PB96-964115
EPA/ROD/R05-96/312
December 1996
EPA Superfund
Record of Decision:
Feed Materials Production Center,
(USDOE) Operable Unit 5,
aka Fernald Environmental Management
Project, Fernald, OH
1/31/1996
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RECORD OF DECISION FOR REMEDIAL ACTIONS AT
OPERABLE UNIT 5
FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
FERNALD, OHIO
JANUARY 1996
U.S. DEPARTMENT OF ENERGY
FERNALD AREA OFFICE
FINAL
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TABLE OF CONTENTS
List of Tables v
List of Figures . vi
List of Acronyms vii
Declaration Statement D-i
1.0 Site Location and Description 1-1
1.1 Location 1-1
1.2 Surface and Subsurface Features 1-1
1.3 Demographics and Land and Water Use 1-5
1.4 Topography and Surface Water Hydrology 1-6
1.5 Soil 1-6
1.6 Geology and Hydrogeology 1-8
1.7 Ecology 1-8
1.8 Cultural Resources 1-10
2.0 Site History and CERCLA Enforcement Activities 2-1
2.1 Site History 2-1
2.2 Operable Unit 5 History 2-2
2.3 Enforcement Activities 2-2
2.4 Operable Unit 5 Removal Actions 2-3
3.0 Highlights of Community Participation 3-1
4.0 Scope and Role of the Operable Unit 5 Remedial Action 4-1
5.0 Summary of Operable Unit 5 Characteristics 5-1
5.1 Extent of contamination and affected media 5-1
5.1.1 Soil 5-1
5.1.2 Groundwater 5-7
5.1.2.1 Perched Groundwater 5-7
5.1.2.2 Great Miami Aquifer 5-11
5.1.3 Surface Water and Sediment 5-14
5.2 Conceptual Model of Contaminant Migration 5-15
5.2.1 Air Pathway 5-15
5.2.2 Soil and Sediment Pathway 5-17
5.2.3 Surface Water Pathway 5-17
5.2.4 Perched Groundwater Pathway 5-18
5.2.5 Groundwater Pathway 5-18
5.3 Mobility of Contaminants 5-18
FER\CRU5\NMG\ROD\TOC.ROD\Dccemberl5, 1995 1:36 pm
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TABLE OF CONTENTS
(Cont'd)
6.0 Summary of Operable Unit 5 Risk 6-1
6.1 Human Health Risk 6-2
6.1.1 Contaminant Identification 6-2
6.1.2 Exposure Assessment 6-6
6.1.3 Toxicity Assessment 6-23
6.1.4 Risk Characterization 6-24
6.1.5 Uncertainty Analysis 6-39
6.1.5.1 Uncertainty in the Selection of CPCs 6-40
6.1.5.2 Uncertainty Exposure Assessment 6-40
6.1.5.3 Uncertainty in Toxicity Assessment 6-42
6.1.5.4 Uncertainty in Risk Characterization 6-43
6.2 Site-Wide Ecological Risk Assessment 6-43
6.2.1 Ecological Setting 6-44
6.2.2 Exposure Assessment for Ecological Receptors 6-46
6.2.3 Determining Nonradiological CPCs 6-47
6.2.4 Risk Characterization of Final CPCs 6-52
6.2.5 Assessing Radiological Constituents 6-54
6.2.5.1 Selection of Receptor Organisms 6-55
6.2.5.2 Selection of Pathways 6-55
6.2.5.3 Selection of Calculation Parameters 6-56
6.2.5.4 Calculation of Absorbed Dose Due to External Exposure 6-56
6.2.5.5 Calculation of Absorbed Dose Due to Internal Exposure 6-57
6.2.5.6 Analysis of Results 6-57
6.2.6 Uncertainty in the Ecological Risk Assessment 6-57
6.2.7 Significant Habitat 6-58
6.3 Conclusion 6-58
7.0 Description of Remedial Alternatives 7-1
7.1 Features Common to All Action Alternatives 7-1
7.1.1 Remedial Action Objectives 7-1
7.1.2 Target Risk Cases 7-2
7.1.3 Removal Actions 7-2
7.1.4 Institutional Controls 7-6
7.1.5 Five-Year CERCLA Reviews 7-7
7.2 Remedial Alternatives 7-7
7.2.1 No-Action Alternative 7-10
7.2.2 Alternative 1 - Excavation and Off-Site Shipment 7-11
7.2.3 Alternative 2A - Engineered Disposal Facility 7-14
7.2.4 Alternative 2C - Consolidation with Off-Site Shipment 7-16
7.2.5 Alternative 3A - Engineered Disposal Facility 7-17
7.2.6 Alternative 3C - Off-Site Disposal 7-17
7.2.7 Alternative 4A - Engineered Disposal Facility 7-18
7.2.8 Alternative 4C - Consolidation with Off-Site Disposal 7-18
FER\CRU5\NMG\ROD\TOC.ROD\Decemberl5, 1995 1:36 pm U
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TABLE OF CONTENTS
(Cont'd)
8.0 Summary of the Comparative Analysis of Alternatives 8-1
8.1 Threshold Criteria 8-2
8.1.1 Overall Protection of Human Health and the Environment 8-2
8.1.2 Compliance with ARARs 8-2
8.2 Primary Balancing Criteria 8-6
8.2.1 Long-Term Effectiveness and Permanence 8-6
8.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment 8-6
8.2.3 Short-Term Effectiveness 8-7
8.2.4 Implementability 8-7
8.2.5 Cost 8-9
8.3 Modifying Criteria 8-9
8.3.1 State Acceptance 8-9
8.3.2 Community Acceptance 8-10
9.0 Selected Remedy 9-1
9.1 Key Components 9-2
9.1.1 Soil and Sediment 9-2
9.1.2 Perched Water 9-8
9.1.3 Regional Groundwater Aquifer 9-9
9.1.4 Storm Water/Wastewater 9-12
9.1.5 Treatment of Discharges 9-13
9.1.6 Measures to Minimize Environmental Impacts 9-15
9.1.7 Institutional Controls/Monitoring 9-16
9.1.8 Corrective Action Management Unit Rule 9-18
9.1.9 Cost 9-20
9.1.10 Community Involvement 9-21
9.2 Remedial Action Objectives and Cleanup Levels 9-21
10.0 Statutory Determinations 10-1
10.1 Protection of Human Health and the Environment 10-1
10.1.1 Soil and Sediment 10-2
10.1.2 Perched Groundwater 10-3
10.1.3 Great Miami Aquifer 10-3
10.1.4 Surface Water 10-4
10.1.5 Cumulative Risks from all Media Pathways 10-5
10.1.6 Risks During Remedy Implementation 10-5
10.2 Compliance with ARARs 10-5
10.2.1 Solid Waste Disposal Facility Siting Requirements 10-6
10.2.2 Equivalent Standard of Performance 10-8
10.3 Cost Effectiveness 10-12
10.4 Use of Permanent Solutions and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable 10-13
10.5 Preference for Treatment as a Principal Element 10-15
10.6 Irreversible and Irretrievable Commitment of Resources 10-16
FER\CRU5\NMG\ROD\TOC.ROD\December 15, 1995 1:36 pm iii
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TABLE OF CONTENTS
(Cont'd)
References R-l
Appendix A Responsiveness Summary
Appendix B Applicable or Relevant and Appropriate Requirements and To Be Considered Requirements
for Operable Unit 5
FER\CRU5\NMG\ROD\TOC.ROD\Decemberl5, 1995 1:36 pm IV
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LIST OF TABLES
Table
5-1 Summary Statistics for Predominant Contaminants in FEMP Surface Soil 5-3
5-2 Summary Statistics for Predominant Contaminants in FEMP Subsurface Soil 5-4
5-3 Summary Statistics for Predominant Contaminants in FEMP Type 1 Wells 5-10
5-4 Summary Statistics for Predominant Contaminants in FEMP Type 2 Wells 5-13
6-1 Constituents of Potential Concern in Each Medium for Operable Unit 5 6-4
6-2 Major Constituents of Concern for Operable Unit 5 as Defined in the CRARE 6-7
6-3 Summary of Land Use Scenarios and Receptors 6-11
6-4 Range of Exposure Point Concentrations for Contaminants Contributing 99 Percent or More
of Total Risk 6-15
6-5 Exposure Parameters in the Operable Unit 5 Baseline Risk Assessment 6-21
6-6 Cancer Slope Factors for FEMP Radiological Contaminants Contributing More than 99 Percent
of Total Incremental Lifetime Cancer Risk and Hazard Index 6-25
6-7 Oral and Inhalation Slope Factors and Reference Doses for Inorganic and Organic Chemical
Contaminants 6-26
6-8 Estimated Carcinogenic Risks and Potential Noncarcinogenic Effects for Current Land Use with
Access Controls 6-29
6-9 Estimated Carcinogenic Risks and Potential Noncarcinogenic Effects for Current Land Use
without Access Controls 6-31
6-10 Estimated Carcinogenic Risks and Potential Noncarcinogenic Effects for Future Land Use with
Access Controls 6-33
6-11 Estimated Carcinogenic Risks and Potential Noncarcinogenic Effects for Future Land Use
without Access Controls 6-35
6-12 Incremental Lifetime Cancer Risks and Hazard Quotients from Exposure to Background
Concentrations of Major Contaminants Detected in Environmental Media According to Critical
Receptor 6-37
7-1 Target Risk Cases Evaluated in Feasibility Study 7-3
7-2 Summary of Alternatives 7-8
8-1 Comparative Analysis of Operable Unit 5 Remedial Alternatives 8-3
9-1 RCRA Characteristic Soil Areas Designated for Identification, Segregation, and Treatment 9-7
9-2 Estimated Costs for the Operable Unit 5 Selected Remedy 9-21
9-3 Final Remediation Levels for Soil 9-23
9-4 Final Remediation Levels for Great Miami Aquifer Groundwater 9-26
9-5 Final Remediation Levels for Surface Water in Paddys Run and the Great Miami River 9-28
9-6 Final Remediation Levels for Sediment 9-30
9-7 Operable Unit 5 On-Property Disposal Facility Waste Acceptance Criteria 9-34
FER\CRU5\NMG\ROD\TOC.ROD\Dec«nber 15, 1995 1:36 pm
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LIST OF FIGURES
Figure
1-1 FEMP Site Location Map 1-2
1-2 Major Features of the FEMP 1-3
1-3 Former Production Area Layout 1-4
1-4 FEMP Area Topography 1-7
1-5 Generalized Hydrogeologic Cross Section of the FEMP Area . 1-9
5-1 Total Uranium in Surface Soil, 0-0.5 Foot 5-2
5-2 Estimate of Off-Property Soil Potentially Impacted by FEMP Historical Operations 5-6
5-3 Classification Scheme for Monitoring Wells 5-8
5-4 Impacted Areas of the Perched Groundwater System 5-9
5-5 Impacted Areas of the Great Miami Aquifer 5-12
5-6 Conceptual Physical and Chemical Processes of Contaminant Fate and Transport 5-16
6-1 Operable Unit 5 Conceptual Model - Current Source Term and Land Use Scenarios 6-9
6-2 Operable Unit 5 Conceptual Model - Future Source Term and Land Use Scenarios 6-10
6-3 Study Areas for the Site-Wide Ecological Risk Assessment 6-45
9-1 Excavation Footprint for Selected Alternative 9-3
9-2 Areas of the Great Miami Aquifer Requiring Remediation 9-10
9-3 Projected Extraction Well Locations 9-11
FER\CRU5\NMG\ROD\TOC.ROD\Decemberl5. 1995 1:36 pm VI
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LIST OF ACRONYMS
ALARA as low as reasonably achievable
ARAR applicable or relevant and appropriate requirement
CAMU corrective action management unit
CAWQC chronic ambient water quality criteria
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
COC constituent of concern
CPC constituent of potential concern
CRARE comprehensive response action risk evaluation
CSF cancer slope factor
CT central tendency
DOE U.S. Department of Energy
EPA U.S. Environmental Protection Agency
FEMP Fernald Environmental Management Project
FS feasibility study
HI hazard index
HQ hazard quotient
ILCR incremental lifetime cancer risk
LDR land disposal restriction
MCL maximum contaminant level
MCLG maximum contaminant level goal
MTR minimum technology requirements
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NRC U.S. Nuclear Regulatory Commission
OAC Ohio Administrative Code
OEPA Ohio Environmental Protection Agency
ORC Ohio Revised Code
PAH polycyclic aromatic hydrocarbons
PRL preliminary remediation level
RCRA Resource Conservation and Recovery Act
RfD reference dose
RI/FS remedial investigation/feasibility study
RME reasonable maximum exposure
ROD record of decision
SSOD storm sewer outfall ditch
TBC to be considered
TCLP toxicity characteristic leaching procedure
TU temporary unit
UMTRCA Uranium Mill Tailings Radiation Control Act
FER\CRU5\NMG\ROD\TOC.ROD\Decemberl5. 1995 1:36 pm
Vll
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FEMP-05ROD-6 FINAL
December 15, 1995
DECLARATION STATEMENT
SITE NAME AND LOCATION
Fernald Environmental Management Project (FEMP), formerly the Feed Materials Production Center
(FMPC) — Operable Unit 5
Hamilton and Butler Counties, Ohio
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit 5 of the FEMP site in
Hamilton and Butler Counties, Ohio. Operable Unit 5 consists of impacted environmental media
including groundwater in the underlying Great Miami Aquifer, perched groundwater, surface water,
soil, sediment, flora, and fauna.
This remedial action was selected in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act, as amended by the Superfund Amendments and Reauthorization Act
of 1986 (hereinafter jointly referred to as CERCLA), and to the extent practicable, the National
Contingency Plan, 40 CFR Part 300. The decision is based on the information available in the
administrative record for this site.
The State of Ohio concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Operable Unit 5, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for Operable Unit 5 involves the excavation of contaminated soil and placement
in an on-property disposal facility and the restoration of the Great Miami Aquifer to its full beneficial
use. The selected remedy is comprised of the following major components:
FER\CRU5\ROD\NMG\DECL\.ROD\December 15, 1995 l:50pm D-i
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FEMP-05ROD-6 FINAL
December 15, 1995
• Excavation, using conventional construction equipment, of contaminated soil and sediment
to the extent necessary to establish statistically, with reasonable certainty, that the
concentrations of contaminants at the entire site are below final remediation levels.
• Excavation, using conventional construction equipment, of contaminated soil containing
perched water that presents an unacceptable threat, through contaminant migration, to the
underlying aquifer.
• Placement of contaminated soil and sediment, which attain concentration-based waste
acceptance criteria, in an on-property disposal facility. Soil exhibiting contaminant
concentrations exceeding the waste acceptance criteria (e.g., soil contaminated with organic
constituents) will be treated before placement in the on-property facility or shipped off site
for disposal at an appropriate commercial or federal disposal facility. Soil from six
designated areas where a reasonable potential exists for the presence of characteristic waste
(as defined by the Resource Conservation and Recovery Act) will be treated, as needed,
before disposition. No off-site waste will be disposed of in the on-property disposal
facility. Emergent technologies are being retained as potential options for treating soil to
meet the on-property waste acceptance criteria. Retaining emergent technologies is
appropriate due to the uncertainty of the long-term availability of off-site disposal capacity.
