAO 4b.

 8.1.2    Soils Under Buildings and Structures (Group 2)

       The primary threat posed by Soils Under Buildings and Structures sites is external exposure to
 radionuclides and possible leaching and transport of soil contaminants to the perched water or SRPA.
 The selected alternative for Group 2 is a deferred action. It is assumed that the present buildings or
 structures aid in limiting external  exposure and infiltration directly over the contaminated soils.

       Remediation goals were developed for the Soils Under Buildings and Structures for the pre-D&D
 and post-D&D time periods.  The remediation goals for the pre-D&D time period are to prevent exposure
 to current workers and non-workers and to minimize possible leaching and transport of contaminants to
 underlying SRPA groundwater. The remediation goals for the post-D&D time period are to prevent
 exposure to future workers and residents and to minimize possible leaching and transport of contaminants
 to underlying SRPA groundwater.

Table 8-2. SRPA remediation goals.
 Contaminant of Concern
           SRPA Remediation Goals
       (Maximum Contaminant Levels)
              For Single COCsa
                                                                                 Decay Type
 Beta-gamma emitting radionuclides


 Sr-90 and daughters
 Tritium
 I-129
 Alpha-emitting radionuclides

 Uranium and daughters
 Np-237 and daughters
 Plutonium and daughters
 Am-241and daughters
 Nonradionuclides
 Chromium
 Mercurv
J   If multiple contaminants are present. u.se a
h,   Pernod concentration il'onK beui-uamma
  Total of beta-gamma emitting radionuclides   Beta-Gamma
  shall not exceed 4 mrem/yr effective dose
  equivalent
  8pCi/L                                   Beta
  20,000 pCi/L                              Beta
  1  Pd'-Lh                                   Beta-Gamma
  I5pCi/L                                   Alpha
  total alpha emitting radionuclides
  l5pCi-'L                                   Alpha
  15pCi.'L                                   Alpha
  15pCiL                                   Alpha
  15pCiL                                   Alpha


  100(.tg. L                                  Not applicable
  -  l-ig L                                     Not applicable
sum ol the fractions to determine the combined COC's remediation goals.
radionuchdc present.	

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        These remediation goals will be accomplished by the following:

        1.    Pre-D&D

              a.     Warning current building or structure users that contaminated soils lie beneath the
                    basement floor.  Maintaining the buildings or structures to minimize moisture
                    infiltration and to prevent unacceptable exposure to current industrial users.

             b.     Minimizing surface water run-on and precipitation infiltration adjacent to the
                    buildings or structures by modifying drainage patterns around buildings and
                    performing surface modifications as necessary to minimize leaching and transport of
                    soil contaminants to underlying SRPA groundwater.

        2.    Post-D&D

             a.     Implementing the institutional controls described in Table 11 -1.

             b.     Capping the contaminated areas with an engineered barrier in accordance with the
                   substantive requirements of the hazardous waste landfill closure standards
                   (IDAPA 16.01.05.008 [40 CFR 264.310]).

             c.     Excavating the contaminated soils that exceed the soil remediation goals listed in
                   Table 8-1 and subsequent disposal and management in the ICDF.
•
 water                                          *"* " '""^ * ""*" ""
 8.1.3    Other Surface Soils (Group 3)

       The primary threat posed by the Other Surface Soils is external exposure to contaminated soils
 The remediation .goal for the Other Surface Soils is to prevent external exposure to current workers and
 non-workers and future workers and residents. This  remediation goal will be accomplished by:

       I .    Implementing the institutional controls described in Table ll-l .

       2.    Minimizing future residental exposure to surface soils in 2095 and beyond by excavating the
            contaminated soils exceeding the remediation goals in Table 8- 1, to a minimum depth of 3m
            { 10 ft) and subsequent disposal and management of the excavated soils in the ICDF.

       3.    Capping the contaminated areas that are not excavated with an engineered barrier in
            accordance with the substantive requirements of the hazardous waste landfill closure
            standards (IDAPA 1 6.0 1. 05.008 [40 CFR 264.3 10]).

      The remediation goal supports surface soil RAO 2a.

8. 131    INEEL CERCLA Disposal Facility (ICDF) Goals and Requirements. Contaminated
soi s from the Group 3 sites will be disposed and managed in the ICDF. The primary threats posed bv
soils and debris disposed and  managed in the ICDF are external exposure to radiation and the release of
 eachate to underlying grounduater that could potentially impact the SRPA. The remediation *oal for the
It. Ur is to consolidate contaminated soils at a single location to prevent exposure of human and

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ecological receptors.  This remediation goal will be accomplished by siting designing, operating and
closing the ICDF to prevent exposures or leachate releases to the underlying SRPA uroundwater. The
siting, design, operation, closure, and post-closure requirements necessary to accomplish these
remediation goals include:

      Siting Requirements—The ICDF will  meet or exceed RCRA Subtitle C location standards
specified in IDAPA 16.01.05.008 (40 CFR 264.18).

     Design Requirements—The ICDF design will:

      1.    Meet or exceed RCRA Subtitle C design standards specified in I DAP A 16.01.05 008
           (40 CFR  264.301 and 40 CFR 264.302) and the PCB Chemical Waste Landfill design
           requirements 40 CFR 761.75.

     2.    Minimize precipitation run-on and maximize precipitation run-off to effectively reduce
           infiltration through the contaminated soils and debris.

     3.    Minimize subsidence of the waste and the landfill cap.

     4.    Ensure that the resulting design is protective of human and ecological receptors.

     5.     Ensure that the resulting design is protective of the SRPA.

     Operational Requirements—The ICDF operation will:

     I.     Limit disposed wastes to those generated by the INEEL CERCLA program.

     2.     Limit disposed wastes to those with  contaminant concentrations that will not result in MCLs
           being exceeded in the SRPA.

     3.     Limit disposed wastes to low level radioactive waste. PCB solids, hazardous, and mixed low
           level radioactive waste.

     4.     Treat waste (soils, debris, and treatment residues) on-Site as necessary to meet
           Agency-approved Waste Acceptance Criteria developed during the RD.

     5.    Treat waste (soils, debris, and treatment residues) originating from outside the WAG 3 AOC
          to comply with the land disposal requirements specified in IDAPA 1601 05 01 1
          (40 CFR 268 and 40 CFR 268.49) as applicable.

     6.    Minimize leachate generation.  Leachate will be collected and treated using
          physical.'chemical treatment (i.e.. evaporation  in a surface impoundment designed in
          accordance with the substantive requirements of the hazardous waste surfacelmpoundments
          (IDAPA 16.01.05.008 [40 CFR 264.221 ]). Residues from the evaporation process will be
          managed in the ICDF as necessary durin« the active life and post-closure period of the ICDF
          cells.
                                           s-s

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        Closure and Post-Closure Requirements—The ICDF closure and post-closure will:

        1.     Meet or exceed RCRA Subtitle C closure and post-closure care requirements specified in
              IDAPA 16.01.05.008 (40 CFR264.310).

        2.     Ensure that the final cover is designed to serve as an intrusion barrier for a period of at least
              1,000 years.

        3.     Minimize subsidence of the landfill and its final cover.

        4.     Place easily located permanent markers at all corner boundaries for each cell of the landfill
              that identify the potential exposure hazards.

        5.     Place permanent land use restrictions, zoning restrictions, and deed restrictions on the ICDF
              and its adjacent buffer zone to permanently preclude industrial or residential development
              until unacceptable risk no longer remains at the site.

       6.     Include the disposal records and the surveyed permanent marker locations in the land use
             restriction  documents.


          mdrSRpdiati0n 8°alS SUPPOIt groundwater RAOs  Ia through Ie, surface soil RAOs 2a(l )(a) and

 8.1.4    Perched Water (Group 4)

       The primary threat posed by perched water is migration of contaminants  to the SRPA The perched
 water remediation goals are to:                                                            pcitiicu

       I.    Reduce recharge to the perched zones

      2.    Minimize migration of contaminants to the SRPA, so that SRPA groundwater outside of the
            current INTEC security fence meets the applicable State of Idaho groundwater standards
            by 2095.

      The remediation goals for the perched water are primarily designed to reduce the moisture content
of the perched zone so that the contaminant transport rate in the vadose zone is reduced and radionuclide
contaminants present in the perched zone have more time to naturally decay and reduce the concentration
ot potential contaminants released to the SRPA.

      The perched water remediation goals will be accomplished by:

      I -     Limiting recharge to the perched zone by closing and relocating the existing percolation
            ponds, and ceasing lawn irrigation, where necessary, at the INTEC  so that the moisture
            content is sufficiently reduced to retard Sr-90 migration by approximately three (3) half-lives
            (about 90 years).

      If the moisture content and contaminant flux is not sufficiently reduced as indicated by moisture
content and perched water monitoring and verified by the OU 3-13 vadose zone model, then additional
mhltrat.on controls uill be implemented to achieve the necessarv desaturation. and corresponding
                                             S-9

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  reduction in contaminant transport rate, in the perched zone. The additional infiltration controls that will
  be implemented (in the listed order) include:

        1.    Lining the Big Lost River

        2.    Closing and relocating the existing Sewage Treatment Plant lagoons and infiltrat.on galleries

        3.    Upgrading the INTEC-wide drainage controls, repairing leaking fire water lines  and
             eliminating steam condensate discharges.
       7"cDSp AeS\e^a!L0n g°alS SUPPOrt Sroundwater RA°s I a through 1 c. perched water RAOs 3a and
 ^
 ->D, and

 8.1.5    Snake River Plain Aquifer (Group 5)
    ,  /h!PrJnnry thrCat P°Sed by SRPA is in£estion of contaminated groundwater. The remediation
 goals tor the SRPA outside the current INTEC security fence are to:

       I .     Preventing current on-site workers and non-workers during the institutional control period
             from ingesting contaminated drinking water above the applicable State of Idaho eroundwater
                           -                                                        "      '
            standards or risk-based groundwater concentrations.
            Achieving the applicable State of Idaho groundwater standards or risk-based groundwater
            concentrations in the SRPA plume, south of the INTEC security fence by the year 2095.

                predicts that the Applicable State of Idaho groundwater standards will be naturally
of heistin  ne T?" *"" ^ *' ' ?' '  "' P'Ut°niUm iSOtOpeS'  Modelin« ais° Predicts val
ol the existing percolation ponds (the principal component of the selected Perched Water remedy) will
reduce the moisture content so that the individual Sr-90 MCL is achieved by 2095.

       Modeling also has shown that plutonium, an alpha-emitting radionuclide, is not expected to exceed
 lu is pC.,L .alpha-emitting radionuclide standard in the SRPA inside of the current INTEC security
fence until the year 2750. with a peak concentration occurring in the year 3804.  Remediation if   '
necessary, of the SRPA inside the current INTEC security fence will mitigate the future plutonium
impacts m the SRPA outside the current INTEC security fence. The remedy for the  SRPA inside  the
current INTEC security fence is being developed under OU 3-14. Therefore, a decision on plutonium
remediation goals is deferred to the OU 3- 1 4 ROD.
The SRPA remediation goals will be accomplished by:

I.
            Maintaining institutional controls over the area of the INTEC-derived SRPA contaminant
            plume outside of the current INTEC security fence to prevent exposure to contaminated
            groundwater during the time that groundwater in the aquifer remains above the remediation
            goals specified in Table 8-2.

            Determining if grounduater quality outside the current INTEC security fence will be
            restored by 2095 and beyond.  If the modeled action levels for COCs are exceeded a
            contingent pumping and treatment action uill be implemented to remove sufficient
            contaminant source to facilitate aquifer restoration by 20l)5.

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        These remediation goals support groundwater RAOs la through le, and SRPA RAOs 4a and 4b.

  8.1.6    Buried Gas Cylinders (Group 6)

        The principal threat posed by the buried gas cylinders is a safety hazard, including chemical
  exposure fire explosion, and projectile hazards. The remediation goal for the buried gas cylinders is to
  remedy the safety hazard posed by the disposed cylinders.                            tyiinaers is to

        The remediation goal will be accomplished by:

        I.  Excavating, removing, treating, and disposing the cylinders (waste that meets the ICDF WAC
           will be disposed in the ICDF).

        The Agencies may elect to pursue a contingent remedy of capping in place pursuant to the
  substannve requirements of IDAPA I6.0l.05.008 (40 CFR 264.310) if safety concerns with excavation
  and removal prevent implementation of the selected remedy.

       The remediation goal supports Other Areas RAO 5a.

  8.1.7    SFE—20 Hot Waste Tank System (Group 7)

       The principal threats posed by the SFE-20 Tank system is external exposure and the potential for a
 STs-          * t0    envir°nment- The ^mediation goals for the SFE-20 tank system are as


       I.    Limit potential external exposures to workers and non-workers

       2.    Remove radioactive and hazardous substances remaining in the tank system to prevent
            potential contaminant releases to the underlying soils or groundwater.

       The remediation goals will be accomplished by:

       I -    Maintaining existing institutional controls to prevent current worker and non-worker
            exposure.

      2.    Removing, excavating,  treating, and disposing the SFE-20 hot waste tank system waste and
            components to eliminate the threat  of release to the environment (waste that meets the ICDF
            WAC will be disposed in the ICDF).

      3.    Remediating contaminated soils present beneath the SFE-20 tank system that may pose an
            external exposure risk or threat to groundwater (waste that meets the fCDF WAC will be
            disposed in the ICDF).

      These remediation goals support Other Areas RAO 5a and also support groundwater RAOs 1 a
throuah le.

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(

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                        9   DESCRIPTION OF ALTERNATIVES

   crterareachofrh     a'ter"atl'VeS.was devel°Ped ™<* evaluated against the nine CERCLA evaluation
   renr,    ,       s       ^^ Sl* ^^ The altema^es were developed from a list of
   ep esentauve remed.ation technologies for technical and cost evaluation purposes.  With he exception of
   the  No Act.on  altemat.ve. the selected remedies are protective of ecological concern   The !

      °n
         T ea           df °  Tan  eat and ^ -™    <* the  nstuaUontro,
         i  altematlve/uevaluated for each group are summarized in the following sections  For more
  DOE  D  lIST   f e;'^ated 3lternatiVeS refcr f° the OU 3'13 FS and pSS (DOE-ID I997a
  fhould be  r H rh  HrC      d deSCnPtions of the selec«* alternatives are found in Section 1 1   if*
  what activls co       * ^^^ °f "" "** eStimaKS f°r the FS" ^sumptions were made regarding
  mafntenan ef ?hTfT eXIStl7 mSt'tUtl°"al COntrols - °r ""<" a ^ — dy decision ^ by

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  9.1.1.2 Alternative 2—Enhanced Institutional Controls. Alternative 2 consists of the existing
  institutional controls described for Alternative I and additional monitorinu and institutional controls "
  This additional monitoring and controls include the installation of new clustered monitoring wells in the
  perched water and aquifer to enhance the existing groundwater monitoring capabilities during the interim
  action period and to verify hydraulic parameters and water quality. They also include additional warning
  .signs, surface and subsurface markers, and land use restrictions to prevent exposures to contaminated
  groundwater.

  9.1.1.3 Alternative 3—Enhanced Institutional Controls with Surface Water Control.
  Alternative 3 includes the existing and additional institutional controls described for Alternative'^' and an
  interim remedy to control surface water runon and infiltration at the Tank Farm.  The interim remedv
  includes surface grading and sealing of the Tank Farm soils to divert 80% of the average annual    '
  precipitation away from the contaminated areas, and exterior building drainage improvements to direct
  water away from the contaminated areas so that moisture infiltration  is min.mized and contaminants are
  not mobilized. The run-on water will be managed as part of the existing surface water drainage system
  and the run-offwater will be collected and managed in a lined evaporation pond, to be constructed as part
  of this alternative.                                                                            p


              9.2    Soils  Under Buildings or Structures (Group 2)

       Contaminant source releases are not well defined for the Soils Under Buildings and Structures
 sites.  Contaminated soil release sites are assumed to be present as a result of accidental past releases
 during plant operations. The releases occurred under buildings or structures making characterization
  u  L-i-     pnmary threat P°sed by these s'tes is external exposure to radionuclide-contaminated soil if
 the buildings or structures are removed.  The soils also pose a minor threat to groundwater  Although
 these potential releases to  the environment are recognized, the release sites are not readily accessible and
 may remain covered by the facilities, since the buildings or structures may be closed in place as
 operations cease. The D&D program is determining the fate of individual buildings. Buildings may
 remain in place upon closure. Evaluations, conducted as part of the CERCLA 5-year review process will
 confirm whether the presence of the existing structures over these sites limits soil exposures and moisture
 infiltration. Three alternatives were evaluated for the Soils Under Buildings or Structures group to
 minimize the threat of contaminant exposure or mobilization.

 9.2.1    Alternatives Descriptions

 9.2.1.1    Alternative 1—"No Action" with Monitoring. Alternative I is comprised of existing
 institutional controls currently implemented at the site.  No active remediation will be performed under
 this alternative to alter the  existing site conditions.  The existing institutional controls include DOE land
 use and site access restrictions.  These controls will remain in place until 2095.

 9.2.1.2    Alternative 2—Containment.  Alternative 2 is a deferred action which includes the
 existing institutional controls described for Alternative I. additional institutional controls and soil
 containment with engineered barriers.  The additional institutional controls may include land or regulatory
 restrictions to prevent inadvertent exposure to contaminants.  The proposed engineered barriers will be
comprised of natural earthen materials designed to  isolate the contaminants until they are no longer a risk
The final cover designs will meet ARARs and are subject to the FFA CO review process.  It should be
 noted that the engineered barriers cannot be constructed until adjacent building or structures have
 undergone D&D.  In ;h.e meantime, the presence of the existing bnildinus or structures is assumed to limit
NOI! exposures and moisture infiltration. The effectiveness of the buildings and structures in limiting
exposures and infiltration will be evaluated as part of the CERCLA 5-year review process for Of 1-11
                                              9-"

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                          9.3    Other Surface Soils (Group 3)

             ^






 9.3.1    Alternatives Descriptions

          •scribed for Alfrmari^ ">   A      • A!temative 3 inciudes existing and additional in.mu
          .scribed tor Alternative 2 and containment using an engineered barrier.  The proposed
          barner is compnsed of natural earth materials and designed to isolate the contamTnants
          vater infiltration, and reduce contaminant leaching and transport for up to 1 000 years  The
          Carrier will be subject to operation and maintenance activities and 5-year reviews under
carrier construct?™* en ""f" .     risk remains> Some of the operating facilities may interfere with
several decades in ihellTe    C°ntamment ma>' "ot be ''"iplemented until facility D&D has concluded
                                            9-3

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   institutional controls will be terminated at each site but maintained at the location of the ICDF  The FCDF
   is planned to be constructed southwest of the INTEC facility and west of the current INTJEC percolation


  ,VB  'CDF~"T° imP'ement onsi
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                                      l° reduce m°isture content in the Perch«i water.  The existing
    on o  navnde .d               ^"'^ *' A'temative  ' '  The additional institutiona  '
   controls may include land or regulatory restrictions, to prevent inadvertent exposure to contaminated
   mf±  rWateh    1  I!'0"" PerChed water-monit0^ -ells will be installed to provide adSna
   nforniation about the deep perched water. The proposed remedies are actions that control source
   Mipplying water to the perched zone. The aquifer recharge controls, discussed below are denned to
   perZd Tone".* T ^^ of soil.conttmin^ <° P->-d "«er. reduce the volume oftf  n he
   perched zone, and minimize contaminated perched water releases to the SRPA.

