PB99-964606
EPA541-R99-095
1999
EPA Superfimd
Record of Decision:
Idaho National Engineering Lab (USDOE)
OU3-13
Idaho Falls, ID
9/28/1999
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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
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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
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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,.
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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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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
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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
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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
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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. •
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• 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
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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.
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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.
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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.^
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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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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.
-------
0)
3
O)
iZ
-------
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
-------
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.
-------
=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.
-------
£f
1.1 Jn11
•
-------
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
-------
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).
-------
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
-------
W
INTEC Main Stack
(Reference)
94
50C >:CO Fee:
53C Vie:e-
Figure 1-8. Group 6: Buried Gas Cylinders numbered release sites.
-------
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.
-------
.5
CFA
Figure 1-10. Ol' ."-I? area ofconiaiiiination
i-i:
-------
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
-------
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
-------
, 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«*> ^"^
-------
• 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
-------
-^^
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
-------
-------
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.
-------
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.
-------
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 • -
-------
-------
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
-------
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
-------
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"
-------
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
-------
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
-------
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.
-------
-:: ::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
-------
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
-------
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
-------
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
-------
[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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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.
-------
MTI --M-I... L. >|.|'-"l'l.lri..N \ s,
KM ""I KIM • "'I''' l'.'111'.hi iM(rur.M|| ,|
.'in,,,,,:.,,, „.„ „-,„ „„,„ ,,•„,.„„„„ ,,„ „„, ,,,!„„., « ,„„„„,,„ „.„ .,„,,,„..„„ |
'•'(|-->I|IIII|O|IIM.II|.III:'M|IIS.I>| iu|'UnimVni'l<>TUf-cl«!.) l«'ll |nsixlsi(| jmc j ,„ uiniSloj.i 8ui|duics a?3ui||ii<| itiq i •»IH«TMIU ICIKUIU '
. • « -,1,1.1 ''•'rW''ullf'"s*'™'^,m^^^
1 OIHMOM .'.0111 f| n
I. I II
v\ VN ";« i
v 'N »« .1 1 1
' -ncf> t 1 f [
1 I0--|06f "!ifi(J /". r i
"".' fl VI
c V('--IOf) f "' C 1 -
' ' "O> 1 ^ 11
VN' VN "«sx - ii t-(
(- IO''-|(P X "•/()
<• ' nil/ 6 ^-|
VN VN »;,x | -|
i co-'ion «i,t.c ^ n
Vfs' VN VN i VN
VN VN VN | VN
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
6.
CURRENT AND POTENTIAL SITE AND RESOURCE USES
6.1 Current Land Uses
,DOE)
6.2 Reasonably Anticipated Future Land Use
^^
6-1
-------
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
-------
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
-------
-------
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
-------
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).
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
• \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
-------
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
-------
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!
-------
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
-------
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
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• 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
-------
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.
-------
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
-------
°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
-------
• 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
-------
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
-------
! 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
-------
*
""•*"
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
-------
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.
-------
. 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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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(402
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.
-------
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
-------
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.
-------
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>.
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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< \
-------
\\£ 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).
-------
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
-------
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
-------
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.
-------
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
-------
-------
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
-------
<>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
-------
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
-------
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
-------
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
-------
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
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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
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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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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
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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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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
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^ 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
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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
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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
-------
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
-------
^
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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 °
-------
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
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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]
-------
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
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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.
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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]
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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.
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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.
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C.3.3.3.. ICDF Design
""
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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
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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
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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
A-66
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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
-------
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 .
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
-------
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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
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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
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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
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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
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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
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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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