• Extraction of contaminated groundwater from the Great Miami Aquifer to the extent
necessary to provide reasonable certainty that final remediation levels have been attained at
all affected areas of the aquifer.-
• Treatment of contaminated groundwater, storm water and wastewater to the extent
necessary to attain performance-based concentration discharge limits, mass-based discharge
limits, and final remediation levels hi the Great Miami River.
• Application of institutional controls, such as access controls, deed restrictions, and
alternate water supplies, during and after remedial activities to minimize the potential for
human exposure to site-introduced contaminants and ensure the continued protection of
human health.
• Implementation of a long-term environmental monitoring program and a maintenance
program to ensure the continued protectiveness of the remedy, including the integrity of
the on-property disposal facility.
Operable Unit 5 is one of five operable units at the FEMP. Operable Unit 5 addresses the
environmental media at the site and beyond the property line contaminated by releases from the four
source operable units at the facility. The source operable units contain the principal threat at the site;
Operable Unit 5 is comprised of a large volume of contaminated soil and groundwater exhibiting
relatively low concentrations of contaminants.
FER\CRU5\ROD\NMG\DECLA.ROD\December 15, 1995 l:50pm D-U
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FEMP-05ROD-6 FINAL
December 15, 1995
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal and
state requirements that are legally applicable or relevant and appropriate to the remedial action (or
justifies a CERCLA waiver), and is cost effective. The selected remedy uses permanent solutions and
alternative treatment technologies to the maximum extent practicable. A U.S. Environmental
Protection Agency waiver is required from Ohio solid waste disposal regulations to allow waste
disposal over a high-yield sole-source aquifer. The waiver is granted pursuant to CERCLA
121(d)(4)(D) which allows a waiver of an applicable or relevant and appropriate requirement if "the
remedial action selected will attain a standard of performance that is equivalent to that required under
the otherwise applicable standard, requirement, criteria, or limitation, through the use of another
method or approach." The justification for this waiver is provided hi the Decision Summary of this
record of decision and is supported by the administrative record for Operable Unit 5.
When coupled with the selected remedies for the other four FEMP operable units, the site-wide
remedy satisfies the statutory preference for remedies that employ treatment mat reduces toxicity,
mobility, or volume as a principal element.
Because mis remedy will result in hazardous substances remaining on site above health-based levels, a
review will be conducted no less often than each five years after the commencement of remedial
actions to ensure that the remedy continues to provide adequate protection of human health and the
environment.
J. Phil Hamric Date
Manager, Ohio Field Office,
U.S. Department of Energy
1/3'/ft
r Regional Administrator Date
/X-U.S. Environmental Protection Agency Region 5
FER\CSU5\ROD\NM(roBCLAJtOD\DecaBber 13. 1995 l:Z7pni D-lti
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FEMP-05ROD-6 FINAL
December 15, 1995
1.0 SITE LOCATION AND DESCRIPTION
This Record of Decision (ROD) documents the plans for remediating Operable Unit 5 at the Fernald
Environmental Management Project (FEMP) site. The site, formerly known as the Feed Materials
Production Center, is owned by the U.S. Department of Energy (DOE) and processed high-purity
uranium metal products between 1951 and 1989. Operable Unit 5 addresses the environmental media
(soil, surface water and sediment, groundwater and perched water, flora and fauna) contaminated by
production activities and waste management practices.
1.1 LOCATION
The FEMP site is a 1050-acre facility located in southwestern Ohio, about 18 miles northwest of
downtown Cincinnati. The facility is located just north of the small rural community of Fernald and
lies on the boundary between Hamilton and Butler counties (Figure 1-1). The address is 7400 Willey
Road, Fernald, Ohio.
1.2 SURFACE AND SUBSURFACE FEATURES
Site surface and subsurface features that are a result of human activity are shown hi Figures 1-2
and 1-3 and described in the following operable unit definitions. Operable units are logical groupings
of facilities or environmental media at a cleanup site.
• Operable Unit 1 addresses the Clearwell, burn pit, and six waste pits plus their benns, liners,
and the soil (approximately 3 feet deep) beneath the waste pits.
• Operable Unit 2 addresses the solid waste landfill, lime sludge ponds, flyash piles and other
South Field disposal areas, and the benns, liners, and soil within the unit's boundary
• Operable Unit 3 addresses the former production area and associated facilities and equipment,
such as all structures, equipment, utilities, drums, tanks, effluent lines, wastewater treatment
facilities, scrap metal piles, feedstocks, and the coal pile (see Figure 1-3).
• Operable Unit 4 addresses Silos 1, 2, 3 and 4, their benns and underlying soil and decant
sump tank system.
On-property roads and fences are clearly visible in Figure 1-2; buried utility lines, storm sewer lines,
etc., are located beneath the former production area. Various other subsurface structures such as the
effluent line and monitoring wells are present.
FER\CRU5\ROD\NMG\SECT-l.RDD\Decoober 11, 1995 l:llpm 1-1
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Cincinnati
F INAL
FIGURE 1-1. FEMP SITE LOCATION MAP
1-2
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1376000
1378000
1380000 .
1382000
1334000i
L . BUTLER _C_OyNTY
'HAMILTON COUNTY/"c
LIME
\SPLOUNDDGSE
\ r- INACTIVE '-7f,V'?lt -1 !i
\ / FLYASH i L . ,
- STORM SEWER \,o
OUTFALL DITCH \\,rn
LEGEND:
COUNTY LINE
FEMP BOUNDARY
r
INAL
SCALE
1400 700
FIGURE 1-2. MAJOR FEATURES OF THE FEMP
1-3
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FEMP SITE INDEX
FORMER PRODUCTION AREA
LEGEND:
FINAL"
^^= ROADWAY
FENCE LINES
BUILDING OUTLINES
= RAIL LINES
INDICATES PROPOSED LOCATIONS'
OF STRUCTURES
SCALE
?•—laa
o 100 200 300 FEET
i TENSION SUPPORT STRUCTURE -4
i TENSION SUPPORT STRUCTURE -5
J SUPPORT STRUCTURE '6
PREPi
.TION F
1 STORAGE BLOC
PLANT 1 ORE SILOS
ORE REFiNEPY PLANT
CENERAL/REfNERf SUMP CONTROL BLDG
BULK LUE HANDLING 0LDG.
UETAL DISSCH.VER BLDG.
NFS STORAGE AREA J, PUMP HOUSE
COLO SIDE ORE CONVEYOR
HOI SIDE OPE CONVEYOR
CONVEYOR TUNNEL (FRou PLANT n
MAINTENANCE BLOC
OZONE BLDG
MAR CONTROL HOUSE
MAR TOWERS
MOT RAFFINATE BLDG
HARSHAW SYSTEM
REFRIGERATION BLOC.
REFINERY SUMP
COMBINED RAff IN ATE TANKS
OLD COOLING WATER IQwER
ELECTRICAL POWER CENTER BLOC
GREEN SALT PLANT
PLANT « WAREHOUSE
PLANT 4 MAINTENANCE BLDG
M£TALS PRODUCTION PLANT
PLANT 5 INGOT PICKLING
PLANT 5 ELECTRICAL SUBSTATION
WEST DERBY BREAKOUT/SLAG MH.LNG
PLANT s FILTER BLOC.
PLANT 5 COVERED STORAGE PAD
PLANT 5 INGOT STORAGE SHELTER
METALS FABRICATION PLANT
PLANT 6 COVERED STORAGE AREA
PLANT 6 ELECTROSTATIC PRECIPITATOR (SOUTH)
PLANT s ELECTROSTATIC PREOPITATOR (CENTRAL)
PLANT 6 ELECTROSTATIC PRECIPITATOR (NORTH)
PLANT 6 SALT OIL HEAT TREAT BLDG.
PLANT 6 SUUP BLOC.
PLANT 7
PLANT 7 OVERHEAD CRANE
RECOVERY PLANT
PLANT a MANTENANCE BLDG.
ROTARY KILN/DRUM RECONtHTIOMNG
PLANT 8 RAILROAD FILTER BLDG.
DRUM CONVEYOR SHELTER
PLANT 8 OLD DRUM WASHER
SPECIAL PRODUCTS PLANT
PLANT 9 SUMP TREATMENT FACILITY
PLANT 9 OUST COLLECTOR
PLANT 9 SUBSTATION
PLANT 9 CYLINDER SHED
PLANT 9 ELECTROSTATIC PREOPITATOR
BOILER PLANT
BOILER PLANT MAINTENANCE BLOC.
WET SALT STORAGE BN
CONTAMINATED OJ./CRAPHTE BURN PAD
UTN.1TCS HEAVY EQUIP. BLDG. (PROPOSED)
SERVICE BLOC.
MAIN MAINTENANCE BLDG.
CYLNDER STORAGE BLDG.
LUMBER STORAGE BLOC
MAINTENANCE BLOC. WAREHOUSE (PROPOSED)
PILOT PLANT WET SIDE
PILOT PLANT UANTENANCE BLOC.
SUMP PUMP HOUSE
PILOT PLANT THORUW TANK FARM
ADUN5TRATION BLDG.
BLDG. i« EOC GENERATOR SET
LABORATORY
LABORATORY CHEMICAL STORAGE BLOC.
MAW ELECTRICAL STATION
ELECTRICAL SUBSTATKJN
ELECTRICAL PANELS I TRANSFORMER
MAW ELECTRICAL SWITCH HOUSE
MAIN ELECTRICAL TRANSFORMERS
TRAIER SUBSTATION •!
TRAIER SUBSTATION -2
10 PLEXS NORTH SUBSTATION
» PLEXS SOUTH SUBSTATION
BON SURGE LAGOON
GENERAL SUUP
COAL PI.E RUNOFF BASW
SOOENITRFICATION TOWERS
STORM WATER RETENTION BASNS
PIT -5 SLUICE GATE
CLEARWELL PUMP HOUSE
UGH NITRATE STORAGE TA1
WASTE PIT AREA STORM W
DISSOLVED OXYGEN BLDG.
IAWWT VALVE HOUSE
MAIN TANK FARM
PILOT PLANT AMMONIA TANK FARM
TANK FARM CONTROL HOUSE
OLD NORTH TANK FARU
TANK FARM LiwE SLITTER Efl.DC.
PUMP STATION & POWER CENTER
WATER PLANT
COOLING TOWERS
• ELEVATED POTABLE STORAGE TANK
WELL HOUSE *i
WELL HOUSE '2
. WELL HOUSE -i
: PROCESS WATER STORAGE TAJ*
LIME SLURRY PITS
. GAS METER 8LDC.
: STORM SEWER LFT STATION
HER RUNOFF CONTROL
wEtCH SCALE
METEOROLOGICAL TOWER
RAILROAD SCALE HOUSE
RfiilPQuD ENGINE HOUSE
CULMINATION PLDG
UH 'irvFTr LINE'SAUF-LING BLOC
SE*ACE LIFT STATION BLDG
u v DISINFECTION 6LDG
DIGESTER 1 CONTROL BLDG
SLUOCE DRYING BEDS
. PRIMARY SETTLING BASJNS
TRICKLING FILTERS
1C PLE'S SE**GE LIFT STATION
PUMP HOUSE-HP FRE PROTECTION
ELEVATED WATER STORAGE TANK
MAIN ELECTRICAL STRAINER HOUSE
SECURITY BLOC
HuuAN RESOURCES BLOG.
GUARD POST ON SOUTH END OF TJ" SIR.
• GUARD POST ON WEST END OF "2ND" STF
CHEMICAL WAREHOUSE
DRUM STORAGE WAREHOUSE
OLD TEN TON SCALE
ENGINE HOUSE/GARAGE
OLD TRUCK SCALE
. MAGNESfU" STORAGE BLOC.
BLOG. 12 COVERED LOADING DOCK
. K-65 STORAGE TANK (NORTH!
i K-65 STORAGE TANK (SOUTH)
: RTS BLOG.
, MF.IAL' OXIDE STORAGE TANK RUST ENGINEERING BLDG.
i UTILITY SHEO EAST OF RUST TRAILERS
HEAVY EQUIPMENT BLDG.
SIX TO FOUR REDUCTION FACtlTY -2
. HEALTH s, SAFETY BLOG.
I W-VIVO BLOG.
! SIX TO FOUR REDUCTION FAOLITY -I
I PLOT PLANT SHELTER
: PILOT PLANT DISSOCIATOR SHELTER
.' SLAG RECYCLING BLDG.
I SLAG RECYCLING PIT/ELEVATOR
. CP STORAGE WAREHOUSE
: STORAGE SHED (WEST)
STORAGE SHEO (EAST)
OUONSET HUT -I
OUONSET HUT -2
OUONSET HUT -3
KC-2 WAREHOUSE
THORIUM WAREHOUSE
(OLD) PLANT 5 WAREHOUSE
DRUM RECONOITIOMNG BLDG.
PLANT I THORIUM WAREHOUSE
PILOT PLANT WAREHOUSE
DECONTAMINATION BLOC.
GENERAL W-PROCESS WAREHOUSE
DRUM STORAGE BUiLDtJC
i FFE BRIGADE TRAfJUG CENTER BLDG.
I FRE TRAINING POND
: F«E TRAINING TANK
i FR£ TRAINING BURN TROUGH
. CONFINED SPACE BURN TANK
i PLANT ; EAST PAD
I PLANT 2 WEST PAD
PLANT 3 EAST PAD
(N)
ID PLANT 8 WEST
PAD
PLANT 4 PAD
PLANT 7 PAD
. PLANT S EAST PAD
I PLANT 5 SOUTH PAD
PLANT 6 PADS
PLANT 9 PAD
BULDMG 65 WEST PAD
I BUlDtNG 64 EAST PAD & R.R. DOCK
I BUIDNG 12 NORTH PAD
1 DECONTAUMATION PAD
\ PLANT 8 OLD METAL DISSOLvER PAD
1 PLANT a NORTH PAD
: BUR.DING 63 WEST PAD
PLANT I STORAGE PAD
I PILOT PLAt ~ -
ATOfiY
3 AD
' WCTNEHATOR BLDG. PAD
FIWSHED PRODUCTS WAREHOUSE «
D I D BUP.DWG
PLANT 6 WAREHOUSE
PLANT 8 WAREHOUSE
PLANT 9 WAREHOUSE
RECEIVING/INCOMNG UATTS WSP.
CLEARWELL LINE
PARKING LOIS
INTERIM OFFICE SPACE
INTERIM OFFICE SPACE
WTERIM OFFICE SPACE
WTERiu OFFICE SPACE
FIGURE 1-3. FORMER PRODUCTION
AREA LAYOUT
1-4
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FEMP-05ROD-6 FINAL
December 15, 1995
Natural site surface features include Paddys Run, a 7-mile long intermittent stream that begins
northwest of the FEMP, runs along the western boundary of the site and empties into the Great
Miami River about 1.5 miles south of the property, and other small streams and drainageways.
The major subsurface feature underlying the FEMP is the Great Miami Aquifer, a widely distributed
buried valley aquifer. This important resource is discussed below and in Section 1.6.