        The initial aquifer recharge controls will include removal of the percolation ponds from service and
  discontinuing lawn .mgation at the INTEC, where necessary. A major contributio no the peTched water
  or.gm.tes from the existing percolation ponds, which contribute approximately ^70^ofte water
  rechargmg the perched water bodies. Removal of this water source will slow the rate of conTamLnt
  transport to the SRPA sufficiently to allow natural radioactive decay to reduce ^ the           ™
                                         quality standards will not be
          |em°Vfai °f 'I6 Percolation P°nds and cea«i"g 'awn irrigation do not protect the aquifer
          l aquifer recharge controls will be implemented. Additional recharge controls may include

 firew± r'8    rt r^ 
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   SnH V     T,   ™W ™mediation wi» be Performed under this alternative to alter the existing site
   ,ro±         eXIStmg instltutional controls inc'«*** ^ ** *«** ^ *£ Pro^
          studio For company and cost estimating purposes, the most likelv candidate treatment
                                            9-6

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   technology. ,on exchange, ,s assumed to be part of this alternative. Extracted groundwater will be treated
   n a newly constructed water treatment plant using ion exchange to concentrate the contaminants  The
   concentrated waste w.ll be treated and disposed onsite. The remediated water will be rdijS mto the
   aquifer through (he s* mjection wells.  Remediation could be challenging and may requJSSm^
   .tud.es because current technology is not sufficiently developed to remove 1. 1 29 to its derived MCLof
    P.Cl' L' ,Ther trfatf''ty stud.es will also evaluate the presence of mercury, Sr-90 chromium  Tc-99  and
   tnt.um al I of which are known or are predicted to be present in the groundwater p urn ^significant'
  trea '"nT T       these '°"<™« are not long-term risk drivers, they may foul the groundwater
  GroT T    °r P°Se rad'ol°S1Cal exP°sure co^rns if brought to the surface  for treatment
  Groundwater extraction and  .njection will also reduce contaminant transport by hydraulicaUy controlling
  wa'erorth'mo"16 '" l™l«d"reas- A tOtaI °^ approximate^ 492 billion*!. (.30 bil ion ga o    *
  water, over the  100-year operatmg l.fe, would be extracted and treated under this alternative.

                       9.6   Buried Gas  Cylinders (Group 6)

       The Buried Gas Cylinders group is comprised of Sites CPP-84 and CPP-94  These sites eenenllv

  STstSJTsr1 gastcylinders frr in construction gases at site cpp^ss22
  mn TK         f ' u    Xa  "Umber °f cyhnders 1S ""known but is estimated to be between 40 and
 xn   nn                                                         ™W <™*    punc
explosion of the cylmders.  A risk assessment was not performed for these sites during the RI/BRA
                             and evaluated for the Buried
                                                                                         or
 9.6.1   Alternatives Descriptions

 ».Rf .t    Alternative 1-"No Action" with Monitoring. Alternative I consists of existing
 msmufonal controls. Under Alternative I, no active remediation will be performed a  the site  The
 ex.st.ng .nst.tut.onal controls will consist of security, access restrictions, a'nd site inspections until ?095.

 9*1.2    Alternative 2-Removal, Treatment, and Disposal. Alternative 2 consists of the

 nZ 'leXhS'tU r'™11'' and diSP°Sal °f thC gaS CyHnderS 3t each Slte" This a"e™tive -ill abo include
 in itial site characterization us.ng geophysical surveys to determine the location and quantity of buried «£
 cyhnders pnor to removal  After the cylinders are located, they will be removed using convent.onal  g

  n e" o ;ee±oUnehS " fT C°nUjnment StmCtUre'  GaSCS pr£Sent '" the "cavated'cyl.nders tS  be
 con rac nr rhaf   ^  £     Y are,.be"18n' °r treated usin§ a ™*°* suitable for the particular gas. A
 contractor that specializes in gas  cvhnder removal, treatment, and disposal will perform Alternative "»
                                                                    P                "
                                       - Alteraalivc 3 consi;its «f the existing institutional controls
         iN inc       H           '"S',tut10nal controls, and containment. Additional institutional
       Mill include land-use or regulatory restrictions. The principal component of Alternative 3 is

           US? 3n eng"rred bamer-  Th£ barriCr Wi" C°nS1St of natural earthen materials des gned to
      the bur.ed gas cylmders. A concrete pad will be poured over each of the sites prior to placement
of the engmeered bamer to minimize the potential for an uncontrolled uas release dudng barrfer

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                  9.7    SFE-20 Hot Waste Tank System (Group  7)

        Based on the results of the preliminary investigation conducted at the SFE-20 site in 1984
  radiological contamination is present within the tank liquids and sludges, and on the tank, tank vault and
  pump pit surfaces. The principal threat posed by the SFE-20 tank system is a release of the radioactive
  contaminants from the tank due to loss of integrity that could potentially contaminate soils, perched
  water, or SRPA groundwater beneath the site.  In 1976. the tank and its transfer system were replaced
  The SFE-20 inlet pipe was disconnected, and the pipe leading to the SFE-20 tanks was capped. At
  present, there is no exposure to humans or ecological receptors under existing conditions given that the
  tank vault is 3 m (10 ft) below the ground surface and area access is restricted. However, radiation
  exposure could occur if the existing access restrictions are not maintained.  In addition, the excavation
  needed to cap the piping to SFE-20 may have been backfilled with radionuclide contaminated soil  Four
  alternatives were developed and evaluated for the SFE-20 tank system to limit exposure to radiation or to
  minimize the potential for a release to occur from the tank system.

 9.7.1     Alternatives Descriptions

 9.7.,1.1    Alternative 1—"No Action" with Monitoring.  Alternative I consists of existing
 institutional controls. Under Alternative I, no active remediation will be performed at the site  The
 existing institutional controls will consist of security, access restrictions, site inspections, environmental
 monitoring, and general maintenance until 2095.

 9.7.12    Alternative 2—In Situ Stabilization with Containment  Alternative 2 consists of the
 existing institutional controls described for Alternative 1, additional institutional controls in situ
 treatment, and containment. Characterization of tank liquid, sludge, and surrounding soil is needed for
 remedia design.  Additional institutional controls will include land-use and regulatory restrictions  The
 principal component of Alternative 2 is containment using an engineered barrier.  The barrier will consist
 of natural earthen materials designed to minimize exposure and moisture infiltration at the site for up to
 1.000 years. Prior to placing the barrier, the tank system, including the tank  vault, will be filled with
 concrete grout to stabilize tank liquids and sludge and  minimize differential settlement after capping.

 9.7.1.3    Alternative 3—Liquid Removal and Treatment with In Situ Stabilization.
 Alternative 3 consists of existing and additional institutional controls described for Alternative 2 removal
 and ex situ treatment of the tank liquid, and in situ treatment of the tank sludge, tank, and associated
 structures. Characterization of tank liquid, sludge, and surrounding soil is needed for remedial design and
 liquid waste disposal.  The tank liquid will be removed and treated at the PEW evaporator  The tank
 sludge, tank, and associated structures will be filled with concrete or similar urout to solidify and stabilize
 the contaminants that remain.

 9.7.1.4    Alternative 4—Removal, Treatment,  and Disposal. Alternative 4 includes the
 existing institutional controls described for Alternative I, removal and ex situ treatment of the tank liquid
 and sludge, and excavation, removal, and onsite disposal of the tank and associated structures  The tank
 liquid will be removed and treated as described in Alternative 3. The tank sludge will be removed and
 treated (ex situ) using a suitable grout to solidify  and stabilize the contaminants"^ the sludge
 Characterization of tank sludge, liquid, and surrounding soil is needed for remedial design and waste
disposal. The sludge will be drummed  and disposed at a suitable enuineered  disposal facility The
 remaining components of the tank  system will be excavated, removed, and disposed either in the ICDF or
otts.te  depending on the ICDF waste acceptance  criteria. The excavation will be backfilled to »rade with
clean soils.

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      10.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
  specif,!^ cTRaCLA ^h"^ • " ^'7? *W eVa'Uated against the "^^aluation criteria as
  specmed by LhKLLA. These criteria include:

        I     Overall Protection of Human Health and the Environment-This criterion addresses
             whether a remedy provides adequate protection of human health and the environment and
             describes how risks posed by each exposure pathway are eliminated, reduced, oncontrolled
             through treatment, engineering controls, or institutional controls.

        2.    Compliance with ARARs-This criterion addresses whether a remedy will meet all of the
             ARARs under federal and state environmental laws and/or justifies a waiver.
4.
             *TETT? EffrC thT? * a"d Permanenc^-™S criterion refers to expected residual risk
             and the ability of a remedy to maintain reliable protection of human health and the
             environment over time, once cleanup goals have been met.

             Reduction of Toxidty, Mobility, or Volume Through Treatment-This criterion
             addresses the degree to which a remedy employs recycling or treatment that reduces the
             toxicity mobility, or volume of the COCs, including how treatment is used to address the
             principal threats posed by the site.
                        Effectiveness—This criterion addresses any adverse impacts on human health
            and the environment that may be posed during the construction and implementation oeriod
            and the period of time needed to achieve cleanup goals.             Fomentation period,

      6.    Implementability-This criterion addresses the technical and administrative feasibility of a
            remedy mcludmg the availability of materials and services needed to implement a particular


      7.    Cost-This criterion includes estimated capita] and operation costs, expressed as net
            present-worth costs.                                       .

      8.    State Acceptance—This criterion reflects aspects of the preferred alternative and other
            alternatives that the state favors or objects to and any specific comments regarding state
            ARARs or the proposed use of waivers.

      9.    Community Acceptance-This criterion summarizes the public's general response to the
            alternatives described in the Proposed Plan and in the RI/FS, based on public comments
            received.


      ^-KST^SSt ?±!a'l!riV!i ** ~" '*-sue group is pressed in
                             pr                                                      of
and   T\M   H. 1  •    Tm ?       Cntena ^ ^^^ ^ ^ ^^ ^°UP in the followi^ text
and m Table, IO-! through 10-7. A d.scussion of CERCLA Criteria 8 and 9 is found in Section 10.8.
                                           10-1

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                  10.1   Tank Farm Soils Interim Action (Group 1)

  10.1.1   Overall Protection of Human Health and the Environment

        Alternative 3 provides the most overall protection of human health and the environment. All three
  alternatives limit human and ecological receptor exposure to contaminants by maintaining the existing
.  institutional controls, which are a common component of all of the alternatives. Alternatives I and •>  do
  not provide any direct action to limit leaching and transport of contaminants from the surface soils to  the
  perched water. Alternative 3 includes remedies involving engineering controls to limit surface water
  infiltration into contaminated soils and leaching and transport of contaminants to perched water.
  Implementation of surface water controls to limit future soil contaminant leaching and transport to the
  perched water will reduce the future risk to the SRPA.  All of the alternatives will provide perched water
  monitoring to determine if additional degradation of perched water is occurring. Table I0-l  summarizes
  the comparative analysis of the Tank Farm Soils interim action alternatives.

  10.1.2  Compliance with ARARs

        All of the proposed alternatives comply with the ARARs and to be considered (TBCs) during the
  interim action period, which ends in 2008. These alternatives would  also comply with the ARARs
  beyond the interim action period as long as the existing institutional controls are maintained  ARARs
  concerning monitoring well installation and other construction activities  will be met using engineering
  controls, health and safety practices, and radiological control methods.

  10.1,3  Long-term Effectiveness and Permanence

       None of the proposed alternatives provide long-term effectiveness or permanence. As  interim
 measures, the period of performance is assumed to be about 8 years (until 2008) or until the final remedv
 1S selected and implemented. The proposed alternatives will minimize human and ecological  receptor  "
 exposure to contaminants during the interim action period.  Alternative 3 will limit further perched water
 degradation during the interim action period. It is presumed that the final Tank Farm remedy  developed
 under Ob 3-14 will provide an effective and permanent long-term solution that mitigates human and
 environmental exposure risks and limits further perched water degradation.

 10.1.4   Reduction of Toxicity, Mobility, or Volume Through Treatment

       None of the alternatives provide a reduction of toxicity. mobility, or %-olume through treatment
 since treatment will not be implemented during the interim action period.  Some reduction in contaminant
 mass, and thus volume, is achieved indirectly through natural radioactive decay of short-lived
 radionuclides, such as Cs-l37 and Sr-90; however, the contaminant toxicity will remain the same
 Reduction in contaminant mobility will be achieved by implementing  the surface water controls in
 Alternative 3 to limit leaching and transport of soil contaminants to the perched water.

 10.1.5   Short-term Effectiveness

      All of the alternatives can be implemented u ithout significant additional risk to the community or
 Corkers.  The primary risk to the workers from implementation of Alternatives 2 and 3 involves fueitive
 dust and toxic substance emissions, which will be controlled with dust suppressants and engineering
 controls.  Alternatives 2 and 3 also pose a ver> minor risk to workers from direct exposure to radiation
 and personal injury during construction activities.  Sampling of the monitoring wells, proposed in all
                                              10-2

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                    IQf comparative analyses for the Tank Farm Soils Interin^non  Grouf


                                            Alternative 1
                                        	~

Overall Protection                                v
                                                •^               N                \

Compliance with ARARs                         v

                                                                 Y          '      \
Long-term Effectiveness                          c
                                                3                5                3

Reduction of Toxicity, Mobility, or Volume          N               N

Short-term Effectiveness                          3


Implementability                                 i
                                                                                     N


                                                                                     3


                                                                                     3
   Net Present Value Cost                            c, JVf            f,nn*.
  —	S3.4M            SIO.OM          SI5.1M
                                                        be
                                                                             not be
 10.1.6   Implementability
10.1.7   Cost

                                           10-3

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                                                                                                             1
              10.2  Soils  Under Buildings and Structures (Group 2)

   10.2.1   Overall Protection of Human Health and the Environment

        All of the proposed alternatives provide overall protection of human health and the environment
   during the institutional control period, which ends in 2095. Beyond 2095, only Alternatives ? and 3
   provide long-term protection and satisfy the applicable RAOs. Current workers will be protected bv the
   SmaKrTh COntr°iS Pr°PT d '"" eaCH alternative-  Alternative 2 provides long-term protection of
   hTfor SM   M nnrf enVIr°nmem / 'S°latmg the contami"ants with an engineered barrier desired to
   last for at least 1 .000 years and implementing additional institutional controls. The barrier and the
  additional institutional controls prevent inadvertent exposures to humans or ecological receptors bv
   muting contaminant accessibility through engineering controls and land use restrictions. The presence of
  the existing buildings or structures is assumed to provide the functional equivalent of an engineered
  barrier and will minimize exposures until D&D is completed. Alternative 3 provides the most overall
  protection pt human health and the environment by removing contaminated soils exoosed durine D&D
  and disposing them in the proposed ICDF.  Removal  of the soils will prevent exposure of humans or
  ecological receptors to soil contaminants. Table 1 0-2 summarizes the comparative analysis of the Soils
  Under Buildings and Structures alternatives.

  10.2.2  Compliance with ARARs
 ends inWS '^iTS? T ?f ARARS ** TBCS d"ring the institutional ™™ P^od. which
 ends m 2095  Beyond 2095, only Alternat.ves 2 and 3 satisfy ARARs.  Alternative 2 meets the ARARs
 using institutional controls and an engineered barrier designed for 1 ,000 years of protection
 Alternative 3 satisfies ARARs through the use of engineering controls while removing the contaminated
 soils and disposing of the contaminated materials in an engineered disposal facility designed to provide
 long-term protection of human health and the environment.                         geuioproviae

 10.2.3  Long-term Effectiveness and Permanence

       Alternative I does not provide any long-term effectiveness or permanence, because the existing
 institutiona  controls  will end m 2095, and no exposure controls will remain in place.  Alternative ?
 provides reliable long-term effectiveness and permanence by reducing human or ecological receptor
 exposure to  contaminants beyond 2095. The proposed engineered barrier is designed to provide Ions-
 term isolation of these release sites for up to 1 ,000 years, during which time the residual risk will decrease
 Sinn  '  tra,dl°af tIVC deCa/\ Alternative 3 will provide the most  long-term effectiveness bv removing the
 contaminated soils exposed during D&D and disposing of them in the proposed ICDF that will be    "
 designed for long-term isolation of radioactive materials.  The residual risk posed by soils disposed in this
 engineered disposal facility will naturally decrease by radioactive decay  of the short-lived radk>nuclides. '

 10.2.4  Reduction of Toxicity, Mobility, or Volume Through Treatment

      None  of the alternatives reduce the toxiciiy. mobility, or volume of contaminants through
 treatment, as treatment is not included in any of the alternatives. Contaminants are indirectly reduced
 oxer time by natural radioactive decay under each alternative.  Contaminant bioavai lability to human and
 ecological receptors is also  reduced by the engineered barrier.  Removal and disposal of the  soil
contaminants in the proposed ICDF will also indirectly reduce the contaminant mobility by Ions-term
contaminant  isolation.                                                       .  '  y    ^
                                             10-4

-------
                                        JH£!^^^
                                                 Alternative,      Alternative^      Alternative 3
                    Criterion
    Overall Protection
    Compliance with ARARs
    Long-term Effectiveness
    Reduction of Toxicity. Mobility, or Volume
    Short-term Effectiveness
    Implementability
    Net Present Value Cost
   a. Co. does not .nclude the pro,ata share for construction and opeloTof the ,CDF

                                                              '    '     • — •
 10.2.5   Short-term Effectiveness
 \
 N
 5
 \
 5
 1
S6.4M
                                                                       Y
                                                                       Y
                                                                       3
                                                                       N
                                                                       3
                                                                       1
                                                                      S9.2M
                                                              Y
                                                              Y
                                                              1
                                                             N
                                                             5
                                                             5
                                                             SSJ.Vf
                                * <
im
 Alternatives 2 and 3 can be implemented w^thouTanv
 env,ronmem.  Risks to workers and the env onmem
 or so,l excavation, because of worker expos"? ™
 environment. and the       ja, f       J
 tamer construction, or soil excavaL,
practices will be used to minimize
pathway during the institutional
implementation.
10.2.6   Implementability
                                                                  «he