1.3 DEMOGRAPHICS AND LAND AND WATER USE
On the basis of the 1990 census, the S-mile radius around the FEMP site contains an estimated 22,900
people while the eight-county Cincinnati consolidated metropolitan statistical area has a population of
more than 1.7 million and a labor force of more than 920,000. Unemployment hi late 1994 was 5.2
and 4.9 percent, respectively, in Hamilton and Butler counties. Scattered residences and several
villages are located near the FEMP property. Residential units are concentrated hi Ross to the
northeast, hi a trailer park to the east, and hi New Baltimore to the southeast.
No sensitive subpopulations occur within 1 mile of the FEMP except for 29 children who live in the
area. Within 5 miles there are six schools that enroll 3316 students, two day care centers that enroll
about 160 children, and residences that house about 8140 children.
The area around the FEMP remains predominantly open and agricultural and the site itself was
fanned before construction of production facilities hi 1951. Residences, many of them farmsteads,
are scattered around the area and a dairy farm is located just outside the southeast corner of the
FEMP boundary. Due to a long history of intensive agriculture, there is no nearby land where a
natural environment remains intact.
Recreational facilities are centered hi the Miami Whitewater Forest to the south; two youth camps
operated hi the area but were recently closed.
Commercial activity is generally restricted to the village of Ross, approximately 3 miles to the
northeast. Industrial use is concentrated along State Route 128, hi a small industrial park south of the
FEMP property, hi the village of Fernald, and along the site's western boundary.
FER\CRU5\ROD\NMG\SECr-l.ROD\Decanber 11. 1995 l:llpm 1-5
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FEMP-05ROD-6 FINAL
December 15, 1995
The Great Miami Aquifer is designated as the sole drinking water source (under Section 1424(e) of
the Safe Drinking Water Act) for over 600,000 people in southwestern Ohio, providing 100 and
48 percent of the potable water for Hamilton and Butler counties, respectively. Some residents within
a 5-mile radius of the FEMP rely on private wells, cisterns or bottled water for potable water.
A few area farms use wells to irrigate their fields and fanners along the Great Miami River irrigate
with river water.
1.4 TOPOGRAPHY AND SURFACE WATER HYDROLOGY
The topography in the area of the FEMP includes gently rolling uplands with steep hillsides along the
major streams such as the Great Miami River and Paddys Run (Figure 1-4). Natural surface drainage
on the FEMP property is from east to west and south into Paddys Run, except for 23 acres hi the
northeast corner that drain east toward the Great Miami River. Construction activities since 1951
have significantly altered the topography of the FEMP site.
The FEMP is located within the Great Miami River Basin; the river represents the vicinity's main
surface water feature and is the receiving stream for the FEMP wastewater effluent discharge. The
average flow of the river adjacent to the FEMP is estimated to be 3460 fP/s while estimates of the
100-year flood discharge and the 7-day, 10-year low flow value (Q7.10) are 81,455 ftVs and 267 ftVs,
respectively. Paddys Run is an ungauged, intermittent stream that flows primarily between January
and May with an estimated discharge of .2 to 4 fWs. Paddys Run has eroded through the clay-rich
glacial overburden and for much of its length is now in direct contact with the underlying sand and
gravel deposits of the Great Miami Aquifer. Both Paddys Run and the storm sewer outfall ditch
(SSOD) (an on-property drainageway) lose water to the underlying aquifer, making them pathways by
which contaminants can reach the aquifer. Surface water drainage from the FEMP's waste storage
area (Operable Units 1 and 4) and the former production area (Operable Unit 3) is presently
controlled. These controls were emplaced through removal actions and/or contaminant abatement
actions implemented from 1986 through 1993.
1.5 SOIL
During the last glaciation period, the clay-rich overburden was deposited on top of the valley fill
outwash deposits at the FEMP. The physical, chemical, and engineering properties of FEMP soil
affect the suitability of the site for construction and other activities, the likelihood of erosion, and the
FER\CRU5\ROD\NMG\SECT-l.ROD\Deeember 11, 1995 l:llpm 1-6
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NEW HAVEN TROUGH
i ROSS,-SECTION + -
^mas«-%wb?afci -ii%
LEGEND:
F INAL
'— -FEMP BOUNDARY
» GENERAL GROUNDWATER
FLOW DIRECTION
SCALE
1/CSR0002.UCN
FIGURE 1-4. FEMP AREA TOPOGRAPHY
4000 FELT
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FEMP-05ROD-6 FINAL
December 15, 1995
kinds of habitats (such as wetlands) that can develop. The types of soil identified at the FEMP are
moderately high hi productivity and are frequently used for growing cash crops and raising livestock.
1.6 GEOLOGY AND HYDROGEOLOGY
A comprehensive geologic history has been developed for the FEMP and surrounding area based on
published studies and from data collected during the remedial investigation (RI) at the site.
The FEMP overlies a classic example of a regional, unconfined, buried valley glacial outwash aquifer
system (the Great Miami Aquifer) covered by younger glacial overburden (Figure 1-5). The glacial
overburden has been incised by drainages on the FEMP and has been completely removed by the
erosive forces of the Great Miami River to the east and south of the FEMP.
The glacial overburden is composed principally of clay-rich till and contains a perched groundwater
system. Sustainable yield from wells completed in the glacial overburden is on the order of 1 gallon
per minute. Horizontal flow rates within the glacial overburden have a calculated range from 1 to
58 feet per year. Vertical flow rates have been calculated to be on the order of 0.85 to 2.15 feet per
year. Groundwater flow in the glacial overburden beneath the FEMP generally follows topography
and moves from the northeast toward the southwest.
The Great Miami Aquifer consists primarily of well-sorted sand and gravel material. Sustainable
yields from wells completed in the aquifer are on the order of hundreds of gallons per minute.
Horizontal flow rates have been calculated to be hi the range of 400 to 1000 feet per year.
Groundwater flow hi the Great Miami Aquifer beneath the FEMP is generally from west to east with
a component of the flow directed toward the south (see arrows in Figure 1-4).
1.7 ECOLOGY
Most of the FEMP site is maintained hi early stages of succession by current land management
practices (mowing, grazing, bush hogging and bulldozing), causing habitat fragmentation and
heterogeneity. Relatively undisturbed habitats are restricted to the narrow riparian community along
Paddys Run and several small woodlots.
FER\CRU5«OD\NMG\SECT-l.ROD\Deceniber 11, 1995 l:llpm 1-8
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FEMP-05ROD-6 FINAL
December 15, 1995
The fishery of the Great Miami River remains stable with no indication that the FEMP has had any
discernible effects on the abundance, condition, or species richness of the fish communities. Species
diversity hi Paddys Run also remains stable.
Surveys for seven threatened and endangered species have identified two species of concern at the
FEMP site. The Paddys Run corridor represents excellent habitat for the federally endangered
Indiana bat and the state threatened Sloan's crayfish inhabits portions of the creek. In order to protect
all species, appropriate management practices and follow-up surveys will be implemented throughout
site remediation.
Wetlands on the FEMP cover 35.9 acres, mostly hi the forested north-central sector, with much
smaller acreages hi drainage ditches. The wetlands delineation was approved in 1993 by the Army
Corps of Engineers.
1.8 CULTURAL RESOURCES
The area surrounding the FEMP site has a large and diverse archaeological and historical resource
base. Archaeological sites include three Indian mounds, Adena Circle and Demoret Mound hi Ross
Township and Hogen-Borger Mound to the northeast; and the Colerain Works and Dunlap
Archaeological District along the Great Miami River. All are on the National Register of Historic
Places. These are the known significant archaeological sites; additional studies have been carried out
that indicate there may be more potentially significant sites that remain undiscovered.
Archaeological surveys have been conducted hi certain areas of the FEMP. Preliminary results
indicate the presence of several sites that may be eligible for listing on the National Register of
Historic Places. At this time, mitigation of adverse effects to historic places is conducted on a case-
by-case basis pursuant to 36 CFR 800.4-6. DOE is hi preliminary discussion with the Ohio Historic
Preservation Office and the Advisory Council on Historic Preservation to develop a programmatic
agreement that will address the mitigation of adverse effects to historic properties on a site-wide basis
pursuant to 36 CFR 800.13.
Many of the area's early farmsteads and 19th-century buildings are well preserved and historically
important, with three listed and 12 eligible for listing on the National Register of Historic Places.
FER\CRU5\K3D\NMG\SECT-l.ROD\Dec*niber 11, 1995 l:llpm 1-10
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December 15, 1995
2.0 SITE HISTORY AND CERCIA ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
DOE constructed the FEMP in 1951 to produce high-purity uranium metal in support of national
defense programs. This was accomplished by chemically and physically purifying a variety of feed
materials, converting uranium compounds into uranium metal, casting the metal into various shapes,
and machining the castings to specified dimensions. Some of these materials contained trace
quantities of fission products (e.g., technetium-99) and transuranics (e.g., plutonium-239).
The site consists of three primary areas: the former production area, the waste storage area, and
adjacent forest/pasture land. The production area is a 136-acre tract at the center of the site. The
waste storage area is located west of the production area and is where virtually all processing wastes
were deposited. Contaminants from material processing and related activities were released into the
environment through air emissions, wastewater discharge, storm water runoff, and leaks and spills.
Production at the FEMP ceased in 1989 and the plant focused on environmental restoration and waste
management activities; the 1991 name change from Feed Materials Production Center to Fernald
Environmental Management Project emphasized the new focus. One of these activities, the remedial
investigation/feasibility study (RI/FS), is being conducted pursuant to the terms of a 1986 Federal
Facility Compliance Agreement and a 1990 Consent Agreement (as amended) between DOE and the
U.S. Environmental Protection Agency (EPA). The purpose of the RI/FS is to identify effective
cleanup actions for the FEMP that satisfactorily address environmental concerns. The Ohio EPA
(OEPA) is participating in the RI/FS process through direct involvement in information exchange
meetings and technical review of project documents. Additionally, hi 1988, DOE entered into a
Consent Decree with the State of Ohio that provided for the management of water pollution and
hazardous wastes. This agreement was modified in 1993 by the Stipulated Amendment to the Consent
Decree.
Before the 1988 Consent Decree between the State of Ohio and DOE, the state filed a lawsuit against
the FEMP that included a claim for natural resource damages (State of Ohio v. DOE 1986). This
claim was addressed hi the Consent Decree where the parties agreed to stay the claim until completion
of the RI/FS (Consent Decree 1988). At the time the Consent Decree was signed, the site had not
been divided into the five operable units, so there was to be only one RI/FS document for the site.
FER\CRU5yrfCMyROD\SECT-2.RDD\December 11. 1995 l:llpo> 2-1
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December 15, 1995
Natural resource issues are part of the site's environmental media and DOE believes that the State of
Ohio will continue to stay its claim for injury to those resources at least until the issuance of the
Operable Unit 5 ROD.
The Comprehensive Environmental Response, Compensation and Liability Act as amended by the
Superfund Amendments and Reauthorization Act of 1986 (hereinafter jointly referred to as
CERCLA), the Clean Water Act, and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) designate DOE as a Trustee for natural resources at DOE facilities. These
same authorities also appoint other departments, such as the U.S. Department of Interior and state
representatives, as natural resource Trustees. The State of Ohio has appointed OEPA to act as its
Trustee representative. The Trustees' role is to act as guardian for natural resources at or near the
site. The FEMP site natural resource Trustee representatives are currently negotiating avenues to
compensate for potential impacts to natural resources and to settle the 1986 State of Ohio lawsuit.
To promote a more structured and expeditious cleanup of the FEMP site, the facility's waste storage
areas and the associated environmental media were segmented into five operable units (described in
Section 1.2), each with its own documentation. Operable Unit 5 is the fourth to issue RI and FS
reports, a Proposed Plan, and a ROD. An interim ROD was signed in July 1994 for Operable
Unit 3. The ROD for Operable Unit 4 was signed hi December 1994; the Operable Unit 1 ROD was
signed in January 1995; and the Operable Unit 2 ROD was signed in June 1995.
2.2 OPERABLE UNIT 5 HISTORY
Operable Unit 5 encompasses all environmental media, both on and off the FEMP property, affected
by contaminants released from the FEMP site. It has no operating history of its own, but reflects the
impacts of the "source" operable units (1, 2, 3, and 4) on the soil, surface water and sediment,
groundwater, plants and animals hi the affected area.
2.3 ENFORCEMENT ACTIVITIES
On March 9, 1985, EPA issued a Notice of Noncompliance to the DOE, identifying concerns about
environmental impacts associated with the FEMP's past and ongoing operations. On July 18, 1986, a
Federal Facility Compliance Agreement was signed, detailing the actions DOE was to take to assess
and investigate environmental impacts of FEMP operations. This Agreement initiated the RI/FS to
FER\CRU5\MCM«OD\SECT-2.IlOD\Deeeniber 11. 1995 l:llpm 2-2
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FEMP-05ROD-6 FINAL
December 15, 1995
meet the requirements of CERCLA and the NCP, 40 CFR Part 300. In November 1989, the EPA
placed the FEMP site on the National Priorities List.
2.4 OPERABLE UNIT 5 REMOVAL ACTIONS
Removal actions, pursuant to 40 CFR Part 300.415, are intended to abate, minimize, stabilize,
mitigate or eliminate a release of hazardous substances, pollutants, or contaminants before a final
remedial action. The 31 removal actions underway at the FEMP are being conducted pursuant to the
terms of the Amended Consent Agreement and hi accordance with authorities granted to DOE under
Section 104 of CERCLA by Executive Order 12580. The five removal actions discussed below are
wholly or hi part the responsibility of Operable Unit 5.
Removal Action No. 1 — Contaminated Water Beneath FMPC Buildings. Perched water zones
beneath some former production buildings are of concern due to significant concentrations of uranium
and volatile organic compounds. To minimize the potential for the movement of contaminated water
to the underlying Great Miami Aquifer, a series of wells were installed to extract the perched
groundwater for treatment.
Removal Action No. 3 — South Groundwater Contamination Plume. The five parts of this action
are intended to prevent or minimize the further migration of a plume of contamination within the
Great Miami Aquifer (the South Plume) off of the FEMP property and to mitigate the effects of the
contamination on local users:
• Part 1 — An alternative source of potable and process water was provided to affected
industries.
• Part 2 — A groundwater recovery well system to extract and pump groundwater from the
South Plume back to the FEMP for monitoring and discharge to the Great Miami River was
completed in August 1993, including the installation of a new effluent outfall line.
• Part 3 — An interim treatment system was constructed to remove additional uranium from
site wastewater streams to reduce the amount of uranium discharged to the Great Miami
River hi order to compensate for the additional uranium discharge coming from the South
Plume and other removal actions. This system has been operational since July 1992.
• Part 4 — Groundwater monitoring (including private wells located near areas of known
contamination) and institutional controls have been ongoing since 1992 to prevent use of
contaminated groundwater.
FER\CRU5\MCM\ROD\SECT-2.ROD\D«canber 11. 1995 l:llpm 2-3
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FEMP-05ROD-6 FINAL
December 15, 1995
• Part 5 — Additional investigations were completed to identify the leading edge and the extent
of the South Plume downgradient (south) of the Part 2 recovery wells.
A related supplemental DOE action is the South Plume Interim Treatment project to reduce site
uranium discharges to the Great Miami River. The project's components include successful efforts
to:
• Reduce uranium by approximately 105 pounds per year by March 1994 by installing an
additional unit to treat South Plume groundwater.
• Reduce uranium by approximately 211 pounds per year by January 1995 by converting a unit
treating storm water to treating South Plume water.
• Reduce uranium by approximately 184 pounds per year by January 1995 by using off-peak
capacity in another treatment facility.
• Reduce uranium by approximately 105 pounds per year by March 1995 by eliminating
treatment of low-uranium streams and using the capacity to treat South Plume water.
Removal Action No. 16 — Collect Uncontrolled Production Area Runoff. Regrading and the
installation of drainage controls were completed hi August 1993 to control storm water runoff from
the perimeter of the production area and redirect it to the existing storm water system.
Removal Action No. 17 — Improved Storage of Soil and Debris. An interim program to store and
manage contaminated soil and debris generated by FEMP cleanup activities.
Removal Action No. 30 — KC-2 Warehouse/Well 67. This well, located inside the warehouse, is
sampled twice a year for uranium and other metals to monitor the potential for contaminants to
migrate to the Great Miami Aquifer.
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FEMP-05ROD-6 FINAL
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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
After operating under a veil of secrecy for over 30 years, DOE began a community relations program
in 1985 to provide information about the site to interested members of the public and to correct the
misconceptions and allay the fears of residents living near the site. This program reached out to the
public through newsletters and fact sheets, regular community meetings, availability sessions, site
tours and open houses, and a speakers bureau. DOE made information available and accessible by
opening several reading rooms that were essentially small libraries containing information about all
aspects of the RI/FS. In 1990, DOE established an administrative record at the Public Environmental
Information Center, located about a mile from the FEMP site. The reading rooms were consolidated
and moved to this location as well.
In November 1993, DOE implemented a public participation program at Fernald to involve
community members and other interested parties in the decision-making process at the site. These
efforts, along with the community relations activities required by CERCLA, reflect DOE's intent to
fully involve the community in decision making.
The public is provided with numerous opportunities for learning about and commenting on proposed
cleanup alternatives relating to the remediation of environmental media on and off site. These include
fact sheets, reports, news releases, and monthly updates for Fernald Residents for the Environment,
Safety and Health meetings. Status updates on projects of interest to the public - such as the
advanced wastewater treatment facility and the public water supply - are provided at trimesterly
community meetings and featured in monthly external publications. Presentations are regularly given
at public workshops and range from providing information on the latest project designed to
significantly reduce contamination to discussing the Operable Units 1 through 5 RI/FS reports.
For example, Operable Unit 2 introduced its Proposed Plan and preferred remedial alternative, which
included an on-property disposal facility, at a public workshop on June 28, 1994. The issue of the
disposal facility generated a lot of attention that in turn generated several special availability sessions;
OEPA sponsored one on September 13 followed by DOE on October 25. In all, OEPA, DOE and
the Fernald Citizens Task Force provided seven opportunities in 1994 and 10 in 1995 for the public to
participate in the decision-making process around this issue.
FER\CRU5\ROD\NMG\SEC-3.ROD\December 11, 1995 l:12pm 3-1
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December 15, 1995
DOE held its first Operable Unit 5 workshop on June 1, 1993, to discuss the initial screening of
alternatives process. On November 23, 1993, a second workshop was conducted to increase
stakeholder understanding of groundwater issues so they could make informed comments on the
upcoming RI and FS reports and the preferred cleanup alternative. This workshop focused on the
regional geologic setting of the FEMP and the Fernald area, the occurrence and movement of
groundwater, and on contaminated groundwater and where it can spread.
As work moved beyond sampling and analysis and the draft Operable Unit 5 RI Report was prepared,
a third workshop was conducted to explain the nature and extent of contamination at the site. The
November IS, 1994 meeting focused on the uranium concentrations in soil and the Great Miami
Aquifer, the other contaminants in soil and groundwater, and the cleanup options under consideration.
A fourth workshop was held on March 28, 1995, soon after submitting the draft final Feasibility
Study and Proposed Plan for Operable Unit 5 to EPA and OEPA. This workshop provided the public
with a chance to ask questions and get information on these documents before the formal public
comment period. This workshop focused on DOE's proposed remedy and how DOE arrived at this
recommendation to clean up the soil, sediment, and groundwater, the risks of this proposed action,
and what DOE plans to do with contaminated soil.
Operable Unit 5 launched an aggressive community outreach program during the March-May 1995
time frame with the objective of resolving confusion about the preferred remedy. Operable Unit 5
management personnel attended meetings of the Ross Merchants Association, Ross Lions Club, and
Morgan, Crosby and Ross Township trustees. The purpose of these meetings was to explain how
DOE arrived at its decision to have an on-property disposal facility and respond to questions about the
facility.
The notice of availability for public inspection of the draft RI Report for Operable Unit 5 was
published June 22, 1994 hi the Cincinnati Enquirer, the Hamilton Journal-News, and the Harrison
Press. The notice of availability for the draft FS and Proposed Plan was published November 16,
1994, in the same papers. The Proposed Plan was finalized at the end of April and the Notice of
Availability was published on May 1, 1995, in the Enquirer, the Journal-News, and the Press.
Approximately 650 area residents received the Proposed Plan by mail; another 200 copies were given
to the Ross Area Merchants Association who provided further distribution of the document. All
FER\CRU5\ROD\NMG\SEC-3.ROD\Deconber 11. 1995 l:12pm 3-2
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FEMP-05ROD-6 FINAL
December 15, 1995
RI/FS documents are available at the Public Envkonmental Information Center on Hamilton-Cleves
Highway, Harrison, Ohio.
A public comment period on the Proposed Plan was announced for May 1 to May 31, 1995. On
May 15 OEPA held an availability session in Ross for citizens who wanted to discuss Operable
Unit 5's preferred alternative with representatives of the state. A public meeting was held on May 23
where representatives from EPA, OEPA and DOE made brief presentations and answered questions
about the Operable Unit 5 alternatives. Reminder postcards were sent to the entire mailing list about
two weeks before the meeting, display ads were placed hi the above-mentioned newspapers, and a
billboard containing meeting information was erected hi Ross.
During the meeting a commentor requested an extension to the public comment period. The agencies
and DOE agreed to a 30-day extension, making June 30, 1995, the final date for receipt of public
comments. A notice to this effect appeared hi the above-mentioned newspapers on or before May 31
and postcards were mailed to key stakeholders (approximately 300). When the comment period
closed, postcards were sent to all commentors who included names and addresses, acknowledging
receipt of their comment, thanking them for their input, and informing them of the availability of the
Responsiveness Summary.
The Proposed Plan was submitted to the Toole County, Utah commissioners and to the Utah
Department of Envkonmental Quality. The DOE Nevada Operations Office distributed the Proposed
Plan to the Nevada public, the State of Nevada and the Nevada Test Site Community Advisory Board.
Utah and Nevada public officials and citizen groups have been requesting more information on
proposed destinations for FEMP waste because thek states are identified as representative licensed
disposal facilities. Stakeholder groups hi Kansas also received copies of the Proposed Plan.
Responses to all comments received during the 60-day comment period are included hi the
Responsiveness Summary, Appendix A of this ROD. This decision document presents the selected
remedial action for Operable Unit 5 of the Fernald Envkonmental Management Project, chosen in
accordance with CERCLA and, to the extent practicable, the NCP. The decision for Operable Unit 5
is based on the administrative record.
FER\CRU5\ROD\NMG\SEC-3.ROD\Deconber 12, 1995 7:37«m 3~3
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FEMP-05ROD-6 FINAL
December 15, 1995
Another initiative to foster community input into the FEMP's decision-making process is the Fernald
Citizens Task Force, chartered by DOE in 1993. Much of the information the Task Force has needed
in order to make recommendations on the future use of the site has come from Operable Unit 5
sources. Operable Unit 5 staff have researched, compiled, summarized, and communicated
information to the Task Force on the human health risk assessment, waste volume issues as they
relate to the disposal facility, the status of ecological habitats on FEMP property, and detailed
information on groundwater contamination and modeling. Additionally, Operable Unit 5 management
has made presentations at Task Force special sessions and attended their monthly meetings to help
answer questions. The Task Force's final report was available at the end of July, 1995.
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FEMP-05ROD-6 FINAL
December 15, 1995
4.0 SCOPE AND ROLE OF THE OPERABLE UNIT 5 REMEDIAL ACTION
The broad scope of the remedial action for Operable Unit 5 addresses the principal threats represented
by contaminated soil and groundwater at the FEMP site. The four source operable units discharged
contaminants to environmental media over the 38-year operating history of the FEMP and these
contaminants have moved to environmental media both on and off property and have impacted
groundwater, surface water and sediment, soil, flora and fauna; human receptors are also at risk from
contamination in the environmental media.
Although Operable Units 1, 2 and 4 are addressing contaminated soil within their specific boundaries
to the degree specified in their respective RODs, Operable Unit 5 is addressing the soil under the
production area structures and the remaining site acreage, as well as approximately 11 square miles of
off-property surface soil. Cleanup measures taken will prevent direct contact with contaminated soil
and migration of contaminants to groundwater. Soil remediation is estimated to take between 20 and
22 years.
For the groundwater media, Operable Unit 5 is addressing interim control and cleanup issues hi
addition to long-term monitoring, pumping and treating of the South Plume contamination. These
measures will prevent access to and use of potentially contaminated groundwater. Remediation of the
Great Miami Aquifer is estimated to take up to 27 years.
Operable Unit 5's remedial action provides a permanent solution for remediating the contaminated
environmental media and includes these parameters:
• Establishment of final cleanup levels for soil, sediment and groundwater
• Use of treatment to the extent practical to address the principal threats posed by the
contaminated media
• Removal and permanent disposition of contaminated materials to an appropriate on- or off-
property disposal facility
• Application of appropriate institutional controls to complement engineering measures taken
to address site contaminants
• Return of the Great Miami Aquifer and other useable groundwater to full beneficial use in a
reasonable time
FER\CRU5\NMG\ROD\SEC-4.ROD\December 11. 1995 l:14pm 4-1
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FEMP-05ROD-6 FINAL
December 15, 1995
• Protection, both short and long term, of the public and sensitive environmental receptors
• Accommodation of cost effectiveness, implementability, uncertainties, and emerging
technologies.
The cost of remedial actions, volumes of contaminated materials requiring action, and range of
available remedial alternatives for Operable Unit 5 are sensitive factors in determining the final
cleanup levels for the affected environmental media. These final cleanup levels are the concentration
of a given contaminant which would be permitted to remain in site soil, sediment and groundwater
following the implementation of remedial actions. The final cleanup levels also consider factors such
as technical limitations on attaining the cleanup level (for example, attaining levels below natural
background or analytical detection limits), cross-media impacts, and potential impacts to sensitive
ecological receptors. While the Operable Unit 5 ROD does not establish future land use for the
FEMP, the possible future uses of the property and the costs of remedial actions necessary to
accommodate those uses must be taken into consideration when determining the final cleanup levels
for the operable unit. Projected future land uses which envision more extensive and continued
exposure to site contaminants remaining after remedial actions, such as the creation of a family farm
on the existing government property, would require lower cleanup levels to ensure the long-term
protection of such a future land user. Lower cleanup levels typically would require the removal,
containment or treatment of larger quantities of contaminated site media, both on- and off-property,
resulting in increased costs for a given remedial alternative.
EPA has already selected remedies that address principal site threats for Operable Units 4, 1 and 2
and Operable Unit 3 is proceeding with dismantling the former production area hi accordance with its
interim ROD. Before the placement of bentonite caps, the silos of Operable Unit 4 released radon to
the atmosphere and the structures themselves had reached the end of their design life. The Operable
Unit 1 waste pits have released contaminants to soil, groundwater and air as have the various disposal
areas of Operable Unit 2. The former production area (Operable Unit 3) will remain a source of
contamination to soil and groundwater until decontamination and deconstruction are complete.
Integration of the five remedial actions is recognized as an ongoing process; the three completed
RODs defer final disposition of their contaminated soil and perched groundwater to Operable Unit 5's
remedy decisions. The sequencing of disposal facility preparation, facilities decontamination and
FER\CRU5\NMG\SDD\SEC-4.ROO\Deceaiber 11, 1995 l:14pm 4-2
-------
FEMP-05ROD-6 FINAL
December 15, 1995
dismantlement, and final soil and groundwater remediation will be closely coordinated among all
operable units through the remedial design and remedial action phases of site cleanup.
The DOE, in cooperation with the EPA, OEPA and local citizenry is actively pursuing budgeting
support for an accelerated cleanup program for the FEMP. Under this accelerated program, remedial
actions to address the contaminated soil at the FEMP could be completed within 10 years instead of
20-22; no change is anticipated in the time required for groundwater remediation.
FmCRU5\NMG\ROD\SEC-4.ROD\December 11, 1995 l:14pm 4-3
-------
-------
FEMP-05ROD-6 FINAL
December 15, 1995
5.0 SUMMARY OF OPERABLE UNIT 5 CHARACTERISTICS
5.1 EXTENT OF CONTAMINATION AND AFFECTED MEDIA
This section discusses, by media type, the nature and extent of contamination and the affected area.
The information contained in this section was gleaned from the Operable Unit 5 RI and FS Reports
(DOE 1995d; 1995a). Sources of media contamination are discussed hi Section 2.0 of this report.
5.1.1 Soil
Nature and Extent of Contamination
Extensive soil sampling was conducted during the RI and other programs in order to characterize the
nature and extent of contamination resulting from past FEMP operations. Data from these
investigations clearly show that uranium contamination is widespread on the FEMP property.
Radium-226 and total thorium are also predominant contaminants hi soil. Furthermore, the extent or
boundaries of uranium contamination generally include the extent of all other contaminants —
including inorganic and organic contaminants. Table 5-1 (surface soil, 0 to 1.5-foot depth) and
Table 5-2 (subsurface soil, depth greater than 1.5 feet) list summary statistics for the predominant
contaminants hi soil at the FEMP. Predominant contaminants are defined based on frequency and
magnitude of detections above background.
Total uranium concentrations hi surface soil within the FEMP boundary typically range from 10 to
100 mg/kg (Figure 5-1). Above-background concentrations of total uranium (background is
3.7 mg/kg) hi subsurface soil are found at depths up to 20 feet or more hi the former production area.
Radium-226 contamination is limited to the former process areas and waste storage areas. The only
significant area of subsurface radium-226 contamination is west of the K-65 silos.
Like the radium-226 contamination, total thorium contamination is generally found hi process and
waste storage areas. All thorium detections were within the bounds of uranium contamination, and
were generally in surface soil. Subsurface contamination was limited to a depth of 10 feet.
The predominant inorganic contaminants are cadmium and beryllium. Except for isolated locations
near the K-65 silos, all above-background concentrations of cadmium are located within the
FER\CRU5\NMG\ROD\SEC-5.ROD\Deconber 11, 1995 l:44ptn 5-1
-------
' FEMP
r BOUNDARY
ISOCONCENTRATION CONTOUR
CONTOUR INTERVALS: 10. 20.