                                                                               . or workers;
                                                                          U"der this al*™tive.
                                                                                work^, or the
                            2 and 3
                                                                                    tO the
                                                                   controls w'» be used during
                                                                     °T KleaSeS-  Safe work
                                                                     1"" ^ ^^ f°r thesoii
                                                                  be protective at the time of
                                                                          easi.y implemented.
 easily continued. The additional institutional cTnt ok  nd        y, ™plemented at *e site and are
 have been used at other Superfund ^^s^^^^^" Pr°vided in Alternative 2
 or construction concerns. Engineered barrier con WcTonTs si ^ LT,  T "° SPCdal 'ega'' en8ineering
 h.ghway construction, and requires no special personnel ecu Z          ' ^ °f earthwork' ^uch as
 • mp ementability issue concerns the timfng of bS "onsSSn  ^ T^' ^ °n'y S''gnificant
 unt,l adjacent buildings or structures have undergone D&D  whTch           ' ^T" be construc^
 the future. Alternative 3  also is readily implement but onlv f ' ,h T^ °CCUr f°r SeVera' deCades in
 dunng D&D. The timing for implementation of AUerna^ v  Ms  f " H"   f "* C°mp'etely removed
are projected to extend o^•er the next several decades THH    ?, dependent on D&D activities that
construction of the proposed ICDF.                    dd"1On- Altemative 3 also depends on the
10.2.7   Cost

                                            10-5

-------

                 e^^^

                      10.3   Other Surface Soils (Group 3)
  10.3.1   Overall Protection of Human Health and the Environment
                                                                      reducc human
 10.3.2   Compliance with ARARs







 10.3.3  Long-term Effectiveness and Permanence
existing             r      e
Alternative 2 will prove son e m easu re of!on« i  ^ reStnCtl°rnS 'imiti"8 '^ a"d grou"dwater use in
controls may not effect velv controTno em   g     protection ,f maintained beyond 2095. but these
      s may not
                        s
10.3.4  Reduction of Toxicity, Mobility, or Volume Through Treatment
                                 ^r^ m°bilit>'' °r ^Iume thro^h treatment as no
 lternative 3 reduces co n- u^     n JH? h       "'  °nMmctIon of an engineered barrier under
  ls. roducinu l«chin» "^LT0r "y / T111"1112"1? uater that ^^ through the contaminated
  bH.u a, the re£ ^es,^ ^bv « S? in -TiT'™^  AJtematKcs 4A and 4B «™it contaminant
   downed to hrnit col ,^ So it^'r"1™1"1 *"" " " ^
                                      10-6

-------
    Table 10-3. Summary

            Criterion
           ••

    Overall Protection

    Compliance with ARARs

    Long-term Effectiveness

    Reduction of Toxicity,
    Mobility, or Volume

    Short-term Effectiveness

    Implementability

    Net Present Value Cost
N
N
5
N
N
N
3
N
Y
Y
3
N.
Y
Y
I
Y
.
Y
Y
I
V
                             I

                            S6.8M
I
2
SI5.0M
3
3
S37.5M
3
3
S84.9M
5
5
S 208.4M

  10.3.5  Short-term Effectiveness
«is, a,, hesi.es.
dust emissions or cause personal i
These risks will be
                                                an,y addition*
                                            »t ™ Aliematlvef 3' 4A- and 4B may generate fugitive
                                             f^^ "^ tO WOrkerS °r the environment
      motives win be procec.i™
 10.3.6  Implementability



 also easily implemented as land us^ScSS^  H afe ^ * C°nti"Ued- Altemative 2 «
                                       ^
                                         ir ±rated,soils and either °n-site
use standard excavation equipment and d.l,            i a'tematl Ves are ''mplementable as thev
common landfill opera «on  Altlma ," e 4Au U   '" '!'"     diSpOSal facility Which is similar to a"
         l disposal sit^outh eTo L '^TEcTr ^ ^T^"1' desi§^ ™* construction of an
                              ---

-------
                        S0iis' *reat distanc« off-Site and depends on the availability of off-Site
   10.3.7  Cost




                                                                       "      "
                          10.4  Perched Water (Group 4)

  10.4.1   Overall Protection of Human Health and the Environment

       All of the proposed perched water alternatives will provide overall protection nf h,,™™ »,  i,u  A





 ™1K3£^Z^^^
       *          *           *-viwaotu vvaicr conicnL in inc perched zone will inprpjicf* th#»
 M fvrt* *% MA in^nt/*        *      f                   ^i***HfliuiaI ulLdlLlollOil pTOCCSSCS tO QCCf*^JlQ^




 10.4.2   Compliance with ARARs

     Alternative I does not satisfy the ARARs. Alternatives 2 and 3  meet all of the ARAR, if th. T u






10.4.3   Long-Term Effectiveness and Permanence
                                         IO-.X

-------
                        ^                   for the Perched
                    Criterion
    Overall Protection
    Compliance with ARARs
    Long-Term Effectiveness
    Reduction of Toxicity, Mobility, or Volume
    Short-Term Effectiveness
    Implementability
   Net Present Value
   * = exc.ud.ng Tank Fan, con«am,nant comnbution, reduced contaminant flux ,o «he SRPA wii. sausfy the MCLs

 
-------
   10.4.6  Implementability
        All of the alternatives are technically and administratively implementable. None of the alternatives
  require any special.matenals. equipment, or personnel that are not readily available at the site or from the
  local community.  Existing institutional controls proposed in Alternative I  are currently in place at the
  sue and can be easily continued. Alternative 2 is also readily implemented usins.standard construction
  methods and requires no special personnel, equipment, or materials. Alternative 2 mav pose some
  Implementability challenges, as this alternative requires replacement of the existing percolation ponds
  which are currently used by INTEC operations.  Alternative 3 also poses additional implementabilitv '
  concerns  because of the surface and underground utilities that occur throughout the plant that could be
  damaged  by activities such as installation of perched water extraction welfs or construction of holding
  tanks and transfer lines.                                                                    °

  10.4.7   Cost

       Alternative I  is the least expensive alternative evaluated because it only involves continuation of
  existing institutional controls and perched water monitoring. Conversely, it provides the least overall
  protection effectiveness and reduction of toxicity, mobility or volume of all the alternatives.  Alternative ">
  T? ™ S Capltalcosts  than Alternative I because of the implementation of aquifer recharge controls
  The O&M costs for Alternatives I and 2 are similar since perched water monitoring will be conducted
  under each alternative.  Alternative 3 is the most costly alternative because it involves construction and
 operation of perched water extraction wells and a water treatment facility for 25 years  A detailed cost
 (DOE8!!) 1998? ****** WatCr altemative is Presented in Appendix A of the FS supplement


           10.5  Snake River Plain Aquifer Interim Action (Group 5)

 10.5.1   Overall Protection of Human Health and the Environment

      Each of the proposed alternatives temporarily eliminates human health and environmental risks
 using existing institutional controls.  Alternative I will not provide human health protection beyond the
 institutional control period,  which ends in 2095. Alternatives 2A. 2B and 3, provide long-term protection
 through implementation  of additional institutional controls such as land  use restrictions until groundwater
 cleanup goals are achieved.  These controls would limit land and groundwater use as long as they remain
 S£ it* ™n,    g W conservative groundwater modeling, predictions Alternative 2A may not satisfy
 .YICLs by 2095 (see Figure I0-l). Groundwater monitoring is required to verify that RAOs are achieved
 Alternatives -B and 3 contain contingent active remediation of the SRPA to meet MCLs by ">095  if the
 COC action level(s) are exceeded. Table 10-5 summarizes the comparative analysis of the SRPA
 alternatives.                                                            '

10.5.2   Compliance with ARARs

      Alternatives I  and  2A do not comply with ARARs beyond the institutional control period
Altemames 2B and 3 are predicted to achieve ARARs before 2095.

-------
                 •129 (pCi/L) (10/2095) For Slice (11
                                                              1-129 (pCi/U (10/2095) For Slice (21
  199000:
     79900
 199000
    79900
-.99000
               83500     87100     90700
                           EASTING (M)
               51830.0 DAYS FROM 1953MAX C . 3.18*01
                                                                      87100     90700     94300
                                                                        EASTING (M)
                                                            51830.0 DAYS FROM 1953MAX C. 381*-01
                                                            97900
                                                                          1-129 (PCM.) MO/2095) For Slice 14}
                        B7100     90700     9430O
                          EASTING (M)
              51830 0 DAYS FROM 1953MAX C » 1 27e*00
                                       97900
                                                 79900
                                                                                        94300
                    83500     87100     90700
                                EASTING (M)
                    51830.0 DAYS FROM 1953MAX C « 1 21»»00
               1-129 (pCi/Ui (10/2095) For Slice (5)
                                                                         M29 (pCi/U (10/20951 For Slice (6)
    79900
                                          94300
83500      87100     90700
            EASTING i Ml
51830 0 DAYS FROM 1953MAX C • 4 68e»OO
      199000
97900      79900
                                                                                                    94300
                   83500     87100      90700
                               EASTING {M)
                   5'83OO DAYS FROM 1953MAX C > 2 B4«,OO
                                                                                                              97900
Figure 10-1.  Predicted 1-129 concentrations for slices l-IO in 2095.

-------
(Q
C

3
r,
C
C
a.
NORTHING (M)
                                     8  8

                                    JJLJJJLI
                       NORrHING(M)

                        8 8

-------
         ^O-S. -Summary of comparative analyses for the Snake River Plain Aquifer Interim Action,
Alternative 1   Alternative 2A  AltemativejBAIr.m,,.-,,,. 3
                  Criterion
    Overall Protection
    Compliance with ARARs
    Long-term Effectiveness
    Reduction of Toxicity. Mobility, or
    Volume
    Short-term Effectiveness
    I mplemen lability
    Net Present Value Cost
                                            S13.9M
                SI4.8M
3
5
S39.8M
3
4
S787.9M
   ^leas. sat.sfies cn.enon; 1 - hes, saosnescntenon; V - ves. cntena
  10.5.3  Long-term Effectiveness and Permanence
                                                                                          d


 10.5.4  Reduction of Toxicity, Mobility, or Volume Through Treatment


10.5.5   Short-term Effectiveness


10.5.6  Implementability
                                          IU-13

-------
                                              ter and available groundwater treatmem
       -  _..— «*.1N,4 v.x-»\_a iciuuvm. ijround\vatt?r ^Ytm  t'      -i   L             ***»nvni **-*,*»n\yiu^jc:j> i^j-
     without any special personnel, equipment or materiil'0^!     •  ot ]S3 m (60° ft> can be implemented
     and treatment of millions to billions of callon^ ntv   ,   .   er"atlves ~B and 3 will also require handling
     testing may be required to determine the most an r     1lnated S^md^ater.  Bench-scale treatability
     concentration contaminants present in the SRPA BrnfinH^ ttreatmentja"d extract|on technology for the lov
    groundwater from the low permeability H l'hvU ;         u'    addltlon- "faction of contaminated
    contemplated in Alternative 3       '                technically challenging than aquifer extraction
    10.5.7  Cost
                    .;:^                                "-« provides the least overall
   costs. Alternatives 2B and 3 cost the ^mo« S« r^v'? T? C°St'y beCaUSC of addltio«al monitoring
   Alternative 3 extraction and treatment ^aoacitv fc£ ?7i      u eXtraCt'°n 3"d treatment costs"
   protection, long-term efTect^e^dSon^^^^                    hi^her ^ Oveml.
   increased costs.  A detailed cost estimate for each altem^v           !/  a"d V°lume increase with
   supplement (DOE-ID I998a).                  alternat.ve ,s presented m Appendix- A of the  FS
                         10.6  Buried Gas  Cylinders (Group 6)
  10.6.1   Overall Protection of Human Health and the Environment
                   ^                             of human health and the environment.
  sites. Alternatives 2 and 3 Ml^fy1'^^^^^'' acf s «>n««,.s are in force at these
  the RAOs through containmenfand will be proSSe ?or a  LastTooo     ^ A'tematiVe 3 achieves
  protective beyond  1 ,000 years, but it was onl v eva nlTr   t    '    -1"5-  Altemative 3 may be
  Alternative 2 provides the most ove all protection ^theburild6 ""T^ ^'^ Hfe °f the barrier'
  reactive and ignitable gasses will be removed I  reated ^T  gas/ylinder Sltes be"use the hazardous
  Table ,0-6 summarizes the comparativ^S                                    ™*

  10.6.2   Compliance with ARARs
                        Ot comolv with A R A PC rlnt-;«,. ,u
 ^..e* an o, me ARARs usina engineering com™1  ™d nm ms^tlona Controi Pe"°d- Alternativ
 complies with all of the ARAR^s durin "he tardier  ! onnpr°pei;,dlSPosal Procedures.  Altemative 3
 1.000 years, it is assumed that the waste and the h™/™ i    ""functlonal des'Sn life-  Beyond
 minimize risks.                                fee so" mass comprising the barrier will continue to

 10.6.3   Long-term Effectiveness and Permanence
                                                                                  ' buried
           an approved ^          ^ •-^e YSv'"AT "^ 'T'"16"1 resid"e wi" be
long-tern, e.Tectiveness and permanence^- coma 1 M^';  ^!ternal1 v?   P^des a high degree o
u-, reduce the current risk to huma.and cco^ca
                                            10-14

-------
    TableJO-6.  Summary- of comparative analyses for the
                    Criterion
                   —	
    Overall Protection
    Compliance with ARARs
    Long-term Effectiveness
    Reduction of Toxicity, Mobility, or Volume
    Short-term Effectiveness
    Implementability
    Net Present Value
                                                                      i. Group 6.
Alternative 1
	 . 	
N
N
5
N
1
1
	 • 	 : 	 -t_J
Alternative 2
Y
Y
1
Y
5
3
Alternative 3
Y
Y
3
N
3
3
                                                                                    S8.2M
                cn.cnon: I • hes, sansjle^e.^ y - yes, cnter.a wi.l he
1 0.6.4
           Reduction of Toxicity, Mobility, or Volume Through Treatment
  10.6.5   Short-term Effectiveness








10.6.6   Implementability
                                                    is technicall-v and administratively



.mplementabk. Alternate 3 reqmres no spec,al,zcd conMniciion personnel, equipment, or matenak
                                           \n-\5

-------
  Existing institutional controls are currently implemented at the site and are easily continued.
  Construction of an engineered barrier is similar to other types of earthwork, such as highway
  construction, and can be readily implemented.

  10.6.7   Cost

       Alternative 2 is the least costly of the alternatives evaluated, and provides the most overall, long-
 term protection.  Alternatives I  and 3 are similar in cost and are much more costly than Alternative 2 "
 because these alternatives include^ 100 years of environmental monitoring, whereas. Alternative 2 does
 not include environmental monitoring after the buried gas cylinders are removed. Alternative 3 is the
 most expensive alternative because it includes increased capital costs for constructing an engineered
 barrier.  A detailed cost estimate for each alternative is presented in Appendix A of the FS supplement
 (DOE-ID I998a)

                10.7   SFE-20  Hot Waste Tank System (Group 7)

 10.7.1   Overall Protection of Human Health and the Environment

       Alternative I is not protective of human health and the environment because no active remedial
 measures will be implemented to limit the threat of contaminant release to the environment.
 Alternatives 2. 3. and 4 are the only alternatives that fully satisfy the SFE-20 tank system RAOs.
 Alternative 2 achieves the RAOs through in situ treatment and containment and will be protective for at
 least 1,000 years. Alternative 2 probably may be protective beyond 1,000 years, but it was only evaluated
 for the minimum design life of the barrier. Alternatives 3 and 4 provide the greater protection of the
 SFE-20 tank system alternatives because the radioactive liquids and/or sludges will be removed, treated.
 and disposed in an engineered disposal facility. Alternative 4 provides the most overall protection of
 human health and the environment. Table 10-7 summarizes th; comparative analysis of the SFE-20 tank
 system alternatives.

 10.7.2  Compliance with ARARs

      Alternative I  does not comply with the ARARs either during the 100-year institutional control
 period or beyond. Alternative 2 complies with all of the ARARs and TBCs during the barrier's
 1.000-year functional design life. Beyond 1,000 years, it is assumed that the solidified waste and the
 large soil mass comprising the barrier will continue to minimize exposure risks from alpha-emitting
 radionuclides and satisfy all of the  ARARs and TBCs. Alternatives 3 and 4 will satisfy all of the ARARs.

 10.7.3   Long-term Effectiveness and Permanence

      Alternative I does not provide any measure of long-term effectiveness or permanence beyond the
 institutional control period, which ends in 2095. Alternative 2 provides a high degree of long-term
effectiveness and permanence by solidifying and containing the waste.  Alternative 3 will provide a hiah
degree of long-term  effectiveness and permanence because the tank liquid  will be removed, treated and
disposed, the tank sludge solidified using grout, and the tank and associated structures filled with grout to
 prevent future exposures.  Alternative 4 will provide the  highest degree of long-term effectiveness"and
permanence because the tank liquid and sludge will be removed, treated, and disposed, and the remaining
components of the tank system will be excavated and disposed at the proposed ICDF.

-------
   Table 10-7.  Summary of comparative analyses for the SFE-20 Tank System  Group 7.
                                           Alternative I  Alternative 2  Alternative 3  Alternative 4
               Criterion
 Overall Protection
 Compliance with ARARs
 Long-term Effectiveness
 Reduction of Toxicity, Mobility, or
 Volume
 Short-term Effectiveness
 Implementability
NPV Cost
                                               N
                                               N
                                               5
                                               N

                                               I
                                               I
                                              S6.4M
 Y
 Y
 3
 Y
3
3
                                                        S8.7M
 Y
 Y
 3
 Y

5
5
S8.5M
 Y
 Y
 I
 Y

5
5
S4.6M
   5 • to., sat-sfies cmenon^, - best satisfies critenon; V - yes, criteria w.ll be met; N = no, cnteria will not be met.
  10.7.4  Reduction of Toxicity, Mobility, or Volume Through Treatment
 10.7.5   Short-term Effectiveness









10.7.6   Implementability
                                                    '» *Ch™M* and administratively

-------
  Barriers are routinely used to control exposures and leaching and transport of contaminants. Barriers
  have been used at numerous Superfund sites. Alternatives 3 and 4 are more difficult to implement than
  Alternatives 1 and 2 because of the potential for construction workers to be exposed to radiation or
  occupational injury during the characterization, removal, handling, treatment, or disposal of the tank
  liquids, sludges, and other components. Engineering controls, health and safety plans, radiation controls,
  and safe work practices will be used to minimize radiation exposure and reduce personal injury.
  Treatment of similar tank liquids at the PEW evaporator is routinely conducted and would be reliable for
  these alternatives.  Solidification of the tank system is readily implemented, as grouting is a demonstrated
  technology that has been used at numerous Superfund sites.

  10.7.7   Cost

       Alternative 4 is the least costly of the alternatives evaluated for the SFE-20 tank system,  and it
 provides the most long-term effectiveness of the alternatives.  Alternatives  1,2, and 3 are similar in total
 costs but vary slightly in capital costs. Alternative 4 is much less expensive than the other alternatives
 because Alternative 4 does not include long-term environmental monitoring for the 100-year institutional
 control period. Alternatives 2 and 3 cost essentially the same because of higher capital costs.
 Alternative 2 is the most expensive alternative because it includes capital costs for grouting the  tank
 system and constructing an engineered barrier.  A detailed cost estimate for each alternative is presented
 in Appendix A of the FS supplement (DOE-ID  1998a).

                                10.8   Modifying Criteria

      The modifying criteria, state and community acceptance, are used in the final evaluation of
 remedial alternatives. For both of these criteria, the factors include the elements of the alternatives that
 are supported, the factors of the alternatives that are not supported, and the elements of the alternatives
 that have strong opposition.

 10.8.1   State Acceptance

      The  IDHW has been involved in the development and review of the OU 3-13 RI/FS report the
 Proposed Plan (DOE-ID I998b). and this ROD. All comments received from IDHW on these documents
 have been resolved and incorporated into these documents accordingly.  In addition, IDHW has
 participated in public meetings where public comments and concerns have been  received and responses
 offered.

      The IDHW concurs with the selected remedial alternatives for the sites contained in  this ROD and
 is signatory to the ROD with  DOE and EPA.

 10.8.2   Community Acceptance

      Community participation in the remedy selection process and Proposed Plan reviews includes
participation in the public meetings held November 16 through 19, 1998.  Community acceptance is
summarized in the Responsiveness Summary presented as Appendix A of this document.  The
Responsiveness Summary includes comments received either verbally or in writing from the public, and
the Agencies' responses to  these comments.  A total of about 55 people not associated with the project
attended the Proposed Plan public meetings. The community was generally supportive of the proposed
remedial actions. All comments received on the Proposed Plan \vere considered  during the development
of this ROD.
                                             in-is

-------
                                                                                        1
                           11.  SELECTED REMEDY

                11.1   Descriptions of the Selected Remedies

































                  -                                               '
                                                           drg
mechanism to identify, at a minimum, all CERCLA hnd a     ,NEFT   H    '*  • ^

This planning document mav itself become a pLt of ,  I\EEL St -waf } h  P^ reStnC"O-n T C°ntroL
modifications to the I\EELL-md L\e Finn  m h           L      P  a" °r e^uivalent- but any
               J.  CCL Lana L*«. I Ian uill be consistent with the requirements of this ROD.

-------
  Table 11-1.  Institutional controls lor OU 3-13 ROD.
dump III
-SniiKe AIC.I
I I. ink I .inn
-SniK Inlet mi
At lion
1 line 1-rame
< iineni DOI-
operations until
final action
implemented
Land
Restriction
lndiiMri,tl
radiological!}-
conlrollcd area.
C«t Vaud
l-xptisure 1 hrcat
Radinnuchdcs
and metals
Moderate
exposure ilircat
                                                                             Objective
I'ndei
lilllllllllUs .Illll
Sli in.-liili.-s
(i-.ip -m-pl.icc)
cm i cm nor
opeialions
prior to I),VI)
ol 'building
liuliisin.il        Kudidiiuclidcs
rudiologiciilly    and niulal
conlrollcd area.   ,
                 l.o\\ exposure
                 Ilircul
                                                                      1'rcvcni inirusion inio
                                                                      underlying
                                                                      coiilaininaicd .soils,
                                                                      except for, approved
                                                                      activities pursuant to
                                                                      the KKA/CO.  Limn
                                                                      access to only
                                                                      auihori/.ed personnel
                                                                      and/or DOli certified
                                                                      radiation workers.
Limit access to only
authori/ed personnel
and/or [)()!•: certified
radiation workers.
                                                                                                        Controls
                                                             Visible accevs rcslnciiiHis
                                                             (warning signs, provide
                                                             copies of .surveyed maps)
                                                             Control of activities
                                                             (drilling or excavating).
                                                             Publish surveyed
                                                             boundaries and description
                                                             ofcontrols in INI-1:1. Land
                                                             Use Plan.
Visible access restrictions
(warning signs, provide
copies of surveyed maps).

Control of activities
(drilling or excavating).
Publish surveyed
boundaries and description
of controls in INI-1:1. Land
Use Plan.
                                                             Regulatory
                                                     , 	liaxi.s/Auiluiriiy
                                                      M-A/CO. IOC1-KXJ5.
                                                      "Radiological Worker
                                                      Protection." I )()!•" Ordei
                                                      5400 5. "Radiation
                                                      Protection of the Public."
                                                      Ai.ARA40CI-RI>art
                                                      300.
M;A'CO, 10 (TRIOS.
"Radiological Worker
Protection," |)()l-Order
5400.5, "Radiation
Protection of the Public,"
ALARA40CFR
Pan 300.
   Surveillance to ASMIIC
  _____ Controls in place

  Periodic inspectioii% by
  lX)I:andU)IIW.||'A
  reviews.  |-rei|uenc> to
  lie determined m the
  remedial action work
  plan.

  Nnu:  Hit- Intci im
  .•tfllOII 11 ct/ICf/l'i/ III ltl\l
  fi>rk\\ than I II wars
  timl he ivfiUuvtl hy llic
Jinul actiutt. A
 reviews,  l-'iequeiicy to
 be determined in the
 remedial action  work
 plan.
                                                                                                                                                    ilcmnliinin it •/// he
                                                                                                                                                    l>er/t>rmeti initsitle V( •«/>,•

-------
Table 11-1. (continued).
- 	 	 • •• 	 	
<"'»i'l"" Land COCs/and
Soiin-e Area '1 ime iTiime Restriction Lxpostire Threat
Current DOli Industrial Radiomichdes
operations after landlill no and metal
building D&D- unautliori/ed ,
Low exposure
coni.imination intrusion into .,
iii . threat
[ell in place capped area.
I-VA/CO
approved
O&M activities
authori/ed.








••- — 	 — - 	 —
1)01' control Landfill no
post operations unaulhon/ed
intrusion into
capped area.
I'l-A/CO
approved
O&M activities
auihori/ed.












Objective
Limit direct exposure to
underlying
radiologically
contaminated soil areas'
by public to < \ li-4 risk
through shielding
provided by building.
Limit water recharge
activities adjacent to
 . .
I-I-A/CO, 10 CIR 835. Periodic inspections and
"Worker Protection," reviews, l-rcqueiicy to
DOI-: Order 5400.5. be determined m the
"Radiation Protection of Remedial Action Work
the Public," ALARA 40 Plan.
CI-'R Part30()C!:RCI.A










H'A/CO, Ch'RCI.A 5-year review until
Section I20(h)(5),' Hall determined to not be
Amendment Section needed.
3154 of the National
Defense Authori/alion
Act,' DOli order 5400.5,
"Property Release
Restrictions "











-------
Table 11-1.  (continued).
dump 01
.Si HI no AHM 1 ime 1 r.nnc
I'osl 1)01-
innliol







1 and cot
Rj^liictHHi 	 	 (•.\posui
1 andiill no
uiiaiilhori/cd

mirusion into
capped area
M-'A/CO
approved
O&M activities
authoriVed.
\ and
vllmu _ Obteeiivc
Maintain integrity of
cat).
§





                                                                                             	,	Controls
                                                                                               Notice Iti allected
                                                                                               Mak-clMildcn. (e.g., HI.M
                                                                                               l;&W.SIuiIJan Tribal
                                                                                               Council, loeal coiiniy
                                                                                               governiiieni.s; Stale and
                                                                                               I'-I'A), ineliiding nonce ol"
                                                                                               any change in land use
                                                                                               designation, restriction.
                                                                                               land users or aciivitie.s.
                                                                                               Property iransler
                                                                                              requirements including
                                                                                              i-'ntdmg oI'Miitabiliiy to
                                                                                              ininsler and requirements
                                                                                              lor control ol'land-use
 H-A/CO.CWl.A
 .Section I2»(h)(3).'
 CI-.RCl.A Section
                                      cc to Avstire
                             ..Controls ni.n
                                 .... i ^^ „ __, ^
5-year rev icu mini
determined ID not he
needed
 CI-RCI.A Section
 i20(h)(.i)(A)(i,,);
 CI-RCI.A Section
             .:
Section I20(h)(4).7 j\
CI;R2.172.I.X4.U-|--R
2.174.2." 4 1 CI-R 101 .
47.202- 1, -2.-7.1" l)()|:
order 5400.5 property
release restrictions.
-1' Soils Cuirent 1)01:
l'"lln opeialions
Mmlilitius .nul
•Sllliclllies
(K'ln.iiiiuii!
•llk-l IfllHU.ll
1" «IIK| disposal
ill l( 1)1 )
1 \i \ 1 1
DOr control
post operations

Industrial. Coiiiamiiianis
removed to
10 It.



	 	 	 	 .. 	 	
Industrial. Contaminants
removed lo
10 ft.

	 . 	
l-.nsure land-use is
appropriate if
contamination left
ill-place > 10 ft.



(•insure land-use is
appropriate if
contamination left
m-place>IOtt.
coiisisleni with the ROD
Review and control of
activities as applicable.




Property lease requirements
including requirements for
control of land-use
consistent with the ROD.
                                                                                                                          10 CI-R 1021 NI:|>A
                                                                                                                          Review of Activities.
                                                                                                                         I«(TR 1021 NI-.PA
                                                                                                                         Rev lew of Activities.
                                                                                                                         CI-RC'I.A Section
                                                                                                                                  ,
                                                                                                                         Amendment Section
                                                                                                                         3 1 54 of the National
                                                                                                                         Defense Authori/ation
                                                                                                                         Acr DOli Order 5400.5,
                                                                                                                         "I'ropeny Release
                                                                                                                         Restrictions "
                          5-yi'arievie\v until
                          (leleriinned to not he
                          needed including review
                          <>l land use assumptions
                         W55.7-02A)
                         (Supplemenlal l-ive-year
                        --^iiii.1:' w ii.lildance).

                         5-year review until
                         deiermiiKxl lo not he
                         needed including review
                         <>l land use assumptions.

-------
 Table 11-1. jconiimitfd)._
     (iwup or
    Somce Arc;
                   Post I )()!•:
                   control
	 .— — . „ 	 , 	 	 .
1 and
Restriction
Industrial to
2095.
lesidcntial alter
2(W5.


COCVand
_hxposure Threa
Coniaminanis
removed to
10 It.



' Objective
l-.nsure land-use is
appropriate if
contamination left
m-place >IO ft.



C'ontrols
Property transfer
requirements including
Finding of suitability to
transfer and requirements
tor control of land-use
consistent with the ROD.
	 . _
Regulatory
Basis/Authorily
Oil 3- 1 3 ROD, H- A/CO.
U-ilU'l.A Section
l20(h)(3),Vl-:RCI.A
Section

CHRC1.A. Section
 '•'  ICDI-        Same as 2a
                                                                                                          C'hRCl.A Section
                                                                                                          l20(h)(l)-(3),"cl-.RCI.rt
                                                                                                          Section I20(h)(4),'41
                                                                                                            Othei Soil   Same as 2b

 Uonl.imm.ilinii
depth  -I (Ml
•iltci removal
t» and di.s
4   I'eiched
U'aler
1 Current I)()!•:
 operations
Industrial.
                                  Prevent consumption
                                  anduseof>MCL&/or
                                   • 11--04 risk drinking
                                  water.
Control of activities
(drilling of wells for
drinking).
                                                                                                                            ii-IO directive
                                                                                                                        limiting access lo prevent
                                                                                                                        groundwater use while
                                                                                                                        INTf-C operations
                                                                                                                        continue1, and to restrict
                                                                                                                        future groundwater use
                                                                                                                        (through noticing this
                                                                                                                        restriction to local county
                                                                                                                        governments, ShoBan
                                                                                                                        Tribal council, (iSA,
                                                                                                                        BLM, etc.) including site
                                                                                                                        access restrictions, and
                                                                                                                        drilling restrictions.
                                                                                                                                  5-year review until
                                                                                                                                  determined to not he
                                                                                                                                  needed.

-------
Table 11-1. (continued).
    (noiipiil
   .SoilHT AlCil
  I inn-1 r.iinc
OOI- control
post opcr.itioiis
UXVand
     e Threat
                                   ImliiMriHl,
                                                                            Objective^
                                                Controls
                                                                      Prevent consumption
                                                                      anduseof>MCI. &/or
                                                                      * I I:-1M risk drinking
                                                                      water.
                                                                            (drilling ol'well.s fur
                                                                            drinking).
                                                                            Property lea.se requirement:,
                                                                            including liuding of
                                                                            .suiiahiliiy to transfer and
                                                                            requirements for control of
                                                                            UL-IIVIIIC.S.
        Regulatory1
	Basiji/Aulluiriiy 	
  OU.VI3ROD.CI-.RCI.A
  Section I2()(li)(5).'Hall
  Amendment .Section
  315-loftlicNalional
  Defense Antliori/uiiiia
  Act.;
  DOIM!) directive
  limiting access to prevent
  groundwaleru.se while
  INTliC operations
  coniinuc. and to restrict
  future grnuiidxvaier use
  (through noiicing this
  restriction to local couniy
  governments, ShoBan
  Tribal council, (ISA,
  BI.M, etc.) including site
 access restrictions, and
 drilling restrictions.
 Surveillance to Assure
	C 'pnlrols ill-place
5-year a-Mcwuniil
delennmed to not lie
needed.

-------
Table 11-1.  (continued).
(inwpor
Soiiu-c Area lime l-'ramc
Post 1 )()(•.
control
( -2(W5)
	 	
Land
Restriction
Residential.
	 . 	
COCs/and
Hxposure Threat Obiective
Prevent drilling through
"contaminated inierbeds
and dragging
contamination
downhole to the SRPA.

Controls
Property transfer
requirements including
finding of suitability to
transfer and requirements
for control of activities

Regulatory
B-A/CO, CHRCI.A
Section I20(h)(.1),'
CHRCl.A Section
CHRCLA Section

Surveillance to Assure'
( onlrols m-place
5-year review until
delennined to not be
needed including review
of land use assumption*
5  Siukc
Ui\ei I'lam
Ai|infer -
milside IN'1'I-C
IWHencelnie
Cuiieiil DOI-.
Operations
Industrial.
                                  Prevent consumption
                                  and use of >MCL &/or
                                  >lh'-04risk drinking
                                  water.
                                                                                              consistent with ROD.
Control of activities
(drilling of wells for
drinking).
                                                                                                                          ChRCI.A Section

                                                                                                                          Section I2()(h)(4),'4.}
 M)l-47.202-l,-2,-7."'
 l>OI-:-ll) directive
 limiting access to prevent
 groundwater use while
 I NThC operations
 continue, and to restrict
 future groundwater use
 (through noticing this
 restriction to local county
 governments, ShoBan
 Tribal council, (iSA,
 Hl.M, etc.) including site
access restrictions, and
drilling restrictions.
I'TA/CO
                                                                                                                                  5-year re\ lew until
                                                                                                                                  delennined to not be
                                                                                                                                  needed.

-------
Table 11-1.  (coniimictl).
    (iinupoi
   Snuii tf AfCi
  I line I mine

l)t)l eoniiol
post opcialiniis
      S lip |(l
     Land
  Resinclioii
Industrial
    fOlVand
J:\posnre 1 lircaj_
                                                                             Objective
                                                                      Preveffl cunsumpiHtn
                                                                      andu.se of >M(*I. &/or
                                                                       •N:-(M risk drinking
                                                                      wilier.
                                                                                                        ('onirols
                                                            Conirohifacliviiieh
                                                            (drilling of wells for
                                                            drinking)
                                                            I'riiperty lease reqiiireinenis
                                                            including finding of
                                                            suiiabiliiy to Iraiisfer.
        Keguljiiny
      Hasis/Aulluiriiy
 OM.M3ROI). I-TA/CO.
 (T.KTI.A Seeiion
 120(11X5).'Hall
 AnieiKlnieni .Section
 3154 of llieNaiion.il
 Defense Aulhori/alion
 Acl.-

 IK)I:-I I) directive
 liiniling access to proven)
 groundwaler use while
 IN'I'l-.Copcniiions
 eoniinue, and to restrict
 future groundwaier use
 (through noticing tins
 reslricluin lo local couniy
 Boverninenis. Sliolian
 Trihal council, (iSA,
 UI.M. eie.) including sue
 access restrict ions, and
drilling restrictions.
Xuneillunce to Assure
  ('oiUrolsiu-pljec
                                                                                                  5-year review until
                                                                                                  delerinined to not lie
                                                                                                  needed.

-------
Table 11-1.  (conlinued).
     (iroup or
   .Souice Area
•- - 	 	 . .
lime l-rainc
control -
applies up to
2(WS



Land
Restriction
Industrial
(residential
after 20l>5).



COCs/and •
Exposure Threat Objective
Prevent consumption
and use of >MCL &/or
--lli-04 risk drinking
waier(NA after 100
years).


Controls
Property transfer
requirements including
finding of suitability to
transfer (NA after
100 years).


Regulatory
0113-13 ROD, I-FA/CO.
CI-RU.A Section
l20(h)(3),5U-RCI.A
Section l2()(h)(3)(C)(n|4
CI-RCL.A Section
l20(h)(3)(A)(ni)/
CI-RCI.A Section
Surveillance to Assure
t onlrols iii-plucu
5-year review mini
determined to not be
needed.



l>ii   Uuiicil
<  )lmdcis"
dcnunal)
Current DOI-
operations


I'osl-
leniediation
Industrial.
                                 t 'nre.slricled.
                                  Prevent access to sites
                                  except by authorized
                                  workers.
                                  NA- to be remediated.
Visible access restrictions
(warning signs,  provide
copies of surveyed maps)
                                                                                                                          Section I20(h)(4),743
                                                                                                                          CI:R2372.I,"43(TR
                                                                                                                          2374.2,"41 C.FR 10|-
                                                                                                                          47.202-l,-2,-7."'
                                                                                                                          l)OI-:-ll) directive
                                                                                                                          limiting access to prevent
                                                                                                                          groundwater use while
                                                                                                                          INTI-C' operations
                                                                                                                          continue, and to restrict
                                                                                                                          future groundwater use
                                                                                                                          (through noticing Ihis
                                                                                                                          restriction to local county
                                                                                                                          governments, ShoBan
                                                                                                                          Tribal council, (iSA,
                                                                                                                          BLM, etc.) including site
                                                                                                                          access restrictions, and
                                                                                                                          drilling restrictions.
I-TA/CO, HKTRX35
"Worker Protection"
Periodic inspection until
remediation is complete.