100. 1000 it 10,000 (mg/kg)
ISO-CONCENTRATION
CONTOURS GREATER
THAN 100 ma/kg
FIGURE 5-1. TOTAL URANIUM IN SURFACE SOIL, 0-0.5 FOOT
5-2
-------
TABLE 5-1
SUMMARY STATISTICS FOR PREDOMINANT CONTAMINANTS IN FEMP SURFACE SOIL
(0 - 1.5 FOOT DEPTH)
Parameter
Radionuclides
Radium-226
Thorium-228
Thorium-232
Uranium-234
Uranium-235/236
Uranium-238
Uranium, total
Inorganics
Beryllium
Cadmium
Units*
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
mg/kg
mg/kg
mg/kg
Summary of Detections
Frequency of
Detection
1104/1256
889/943
1223/1435
1093/1107
774/1123
1411/1588
2235/2583
245/420
158/432
Frequency of Detection
Above Background
345/1256
307/943
404/1435
950/1107
652/1123
1279/1588
1956/2583
195/420
153/432
Range of Detections'*
0.300-2950
0.200-315
0.180-283
0.200-18100
0.0180-1020
0.300-19100
1.00-90400
0.280-5.70
0.490-12.4
Average of
Detections
10.8
3.52
3.28
98.6
7.97
91.2
244
0.980
3.70
95th Percentile
of Background
1.42
1.43
1.36
1.24
0.156
1.24
3.73
0.600
0.870
Ul
* Unit equivalents: mg/kg = ppm; fig/kg = ppb
b Based on total number of samples collected
-------
TABLE 5-2
SUMMARY STATISTICS FOR PREDOMINANT CONTAMINANTS IN FEMP SUBSURFACE SOIL
(GREATER THAN 1.5 FEET IN DEPTH)
Parameter
Radionudides
Radium-226
Thorium-228
Thorium-232
Uranium-234
Uranium-235/236
Uranium-238
Uranium, total
Inorganics
Beryllium
Cadmium
Units*
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
pCi/g
mg/kg
mg/kg
mg/kg
Summary of Detections
Frequency of
Detection
415/482
391/530
343/541
422/496
106/500
440/512
1084/1644
228/326
168/317
Frequency of Detection
Above Background
36/482
53/530
31/541
235/496
104/500
237/512
813/1644
183/326
168/317
Range of Detections**
0.300-137
0.200-19.5
0.200-8.07
0.200-319
0.0480-36.2
0.200-317
0.500-69300
0.290-5.20
0.920-8.00
Average of
Detections
1.25
1.12
0.920
9.99
2.86
9.88
202
1.03
3.77
95th Percentile of
Background
1.47
1.38
1.26
1.04
0.150
1.12
3.69
0.620
0.910
Ul
* Unit equivalents: mg/kg = ppm; fig/kg = ppb
b Based on total number of samples collected
-------
FEMP-05ROD-6 FINAL
December 15, 1995
boundaries of uranium contamination. Cadmium is a trace element in the earth's crust and is a trace
constituent in the uranium ores processed at the FEMP.
Beryllium contamination is also primarily within the boundaries of uranium contamination, the
exceptions being an area northeast of the former production area as well as near the active flyash pile.
Beryllium is a trace element hi the earth's crust and is a trace constituent hi coal and the resulting
flyash when burned. Low-level beryllium contamination is widespread at the FEMP, probably due to
emissions from the boiler plant as well as dispersion from the coal and flyash piles.
Volatile organic and semivolatile organic compounds and PCBs were detected hi select samples hi the
vicinity of all major processing and supporting facilities. Generally, all detections of organic
contaminants are within the boundary of uranium contamination.
Uranium is the predominant contaminant in off-property soil and is mainly hi the areas east,
northeast, and southwest of the FEMP property boundary. There were also isolated areas of
significant uranium contamination located along the FEMP outfall line and along the eastern boundary
adjacent to the sewage treatment plant. Isotopic thorium and radium were detected at concentrations
slightly above background hi off-property surface soil. For nearly all off-property soil samples,
inorganic constituents were either detected at insignificant levels or analyzed for and not detected.
In general, off-property total uranium concentrations were hi the 5 to 6 mg/kg range, which is slightly
above the background concentration. Figure 5-2 depicts off-property areas where soil is potentially
impacted by FEMP historical operations. Concentrations of approximately 20 mg/kg of uranium
(approximately five times background) were identified hi surface soil samples collected off property
immediately adjacent to the eastern and northeastern boundary of the FEMP. The source of the
uranium contamination is emissions of dust particles to the atmosphere from plant stacks during
FEMP operations.
Area and Volume of Affected Soil
The estimated affected area of soil (both on- and off-property) with uranium concentrations above
background is approximately 7907 acres or 12.4 square miles. The estimated volume of soil
requiring remediation ranges from 1,750,000 cubic yards to more than 9,350,000 cubic yards. These
volumes are dependent upon the various alternatives and their associated cleanup levels.
EER\CRU5\NMG\ROD\SECT-5.RQD\Decanber 11. 1995 l:44pm 5-5
-------
1360000
1370000
1380000
1390000
1400000
LEGEND:
SOIL URANIUM CONCENTRATIONS
GREATER THAN 5 mg/kg AND LESS
THAN 20 mg/kg
FEMP BOUNDARY
SCALE
FINAL
9000 4500 0
FIGURE 5-2. ESTIMATE OF OFF-PROPERTY SOIL POTENTIALLY
IMPACTED BY FEMP HISTORICAL OPERATIONS
5-6
-------
FEMP-05ROD-6 FINAL
December 15, 1995
5.1.2 Groundwater
To measure the flow and contaminants hi groundwater, monitoring wells were installed to four
different depths; Figure 5-3 shows well types and installation depths. Wells completed in the glacial
overburden (Type 1) are screened hi the material most likely to be contaminated by direct contact
with wastes and by surface water infiltrating through waste areas and adjacent contaminated soil.
Wells with a screen that straddles the water table hi the Great Miami Aquifer (Type 2) monitor
general groundwater quality at the top of the aquifer, the first zone to be impacted by vertically
infiltrating contaminants.
Wells with a screen set within the 10-foot interval above the discontinuous clay layer sometimes
present near the middle of the Great Miami Aquifer (or at the equivalent elevation if the clay was not
encountered; Type 3) were installed to better define the extent of the clay unit and to determine if the
clay layer influenced the migration of contaminants or groundwater flow. Wells with a screen set
10 feet above bedrock at the bottom of the aquifer (Type 4) were advanced until bedrock was
encountered.
Contamination of the Great Miami Aquifer is largely confined to the uppermost portion. In general,
the plume is most laterally extensive at the top of the aquifer (Type 2 wells), less laterally extensive
with lower concentrations at the middle (Type 3 wells), and essentially nonexistent at the bottom
(Type 4 wells). ,
5.1.2.1 Perched Groundwater
Nature and Extent of Contamination
Extensive sampling of perched groundwater on the FEMP property identified the presence of site-
related contaminants across much of the former production area, adjacent to the storage pits and silos,
and hi several other locations (see Figure 5-4). Concentrations of contaminants are greatest
underlying several of the former production buildings but diminish to near natural background levels
at the perimeter of the FEMP property. Table 5-3 summarizes the constituents hi perched
groundwater (Type 1 wells) which have concentrations above background and are discernable as areas
of contamination on isoconcentration contour maps of groundwater results.
FER\CRU5\NMG\RDD\SECT-5.SDD\December 11, 1995 l:44pm 5-7
-------
FINAL
FIGURE 5-3.
CLASSIFICATION SCHEME FOR MONITORING WELLS
5-8
-------
1377000
I 380000
1383000
8 -.
LEGEND
FINAL
APPROXIMATE 20 ppb
URANIUM-238 FOOTPRINT
IN TYPE 1 WELLS
FIGURE 5-4. IMPACTED AREAS OF THE PERCHED GROUNDWATER SYSTEM
5-9
-------
TABLE 5-3
SUMMARY STATISTICS FOR PREDOMINANT CONTAMINANTS
IN FEMP TYPE 1 WELLS (PERCHED WATER)'
EC-S.RQDUJec
|
M
K*
f"
V
H- *
o
Parameter
Technetium-99
Technetium-99
Uranium-234
Uranium-234
Uranium-235/236
Uranium-235/236
Uranium-238
Uranium-238
Uranium, total
Uranium, total
Calcium
Iron
Magnesium
Manganese
Sodium
Vanadium
Zinc
Chloride
Nitrate
Sulfate
Filter Flagb
FIL
UNF
FIL
UNF
FIL
UNF
FIL
UNF
FIL
UNF
FIL
FIL
FIL
FIL
FIL
FIL
FIL
UNF
UNF
UNF
Unitc
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
Mg/L
Mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Frequency of
Detection*1
56/138
64/170
129/147
186/206
78/148
100/189
126/148
191/211
174/181
273/275
203/204
98/203
2&3/204
175/202
203/203
36/195
72/195
169/173
153/253
168/171
Frequency of Detection
Above Background
45/138
55/170
124/147
175/206
78/148
100/189
. e
185/211
169/181
268/275
95/204
11/203
97/204
95/202
35/203
23/195
13/195
54/173
105/253
56/171
Range of Detections
15.1 - 2670
15.8 - 6130
0.300 - 42800
0.00100 - 25000
0.236 - 2170
0.208 - 2490
0.400 - 44100
0.300 - 39000
0.290 - 1290000
0.400 - 4360000
4.65 - 1800
0.0104-21.3
1.55-690
0.00250 - 35.0
2.35 - 1300
0.00290 - 0.299
0.00200- 1.78
0.0320 - 6300
0.0120 - 2670
0.170-6200
95th Percentile of
Background
30.0
30.0
0.600
0.900
—°
—e
c
0.800
1.40
1.30
131
3.58
47.8
0.180
56.3
0.0195
0.0443
45.0
0.290
136
* See Section 5.1.2 for well type depth description; sources are Tables 4-44 and 4-45 in the Operable Unit 5 RI Report.
b Indicates analysis was performed on filtered or unfiltered samples
0 Unit equivalents: mg/L = ppm; /*g/L = ppb .
d Frequency of detection is defined as the number of detectable results divided by number of wells tested and is based on one sample from each
well sampled.
e Data not sufficient to determine background value; see Table 4-7 in the Operable Unit 5 RI Report.
3 70
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Area of Affected Perched Water
The estimated area of affected perched water is 96 acres. This is based on the areas where the
uranium concentrations hi perched water are greater than or equal to 20
5.1.2.2 Great Miami Aquifer
Nature and Extent of
Uranium, the principal site-related contaminant in the Great Miami Aquifer, is primarily found in the
uppermost portion of the aquifer. Figure 5-5 shows impacted areas of the Great Miami Aquifer.
Significant levels of contamination exist in several areas, including:
• A localized area beneath the former production area (up to 50 jtg/L of uranium)
• Beneath the waste storage area (up to 70 /*g/L of uranium)
• Along the length of Paddys Run from the waste storage area to approximately one mile south
of the FEMP property (up to 350 /ig/L of uranium)
• Beneath a solid waste disposal area, termed the South Field, located on the southern portion of
the FEMP property (up to 2100 pg/L of uranium).
Above-background concentrations of uranium also exist in the groundwater beneath the west bank of
the Great Miami River south of the confluence with Paddys Run. Concentrations of uranium hi this
area are typically less than 10 jtg/L. Table 5-4 summarizes the constituents hi the uppermost Great
Miami Aquifer (Type 2 wells) which have concentrations above background and are discernable as
areas of contamination on isoconcentration contour maps of groundwater results.
Several other site-related contaminants are also present in the aquifer, occurring as localized areas
within the plume of uranium contamination.
Area of Affected
The estimated area of affected groundwater hi the Great Miami Aquifer at a concentration of greater
than or equal to 20 jtg/L uranium is 172 acres.
FER\CRU5\NMG\ROD\SECT-S.ROD\Deceniber 11, 1995 l:44pm 5-11
-------
ADMINISTRAT
BOUNDARY
0 S00\ 1000 2fX> FEET
\
LEGEND:
EXISTING EXTRACTION WELL
FEMP BOUNDARY
URANIUM CONCENTRATION
CONTOUR (ppb)
REGIONAL GROUNDWATER
FLOW DIRECTION
> 3 ppb < 20 ppb
> 20 ppb
PADDYS RUN
ROAD SITE
PLUME
FIGURE 5-5. IMPACTED AREAS OF THE GREAT MIAMI AQUIFER
5-12
-------
TABLE 5-4
SUMMARY STATISTICS FOR PREDOMINANT CONTAMINANTS
IN FEMP TYPE 2 WELLS (UPPER PORTION OF THE GREAT MIAMI AQUIFER)"
i\SEC-5.ROD\
I
1
H
**
i
»-•
|
P
Ul
h~*
W
Parameter
Technetium-99
Technetium-99
Uranium-234
Uranium-234
Uranium-235/236
Uranium-235/236
Uranium-238
Uranium-238
Uranium, total
Uranium, total
Cadmium
Calcium
Chromium
Cobalt
Iron
Magnesium
Potassium
Sodium
Ammonia
Chloride
Nitrate
Sulfate
* See Section 5.1.2
TnHir.utes analysis
Filter Flagb
FIL
UNF
FIL
UNF
FIL
UNF
FIL
UNF
FIL
UNF
UNF
UNF
UNF
UNF
UNF
UNF
UNF
UNF
UNF
UNF
UNF
UNF
for well type and
was tv.rfnrmfirf or
Frequency of
Unit0 Detection"1
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
pCi/L
Mg/L
Mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
depth description;
i filtered or nnfilte
7/70
12/140
105/128
121/156
25/128
31/156
106/129
114/156
127/135
159/171
18/134
134/134
32/135
13/133
115/134
134/134
115/134
133/134
61/154
149/156
100/139
149/155
sources are Tables
red samnlp.s
Frequency of Detection
Above Background
7/70
9/140
79/128
93/156
25/128
31/156
77/129
96/156
108/135
129/171
5/134
25/134
9/135 .
6/133
22/134
29/134
99/134
11/134
4/154
12/156
7/139
Range of Detections
19.2 - 204
17.8-211
0.270 - 358
0.268 - 662
0.240 - 15.7
0.220 - 31.7
0.240 - 381
0.300 - 707
0.200 - 1130
0.200 - 207
0.00220 - 0.0459
1.63 -411
0.00360- 1.11
0.00500-0.168
0.0329-913
0.285 - 507
0.724 - 182
3.76 - 130
0.0200 - 17.0
3.00 - 340
0.0160 - 79.4
22/155 0.0620 - 740
4-54 and 4-55 in the Operable Unit 5 RI Report
95th Percentile of
Background
e
22
0.900
0.800
e
0.094
0.900
0.640
0.800
1.20
0.0135
159
0.0211
0.00860
5.72
38.5
1.96
47.1
4.20
73.0
11.4
197
FEMP-05RO1
Decemb
c Unit equivalents: mg/L = ppm; /ig/L = ppb
d Frequency of detection is defined as number of detectable results divided by number of wells tested and is based on one sample from each well tested
e Data not sufficient to determine background value; see Table 4-8 in the Operable Unit 5 RI Report.