-------
Table 11-1.  (continued),,
    (mini) in
   Suiilie Aiea
  I line I i.inic
( inn-ill !)()!•
npci.ilioiis .illci
                  uiiiianiinalinn
                  left in place
                  Dot- contiol
                  post OpeiallOII
     I. mil
   Restriction
                                      (()('«. Jiiil
IllllllSlll.ll
Ijiitll'ill  mi
uii.inllioii/eil
intrusion inlo
capped aiea.
FFA/CO
approved
O&M activities
aulluiri/ed.
                 I Ulllllill  III)
                 iinatilhoii/cd
                 intrusion inln
                 capped area.
                 I I-A CO
                 approved
                 OKM activities
                 autlu>ri/ed.
                                                                               Obiociivu
Limit water recharge
aciiviiie.s adjacent to
(iroup 2 buildings.
Maintain integrity of
cap.
                                   Maintain integrity of
                                   cap
	   <'ontrt)l.s	
  Visible access re.stnctitins
  (\\uinnig .signs, provide
  copies of surveyed map.s).
  C'untrol of activities
  (drilling or excavating).
  Publish .surveyed
  boundaries and description
  of controls in INI-.I-I. Land
  Use Plan.
  Nonce to affected
  stakeholders (e.g.. 1)1.M,
  I-'&W, ShoHan Tribal
  Council, local county
  government;.; Slate and
  H'A). including notice of
  any change in land use
  designation, restriction,
  land users iir activities.
  Visible access restrictions
  (warning signs).
  Control of activities
  (drilling or excavating)
  Notice to affected
  stakeholders (e.g., Dl.M,
  I-'&W, ShoHan Tribal
  Council, local county
  governments; State and
  I-I'A). including notice of
 any change in land use
 designation, restriction.
 land users or activities.
 Property lease requirements
 including requirements for
 control of land-use
 consistent with the ROD.
                                                             Regulatory
                                                                                                                              H'A'CO. IOCI-RX.15.
                                                                                                                              "Worker Protection "
                                                      n;A/U),CI-RCI.A
                                                      Section  12<)(h)(.">),' ||u||
                                                      Amendment Section
                                                      3154 of the National
                                                      Defense Aulhori/aiion
                                                      Acl,J DOM order 5400.5,
                                                      "Property Release
                                                      Restrictions."
                                                           Smveillaiiceto Assme
 Periodic inspections ami
 reviews,  l;iet|iienev tii
 be deiermined in (lie
 Remedial Action \Voik
 Plan.
5-year rev lew until
determined In not be
needed.

-------
 Table 11-1. (continued).
    Source Area
                  I'osl l)(
                  control
                     I imc l-rame
                   DOI- control
                   POM operations
                        Land
                     Restriction
7   I lot Waste
lank System
Prior lo
I-\cu\ation"
Current DOI:
operations
                   l.aridllll  no
                   unauthon/eil
                   intrusion into
                   capped area.
                   !• FA/CO
                   approved
                   O&M activities
                   auihori/cd.
                  Landfill  no
                  unaulliori/cd
                  intrusion into
                  capped area.
                  II A CO
                  approved
                  O&M activities
                  aullion/cd.
Industrial.
                                   Maintain integrity of
                                   cap.
           C'onlrol.s
  Visible access restrictions
  (warning signs).
  Control of activities
  (drilling or excavating)
  Notice lo affected
  stakeholders (e.g., HLM,
  I-'&W, SluiUan Tribal
  C'ouncil, local county
  governments; State and
  HI'A), including notice of
  any change in land use
  designation, restriction,
  land users or activities.
  Property lease requirements
  including requirements for
 control of land-use
 consistent with the ROD.
 Notice lo affected
 stakeholders (e.g., Hl.M,
 F&W, ShoUan Tribal
 Council, local county
 governments; State and
 I:PA), including notice of
 any change in land use
 designation, restriction,
 land users or activities.
 Property transfer
 requirements including
 Finding of suitability to
 transfer and requirements
 for control of land-use
consistent with the ROD.
                                                                                                Regulatory
                                                                                             Basis/Aulliorily
                                                                                         H-A/CO.CHKCl.A
                                                                                         Section I20(h)(5),'l|all
                                                                                         Amendment Section
                                                                                         3154 of the National
                                                                                         Defense Authori/aiion
                                                                                         Act.'' DOI: order 5-400.5,
                                                                                         "Property Release
                                                                                         Restrictions."
                                                                                                                         I'FA/CO, CHRC1.A
                                                                                                                         Section 1 20(h )(.}),'
                                                                                                                         CKRCLA Section
                                                                                                                         120
-------
Table 11-1.  (continued).
( lump III
SIIIIKC \ic.i I line l-rame
"No I uillia DOI control
Action" (M A I post opci.ilmns
Slk-s

I'usl DOI-
lonliol

land COl'vaild
Restriction l-xpuMirc I hreat
Industrial
radiological
controlled

Industrial ID
2IW5,
residential
following
2(W5.

Objective
Control land Ube as Prope
protective and melw]
consistem with NI-A cmiirt
determination. con.sis
( 'onirol land use a.s I'rnpei
protective and requin
consisteiil with NI;A l:iiulin
determination. transit
I'nr mi
                                                                                                                 C'tinlmls
                                                                                                       Property lease requirements
                                                                                                       including requirements Im
                                                                                                       control of hind-use
                                                                                                       consistent with the ROD.
                                                                                                                                             Regulatory
                                                                                                       requirements including
                                                                                                       Finding «>!'suitability to
                                                                                                       transfer and requirements
                                                                                                       for control of land-use
                                                                                                       consistent with the KOI)
 I     \tilllu .llh in hi -.l.lli's til ILMM/S HlUtlwilL! OHtl.llllin.il It 111

 .*     Ki'i|in-,l KilU-IIIICIkC "I I l'.\ 111! IC.IM.-. Ill MM  SIIC>

 '     M.iiviin-ni in ilcctl lli.H  iciiii.-ili.il .H-linii is conipli-lc

 •I     II iciiicili.il .iclinii i> mil coiiiplclc. icMiicliiiii-.. rcspiHiM-. yu.ii.iiilcc, uml schalulc. budget a.ssiiranccs lo be melwlcil in deed

 s     ( l.imc .illiiumi! I S .n.-i-ess in |)ii>pcil\ ti> he niciiidfd indeed

 (i     Nonce nl iiiliinn.iliiiii mi lia/jnlou-, Mihslance In be incliidctl in deed

      lili-nnh uikiiiilninnuled parcels ol hind

 s     Viiiee nl nilciil In ichni|iiibli In DOI wilh anilaminulion inlbniKilinii and pruleetiiui needs.

 '»     I i.mslei In  IM)I should mdicaie L-onliniiuliiin ol DOI- responsibility

 In   Kcpmi mi coiilainiiiiiiuin iiiliiniuilum uml alloued land-use

 II    ' >i' is iiiiicsliiclcil allci icnicdi.ilioil aclu Hies, and iiislilulmiial conlroLs do nnl apply
ll-A.CO.t'KKCI A
Scelion 12(1(10(5).'
Amendment Section
3 1 54 of ihe National
Defense Auihori/aliini
Ael.-'DOl-; Order 5400.5.
"I'roperty Release
Restriction!,."
ri;A'C()CI-IU-|.A
Section 120(h)(.1),'
fliRl'I.ASeetion
CI-iRfl.A Sectio
                                                                                                                                     fl-RCI.A Section
                                                                                                                                     l20(h)(|).(3),"CI-RCI.A
                                                                                                                                     Section I2()(h)(4),;43
                                                                                                                                     (•|;R2372.I."4.U'I-R
                                                                                                                                     2374.2," 4 1 CI-R  101-
                                                                                                                                     Order 5400.5, "Property
                                                                                                                                     Release Resirictuins."
  Sun eillancelo Assure
    roniHils m-]ilace	
Syeai renew iiniil
determined to not he
needed.
5 year review until
determined to not he
needed

-------
                                   en     f bc prred K pm of the RD'RA
    Facilities.  The firs, Lni.ormg report wm feZifnS ^h" f USe°fl"s'it'''i<™' Control, a, Federal
    monitoring reports will be subLted annually the™ to  Ah" f       °f R°° Si8I""Ure The
    cor,ro,s is  a,so prov.ded ,„ ,he
                                                             K H
   OU 3-13 RD/RA activities and  DW w I be ,emDor  T       *   f"0^ in 'he ICDF'  WaslM
   disposition of these wastes wil  be       lTS"?^ ™? *f ^^ l° LDRs' The final
   -ter, personnel protects ^n^™       ™                      ^ *"*
   CERCLA remedies are Jlv implemented  The e con±naL  T ^'.T dUdn8 the PCri°d before the
   remediation waste, as the removal and "subse^m Ct°ntamina'ed soils Wlil be considered CERCLA
   progress toward cleanup             ^equent storage or d.sposal of any contaminated soil represents
  area *m*GT          ^ ^ 3 A°C
  CERCLA AOC. The AOC .lIoT^fl^^in' "       !f   ^ NIO) ^ be C°nsidered a
  implementing selected remedial alternatives               8 "^ Stagm8 nonconlig"°^ soils while
  11.1.1   Tank Farm Soils Interim Action (Group 1)
                            S                           Ta"k Fa™ Soils «*« sites has been


 at the Tank Farm until a final decision is made bv the Aafn,    ri      ,'   " Intenin actlon is sdected
 Soils Interim Action is Alternative 3- nsTiSona Co^frl Sih .  f'^ w" ^ f°r the Tank Farm
 will assure that public exposure to the contam^H °"i    .^    J^ W*ST C°ntro1- This alternative
 control to reduc'e water infiltratlngttoThe CO  an latd Ta  k FarT  T' T" ^ ^ ^^
 warning signs: administrative controls to resect accent     f   • fnstltutlonal controls include:

contaminated areas so that moure infilt  t on ,„     "TT""'5 (° dirCCt Water 3Way from the
diverted run-on water will be mSa » d a ^ "no f ,h e""™    '  ^"^mants are not mobilized. The
Run-off uaier from the sealed ITnl F,m  SI  be' ',',""' T^ ^^ ^'"^ ™™Z™™ sys^
-th leak detecnon. The .n-aponttn    d        o s  Sd and us^^t " " ^ ^^^
reduce infiltration in the INTEC are-i Ir u ,11 ,    conMrL"-t^ and used as a best management practice to
unplanned N,,ll or release                     C°nlam thc Ta"k Fami run-°ff in the event of an
                                             1-13

-------
        The goal of this action is to significantly reduce surface water infiltration into Tank Farm soils
  Reducing surface water infiltration into these contaminated soils is expected to limit leaching and
  transport of soil contaminants to the perched water and reduce available water in the perched zone
  INTEC-wide monitoring will be performed during the interim action period to evaluate potential changes
  in water content and quality in the perched water and SRPA. if they occur.

        The selected remedy provides an interim solution that reduces the potential for further soil
  contaminant leaching and transport to the perched water, reduces the available water in the perched zone
  beneath the  Tank Farm, and potentially minimizes further water quality impacts.  The Agencies believe
  this interim  action will  be protective of human health and the environment while the OU 3-14 Tank Farm
  RI/FS is being performed. Further, this action will comply with  ARARs, be cost effective  and be
  consistent with the final Tank Farm remedy and the Idaho High Level Waste and Facility Disposition
  Environmental  Impact Statement (HLW &  FD EIS) currently being conducted.

  11.1.2  Soils Under Buildings and Structures  (Group 2)

       The selected remedy for the Soil Under Buildings and Structures is Alternative 2—Institutional
 Controls with Containment. Alternative 2 is a deferred action and consists of implementing institutional
 controls and soil excavation or capping. The institutional controls include: warning signs and
 administrative controls to restrict access to the contaminated soils. For those areas capped in place
 additional institutional controls will  be instituted to prevent future disturbance of the caps. This action
 assumes that the contaminated soils  are currently contained in place due to the presence of the existing
 buildings and structures. The operation and subsequent demolition of these buildings and structures are
 outside the scope of this action. However, upon completion of D&D, an evaluation will be performed by
 the Agencies to determine if the soils, to a minimum depth of 10 ft bgs, contain contaminants exceeding
 the action levels specified in Table 8-1 of this ROD. If these action levels are exceeded then the
 Agencies will either cap these soils in place  in compliance with the substantive requirements of the
 hazardous waste landfill closure requirements or excavate and manage the soils as a Group 3 soil  as
 described below. If the buildings are demolished and closed in-place as a landfill under the D&D
 program, an assessment  will be performed by the CERCLA program to evaluate the effectiveness of
 D&D containment to meet the Group 2 RAOs and remediation goals, specified in Section  8  The  D&D
 containment structure would be augmented, as necessary, to meet these goals.

      Prior to D&D. and in addition  to the institutional  controls described above, a process will be
established as part of the Group 2 Remedial Design Work Plan, to review the effectiveness of the
buildmg(s) as aids in limiting infiltration through the underlying contaminated soils. This  evaluation will
consist of the following periodic steps being taken:

      I.   Review Operations maintenance of each building to be sure the buildings are  kept in a
           protective configuration.

      2.   Examine roof drains/surface drainage system to determine if water is percolating into the
           contaminated soils or is  being diverted somewhere else.

      3.   Monitor building or structure perimeter to determine  if (based on drainage patterns) there is
           enough moisture to exceed the field capacity of the soils. Determine how much seepage into
           the soil poses a problem.

     4.    If there is a seepage problem, upgrade drainage patterns and perform surface modifications
           .is necessarv.
                                             H-14

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        The final buildmg or .tructure and release sue conjuration u ,]] be assessed under the Group, ">
         -
  11.1.3   Other Surface Soils (Group 3)


        The selected remedy for Group 3. Other Surface Soils ,s Alternative 4A -Removal and On Sir -

  Disposal  Alternate 4A consists of excavating contarmnated surface so,ls and bacS^th s

  clean soils to reduce the risk from external exposure to < 1 x 10^  Sites will be backfilled ™H
       The excavated material will be disposed on-Site or off-Site. On-Site disposal will be an on S.r,.

 engmeered landfill, the ICDF.  The ICDF will be constructed under this aitenTi  O T sL d,s±  u-

 bem accordance w,th the Off-Site Rule (40 CFR 300.440). Prior to excavation, the micvcle cost
                                                                                 to
 rox
 the purpose of final placement of WAG 3 CERCLA soils The ICDF wi n,l  'SC.f/RCRA-co.mPl'™ for
 ,n ,NEEL-w,de d,sposa, fac.i.ty to accom^X*, o^cSL"    ^dtSol'r '°" "
                                      ™"""5,"1 FaC"1Iy (SSST) WI" al» te «cSand orL.ed
                                    ^^
                                                             ^
                             for long-term protection of human health and the e^Tnment
In.t.umonal controls w,ll be maintained at the ICDF as long as necessary- to ensure .on£e ™ protccuon.
 ,11 , .ht>      UI" redUCf Uie mtfral1 area' extenl of SO|J ^n^mmation at 1NTEC and the INtEL and
 ,11 ach exe cost sav.ngs relauve to off-INEEL disposal, or on-sue management because the oils vv'.H h •

        1                             '                                                   '1'
                  n                                                and const  cn
           t the ICDF sufficient to contain the Group 3 soils.
           T'cn?n Vf ' Pr°VldeS a f.hemalic cross-s^t.on of the ICDF facility. A conceptual cross

           Bamon  h« m 8"T    ^' ^,™ ****'** L00°-year deS'gn llfe (i'e- Hantbrd
           Bamo ). that may be used to cap the ICDF at closure is presented in Figure 1 1-2  ICD1-


           SLTTT;0"' OPCraI'°"- T^ Cl°SUIV °bjCCtlVCS lndudc: C°nstruct the 1C"DF ^'"'"

              V\  V i( HUtsanheTinr   , taC,  " mCetmS Wah° HaZard°US WaSte Manaucmen. Ac,
           (H\V MA), RC RA Subtitle C . and polvchlonnated h.pheml (PCB) landfill des,»n and
                                           11-15

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     I eachate Colleclion
     and Removal System

    l.oachate Detection,
    Collection, and
    Momoval System (LOCRS)
   Snurce: EMCON, 1988
                                             Double Liners and Leachate Colleclion Sysd

                                                        Components
                                      !em
                                    Protective Soil or
                                    Cover (Optional)
                                                                                                 |- Top Liner (FML)
Compacted Low-Permeability Soil
              	    y
                                                                               3' — 5' Minimum
                                                                               Depth to Bedrock
Bottom
Composite Liner
Upper Component
(FML)
Lower Component
(compacted soil)
                                                        Leachate Colleclion
                                                        System Sump
                                                        (Monitoring Compliance
                                                        Point)
Figure 11-1.  Schematic cross-section of the ICDF facility.

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     Notes:
        The ICDF will be closed with
        a final cap that will meet or
        exceed the performance of the
        RCRA Subtitle C MTG design
        and will meet all ARARs,
        RAOs, and RGs designed for
        the ICDF.

        This design is presented for
        discussion purposes. The
        actual barrier implemented will
        be developed during remedial
        design (RD).
   Water
  Storage
Component
 Capillary
   Break
Component

  Barrier
Component

   Fill
                                   Contaminated
                                       Soil
                                                                                                                      Contaminated Soil
 Cover Vegetation: Mixed perennial grasses.

 Layer 1: Silt loam topsoil with pea gravel admixture.
 Layer 2: Silt loam topsoil without pea gravel.
 Layer 3: Geotextile filter fabric.
 Layer 4: Sand filter layer.

 Layer 5: Gravel filter layer.
 Layer 6: Coarse, fractured basalt.

 Layer 7: Lateral drainage layer.

 Layer 8: Low-permeability asphalt.
Layer 9: Asphalt base course.
Layer 10: Grading fill.
Figure 11.2. (-onc,ptual CI,)Ss.sectmrl of |hc

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    construction requirements. The ICDF will be located within the WAG * area or
    contamination (AOC)  Design, construction, operational, and closure requirement 'bi •'-
    ICDF include:                                                            ......

          Designed to have a total capacity of approximately 466.000 in3 (5 10,000 yd:'»

          Engineered to meet IDAPA 16.01.05.008 (40 CFR §264.301) hazardous  waste
          40 CFR $761.75 PCB. and DOE Order 435.1 radioactive waste landfill desim 'and
          operating substantive requirements                                     ~

   -  .    Double leachate collection/detection liner system

         Minimum of 3 feet of compacted clay soils and flexible membrane liner (FML) will
         serve as the bottom liner

         The cap will be designed to minimize infiltration and run-on and maximize run-off

         Cover designed to protect against inadvertent intrusion for > 1,000 years

         Void spaces will be filled to minimize future subsidence.

   Only INEEL on-Site CERCLA wastes meeting the agency-approved ICDF Waste
   ;tCCrrn?Ceu?iteria (^C)' * be devel°Ped durinS the remed.al design, will be disposed :n
   the ICDF.  Wastes will be limited to low level radioactive, PCB  solids, hazardous and
   mixed low level waste.  An important objective of the WAC w,ll be  to assure that'hazardous
   subsrances disposed in the ICDF will not result in exceeding groundwater quality standards
   in the underlying groundwater aquifer, even if the ICDF ieachate collection system were to
   tail atter closure.

   Located in an area meeting hazardous waste, PCB waste and low-level waste (LLW) landfill
  siting requirements. Through a preliminary evaluation of all relevant decision criteria the
  Agencies have determined the Study Area for siting the ICDF to be the CPP-67 Perco'lation
  Ponds and adjacent areas to the west. However, the specific ICDF cell locations will be
  determined through the completion of a comprehensive geotechnical  evaluation of the ent-r-
  btudy Area, which shall be reviewed and approved by  the Agencies.  Siting criteria for the
  location of the ICDF included:

       Outside the 100-year flood plain

       Outside of wetland areas

       Not in active seismic zones

       Not in high surface erosion areas

       Not in an area of high historic groundwater table.

• The construction and operation of an ICDF supporting complex including a facility waste
 storage, sizing staging, and treatment (SSST) facility in accordance with the substantive
 requirements of IDAPA 16.01.05.008 (40 CFR 264 Subparts I, J, and  DD). Operations at
 the facility will include chemical/physical treatment to prepare ICDF wastes to meet
 applicable Waste Acceptance Criteria and RCRA land disposal restrictions.

 One or more remedial waste staging and storage areas will be utilized  to stage and hand's
 remediation waste.  The storage area be operated in accordance with the substantive
 requirements of IDAPA 16.0105.006.01 and 16.01.05.006.02 (40 CFR 26~> 34[u'f!',
                                  11-18

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       •     \Ionuormg uell construction and Campling wastes generated prior to construction of the
             1CDI- and SSST facility (i.e.. purge \\aierand drill catlings) may be managed and treated
             using remediation waste staging piles and temporary treatment units  in accordance with the
             substantive requirements of IDAPA 16.01.05.00$ (40 CFR 264.553 and 40 CFR 264.554).

       •     Treatment will be accomplished using mobile tankage and physical/chemical treatment and
             will comply with the substantive requirements of IDAPA 16.01.05.008 (40 CFR ?64 Suboart
             J. BB. and CO.                                                          ~      F

       •     An evaporation pond will be constructed and designated as a corrective action management
             unit (CAMU) in accordance with the substantive requirements of IDAPA 16.01.05.008 (40
             CFR 264.552 and 40 CFR 264 Subpart K and CC) for purpose of managing ICDF leachate
             and other aqueous wastes generated as a result of operating the ICDF complex.

             Operate, close, and post-close the ICDF Complex in accordance with the substantive
             requirements of IDAPA 16.01.05.008 (40 CFR 264 Subparts G, F, and N) Maintain site
             access restrictions and institutional controls throughout the post-closure period.

 Closure requirements will include:

      •      Access restrictions to prevent intrusions into the closed area, including the creation of a
             buffer zone surrounding the capped ICDF and supporting structures

      •     Access controls, monitoring and maintenance will remain in place for as long as the contents
            of the landfill remain a threat to human health or the environment if uncontrolled.

      The best  location to site the ICDF was evaluated using the analytic hierarchy process (AHP)
decision analysis technique.  Figure 11-3 shows the AHP decision evaluation criteria used in the
preliminary ICDF siting evaluation.  Based on this evaluation,  it was determined that locating the facilitv
within the AOC was the most cost effective and ARAR-compliant location for siting the ICDF. The   '
Agencies have determined the Study  Area for siting the ICDF to be the CPP-67 Percolation Ponds and
.Kljacent areas to the west as depicted in Figure 11-4 based on the preliminary geotechnical information.
I lowever. the specific 1CDF cell locations will be determined through the completion of a comprehend e
ueoteehmcal evaluation of the entire Study Area, which shall be reviewed and approved by the Agencies.

      The preliminary suing evaluation criteria included:

      •     Public health and safety  (e.g.. effects on surface water, effects on groundwater, floodplam)

      •     Natural environment (e.g.. effects on the habitat of rare, threatened or endangered species i

      •      I echntcal (e.g.. depth to bedrock, underlying soil properties, perched aquifer protection i

      •     Social Economic em ironment (e.g.. effects on future land use)

      •     Cultural Environment (e.g.. effects on archaeological or heritage sites)

      •     Community acceptance (e.g.. public comments. Citizens Advisory Board comments)

      •     Cost.
                                            11-19

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                                     I r'lil.ln  III..,)!!, \ ;

                                     ! •  .11.           If
     .jetfeus on hurtle Dusigii L




     | b Heels o,, Soffit t.w.,iui




     I HIcU:, (in < ,IUUMI;





      A5!»HiH|i^JllCiiH.ja«rH.y jk^i
              —— •—™. ..    -ni  U,-
                                                                             1
                                    I  N.ilni.il        }

                              -      !Ci""'"	".'   r






L''.a,,!al"'   ^                    !S...u.»'F,.,,„„,„,I
               t_                   ;  LiiviiiiMlnniil    I
                                     t M
                                     - ............
                                     Comnlullily  I

                                     Com ernv,    r"
                                                                               EIIc.'c.ts mi Aii.hiiul(ii|ii.,(|

                                                                               Resources
                                                                                                                                     m*  INCLLWA. 5J..1 A,,.'.,
                                                                             PuithedAquitu, P,un,,uty



                                                                             Easeof Moniiimnu
                                                                             Soil Suitability lor

                                                                             fcnguiecred Slruciuios'
                                                                                                                                            INI I I (BXlJurlllKJ »J)
             rtv"sory Co


-J Public Commenls,
                                                                                             ,0>K si,i

-------
                                                                                                                                             INTEC
                                                                                                                                         Depth to Basalt Map
Figure 11-4. Proposed Stud; Area :br the ICDF.

-------
         Figure 1 1-4 shows the proposed Study Area that the ICDF is to be sited m.

         In special circumstances (e.g.. Sue CPP-37b). where a source area is located so as to become part
   protection standards applicable to the
                                               e met.
         Although more costly than Alternative 3. which requires capping each Group 3 sue m place  the
  health and the environment, complies with ARARs. is a permanent solut.on. and is cost-effective

  1 1 .1 .4   Perched Water (Group 4)


  Rechar^Commf ^'^ ?" ^'^ Water 1S Alternant 2-Insututional Controls wuh Aqu.fer
  RcJurge Control  Alternative 2 is comprised of institutional controls in the form of administrative
  actions to restrict future use of perched water and implementation of remedies to control infiltration
  and m,nim.ze perched water releases to the SRPA. The institutional controls include         Inl'"™,on

        •     Site access restrictions

        •     Warning signs on wells screened in the perched water

        •     Locked and labeled wells screened in the perched water

       •     Well drilling/water usage restrictions

       •     Radiation surveys

       •     Environmental monitoring

       •     General maintenance and upkeep.

       The DOE will periodically inspect and repa.r the waminjj siuns. conduct environmental
 monuormg and perform routine mamtenance and upkeep, as necesW  Land use contm "v II renrun m
 place mdehnuely  to prevent unauthorized drilling through the contaminated perched zone

      Perched water monitoring will include sampling and analysis of existine and new perched uat,-r
 uells to determme changes in the area, extent of perched water (water levels and hvdau'c head )  n

 m^tiSe^ d   f ^ COnteiYnd C0mammant °f C0ncera (C°C) concentration* w it
  .;     "I th_6 Pen*ed ""tor zones to determine if water contents and contaminant fluxes are decrcasm-

               °           *      "***      ' "   °
       hmna   n    SR     n       -
       l  ,mpaa.> to the SRPA.  I he spec i tic mon.ionnjj to determme perched water dram-out u ,|| ho
dcMrnbcd ,n the «0l 3-13 (iroup 4 Post-ROI) Monuonnu Plan. The momtorm, w,l! be pe tb ,      r ,
m mmum o, 20 >-ears after the percolat.on ponds are removed from service. The perched water, n
r ate,  ,o the existing percolat.on ponds are calculated to dram out m approximately 14 vears from the

      '     "                          '
b
N.
                                r                  '            -                  -on
                      prov.de addu.onal perched water mon.tormi! locations. If after s vears  the
                                            ! 1-22

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        Additional controls may include:

        '
            Curta.ling steam condensate discharges to the subsurface
                  .   . »«»,SSppS±lT.'i!!nr ga.!lCT1K: Subs'"- *=.	«<"« •"• •«
            need to be sued and constructed
                                   in
 reduce the water content
 SRPA. Computer simulations
 ' 70«i of the
                                                                       -P^ to the
                                                                    ™S ""^ 'S
                                                                     "« M«, to be
                                      r tructed at a
 perched water beneath INTEC    e bcatns W the ^ re";ain ' ^^ S°UrCe tO the ^ntam'mated
 P-vsence of perched water at the cu^enn ^  , ^ ^oondf ^H  ""^ T"'5 "'^ "^ O" the measured
 "spread" of water from new percoiaTi on nonds in h P    andsround water modeling.  The amount of
 mterbed parameters from the ^U   3 v^ i^dose zo^J^0^^1^ W3S modded usin= lh^
 are located so that perched wafer from the^r^s^ T   '' FS' Appmdix F)' llie new
 INTEC. F.gure 1 1-5 shows the proposed ^bcatfon ?f rhP    ,     °Ontamin;ited Perc"^ water beneath
evaluated ,n selectmu a new locaZ tbr th      1     replacement percolanon ponds. Other factors
rare, threatened, or ^^^S ^^ 1™™S ^ P°^ ^ °f
cultural and historic artifacts.
                                              " '" areas that have been surveyed for
per:
:o asMiivIhat 'tins conungencVo^rauon undc^          '""K " PI"°Vlded Pri°r tO the rtfmoval ^

.^^:r^°^r^±:£ r^^"1*Howew-duc lu lhc
    Agency, pursuant to this ROD dunnu the interim oeru
                              ~  ». imcnm periou uuu u^fjinraDie permits are souizht.
     1'he Ciroup 4 remedy will include:

         Remox ,ng the c.Mstmg percolation ponds from >er\ ,ce

                  ig lavxn irrigation at the INTW where necessarv!

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o
«tmt
Kim
tMJXO
tnm-
MUOO-
tum-
4UAOO-





f


                                                                                                                      New Percolation
                                                                                                                         Pond Area
                                                                       I   '	1	'	1	•	1	•	1	•	1
      Figure 11-5. Location of replacement percolation pondi.
                                                                                                                                    11-24

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                                        aS* "*« «***• «« Big Los, River, reding

     -moving UK existing STP lagoos and      afiotS,S"f "c? "'^ '° the s*surfL ,"f

                                      ^
                                                                   ,„,„ ,he AgenCies detem,,ne
    con,ro,s „„, _>„ to res(r|c,                  c
                                                                           proving ov
   11.1.5  Snake River Plain Aquifer Interim Action (Group 5)

             aqU,fer is expect ,o    aabo« MCL°       "^ srou"dwaK' """ng ,he ,ime ,he


                            ..
             •han 0.5 gpm. which is consideredhe m°n mum dr f"" '! Cap>b'e of !«*«*'« more
             aquifer ,o serve as a drinking w™r sup™"           8 WaMr yie'd neCMSary forthe
                     a«er 2095 in
         ,hey are no longer necessah  five ,\ S^'T "",' ^ CO°dllCted UWil *e

          and ,he need for i,s con.inua.ion A'^^.''*''''™
                                                                                  «-..
con,amma,ed SRPA „„,„ ,he vear
     •     Area access restrictions



     •     Land use res,ric,ions ,o preven, ,he .ns.aiia.ion of.a.er supplv ,e,,s ,„ ,he SRPA pr,or ,„




     •     A X«.« or A.™™ „,„ afreet fedora, and toe., Soveramen, stakeho,de,>
                                         11-25

-------
        •     Warning signs on wells screened in the SRPA contaminant plume

        •     Locked and labeled wells screened in the SRPA contaminant plume.

  nfm JLaddili0n,!° ^^ Tr*' environmental monitoring and general maintenance and upkeep
  ot momtonng wells will be conducted for as long as it is determined that monitoring is required.

  11-1-5.2   Groundwater Monitoring. Groundwater monitoring activities will be conducted
  throughout the institutional control period to evaluate  the concentration and extent of contaminants in the
  SRPA. Monitoring will cease tf the regulators determine there is no unacceptable risk in the aquifer
  Monitoring will include sampling of the SRPA using new and existing wells to determine the SRPA'
  aquifer intervals with the highest  concentrations of groundwater COCs. The specific groundwater
  monitoring acuons will be described in the OU 3-13 Post-ROD Monitoring Plan that will be developed
  frSr,?^-   8T    SUmmary °f thC gr°undwater monitoring actions that would trigger subsequent
  treatability studies and contingent remediation is shown on the decision How chart in Figure 1 1 -6
  Groundwater modeling presented in Appendix B of the FS Supplement (DOE-ID I998a) suggests that the
  h,ghest I- 1 29 concentrations occur in the H-I interbed of the SRPA. The modeling accounts for
 auenuanon and dispersion  The H-I interbed is a sedimentary interbed that is located approximately 38 m
 (125 ft) below the top of the SRPA water table. The water table at INTEC occurs at an approximate
 depth of 40 m (460 ft) beneath the INTEC. The H-I interbed is about 7.6 m (25 ft) th^k and  hSa ,ow
 penneabiUty (4 ; mDarcy).  The mode! also assumed that potential releases of contaminated perched
 to the SRPA will be controlled by removing the existing percolation ponds from service.
 COP hoi        *?UndpWater TlfT, 3nd Samp'ing WiU be conducted to determine the location of
 £??, ? T  r £   m J-I8T     >- Monitohn8 wells wil] be insta''<* at the predicted hot spots alone
 the centerlme of the predicted plume. Packer tests will be used to determine the zone(s) of highest

 wirbToTtanTed^r^1'11 * T^"** the action levels <™e 8-2). Groundwater quality data
 will be obtained from the SRPA intervals containing the highest COC concentrations to determine if these
 concentrations exceed the action level(s) (Step 2 in Figure 1 1-6). The action levels are based on the
 modeled maximum concentration of the COCs measured in calendar year 2000 that are expected to yield
 individual contaminant concentrations above the MCLs in the SRPA outside the current INTEC security
 fence m  09>. Contaminant transport studies, and refinements to the contaminant transport model will "
 continue during the institutional control and monitoring period. The action levels will be reviewed at
 each 5-year review and adjusted as necessary to insure that RAOs are being met.

      If the action levels are exceeded (Step 3 in Figure 1 1-6), isopleth maps will be developed using the

hot^rr1",'" I'V'lr  ThC iS?leth mapS Wi" be deVe'°ped (Step 4 in Figure ' !-6> <° determine'f the
 f« m  M      of sa fic.ent volume to provide an unacceptable risk to a hypothetical wtmndwater user
 lor more han one year (Step 5m F.gure 11-6).  The isopleth maps will be prepared to determine if the

ulrrtn.nhiT0-!133,? I T™ "*?"* ^ "*' ** ^P^UK dural]on would be to° short to P«senfan
unacceptable mk. If the hot spot is small, or if it moves too quickly to present an unacceptable risk then
no further active measure would be pursued, but monitoring would continue and the data and model'in»
\\ould bo rex lewed at the 5-year review  period.                                                 °

            If the contaminated aquifer interval exceeds the COC action level(s) and is of sufficient
            \olume to potentially expose a hypothetical groundwater user to an unacceptable risk
            representative wells will be selected to determine if the affected portion of the SRPA is
           capable ot producing a sustainable yield (for at least 24 hours continuous pumping of more
           than .)..-> sprn (Step 6 in Figure 1 1 -6). The 0.5 gpm pumping rate is based on the minimum
           amount ot drinking water necessary to sustain an axeraue household. The wells that are
           >elected to determine these limits »il| he screened oxer the aquifer interval exhibiting the
                                             1-26

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                      Step I
        Perform modeling and sampling of the
             SRPA contaminant plume.
                     Step 2
        Identify vertical and lateral location of
                    hot spots.
                    Step 3
                   Does COC
                           Does not exceed
              concentration exceed
                action levels (I )•'
                    Step 4

      Develop isopleth map of SRPA I-129
                concentration.
                                               PERIODIC MONITORING
                                                 Does riot exceed
                   Step 6
     Determine potential sustainable yield
             of hot spot zones.
                                            No
                 Steps
    Prepare RD work plan pursuant to the
       '•FA CO to include necessary
        tritttubility study work plan
                                                                     Notes
                                              (1)  Action level for COC determined by
                                                  computer simulation

                                              (2)  Action level for volume determined by
                                                  field mapping of extent of secondary
                                                  source exceeding COC action level and
                                                  computer simulation of potential impact
                                                  on restoration timeframe to meet RAOs
                                                 and RGs.
                                             The RD work plan will contain the schedule
                                             and process for implementing the continent
                                             remedial action.
Figure 11-6.  SRPA
contingent remediation decision flou chart.

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  highest concentrations of COCs. If the water yield is greater than 0.5 gpm on a sustained basis  and the
  action level(s) is exceeded (Step 7 in  Figure 11-6). then active remedial action will be pursued  If
  monitoring does not support the need for remedial action, periodic groundwater monitoring will be
  continued and the data reviewed during each 5-year reviews until restoration is achieved.

             Treatability Studies and Contingent Remediation.  If all of the above described
             criteria (Steps  1 through 7 in Figure 11 -6) are met for a well screened in the SRPA.
             treatability studies will be performed (Step 8 in Figure 11-6). The treatability studies may
             include analytical calculations and/or numerical modeling, pumping tests, and bench- or"
             pilot-scale treatment testing. The treatability studies will determine if long-term pumping
             from the affected interbed is feasible and whether the COCs exceeding the action level(s)
             can be cost-effectively removed from groundwater.  In addition to [-129 and other COCs the
             treatability studies will also evaluate the presence of mercury, Sr-90, chromium. Tc-99, and
             tritium, all of which are known or are predicted to be present in the groundwater plume at
             significant concentrations. While these contaminants are not long-term risk drivers, they
             may foul the groundwater treatment system or pose radiological exposure concerns if
             brought to the surface for treatment. Further monitoring will be performed to define the
             optimum path forward. The treatability study will be developed during RD  if needed.  If the
             treatability studies determine that selectively pumping and treating contaminated
             groundwater from the affected portions of the SRPA will meet the MCL(s) in 2095, and
             treatment and recharge or evaporation of treated groundwater is implementable and cost-
            effective, then Remedial Design and active remediation will be implemented.

       Prior to installing a pump and treat system, the COC action limits will be verified or reestablished
 by additional modeling using the data obtained from the new monitoring wells, the packer tests and
 pump/yield/concentration data.  The duration of pumping  and treatment will also be estimated using  the
 model. If treatability studies determine that pumping the affected SRPA interbed is not technically
 feasible, then a technical impracticability waiver will be sought through a ROD Amendment.

       Active remediation would consist of:

       •     Contingent pump and treat remedial action will be implemented if groundwater monitoring
            determines  that combined COCs in groundwater exceed their respective action levels in the
            year 2000 or during subsequent monitoring. The action levels are based on modeling that
            predicts that individual or combined contaminants will exceed MCLs in the year 2095 for
            portions of the aquifer that is capable of sustaining a production of rate 0.5 gpm.Components
            of the pump and treat action include:

                  Installation of extraction wells to remove the zone of maximum contamination or hot
                  spot

                  Above ground, on-site physical chemical treatment of the extracted water in
                  compliance with ARARs

                  On-site recharge to  the SRPA or e\ aporation of the treated effluent in compliance
                  witliARARs.

      The treambiliu  studies u ill consider the presence of all contaminants. Mercury, Sr-90, chromium.
Tc-W. H-3. are  known or are predicted  to be present  in the SRPA at signiilcant concentrations.  Although
the.-.e additional  contaminants are not necessarily long-term risk-drivers, they become problematic once"
brought to the surface  for treatment because they may foul  the treatment system or may pose radiological
                                             11-2S

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                              °f TC'"  '" addi"0n' a" C°maminan ts mus< be removed ^ below
                     u                ,          '
            treated groundwater is injected into the aquifer.
      Although Alternative 2A is less costly than the selected alternative 2B, it does not provide anv
reduction ,n tox.ary, mob.Iity or volume through treatment and may not mee the RemedfaTIctLn

S5rAXS??B^?± l° drinking7ater ^y b>' '  linder
                                           1-29

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        •     Treatment of cylinders containing acetylene or hydrofluoric acid having inoperable valves
              following vaKe replacement or recontainerization and subsequent disposal or recycling of
              the cylinder.