-------
FEMP-05ROD-6 FINAL
December 15, 1995
5.1.3 Surface Water and Sediment
Nature and Extent of Contamination
Surface Water. The FEMP's primary drainageways are the storm sewer outfall ditch (SSOD) and
Paddys Run. Because the composition and spatial boundaries of surface water rapidly change, the
concentrations discussed here reflect the most recent sampling results (1993). Surface water samples
collected from the SSOD indicated elevated concentrations of total uranium (up to 64 /ig/L) and
thorium-230 (up to 6.4 pCi/L).
Surface water samples collected from both the off- and on-property portions of Paddys Run exhibited
above-background concentrations for total uranium and total thorium. Samples collected from the
Great Miami River immediately downstream from the FEMP wastewater discharge outfall line
indicated concentrations of uranium ranging up to 2.8 ngfL (background concentrations range from
0.52 to 1.1 jtg/L). Concentrations of uranium in the Great Miami River were found to quickly
dimmish downstream of the outfall line, nearing background levels within one mile. Volatiles,
semivolatiles, and inorganics were also detected and are listed in detail in Appendix C of the Operable
Unit 5 RI Report.
Sediment. Sediment samples were collected from the SSOD, Paddys Run, and the Great Miami River
(downstream of the FEMP outfall line as well as downstream of the river's confluence with Paddys
Run). Because the composition and spatial boundaries of sediment change rapidly, the concentrations
discussed here reflect the 1993 sampling results. In sediment samples collected from the SSOD, total
uranium was the most frequently detected radionuclide with concentrations ranging up to 3.3 mg/kg
(background concentrations range from 1.0 to 3.0 mg/kg). Inorganic contaminants were also detected
at above-background concentrations.
Radium-226 (1.4 pCi/g) and total uranium (22.8 mg/kg) were detected in sediment from the on-
property portion of Paddys Run in above-background concentrations. Volatile organics, semivolatile
organics and inorganics were also detected in select samples of on-property sediment; the
concentration of semivolatile organics ranged up to 350 mg/kg. Off-property sediment sampling
detected only total uranium (11 mg/kg) and zinc (50 mg/kg) concentrations exceeding background.
Sediment samples from the Great Miami River indicated concentrations of total uranium, radium-226,
and total thorium at or slightly above background.
FER\CRU5\NMG\KOD\SEC-S.K0D\Oeccmber 11. 199S l:44pm 5-14
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Volatiles, semivolatiles, and inorganics were also detected in sediment from just below the FEMP
outfall line; Appendix C of the Operable Unit 5 RI Report includes a detailed list of contaminants in
sediment.
Area of Affected Surface Water and Sediment
Because of the dynamic nature of surface water (constantly moving) and sediment (agitated and
redistributed), it is difficult to quantify the affected areas. Site characterization data indicate that
certain locations are affected, including the area immediately downstream of the FEMP wastewater
discharge outfall line (surface water) and the uncontrolled drainages that flow to Paddys Run and the
Great Miami River (surface water and sediment).
5.2 CONCEPTUAL MODEL OF CONTAMINANT MIGRATION
Operable Unit 5 includes all of the FEMP environmental media. The Great Miami Aquifer and the
perched groundwater zone hi the glacial overburden are both part of the groundwater media. Surface
soil and the underlying glacial deposits make up the soil media. The Great Miami River, Paddys
Run, and the SSOD are examples of the surface water media. Sediment within these surface water
bodies includes material carried hi storm water runoff or site effluent discharged to surface water or
drainage ditches. All of the air hi the vicinity of the FEMP makes up the air media. Contaminant
migration and further human exposures through flora and fauna are considered hi the baseline risk
assessment and the FS, based on the modeled and measured contaminant concentrations in air, water,
and soil.
Residual contaminants can migrate through multiple media pathways and impact potential receptors,
as shown hi Figure 5-6. Understanding the physical and chemical processes that control contaminant
migration in these pathways was the basis for determining acceptable remedial alternatives in the FS.
The Operable Unit 5 FS focused on the effects that remedial actions have on contaminant migration hi
each of the pathways, and factored pathway-specific protective requirements into the remedial
components.
5.2.1 Air Pathway
Before production activities ended, ah* emissions from the former production area were the most
significant source of contamination to the environment. Residual contaminants in uncovered surface
soil can impact potential receptors through the air pathway. Therefore, remedial alternatives need to
FER\CRU5\NMG\ROD\SEC-5.ROD\December 11. 1995 l:44pm 5-15
-------
RAINFALL
AIR DISPERSION
AIR/PARTICULATES
AIR DEPOSITION
c
D
F INAL
CONTAMINANT SOURCE
SURFACE
RUNOFF
LEACHING
VADOSE ZONE
SOIL/PERCHED
GROUNDWATER
INFILTRATION
SATURATED ZONE
SOIL/GROUNDWATER
GROUNDWATER TRANSPORT
SEDIMENT
t
(ADSORPTION/
DESORPTION)
SURFACE WATER
cc
o
Q_
oc
DC
LU
LJJ
o
CC
13
in
SEEPAGE
LEGEND:
Q SOURCE
PI ENVIRONMENTAL MEDIA
-»• MIGRATION PATHWAY
- »- CHEMICAL PROCESS
•URE 5-6. CONCEPTUAL PHYSICAL AND CHEMICAL F 'ESSES OF CONTAMINANT FATE AND TRANSPORT
-------
FEMP-05ROD-6 FINAL
December 15, 1995
be protective of the air pathway. Air emissions associated with Operable Unit 5 residual source areas
may involve different types of release mechanisms. If organic compounds are present in the soil,
volatilization of these compounds may occur. Radon gas, generated as a result of radioactive decay
of radium-226, may be released. During periods of turbulent wind conditions, particles of
contaminated surface soil can become suspended in the air and possibly inhaled by on- or off-property
human receptors. In the event that previously covered subsurface contaminant sources become
uncovered during remediation, the possible transport of this material by wind erosion could become a
concern. The amount of material that may be suspended depends on the wind speed and other site
conditions such as soil moisture, particle size, and vegetative cover.
5.2.2 Soil and Sediment Pathway
Contaminated soil and sediment serve as source material for the air and various water pathways at the
FEMP. Contaminants in soil can be mobilized into the air pathway via resuspension and
volatilization. Erosion and dissolution of contaminated soil/sediment by surface water mobilizes
contaminants. Surface water infiltrates contaminated soil and sediment, mobilizing contaminants into
the perched groundwater system and to the Great Miami Aquifer. Contaminated soil/sediment can
also be mobilized via plant uptake and ingestion by animals.
5.2.3 Surface Water Pathway
Surface water runoff is a viable transport pathway for all contaminated surface soil at the FEMP.
During a rainfall event, soil particles are dislodged by the impact of raindrops and by the flow of
runoff across the soil surface. The dislodged soil particles travel overland in the runoff and
eventually become sediment in the receiving water courses. Contaminants hi the soil particles are
also dissolved and transported into the runoff and the receiving surface water. Some of the
contaminated surface water infiltrates through the upper portions of the glacial overburden to the
perched water. Infiltration to the Great Miami Aquifer through portions of the streambeds of Paddys
Run and the SSOD where die streams have cut through the glacial overburden also occurs. The
South Plume in the Great Miami Aquifer is an example of the impact caused by contaminant
migration hi the surface water pathway and subsequently the groundwater pathway. Although it is not
known to occur at the FEMP site, the potential exists for contaminated surface water to affect area
crops if it is used for irrigation. The potential for direct human exposure to contaminated surface
water exists along site drainages, Paddys Run and the Great Miami River.
FER\CRU5\NMG\ROD\SEC-5.ROD\Deeonber 11, 1995 l:44pm 5-17
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December 15, 1995
5.2.4 Perched Gfoundwater Pathway
Once contaminants reach the perched water beneath the FEMP they have the potential to migrate
laterally to various site drainages where they may reenter the surface water pathway via seepage.
Vertical seepage of contaminated perched water through the glacial overburden to the Great Miami
Aquifer is also a recognized pathway. Site characterization data indicate that these two pathways are
not presently contributing significant contamination to site surface water drainages or to the Great
Miami Aquifer; however, fate and transport modeling indicates that these two pathways will become
significant in the future if remedial action does not occur.
5.2.5 Groundwater Pathway
Rainfall, surface water runoff and perched water can infiltrate through the surface soil/sediment and
percolate down to the Great Miami Aquifer. The three major controlling mechanisms for the
groundwater migration pathway are:
• The leaching of contaminants from the soil matrix into the dissolved phase
• The percolation of the contaminated leachate or perched water through the overburden to the
underlying aquifer
• The movement of groundwater in the Great Miami Aquifer.
The groundwater pathway of migration has carried contaminants outside the FEMP property boundary
to the south and east of the FEMP. This contaminated groundwater has the potential to re-emerge as
surface water in Paddys Run where the Great Miami Aquifer water table intercepts the streambed
south of the FEMP. Fate and transport modeling indicates the Great Miami River to the east and
south of the FEMP could be impacted by this pathway in the distant future if remediation does not
occur.
Contaminated groundwater could affect crops and livestock by irrigation with or consumption of
water from wells in the affected area(s). Although presently not occurring, the potential for human
exposure to contaminants in groundwater exists in the affected areas.
5.3 MOBILITY OF CONTAMINANTS
Detailed discussions of contaminant mobility are provided in the Operable Unit 5 RI and FS reports
(DOE 1995d; 1995a) and in a site-specific contaminant mobility study entitled the Operable Unit 5 K[
FER\CRU5WMG\ROD\SEC-5.ROD\D«anber 11. 1995 l:44pm 5-18
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FEMP-05ROD-6 FINAL
December 15, 1995
Sampling and Analysis Results (Draft) (DOE 1995b). Kt is the source leaching coefficient used to
define the initial aqueous loading of uranium (for a full discussion see Section F.2.4 in the Operable
Unit 5 FS Report). The mobility of uranium, the predominant site contaminant, is discussed below.
Site investigations documented in the above-referenced reports show that outside the former
production area the majority of remaining uranium contamination has relatively low solubility and is
contained in the top 2 inches of surface soil. Aqueous spills and leaks occurred from production
activities and placed a large source of soluble uranium in local areas in the glacial overburden hi both
the former production area and waste storage area. Historic air emissions also deposited uranium hi
the form of uranium fluoride and oxide particles both inside and outside the production area (see
Figures 5-1 and 5-2).
After deposition, rainwater rapidly dissolved the soluble uranium fluoride particles and the resulting
plume quickly reached its maximum uranium concentration. Outside the former production area the
maximum uranium concentration hi the perched groundwater occurred many years ago. However, hi
the former production and waste storage areas, the soluble uranium has not been depleted and the
uranium concentration hi the migrating plume continues to increase.
In general, most soluble uranium forms at the FEMP have been removed by leaching, leaving the less
soluble forms. The leachability, and hence mobility, of the remaining uranium hi surface soil and the
percent of extractable uranium mass decreases with distance from the former production area.
FER\CRU5\NMG\RDD\SEC-5.ROD\December 11, 1995 l:44pm 5-19
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December 15, 1995
6.0 SUMMARY OF OPERABLE UNIT 5 RISK
DOE conducted a Baseline Risk Assessment for human health and a Site-Wide Ecological Risk
Assessment to evaluate and document potential threats to human health and ecological receptors,
respectively. The baseline risk assessment for human health evaluates risk under various hypothetical
scenarios to hypothetical receptors exposed to contaminants within Operable Unit 5 if remedial actions
are not taken. Baseline risk provides a measure against which the reduced risk associated with
various remedial action alternatives may be compared, as well as a measure of their relative
effectiveness. The ecological risk assessment determines if radiological and nonradiological
contaminants associated with the FEMP represent a current or future risk to ecological receptors
inhabiting the facility and nearby off-property areas if remedial actions are not taken. These receptors
include all organisms, exclusive of humans and domestic animals, potentially exposed to
contamination originating from the FEMP.
The baseline risk assessment (Appendix A of the Operable Unit 5 RI Report, DOE 1995d) was
conducted according to EPA guidance (EPA 1991a), the Risk Assessment Work Plan Addendum
(DOE 1992), and supplemental guidance to the Risk Assessment Work Plan Addendum. The media
of interest for the Operable Unit 5 baseline risk assessment are perched groundwater, groundwater in
the Great Miami Aquifer, surface water and sediment, surface and subsurface soils, flora and fauna
(including cattle grazing on the FEMP property), and crops and produce potentially affected by
contamination originating from the FEMP.
The site-wide ecological risk assessment (Appendix B of the Operable Unit 5 RI Report, 1995d) was
conducted following guidelines prepared by EPA Region 5 (EPA 1992). Both risk assessments are
briefly summarized in the Operable Unit 5 FS Report and the Proposed Plan (DOE 1995a and 1995c).
The baseline risk assessment for human health shows that, for all sources and pathways, every
receptor for each of the land use scenarios evaluated had a maximum calculated incremental lifetime
cancer risk (ILCR) greater man 1 x 10"5. In addition, the maximum calculated noncarcinogenic risk,
known as the hazard index (HI), was greater than 1 with two exceptions. The results of the site-wide
ecological risk assessment indicate that a number of constituents are present in soil, surface water and
sediment hi concentrations that may pose a risk to ecological receptors. The results of both the
baseline and the ecological risk assessments support the decision to take remedial action.
FER\CRU5\AEMVKOD\SEC6.ROD\December 11, 1995 2:13pm 6-1
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December 15, 1995
Sections 6.1 and 6.2 provide a summary of the baseline risk assessment for human health and the site-
wide ecological risk assessment, respectively.
6.1 HUMAN HEALTH RISK
The baseline risk assessment for human health determines whether adverse human health effects are
possible assuming an individual is exposed to the environmental media which define Operable Unit 5.
The baseline risk assessment is organized according to the four primary components listed below:
• Identification of constituents of potential concern
• Exposure assessment
• Toxicity assessment
• Risk characterization.
The following discussion follows the same organization and explains how Operable Unit 5 arrived at
the estimates of carcinogenic and noncarcinogenic risk. The results of the baseline risk assessment
support the FS by identifying constituents of potential concern (CPCs) and by providing risk estimates
for various human receptors under several plausible current and future land use scenarios.
6.1.1 Contaminant Identification
The identification of the major contaminants that are the primary contributors to risk begins with
identification of CPCs in the RI. Constituents of concern (COCs) are identified in the FS, and the
COCs that contribute 99 percent or more of the total estimated carcinogenic and noncarcinogenic risk
are identified in the Comprehensive Response Action Risk Evaluation (CRARE) in Appendix H of the
FS. The identification process is described in the following paragraphs.