        A contractor specializing in gas cylinder removal, treatment, and disposal will perform the
  activities associated with this alternative.

        After removal of the cylinders from the burial sites, a post remediation survey of each burial site
  will be performed to determine earthwork requirements for the final grading. The burial sites will be
  graded to blend with the surrounding topography. Clean fills for thermal grading will be obtained from
  an onsite borrow source if necessary.

       The Agencies may elect to pursue a contingent remedy of capping in place pursuant to the
 substantive requirements of IDAPA  16.01.05.008 (40 CFR 264.310) if safety concerns with excavation
 and removal prevent implementation of the selected remedy.

       Alternative 2 is selected because it best meets the five balancing criteria while providing overall
 protection of human health and the environment. The Agencies believe the selected alternative is
 protective of human health and the environment, complies with ARARs. uses a permanent solution and is
 cost effective.

 11.1.7   SFE-20 Hot Waste Tank System (Group 7)

       The selected  remedy for the SFE-20 Hot Waste Tank System is Alternative 4—Removal,
 Treatment, and Disposal.  Alternative 4 consists of:

       •     Institutional controls (i.e.. warning signs') until the removal of the tank liquid and sludge

       •     Sampling the tank contents

       •     Removal and ex situ treatment of the tank liquid and sludge

       •     Excavation and removal of the tank, tank vault, pump pit enclosures and other associated
            structures

       •     On-.site disposal of the tank and associated structures.

       Following characterization, the tank liquid will be removed and treated at the PEW evaporator if it
meets the specified waste criteria. The tank sludge will be removed and treated (ex situ) using a suitable
grout to solidify and stabilize the contaminants in the sludge. The stabilized sludge will then be drummed
and disposed either on-Site or off-site at a suitable engineered disposal  facility. Depending on waste
characteristics, the remaining components of the tank sy-»tem will be exca\ ated. removed, and disposed in
the ICDF or off-site, depending on whether they  meet the ICDF waste acceptance criteria.  The
cxcasation will be backfilled.to grade with clean soils.

      it i* assumed  that the liquid within the SFE-20 tank w ill meet the PEW  WAC. The liquid contents
of the tank are consistent with previous INTEC waste processed through the tank system and discharged
to the PEW.  However, if the PEW is unable to accept the liquid wa>te or is unavailable at the time the
respond action is conducted, a small portable evaporator um. would be utilized on-Site: or the waste
would  be disposed off-site in accordance with the Off Site Rule (40 CFR 300.440).
                                               I -30

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   11.1.8   Future Site Closures Under RCRA and D&D

   wil, h f" ^diti0n t0 !he l0' CERCLA SiteS addressed in this ROD< approximately 79 INTEC facilities
   w.il be undergo,ng closure under RCRA/HWMA and D&D in the future, after this ROD becomes final.
        To minimize duplication of resources and in keeping with the RCRA/CERCL A PaHtv pniin

  determme that the closure plans include an approach that ensures the foUowing
       •     Both RCRA/HWMA and D&D closures of INTEC facilities will satisfy RAOs and will not
             add s.gmficantly to human health or environmental risks.
       •     Risks to human health and the environment resulting from any residual contamination
                                ated and mmimized in °rder to be c°nsistent with the RA"°
  11.1.9   Five-Year Reviews


 11.1.10  Post-Closure Care and Monitoring



                11.2  Estimated Costs of Selected Remedies
cos, - rJ"b'C;S '» ' "2 Lhr°UghM! ' '* Pr°VideS the CStimated CaPital and °Peration c^^ for each group  The
                                          I-3 I

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                11 .3  Expected Outcome of Selected Remedy

            f>UPS- exT the Tank Fami and SRPA interim actions, the expected outcome of the

                                                   i these sites J b

 grade ,f necessary), backfilled with clean fill, and revegetated where appropST Where Tcap is n

 ±n' HerarUP t0 the,edge °f thC C3P WHI b£ aV3ilabIe for indus'ri" ^- Where soils have been
 removed, the former soil site will be available for industrial use.


  ,r . G;°UP 3' Other Surface Soils, will have been excavated and disposed in the ICDF or suitable

                               iwil1 be fi"5d """ dean
         d^^^^
potentially will contain CERCLA wastes from other parts of the INEEL The can of L f  r?'   n u









    e SRPA. will meet MCLs oulsidc of the current INTEC security fence bv '
            lro  w  ' be implemeniMi io prev=m the use °r ^u"d— tai
                                                               « >* -ailable for


                     Ho' Wastt ™k System- >vi
                                       1-32

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   !    n      Es'ima'ed CaPjtal and Operations Costs (6 years) for Tank Farm Soils Interim Action
 Selected Alternative 3.  Costs are in  1997 dollars except as noted.	
                      Elements	Estimated Costs in S
  Capital Costs
  FFA/CO Management and Oversight3                                   1 574 000
  Remedial Design*                                                      235 000
  Remedial Action Construction"                                        j Q -786 000
  Total Capital Cost in FY97 dollars                                     12 Q96 000
  Operation Costs
  Remedial Action OperationsJ                                            49, QQQ
  D& DofFacilities                                                          NT.
                                                                             NA
 Surveillance and Monitoring                                           3 679 QQQ
 Total Operation  Cost in FY97 dollars                                   4,170,000
 TOTAL PROJECT COST IN FY97 $'.                              16,266,000
 Total Capital  Cost  in NPV                                             11,428,000
 Total Operation Cost in NPV                                           3 ?25 Q()0
 TOTAL PROJECT COST IN NPV                                 15,153,000
 a. Includes Program Management. RA documentation preparation. RD RA SOW RA Work Plan  Packaei™ Shmn.no
   TranSportat,on documentation. RA Report. WAG-wide RA 5-yr review. RD documemauon preparation lafetSvsis
   documemat.on. Samplmg and  Analys.s Plan, and Pre-Final Inspection Report.                         V    '
b. Includes added institutional controls and title design construction document package.
c.  Includes sue charactenzat.on. construction subcontract, and project construction management.
                         it. continued and new construction caretaker maintenance, operations, maintenance, matenals.
                                              1-33

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  Table 11-3.  Estimated Capital and Operations Costs (100 years) tor Soils Under Buildings and
  Structures Selected Alternative 2.  Costs are in 1997 dollars except as noted.	

 —	Cost Elements	   Estimated Costs in S	
  Capital Costs

  FFA. CO Management and Oversight4                                   6.748,000
  Remedial Design"                                                       910 000
  Remedial Action Construction''"                                           524 000
  Total Capital Cost in FY97 dollars  ,                                     g, \ 82,000


 Operation Costs

 Remedial Action OperationsJ                                           9.032,000
 D&Dof Facilities                                                          NA

 Surveillance and Monitoring                                             676,000
 Total Operation Cost in FY97 dollars                                   9.708,000
 TOTAL PROJECT COST IN FY'97 S's                             17,890,000


 Total Capital  Cost in NPV                                              5 ] 93 QOO

 Total Operation Cost in NPV                                           4.076.000

 TOTAL PROJECT COST IN NPV	                         9,179,000
a. Includes Program Management. RA documentation preparation. RD RA SOW. RA Workplan. Packaging Shipping
   Transportation documentation. RA Report. VVAG-wide RA 5->r review. RD documentation preparation. Safety Ana'lvsi-,
   documentation. Sampling and Analysis Plan, and Pre-Kmal Inspection Report.                         '     "
h  Includes  added institutional controls and title design construction document package.
c  Includes  Mte characterization, construction subcontract, and project.construction management.
d  Includes  Program Management, continued and new construction caretaker maintenance, operations, maintenance material-,
   Jiid disposal.	____	
                                               I ! -34

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  Table 11-4  Estimated Capital and Operations Costs (100 years) for Other Surface Soils Selected
  Alternative 4A.  Costs are in 1997 dollars except as noted.  	_'      ieiected
  	Cost Elements	Estimated Costs in S
  Capital Costs
  FFA/CO Management and Oversight3                                 5 j 99 000
  Remedial Design"                                                   , 699 000
  Remedial Action Construction0                                     85 056 000
  Total Capital Cost in FY97 dollars                                  9, <955 000

  Operation Costs
  Remedial Action Operations'1                                       11 514 000
  D&D of Facilities                                                        MA
                                                                          NA
 Surveillance and Monitoring                                        8 213 000
 Total Operation Cost in FY97 dollars                                 19727000
 TOTAL PROJECT COST IN FY97$'s                           111,682,000

 Total Capital Cost in NPV
                                                                  76,626,000
 Total Operation Cost in NPV                                        8 283 OOQ
 TOTAL PROJECT COST IN NPV                                84,909,000

 °
b. Includes added institutional controls and title design construction document package.
c.  Includes site characterization, construction subcontract, and project.construction management.
                                      eW eonslnjctl™ «T ™>ntenance. operations, maintenance.
                                             11-35

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  Table 11-5.  Estimated Capital and Operations Costs (100 years) for Perched Water Selected
  Alternative 2. Costs are in i 997 dollars except as noted.
                  Cost Elements
  Capital Costs


  FFA CO Management and Oversight"1


  Remedial Design1*


  Remedial Action Construction"


  Total Capital Cost in FY97 dollars
Estimated Costs in S





     5,036,000


     3,774,000


     9.445,000


    18.256.000
 Operation Costs


 Remedial Action Operations'1


 D& D of Facilities


 Surveillance and Monitoring


 Total Operation Cost in FY97 dollars


 TOTAL PROJECT COST IN FY97 S's
    8.171.000


          NA


    2,892,000


   11,063,000


   29,319,000
Total Capital Cost in NPV                                            , 5 j20.000


Total Operation Cost in NPV                                         4 645 000


TOTAL PROJECT COST IN NPV                                  19,965,000


            ogram Management. RA documentation preparation. RD RA SOW. RA Workplan. Packaging Shipping
            :,on documentation RA Report. WAG-wule RA 5-yrrex.ew. RD documentat.on preparation. Satetv Analvs.s
              i. Sampling and Analysis Plan, and Pre-Fmal Inspection Report.

h  includes added institutional controls and title design construction document package.

c  Includes site characterization, construction subcontract, and project construction management.

                i Management, continued and ne« construction caretaker maintenance, operations, maintenance, material;,.
                                               1 1 -36

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                                                                           *
                                                                                              ""•*"
                  Cost Elements
   Capital Costs
   FFA/CO Management and Oversight"1
   Remedial Designb
   Remedial Action Construction0
  Total Capital Cost in FY97 dollars

  Operation Costs
  Remedial Action Operations'1
  D&Dof Facilities
  Surveillance and Monitoring
 Total Operation Cost in FY97 dollars
 TOTAL PROJECT COST IN FY97 $'s

 Total Capital Cost in N'PV
 Total Operation Cost in NPV
 TOTAL PROJECT COST IN NPV
Estimated Costs jn S

      5,300,000
      4,302,000
     14.855,000
     24,457,000
    16,141,000
     1,647,000
    16,911,000
    34,699,000
    59,156,000

   20,701,000
    19,149,000
   39,850,000
a.  Includes Program Management. RA documentation preparation, RD/RA SOW RA Workolan  Parkin. «ih'
   Transportation documentation. RA Report WAG-wide RA S vr rev.euT nni     WorkPlan- Packag"ig, Shipp.ng.
   documentanon. Sampling and Analysis^, an?^Sinai In^on R^^^^ mt™~ S*fe*
b.  Includes added mstitutional controls and t.tle design construction document package.
c.  Includes s.te charactenzat.on. construction subcontract, and project construction management.
                          t' C°m'nued and "- —'- canker maintenance, operat.ons. ma.ntenance. mater.als.
                                               1-37

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  Table 11-7.  Estimated Capital and Operations Costs {100 years) for Buried Gas Cylinder Sites Selected
  Alternative 2. Costs are in 1997 dollars except as noted.	

 	Cost Elements	;	;	Estimated Costs in S	
  Capital Costs

  FFA=CO Management and Oversight11                                    92"> 000
  Remedial Designh                                                       48 QQQ

  Remedial Action Construction"                                          955 000

  Total Capital Cost in FY97 dollars                                     1.926.000


  Operation Costs

  Remedial Action Operations'1                                                 ^ *
 D&D of Facilities                                                          N(SL

 Surveillance and  Monitoring

 Total Operation Cost in FY97 dollars
 TOTAL PROJECT COST IN FY97 S's                              1,926,000


 Total Capital Cost in NPV                                             I  ^34
 Total Operation Cost in NPV

 TOTAL PROJECT COST IN NPV	                        1.834,000
 a, Includes Program Management. RA documentation preparation. RD. RA SOW, RA Workplan. Packaitinii Sh.pnlnlJ
   Transponation documentation. RA Repon. \VAU-w ide RA 5-vr reu^v. RD documen.at.on preparatmn. Safen An'alvM,
   documentation. Sampling and Analysis Plan, and Pre-Fmal Inspection Repon.
 b  Includes added institutional controls and title design construction document package.
C  Includes site characterization, construction subcontract, and project construction management.
J. Include;, Program  Management, continued and ne* cons.ruct.on caretaker maintenance, operations, maintenance, matenak
   jnu uisposal.	

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               .  Estimated Capital and Operations Costs (100 years) for SFE-20 Hot Waste Tank System
               emat.ve 4.  Costs are in 1997 dollars except as noted.                             *
                                                                        —
  	-C°st Elements	.	Estimated Costs in S
   Capital Costs

   FFA/CO Management and Oversight3                                     862 OQO
   Remedial Designb
   Remedial Action Construction1-                                         3 oog
   Total Capital Cost in FY97 dollars                                      4 ?63

  Operation Costs
  Remedial Action Operations'3
                                                                             NA
  D&Dof Facilities
                                                                             NA
  Surveillance and Monitoring                                                 NA
  Total Operation Cost in FY97 dollars
                                                                             IN A
  TOTAL PROJECT COST IN FY97$'s                               4,763,000

  Total Capital Cost in NPV                                             4 639 OQO
 Total Operation Cost in NPV
                                                                            NA
_TOTAL PROJECT COST IN NPV                                    4,639,000
                                                                RA *«**"• ^^ Shipping
    documentat.cn. Sampling and AnalysiSL and Pr^ Fina" Se^nReor; J—at.on P«P««ion. Safety Analvs.s
 b.  Includes added institutional controls and t.tle desiun constructs document package.
 c.  Includes site characterization, construct.on subcontract, and project construction management.
                           - C°minut-'d «« «»• "-«»«™:,,on caretaker ma.ntenancl opera,,ons. maintenance, matena.,
                                               ! -39

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                           12.  STATUTORY DETERMINATION
    requirements of the FFA-CO for the INEEL  Reu a o  ^"l01* COntained '" the NCR. and the
    group is summarized in the follortn**^^^"1*11™? fT Cach selected remedy for each
    NCR (i.e.. protection of human health ^tewf^^JT ^lhKShold criteria ""Wished in the
    requ-res that the remedy use permanent so uhon"  nd aTernaTilT' '^ *'? ARARS)" CERCLA also
    extent practicable, and that the implemented act "on 1  hTT £    "' technol°g'es <° the maximum
    preference for remedies that employ trea"mentTat pe^anenT    ^% ^^ the Statute indud«a
    tox,c,ty, or mobility of hazardous wastesmt^pnSeS^ ^^ «"«ces the volume,
    with rad.onuclides, effective treatment technologies are c^lnT   ^."""y of the sites contaminated
                                             ^^



             12.1  Protection of Human Health and the Environment
                                                                  rhe
                                 this

   12.1.1   "No Action" Sites
          lo be ~No Ac,ion" si.es
s,,es are ,hose si.es ,hat have no
                                            or
                                                    FFA/CO' An
                                                                        24 sites were

                                                                        "alySIS- "N° A«'°""
si.es
dec,s,on
               s for Overall

 12.1.2  "No Further Action" Sites
                                    es                                      a. si, s,.es.
 source or a potential contaminant source present that doT™, h   "  ^ 'S 3 *'* Ihat has a c°ntaminant
 greater than I  * ,0- for the risk scenario e a ua ed under the    ' "I eXP°SUrC r°Ute rCSUltin= in "**
 determined to be "No Further Action" Ls mroul Trt  ^  T"^ '"" C°ntr°ls-  These sites **«
 The -No Further Action" sites are sL  he e ™£eJ,T   Or2'nvest^t.ons and RJ/BRA analysis.
 action is Institutional Controls.                 d'a' actl0n 'S bein^' take"- However, the only 'remedial
                                                    "No Funher Action" sites usm,
detennine that access or land ™  * ™£c ™± no    ^^ " lhese silcs Until the Agencies
perceived r,sk ,s considered accept,"  "Se n  t  utS"" "^ '° P^6"1 P°tentiai exposures or the
- '•« '"elude proper^ lease requireme ms. he!     " "   "  ™     " '** ^ °f °°E
          co-nro, a«cr DOE operanons                                                 a

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  tindmg ol .suitability to transfer and requirements for control of land use consistent with this ROD The
  institutional controls will be tracked using the 1NEEL Land Use Plan. The "No Further Action" sites will
  be rev iewed during the CERCLA 5-year review process to verify the effectiveness of the "No Further
  Action  decisions-

        The Agencies believe that these controls will provide overall protection of human health and the
  environment tor the "No Further Action" sites. The institutional controls will be maintained at these sites
  until an unacceptable risk to human health or the environment no longer exists .

  12.1.3   Tank Farm  Soils Interim Action Selected Remedy: Alternative 3—Institutional
           Controls with Surface Water Controls

       An interim action was selected for the Tank Farm Soils release sites. A final remedial action will
  be developed under OU 3-14 following additional site characterization, risk analysis, and remedial
  alternative evaluation.  The interim action  will be performed to minimize contaminant exposures to the
  public and to limit further impacts to soil and groundwater until a final remedy is implemented under
  OU 3-14.  A final remedy decision is anticipated prior to 2008.  Based on currently available information
  the interim action is not inconsistent with the expected  final remedy for the Tank Farm Soils The
  selected interim action is designed to prevent short-term exposure to contaminants present at the site and
  to minimize moisture infiltration that may occur and leach and transport contaminants to the perched
 water or SRPA.

       The selected interim action will provide short-term protection of human health and the environment
 white the final remedy is developed and selected.  Short-term protection will be provided by this
 alternative through existing and additional institutional controls, including radiological engineering
 controls and health and safety procedures, which will limit current worker and non-worker access or
 exposure to contaminated soils.  Engineering controls will be used to minimize fugitive dust or toxic-
 emissions during construction activities and provide short-term protection during implementation of the
 interim action.  Additional short-term protection will be provided by surface water controls  which will
 facilitate management of an unplanned spill or release and significantly reduce surface water infiltration
 into the Tank Farm soils. Some measure of long-term protection is provided by the reduction of surface
 water infiltration into the Tank Farm soils which will limit expected leaching and transport of
 contaminants to the perched water and minimally reduce available water in The perched zone  These
 actions will provide overall protection of human health and the environment by minimizing the potential
 tor environmental releases and future groundwater quality impacts to the SRPA.