Constituents of Potential Concern
CPCs are those chemicals and radionuclides hi environmental media that are retained for quantitative
evaluation in the baseline risk assessment. To select CPCs, a comprehensive review of analytical data
was conducted, focusing on the chemicals and radionuclides that, based on their prevalence,
concentration and toxicity, are considered to be of concern to human health. Organic constituents
detected in a given environmental medium were selected as CPCs based on toxicity screening and
frequency of detection. (A conservative toxicity screening value was used as a benchmark for CPC
selection.) Radiological constituents and metals (and other inorganic chemicals) were selected as
CPCs by comparing measured, on-property concentrations of a constituent to background
concentrations of that constituent hi the same environmental media. Laboratory contaminants
FER\CRU5\AEM\ROD\SEC6.ROD\Deconber 11. 1995 2:13pm 6-2
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FEMP-05ROD-6 FINAL
December 15, 1995
(identified during data validation), essential macronutrients and micronutrients (calcium, etc.), or
ubiquitous minerals (silica, etc.) were screened out as CPCs in the selection process. Table 6-1
identifies CPCs by media.
The methods and results of the CPC screening process are described in Sections A.2.3 and A.2.4 of
Appendix A of the Operable Unit 5 RI Report; the CPCs and their concentrations are presented in
Tables A.2-1 through A.2-12 (DOE 1995d). Due to the very large number of CPCs and their
associated data, these tables are not repeated hi the ROD.
Constituents of Concern
Not all CPCs identified in the Operable Unit 5 baseline risk assessment pose significant health risks
and many need not be considered in future remedial activities. The ones that remain are called
COCs. The purpose of restricting the number of COCs hi the remedial alternative evaluations during
the FS is to focus on the contaminants that require the implementation of remedial actions to ensure
the protection of human health and the environment.
This screening of CPCs to COCs is accomplished by following NCP guidelines, which establish a
general point of departure for acceptable risk as one in a million (10"6) for carcinogenic compounds
including radionuclides. The acceptable limit for noncarcinogenic effects is a HI of 1.0; an HI
greater than 1.0 indicates a potential toxic effect. However, because multiple contaminants are
considered, and to ensure no significant COCs are ignored, the screening point for selection of COCs
for the Operable Unit 5 FS is set at an ILCR of 10"7 and an individual HI of 0.1 to the hypothetical
on-property farmer. Any constituent with a risk level or HI less than these FS screening criteria is
not considered further. Details of the COC selection process can be found hi Section 2.3 of the
Operable Unit 5 FS Report (DOE 1995a).
Identifying Major Contaminants Driving Risk
The CRARE estimates the human-health risks associated with the FEMP after all remedial actions
have been completed. To ensure that the risk evaluated in this CRARE is focused on the most
significant constituents, risk assessors evaluated the COCs identified in the Operable Unit 5 FS
F£R\CRU5\A£M\ROD\SEC6.ROD\Oecember 11, 1995 2:13pm 6-3
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-1
CONSTITUENTS OF POTENTIAL CONCERN IN EACH MEDIUM FOR OPERABLE UNIT 5*
Constituent
Radionudide
Cesium-137
Neptunium-237
Protactinium-23 1
Lead-210
Plutonium-238
Plutonium-239
Plutonium-240
Radium-226
Radium-228
Radon-222c
Ruthenium-106
Strontium-90
Technetium-99
Thorium-228
Thorium-230
Thorium-232
Uranium-234
Uranium-235
Uranium-236
Uranium-238
Chemical
Acenaphthene
Acetone
Alpha-chlordane
Anthracene
Antimony
Aroclor-1221
Aroclor-1248
Aroclor-1254
Aroclor-1260
Arsenic
Barium
Benzene
Benzole acid
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Mediumb
SoU
SoU, GW, SW, Per
NA
SoU, Per, SW, Sed
SoU, SW, Per
SoU, SW, Per
SoU, SW, Per
SoU, GW, Per, SW, Sed
SoU, GW, SW, Sed
Air
SoU
SoU, GW, SW, Per
SoU, GW, Per, SW
SoU, Per, SW, Sed, GW
SoU, Per, SW, GW
SoU, Per, SW, Sed, GW
SoU, GW, Per, SW
SoU, GW, Per, SW, Sed
SoU, GW, Per, SW, Sed
SoU, GW, Per, SW, Sed
NA
SoU
GW, SW
NA
SoU, GW, SW, Per
NA
NA
.SoU, SW, Sed, GW
SoU, SW, Sed, GW
SoU, SW, Sed, Per, GW
SoU, SW, Per, GW
GW, SW , Per
NA
SoU.SW
SoU, SW
SoU
Constituent
Chemical (Continued)
Bis(2-ethylhexyl)phthalate
Boron
Bromodichloromethane
Bromomethane
2-Butanone
Butylbenzyl phthalate
Cadmium
Carbazole
Carbon disulfide
Carbon tetrachioride
4-Chloro-3-methylphenol
Chlorobenzene
Chloroethane
Chloroform
Chromium VI
Chrysene
Cobalt
Copper
Cyanide
4,4-DDE
Dibenzo(a,h)anthracene
3 ,3-Dichlorobenzidine
1,1-Dichloroethane
1 ,2-Dichloroethane
1,1-Dichloroethene
1 , 1 -Dichloroethy lene
1 ,2-Dichloroethylene
Dieldrin
Diethyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Endrin
Ethylbenzene
Ethylether
Fluoranthene
Fluorene
Fluoride
Mediumb
SoU, Per, SW,
SoU, GW, Per
SoU, GW, SW
GW, SW, SoU
SoU
NA
SoU, Per, SW,
SoU, GW, Per
Per, GW
Per
NA
NA
GW
GW, SW, Per
SoU, GW, SW
SoU
GW
SoU, Per, SW,
SW, GW, SoU
NA
SoU, SW
SW, SoU
SoU, GW
GW, Per
SoU, SW, Per,
NA
Per
SW
NA
SW
SoU, SW
NA
NA
NA
NA
NA
SoU, GW, Per,
GW
GW
GW
GW
SW
FER\CRU5\AEM\ROD\SEC6.ROD\Deconbcr 11, 1995 2:13pm
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-1
(Continued)
Constituent
Medium*
Constituent
Medium1*
Chemicals (Continued)
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Beryllium
Beta-BHC
Bis(2-chloroisopropyl)etlier
Manganese
Mercury
Methanol
Methylene chloride
2-Methylnaphthalene
4-Methyl-2-pentanone
4-Methylphenol
Molybdenum
Naphthalene
Nickel
Nitrate
4-Nitrophenol
N-Nitroso-di-n-propylamine
N-Nitrosodiphenylamine
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
Pentachlorophenol
Phenanthrene
Phenol
NA
Soil
SoU, GW, SW, Per
Soil
Soil, GW, SW
Soil, GW, Per, SW, Sed
SoU, GW, SW
NA
Soil, GW, Per, SW
NA
NA
SW, Soil, GW
Soil, Per, GW
NA
son, sw, GW
Soil, GW, Per, SW
Soil, GW, SW
Soil, Per
Soil, Sed
Soil
Soil
Per
NA
NA
Chemicals (Continued)
Heptachlorodibenzo-p-dioxia
Heptachlorodibenzofuran
2-Hexanone
Indeno(l ,2,3-cd)pyrene
Lead
Pyrene
Selenium
Silver
Styrene
1,1,2,2-Tetrachloroethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Tetrachlorodibenzo-p-dioxin
Tetrachlorodibenzofuran
Tetrachloroethene
Thallium
Toluene
Tributyl phosphate
Trichloroethene
Vanadium
Vinyl chloride
Xylenes (Total)
Zinc
Soil
Soil
NA
Soil
SoH, SW, Sed
NA
SoU, GW
SoU, Per, GW
NA
SoU, Per
SW
SW, Per
NA
NA
SoU, SW, Per
SoU, Per
NA
Per
SoU, GW, Per
SoU, Per, SW, GW
SoU, GW, Per
NA
SoU, SW, GW
* CPCs for Operable Unit 5 were taken from the RI Report.
b Abbreviations used in this table:
GW = Groundwatcr
Sed = Sediment
Per = Perched groundwater
SW = Surface water
HWMU = Hazardous waste management unit
e Radon was the only CPC detected in on-site air samples. However, all surface soil CPC exposures through paniculate
inhalation are evaluated quantitatively in the CRARE.
NA - Not a CPC for OU5 but a COC for one or more other OUs as noted in the OUS FS Report, Table 2-3.
FER\CRU5\AEM\SOD\SEC6.ROD\Dceanbcr 11, 1995 2:13pm
6-5
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FEMP-05ROD-6 FINAL
December 15, 1995
Report. This process is detailed in Appendix H, Section H.2.3 of the FS. The CRAKE COC
selection process determines the total risk to the target receptors (undeveloped park-user and
off-property adult farmer and child) as calculated in the Operable Unit 5 baseline risk assessment.
Beginning with the constituents which contributed greatest to carcinogenic and noncarcinogenic risk,
the fractions of risk for each CPC (the CPCs as determined in the RI) were added until the
constituents which contributed 99 percent of the total risk were determined. Those CPCs contributing
to the remaining 1 percent were not included in the list because their contribution becomes
insignificant under postremedial conditions.
Table 6-2 presents the COCs that contribute 99 percent or more of the total carcinogenic and
noncarcinogenic risks and potential health effects as evaluated in the Operable Unit 5 CRARE.
6.1.2 Exposure Assessment
The second primary component of the baseline risk assessment is the exposure assessment. Exposure
is defined as contact between a person and a chemical or physical (e.g., radiological) agent. The
magnitude of the exposure resulting from such contact is determined by measuring or estimating
(through modeling) the amount of an agent available to the lungs, gastrointestinal system, or skin
during a specific period. Human activity patterns are a key determinant in predicting the nature and
magnitude of potential exposures. Exposure assessment is the determination or estimation of the
magnitude, frequency, duration, and route of exposures to plausible hypothetical receptors under
current and future land use scenarios. Quantitative exposure assessment is the estimation of an intake
by a receptor. The intake quantified during the exposure assessment is evaluated during the risk
characterization to estimate potential health risks to receptor populations.
The exposure assessment is conducted in three stages, and each stage is discussed in the following
paragraphs:
• Characterizing the exposure setting
• Identifying contaminant migration and exposure pathways (development of the conceptual
model for the site)
• Quantifying exposure.
Details are provided in Appendix A, Section A.3 of the Operable Unit 5 RI Report.
FER\CRU5\AEM\ROD\SEC6.ROD\December 11. 1995 2:13pm 6-6
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-2
MAJOR CONSTITUENTS OF CONCERN FOR OPERABLE UNIT 5
AS DEFINED IN THE CRARE*
Radionuclides
Cesium- 137
Radium-226
Radon-222
Strontium-90
Technetium-99
Thorium-228
Thorium-232
Uranium-234
Uranium-235/236
Uranium-238
Inorganics
Antimony
Arsenic
Beryllium
Cadmium
Copper
Cyanide
Manganese
Mercury
Molybdenum
Silver
Uranium-total
Zinc
Organics
Aroclor-1254
Aroclor-1260
Benzo(a)pyreneb
1 ,2-Dichloroethane
* This table includes those COCs mat contribute 99 percent or more of the total ILCR and HI.
b Concentrations of these compounds were determined from relative potency factors of other carcinogenic
polycyclic aromatic hydrocarbons identified on site.
FER\CRU5VROD\NMG\TBLS-2.ROD\December 11. 199S 2:13pm
6-7
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FEMP-05ROD-6 FINAL
December 15, 1995
Characterizing the Exposure Setting
An important component of characterizing the operable unit setting is identifying potentially exposed
populations. Demographic information is used, hi part, to select receptors for the exposure
assessments. As presented hi Section 1.3, the 1990 census estimates 22,900 people live within a
5-mile radius of the FEMP hi scattered residences and several villages.
Some of the nearest residences are along the western side of Paddys Run Road, a road that closely
parallels the western property boundary. A dairy farm is located on Willey Road just outside the
southeast corner of the boundary; leased grazing areas include acres inside the FEMP boundary.
Several residences located south of the FEMP property boundary are located over the South Plume,
that portion of the Great Miami Aquifer along Paddys Run contaminated by uranium that extends
approximately one-half mile south of the FEMP boundary. Several industries are located south of the
FEMP, and Miami Whitewater Forest (a county park) is located within 5 miles of the FEMP.
Future land use scenarios are difficult to develop at government facilities. A reasonable scenario is
that the government retains control of and restricts access to the property. However, because the
possibility exists that the government will not control the site, the future land use includes a second
scenario which considers unrestricted use of the property including farming hi the baseline risk
assessment for both current and future land use scenarios. Table 6-3 describes receptors, exposure
locations, media to which receptors are exposed, and exposure routes evaluated.
Identifying Contaminant Migration and Exposure Pathways
In many cases, the size or area of a site or operable unit is small enough so that the risk assessor can
evaluate all data as one group or set. However, the large area of Operable Unit S, and the uneven
distribution of contaminants present hi the environmental media made it necessary to divide the site
into 10 areas. An evaluation of the site as one area would underestimate total risk because several
areas have constituents present hi relatively low concentrations. By evaluating separate areas, the
results clearly identify those areas with the highest risk.
Each of the 10 areas was examined much the same as if each area were the site. A conceptual model
was developed to provide the basis for identifying and evaluating the potential risks to human health
hi the baseline risk assessment assuming current and hypothetical future contaminant sources hi
environmental media (referred to as source terms) and land use conditions (Figures 6-1 and 6-2). As
outlined hi the following paragraphs, the model considers four scenarios and is used to evaluate
FER\CRU5\NMG\ROD\SEC6.ROD\Deconber 11, 199S 2:13pm 6-8
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ACAO N \DA1A\B8RE902\JUNE1994\6-1DWG 10/26/94
FIGURE 6-1.
OPERABLE UNIT 5
CONCEPTUAL MODEL
CURRENT SOURCE TERM
AND LAND USE SCENARIOS
6-9
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ACAO C \JUNE 199*\6-2 OWG 10/21/9* MJJ
FIGURE 6-2
OPERABLE UNIT 5
CONCEPTUAL MODEL
FUTURE SOURCE TERM AND
LAND USE SCENARIOS
6-10
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TABLE 6-3
SUMMARY OF LAND USE SCENARIOS AND RECEPTORS'
Receptor
Description
Exposure Locations
Media to which Exposed Exposure Routes
Current Site Conditions and Land Use With Access Controls
Off-Property resident
Farmer/Child
Farm family lives adjacent to
the FEMP property boundary.
Rural/agricultural area along eastern,
southern, northern, and western
fencelines of site.
Rural/agricultural area at the northeast
comer of site.
Rural/agricultural area at the southeast
comer of site.
Air, groundwater, and soil Inhalation of fugitive dust, volatiles, and
gases; consumption of farm-produced
foodstuffs; dermal contact and inhalation
while using groundwater in the home;
incidental ingestion of, direct radiation
exposure from, and dermal contact with
soil.
u Consumer of Meat and
I* Milk Products
a\
H* Groundskeeper
User of animal products
produced by cattle grazing on
FEMP property.
Grazing areas exist within the FEMP
property boundary to the northwest,
northeast, south and west of the
production area.
Cattle exposed to soil and Ingestion of meat; ingestion of milk
surface water.
Full-time employee who does
routine maintenance and security
work.
All on-property areas
Soil and air
Inhalation of fugitive dust, volatiles, and
radon; incidental ingestion of soil; dermal
contact; external radiation exposure.
Visitor
A regular visitor to the FEMP
who is not covered by a health
and safety or radiation
protection program. An
example is a delivery person.