      The Agencies believe that this interim action best satisfies the 5 balancing criteria and will be
 protective of human health and the environment while the OU  3-14 Tank Farm RI/FS is performed
 Further, this action will satisfy RAOs and will not be inconsistent with the expected final Tank Farm
 remedy and the HLW &  FD E1S currently being conducted.

 12.1.4  Soils Under Buildings or Structures  Selected Remedy:  Alternative 2—Existing
         and Additional Institutional Controls and Containment

      The selected alternative for the Soils Under Buildings .and Structures is a deferred action that
 consists ofexistmg and additional institutional controls and soil capping or excavation. The selected   •
 remedy will provide short-term protection of human  health and the environment throuuh tbe
 implementation of existing and additional institutional controls that reduce the  potential for current
 worker, non-worker, or community access or exposure to contaminated soils. Implementing the remedv
 will not po^e unacceptable Miort-term ri*ks to the community, workers, or the environment" En<>ineerin»
control, radiological engineering controls, and health and vitou procedures will be u*ed to minimi/e anv

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 construction activities          P       '" be used C0 mmim'ze P^sonnel injury during
                               S:^^^^^^
allowable levels for up to  M™^ct^ ? C-TT '°   ^ 8'°U"dwaKr 1"ali'X above
concentrates to leve^ that are nou 'rilTSn                   """ "*"





                                 12-3

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   footprint will cover no more than 80 acres. Short-term protection of human health and the environment
   will be provided through the implementation of institutional and engineering controls, radiological
   °??iro r/!?       safety procedures, and safe work practices during construction, operation and closure
   of the ICDF to protect workers, non-workers, and the community from exposure to the disposed
   contaminated soils. Long-term protection of human health and the environment will be provided by the
   «nL*J   Jr     ^'C  ' constructed< °Pera*d. and closed to inhibit intrusion by humans and biota
   o prov.de sufficient shielding to mmimize external exposure to radionuclide-contamfnated soils, and to
   ™i£! -f H ?        Prrec'pltatlon infiltrvion through the contaminated soils to reduce the potential for
   leaching and transport of soil contaminants to the perched water or SRPA.  The final cover on the ICDF
   win oe designed to provide human and biotic intrusion protection for at least 1,000 years.

        Construction of the ICDF will disturb the environment. Environmental disturbances will be
  minimized by performing the construction activities in compliance with ARARs, the INEEL Storm Water
  PO ut,on Prevention Plan, and performing a cultural resource evaluation. Ail soil disturbance Si ies
  w inriOT itiv     C°mpll'anCe Wkh the INEEL St0rm Water Po""tion Prevention Plan, including re
               rH   cultural reso"rce evaluation has been conducted for the areas that might be disturbed
  be, a         dur'ngn    *««*»«* activities, unusual materials such as arrowheads, obsidian, or
  bones are discovered, all work w,|| cease and the INEEL Cultural Resources Office will be contacted for
  ass,stance. The land that will be disturbed during ICDF construction has been evaluated for biologica
  -n^^A    ! ate n°,knOWn We,tla"dS- UniqUe habitatS' °r areas occuPied by Threatened or Endangered
  bpec.es.  As such, consultation with the Fish and Wildlife Sen-ice will not be necessary.        naan§erea

       Although more costly than Alternative 3, which requires capping each Group 3 site in place the
 selected Alternative 4A. reduces the footprint of the WAG 3 restricted area allowing for tluT
                  r fXPandable to address INEEL-wide CERCLA contaminated media and debris
            CA°nSohdat'°" m an ^"leered landfill with leachate collection will safeguard the underlying
            AgenCie?believe eeC ed remedy w.Il be provided by the implementation of institutional and engineering controls
 radiological engineering controls, health and safety procedures, and safe work practices  These actions

         CUrrent       '     n°n-U°rker CXpOSUres to perched "ater durin^ dri"i^ ^ll installation, and
      Long-term protection of human health and the environment will be achieved bv institutional
controls, including land and grounduater use restrictions, to eliminate future use of perched water as Jong
as an unacceptable nsk remains. The estimated yield of u ells completed in the perched water further  "
precludes demesne use and prox ides a measure of long-term protection.  Additional lona-term protection
innnifn     ,  M  m^^Mn of a*'uifcr recha'S" Controls, to reduce leaching and transport of soil
contaminants to the perched /one. to limit the available uat,-r content m the perched zone and reduce tho
                                              12-4

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                                             SRPA-
                   ,„
 with similar earth work projects These
                                                                 USU3' shorMemi r'sks involved

.he INEEL Stem,
                                                                             Env,ronmental


                                                               . '" ~"""i"1« Wlth ARARs
                                           so                ror ih




  wetlands, unique habitats, or areas occupS^«S3 S E^08"  H1*80"^'  TherC "* "° k"°Wn
  with the Fish and Wildlife Service will not be necessaw     Endangered sPec'es' ^ such, consultation
                                                     bat rg cr ia while providin^ °vera"

the current INTEC security fence w llLTeve lopS undc^ Sb /U° r   , ^ P°rti°n °f ^ SR?A in










These controls * j]| also protect currem u ^     ,         "stallat.on. and groundwater monitorinu.

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  from ingesting SRPA groundwater using institutional and engineering controls, such as locked wells or
  groundwater use restrictions.

        Long-term protection of human health and the environment will be achieved by maintaining
  existing and additional institutional controls, such as land and groundwater use restrictions, over the area
  ot the contaminant plume.  These restrictions will prevent exposure to contaminated groundwater during
  the time that the aquifer is expected to remain above the applicable State of Idaho groundwater quality "
  CDD  ™ Long'term Protection w>" also be provided by groundwater monitoring to determine if the
   *£.. COCs exceed their actlon levels and if the impacted portion of the aquifer is capable of providing
  sufficient yield to serve as a water source. If these two conditions are met, contingent pump and treat
  remediation will be implemented to reduce the contaminant concentrations in the impacted portion of the
  bRPA so that the unacceptable risk is reduced by meeting the applicable State of Idaho groundwater
  quality standards and federal MCLs.

       SRPA groundwater does not pose either short- or long-term risks to environmental receptors as it is
  not accessible to biota.

       Although Alternative 2A is less costly than the selected alternative 2B. it does not provide any
  reduction in toxicny. mobility or volume through treatment  and may not meet the Remedial Action
  Objective ot restoring the aquifer to drinking water quality by the Year 2095.  Therefore, the contingency
  remedy. Alternative 2B best addresses groundwater modeling concerns regarding aquifer restoration  The
  Agencies believe that the selected remedy will provide overall protection of human health and the
 environment and satisfy RAOs by restricting potential SRPA groundwater use outside the current INTEC
 security fence and implementing contingent pump and treat  remediation if contaminant action levels are
 exceeded and the aquifer is capable of producing a sustainable yield.  This remedy will reduce potential
 risks to human health to less than  1 x  IO"4 or an HI less than I.

 12.1.8   Buried Gas Cylinders Selected Remedy: Alternative 2-Removal, Treatment and
          Disposal

       The selected alternative for the Buried Gas Cylinders  is removal, treatment, and disposal
 Implementation of this remedy does not pose any additional  significant risk to the community or the
 environment.  Short-term risks to the workers implementing  the remedy will be minimized using
 mstitutional and engineering controls, health and safety plans, and safe'work practices.  These actions will
 reduce physical hazards and exposures to workers to allowable levels during cylinder removal
 transportation, treatment and disposal.

       Long-term protection of human health and the environment will be achieved by removing all of the
cylinders, treating the cylinder contents as necessary, venting non-hazardous contents' directly to the
atmosphere, and disposing the empty cylinders.

      The Agencies may elect to pursue a contingent remedy of capping in place pursuant to the
substantive requirement of IDAPA 16.01.05.008 (40 CFR 264.310) if safety concerns with excavation
and removal ol the cylinders prevent implementation of the selected remedy.

      Alternative 2 is selected because it best meets the five  balancing criteria while providing overall
protection ot human health and the environment. The  Agencies believe that the selected remedy will
pro% ide overall protection of human health and the environment and satisfy RAOs because the reactive
lymtabie. and potentially hazardous gases uill be removed, treated (if necessary), and disposed  This
remedy u ill eliminate the >atety hazard posed b\ the cylinders.
                                             12-6

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      The selected alternative for the SFF ">n Hot \u  ,  T  i  o
controls, and removal, treatment ° an  disposf, o  he £ nk Hn  H ^7Y"clud«' ex'^ing institutional
and structures.  This remedy can be imp^men e  * th"u ±               "*'    aSS°C'ated pipi"«
           ,            ,       n  an   spos, o  he   nk Hn  H
    and structures.  This remedy can be imp^men e  * th"u ±^±1^ I"*' ^ aSS°C'
    community or the environment. Short-term risks to the ^  addltl°nal sh°™rm nsks to the
    minimized using institutional and enginS^t ^^Pf ^T* *' ^^ Wl"
    These actions will reduce physical hazard^ "aid «,Wr~?    I *   * P    ' and Safe W°rk Practices'
    liquid and sludge removal and treadS^d^S^lT         * '° albwabie '«*'* during tank
    and associated structures.             '      m°Va'' decontam'"at,on. and disposal of the tank, piping,
   structure. Any contaminated soifs that may ex!?, beneaS^ ^ h   ?     geS' ta"k' Pipi"8' a"d associated
   RGs will be excavated and disposed ," Z ICDF to eTminlr, fT"!* at,COncentrations exceeding the
   contaminants to the perched water or SRPA        elim'™te future leaching and transport of the soil
  the selected remedy will provide ov^l^^^of'Z^ S* H^  ThC AgendeS bdieve that
  RAOs because the SFE-20 tank system 7i 1 be n^J ,    T      3   the environment and satisfy
      reduce potential risks to l«£^                                         ™S
  12.1.10 Sites Under Other Regulatory Authority
       .
  investigated and evaluated during the RI/FS incbde  CPP « ?ERCLA" These SItes' which were
  65 (Sewage Treatment Plant lagoons) CPP ootteam plnff,^ f^ T™ INTEC buijdi"^)- C
  transformervard)  CPP-8I (abandnneHn   r   r    / lant % ash p.ts), CPP-61 (area within CPP-7 1
  from ruptured p> ^ ^^ ^"^ ^T\ ™°r "T ^ ^^ <™*»
 evaluation.  These sues will be included under *e1E^
 necessary- actions by the other OUs, WAGs or r^^           " ^ *"
 documem       -                        ^1 f ^^ " INTEC
 Therefore, the Agenc.es decSS ^  ai S?s st u-o ? ^ " "^"^f0™ a"d -presents a low risk.
 (if necessary) under the INEEL Asbestos Aba temJnt P     aPP™P"«e|y administered and remediated
 implemented in accordance with , NESh LAPs           gram"  INEEL 3SbeSt°S management is
3 = INTO Sties'                              am '-^-^ <™ -itary waste from
iagoons indude four ^r^^™^^ ^^ "n'984 '1 « CUrre"tly USed'
u-astewater. The ,agoons were investigated in the R BR^TrJol "SlwT^ ' '^f "^
determined that site CPP-65 is not a significant s™^   r  
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             m      £  a  ed UndCr the 'dah° Was'ew«er Land Application Permit Rules
           16 01.07). This decision was based on the low concentration of contaminants in the plant
  effluent and the continued use of the lagoons. However, if additional perched water actions are deemed
  necessary by the Agenc.es to further reduce recharge to the perched zone, then the closure and relocation
  ofthe Sewage Treatment Plant lagoons will be managed under CERCLA.

  TU    Su e (LPP"66 'VJ* coa|-|lred steam generation facility fly ash pit located southeast ofthe INTEC
  The plt has been  used for the disposal of fly ash produced by the INTEC steam generation facility since
  rPP J,      '?   fl C0nta'nsrnatural radionuclides and metals derived from coal and limestone.  Site
  CPP-66 was evaluated usmg the Track I process in 1 993 and recommended for "No Further Action"
  durin,°tnhea5ULmri ?? PRP? ^'f'011- Subsequently, an ecological risk screening was performed
  during the OL 3-13 RI/BRA. which suggested that a risk to environmental receptors may exist from the

  rTrtht P/Tm, '"    HaSh' T,he AgCnCieS haVC dCtemiined that the Site wi» be transferred^ OU 10 04 for
  further evaluation and remediation, if necessary.
                   'S a" ^f ^,tbe CPP'7 ' 8 transformer yard w^re a PCB oil spill occurred in the
       79 nnm  vT Th' * ii      (4°° ^ ? PCB "" ^ SpHIed'  The PCB concentration in the oil
  o    In K rh   -n     SP  TS C°"tamed- however< some sP«'ed oil contaminated the surrounding
 ±1: ,    r       5   arCa W3S °leaned Up: aPProximateiy 40 drums of soil and debris were removed  A
 new transformer and concrete pad have been installed over the site. Three soil borings were drilled and'
 soil samples analyzed for radionuclides. The radionuclides found were below risk-bfsed soil
 concentrations.  The Agencies have determined that Site CPP-61 will be transferred to OU 3-14 for
 further evaluation. • This decision is based upon the uncertain amount of PCB contamination that mav
 remain under the concrete pad ( WINCO 1 992a).                                "«««»un mat may

       Site CPP-81 is an abandoned line from the 30-cm ( 12-in.) Cafciner Pilot Plant.  The line located
 approximately 0.6- to 0.9-m (2- to 3-ft)  bis. contained simulated calcine that became plugged Mn hetne
 fo  ow,ng a test run. During the fall of 1993, the ,ine was cleaned as part of a time-criS emo a
 action. The Ime was flushed with hot acid to remove the simulated calcine.  No leaks were observed
 during the removal action indicating that no previous release to the environment had occurred  The final
 p^Sdu^-Sm ^  ^ fTd l° n°,! ''"IT con'amina"'s 'bove toxicity characteristic leaching
 for furthS S-aluation              °'eS     determined that Site CPp-81 wili be transferred to OU 3-14


       Site CPP-82 is the location of three waste water spills (designated Sites A. B, and C) caused bv
 rupturing o  prev.ous y abandoned underground lines. The lines were ruptured durmg excavation   "

 ^VnlHS;h   K" ?" !,S?OCiated Wkh  SitC A' a" CStimated 9'4 L (2-5 ^ of low-level  radioactive waste
 ^;"PR  th.erabandoned  hn^ and Contaminated soil associated with the  leak were removed and disposed
 Sues B and C are associated with spills of nonradioactive. nonhazardous waste water; these spills
 ^^."""V   ';epa:riact,ivitiers associated *ith Site A. The Agencies have determined that Site CPP-
 S2 will be transferred to Ob 3-14 for further evaluation.

 12.1.11  Five-Year Reviews

      The remedial actions taken under this ROD will be reviewed  under the CERCLA 5-vear review
process to ensure their protectiveness.  Five-year reviews  w.il  also ensure that any chanees'in the physical
conhgurauon ot any INTEC facility or site (such as D&D, where there is suspicion of a release otP
h^ardou.s or radioactive substances will  be managed to achieve remediation goals established in the
ROD.  The >>car rev icws u ,|| continue  as long as contaminants exist at levels which result in restricted
or limited Mte usaue.
                                              I2-S

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                                                                                                            1
                             12.2   Compliance with ARARs

  th«Uph ^TT* r^" Ch£TiCak 3nd loca'i<>n-sPecific ARARs is described in Sections 12.2.1
  through 12.2.7 for the selected remedy for each group. Chemical-specific ARARs are generally health- or
  rTd n   rHreqUirementS,that CStabliSh nUmedCal 'imitS °n the amounts or concentrations of a panicuar
   ad,onuchdeA compound or material that may be discharged to or present in the environment. Location-
  specie ARARs restrict specific activities occurring in particular locations. Action-specific ARARs
  restrict specific types of remedy activities or technologies.
oresento   t      R                     " ' 3 ^ is Whether °r "Ot RCRA-hazardous materials are
SFF £ Hn, w  ,  T   u      8S S'teS' °ther SUrfaC£ S°iIS SiteS' the Buned Gas cinders. a"d in the
           Waste Tank c
         Hn, w  ,  T  u                                  '                  ners. a"   n te
     t   «P Waste Tank contents and system; as well as in residuals produced while treating SRPA water
                                                fr°m these Sites wi!1 be characterized toMtate
  df          H              -            IDAPA ARARs that Wlfl aPP'y if th«e materials are
  determined to be hazardous are cited in the ARARs tables for the selected remedy for each group with
  quahfymg statements, and are discussed in the following sections.                           P'
       Investigation derived waste (IDW) from OU 3-13 RD/RA  activities and OU 3-14 investigations
                          purge      - penel protective
                                     -                            <     n          «
        wastes generated during sampling and inspection/maintenance activities will be temporarily
 40c2-«54-     w    c                  substantive P°rtions of IDAPA 16.01.05.008
 40 CFR 264.544 Remed.at.on Waste Staging Piles). By managing the wastes in this area, placement will
        rT      !.heSe W3SteS 3re trCated ln temp0rar* Units under IDAPA 16.01.05.008 (40 CFR
         , they may be subject to LDRs. The final disposition of these wastes will be in the ICDF.
       This ROD recognizes that INTEC is an operating facility, it is possible that changes in physical
                                                                             8SdCre Led
              ^  p  u                 at a Slte for which action is required under this ROD
                                         institutional c°ntrols) will be preceded by appropriate
                       v                nCUITed °n by thC AgenC1"eS Pri°r to ^P'e-entation.
                            S  JCCt t0 rCmedial aCti°" PUrSUant t0 the tenns and conditions of the
         WanterFContrSofS 'nterim ACtiOn'' AItemative institutional Controls with Surface

                          ?'' chemicaK and 'ocation-specific ARARs for the selected remedy for the
r^'.f 1 'L  Acti°"'Sf3ecific ARARs-  Site security, inspections, and personnel training will be
reqmred during the interim act.on period. These requirements will be met by institutional and
                             l SafCty meaSUreS' and health and safety P^  implemented or planned
      State of Idaho Fugitive Dust Emission Rules will apply to any activities that generate fugitive dust
            qre     rea:Tabie Precaut'°ns be taken to P^nt the generation of fugitive dust'from
   uhe            ^      ^      8 3CtiVe °Perati0nS:  En*ineerin» Controls wi" ^ Implemented to
                                            12-9

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  Table 12-1.  c«
                                                          JTank Parni Soils Interim Anton Selected Remedy.
            Altcinalivc ARARs

        I Tank Kami Si
                                                       	Description
 IDAI'A  Id (l| OSOOSI40CI-R264 14)


 IDAI'A  ld(i|.i)Si)i)X(40r|-K 264.15)


 IDAI'A  ldO|.(iSoi)X(40