The administration area only.
Soil and air
Inhalation of fugitive dust, volatiles, and
gases; external radiation exposure from soil.
Trespassing Youth
Youth on-property without
permission.
All areas except the production area.
Soil, air, surface water,
and sediment
Inhalation of fugitive dust, volatiles, and
gases; incidental ingestion of, external
radiation exposure from, and dermal contact
with contaminated soil and sediment;
incidental ingestion of and dermal contact
with surface water.
Critical Subpopulations
Local school children and youths Schools located 5 miles NW, 2 miles
(grades K through 8 for SW, 4 miles SE, 4 miles NE of site,
elementary students and grades 9 and 3 miles NE of the FEMP site.
through 12 for high school
students).
Air
Inhalation of fugitive dust, volatiles, and
gases.
Great Miami River
User
Individual who obtains water
from the river for either
domestic, agricultural, or
recreational uses, or any
combination of the three.
This receptor was evaluated at the
outfall effluent line and the Great
Miami River confluence with Paddys
Run.
Surface water and
sediment
Incidental ingestion of surface water;
inhalation of VOCs from use of water in the
home; dermal contact with surface water;
ingestion of farm-produced foodstuffs and
fish caught in the river; ingestion of
drinking water.
-------
1
2)
to
TABLE 6-3
(Continued)
Receptor
Description
Current Site Conditions and Land Use Without Access
Off-Property Same as for case with access
Farmer/Child controls except the family has
unrestricted use of groundwater
and access to potential on-
property grazing areas.
Consumer of Meat and
Milk Products
Groundskeeper
Visitor
Exploring Youth
Critical Subpopulations
Great Miami River
User
Future Land Use with
Off-Property
Farmer/Child
Same as for case with access
controls
Same as for case with access
controls
Same as for case with access
controls
A child playing at the FEMP,
particularly along Paddys Run.
Same as for case with access
controls
Same as for case with access
controls
Continued Federal Ownership
A farm family living adjacent to
the FEMP fenceline or at a
Exposure Locations
Controb
Same as for case with access controls
Same as for case with access controls
Same as for case with access controls
Administration and production areas.
All on-property areas.
Same as for case with access controls
Same as for case with access controls
Rural/agricultural area along eastern,
southern, northern, and western
Media to which Exposed
Same as for case with
access controls
Same as for case with
access controls
Same as for case with
access controls
Same as for case with
access controls
Same as for case with
access controls
Same as for case with
access controls
Same as for case with
access controls
Air, groundwater, and
soil. The farm family
Exposure Routes
Same as for case with access controls except
includes ingestion of groundwater
Same as for case with access controls
Same as for case with access controls
Same as for case with access controls
Same as for case with access controls
Same as for case with access controls
Same as for case with access controls
Ingestion of groundwater; inhalation of
fugitive dust, volatile^, and gases;
location nearby. Assumes an
85 percent vegetative covering
of the FEMP property.
fencelines of site.
Rural/agricultural area at the northeast
corner of site.
Rural/agricultural area at the southeast
comer of site. Three off-site locations.
would have unrestricted
use of groundwater
consumption of farm-produced foodstuffs;
dermal contact and inhalation while using
groundwater in the home; incidental
ingestion of, direct radiation exposure from,
and dermal contact with soil.
3
o- O
a a
"
Recreational Receptors FEMP is accessible to the public
Wildlife as a park. Use may vary
Reserve depending on the type of park; a
Undeveloped wildlife reserve; an undeveloped
Park park with limited recreation; or
Developed a developed park with
Park playgrounds and ball fields.
Seven on-property areas selected based
on the results of air and groundwater
modeling results and a review of
measured soil concentrations.
Surface water, sediment,
air, soil
Inhalation of fugitive dusts, volatiles, and
gases; incidental ingestion of, external
radiation exposure from, and dermal contact
with soil and sediment; incidental ingestion
of and dermal contact with surface water.
-------
TABLE 6-3
(Continued)
Receptor
Description
Exposure Locations
Media to which Exposed Exposure Routes
Future Land Use with Continued Federal Ownership (Continued)
Groundskeeper
Full-time employee who does Same seven locations specified for the
routine maintenance and security recreational receptors.
work.
Soil and air
Inhalation of fugitive dust, volatiles, and
radon; incidental ingestion of soil; dermal
contact; external radiation exposure.
c
Great Miami River
User
Individual who obtains water
from the river for either
domestic, agricultural, or
recreational uses, or any
combination of die three.
This receptor was evaluated at the
outfall effluent line and the Great
Miami River confluence with Paddys
Run.
Surface water and
sediment
Incidental ingestion of surface water;
inhalation of VOCs from use of water in the
home; dermal contact with surface water;
ingestion of farm-produced foodstuffs and
fish caught in the river; ingestion of
drinking water.
Future Land Use Without Federal Ownership
Off-Property
Farmer/Child
Same as for case with access
controls except for assuming 50
percent vegetative cover of the
FEMP.
Same as for case with access controls
Same as for case with
access controls
Same as for case with access controls
Great Miami River
User
Same as for case with access
controls
Same as for case with access controls
Same as for case with
access controls
Same as for case with access controls
On-Property (central
tendency)
Farmer/Child
A farmer resides on the property Same seven locations specified for the
and conducts agricultural
activities. The exposure of the
child is similar to the adult with
modifications of exposure
parameters to reflect those
typical of a child.
recreational receptors identified under
future land use with federal ownership.
Air, soil, perched
groundwater, and radon
Inhalation of fugitive dust, vola tiles, and
gases; ingestion of groundwater (separate
evaluations for perched and aquifer water);
dermal contact and inhalation while using
groundwater in the home; consumption of
foodstuffs grown on the property; incidental
ingestion of, external radiation from, and
dermal contact with soil.
Homebuilder
This exposure evaluates a
construction worker (or a farmer
building her/his own house)
constructing a house.
Same seven RME locations specified
for the on-property resident
farmer/child.
Soil and air
Inhalation of particulates, volatiles, and
gases; incidental ingestion of, dermal
contact with, or external radiation from soil.
"Information summarized from tables in Appendix A.3 of the OUS Final RI Report.
-------
FEMP-05ROD-6 FINAL
December 15, 1995
contaminant concentrations measured or estimated for several on-property and off-property areas or
receptor locations. Risk evaluation areas and receptor locations were determined based on an
understanding of historical and current land use, the plausible future land use, and the location of
sensitive human receptors. The four scenarios are:
• Current land use with access controls: the FEMP is defined as a facility operated by the
DOE. Further, it is assumed that members of the public do not establish residence on the
Operable Unit 5 study area. However, fanners do use on-property areas for pasture land.
• Current land use without access controls: access restrictions at the FEMP site historically
provided by DOE are assumed to be discontinued, and the FEMP site is operated by an
industrial concern other than DOE. This scenario assumes that members of the public do not
establish residence on the Operable Unit 5 study area.
• Future land use with federal ownership or institutional controls (government reserve):
assumes that the federal government continues to maintain control over the land use at the
FEMP. An industrial or recreational land use scenario is plausible.
• Future land use without federal ownership of institutional controls (agricultural): assumes
that no access/institutional controls are in place and includes exposure routes that require
development time, such as establishing a home and farm operations on property.
Quantifying Exposure
The final component of the exposure assessment is the determination of the exposure point-
concentration (i.e., the concentration to which a receptor is exposed and the quantification of the
intake resulting from exposure). For the Operable Unit 5 baseline risk assessment, exposure-point
concentrations for environmental media are mainly based on analytical data resulting from the RI
sampling and analytical programs. However, for certain scenarios, the exposure-point concentrations
must be based on environmental transport modeling. Section 5.0 and Appendix F of the Operable
Unit 5 RI Report address the modeling results in detail. Appendix A.3 of the RI Report specifies the
assumptions regarding source terms and potential release mechanisms on which the transport modeling
is based; estimated exposure-point concentrations used in exposure calculations are tabulated in
baseline risk assessment Tables A.3-3 through A.3-19. Ranges of exposure-point concentrations are
shown in Table 6-4.
Section A.3.4 describes how the exposure-point concentrations are used with scenario-specific
assumptions and intake parameters to arrive at exposure values. The models and equations used to
quantify intakes are described in the Risk Assessment Work Plan Addendum (DOE 1992). EPA
guidance (EPA 1989a) was considered in determining appropriate intake equations. In cases where
FER\CRU5\NMG\ROD\SEC6.ROD\Dccaober 11. 1995 2:13pm 6-14
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 7 - 6.6E-06
4.7E-07 - 4.7E-06
9.2E-07 - 1.1E-05
1.4E05 - 3.1E-04
1.3E-06 - 2.8E-05
1.8E-05 - 3.6E-04
(mg/nf)
NA
2.3E-12-'3.9E-11
6.0E-14 - 1.4E-12
2.3E-12-6.0E-11
1.5&09 - 8.6E09
7.0E-10 - 2.9&O9
7.4E-11 - 3.2E-10
4.1E-10- 1.5E-09
1.9E-09 - 1.0&08
2.9B-11 - 1.5E-10
6.7E-08 - 2.7E07
1.3E-11 - 1.9E-10
5.8E-10 - 2.5E-09
6.6E-10 - 2.8E-O9
5.2E-08 - 9.5&07
1.3&08 - 6.9EO8
Sediment0
(pCS/g)
NA
0.69- 1.1
NA
ND-0.99
NA
0.70 - 0.73
0.57 - 0.80
3.7-3.8
0.025 - 0.90
3.1-46
(mg/kg)
NA
NA
NA
0.13-0.55
NA
ND- 10
ND-3.5
ND-5.5
ND- 19
ND - 0.49
ND- 1600
NA
ND-6.6
ND-6.8
23-31
ND-81
Groundwater
(includes Perched)
(pCi/L)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
(mg/L)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Surface Water4
(pCi/L)
NA
ND- 1.7
NA
NA
ND-89
ND
ND-0.40
11 - 1200
1.7 - 42
1.4 - 1200
(mg/L)
NA
NA
NA
NA
ND - 2.5E-03
ND - 5.4E-03
ND - 1.5E-03
ND - 6.3E-03
ND - 0.020
2.4E-03 - 7.7E-
03
0.041 - 0.83
ND - 6.0E-04
ND - 0.023
ND - 4.0E-03
0.035 - 2900
0.015 - 0.073
FER\CRU5\ROD\NMG\TBLW.ROD\Deconber 11, 1995 2:13pm
6-15
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-4
(Continued)
Constituent
Surface Soil0
Subsurface
Soil
Air*
Sediment*
Groundwater11
Surface Water1
Off-Property, Current Land Use
RadionucKdes
Cesium- 137+ Id
Radium-226+5d
Radon-222+4d
Strontium-90+ld
Technetium-99
Thorium-228+7d
Thorium-232
Uranium- 234
Uranium-235/236
Uranium-238+2d
Organic Chemicals
1 ,2-dichloroethane
Aroclor-1254
Aioclor-1260
Benzo(a)pyrene
Inorganics
Antimony
Arsenic
Beryllium
Cadmium
Copper
Cyanide
Manganese
Mercury
Molybdenum
Silver
Uranium-total
Zinc
(pO/g)
0.60 - 0.87
0.90 - 1.2
NA
1.0 - 5.2
ND-3.5
1.2 - 1.7
1.0 - 1.6
2.6 - 14
ND-3.6
2.7 - 21
(mg/kg)
ND
ND
ND
ND-0.11
ND-2.9
4.3 - 7.0
0.74 - 1.4
ND- 1.9
1.2-2.1
0.42 - 0.43
1200-4400
ND
ND- 1.2
ND- 1.8
8.3-68
8.0 - 430
(pCi/g)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
(mg/kg)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
(pCS/m3)
2.5E-09-5.1E-08
4.4E-08 - 1.6E-03
0.079 - 4.9
2.6E-10 - 2.2&07
2.6E-O8 - 3.7E-06
5.4E-08 - 1.5E-06
6.1E-08-3.9E06
2.9E-07 - 8.2E-05
4.6E-08 - 5.3E-06
l.OE-06 - 7.0&05
(mg/m3)
NA
l.OE-17 - 9.5E-12
l.OE-17 - 1.9E-13
l.OE-17 - 6.6E-12
4.7E-12 - 1.7E-09
2.7E-12- 1.1E-09
2.4E-13 - 1.2E-10
1.1E-12-4.9E-10
7.3E-12 - 4.6E-09
1.1E-13-7.3E-11
2.3E-10-1.1&07
8.2E-14-4.3E-11
1.7E-12 - 8.8E-10
1.9E-12 - 7.5E-10
3.0E-09- 1.9E-07
3.4E-11- 1.8E-08
(pCi/g)
NA
1.1
NA
NA
NA
0.40
0.80
0.80
ND
0.70
(mg/kg)
NA
NA
NA
NA
NA
4.8
1.8
ND
7.6
ND
500
NA
ND
0.25
11
50
(pCS/L)
NA
1.2-3.2
NA
ND-5.7
ND-24
0.30 - 5.9
ND-2.7
0.60 - 100
ND-3.6
0.70 - 3.8
(mg/L)
ND-0.31
NA
NA
NA
ND - 0.031
ND - 0.31
ND- 0.0020
0.0022 - 0.029
0.0063 - 0.060
ND - 0.055
0.13-6.1
ND - 0.0015
ND - 0.045
ND - 0.029
9.0E-04 - 6.6E-03
ND - 0.28
(pCi/L)
NA
2.0 - 2.8
NA
NA
ND
ND-3.2
ND
0.80-7.0
ND-2.0
0.60-3.9
(mg/L)
NA
NA
NA
NA
ND - 0.015
2.9E-03 - 6.0E-
03
ND - 7.7E-03
ND - 0.018
ND- 0.031
ND - 0.021
0.056 - 0.56
ND
ND
ND
2.5E-03 - 8.8E-
03
ND-0.11
FER\CRU5\ROD\NMG\TBL6-4.ROD\DoOTiber 11, 1995 2:13pm
6-16
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-4
(Continued)
Constituent
Surface SoiP
Subsurface
Soilk
Air1
Sediment01
Groundwater"
Surface Water0
On-Property, Future Land Use
Radionucfides
Cesium- 137+ Id
Radium-226+5d
Radon-222+4d
Strontium-90+ld
Technetium-99
Thorium-228+7d
Thorium-232
Uranium-234
Uranium-235/236
Uranium-238+2d
Organic
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-4
(Continued)
Constituent
Sur&ce SoiP
Subsurface
Soil
Air*
Sediment
Groundwatet*
Surface Water"
Off-Property, Future Land Use
Radioaoclides
Cesium-137+ Id
Radium-226+5d
Radon-222+4d
Strontium-90+ld
Technetium-99
Thorium-228+7d
Thorium-232
Uranium-234
Uranium-235/236
Uranium-238+2d
Orgaxnc Cbanicals
1,2-dichloroethane
Atoclor-1254
Aroclor-1260
Benzo(a)pyrene
Inorganics
Antimony
Arsenic
Beryllium
Cadmium
Copper
Cyanide
Manganese
Mercury
Molybdenum
Silver
Uranium-total
Zinc
Source of all Table 6-4
(pCi/g)
0.60 - 0.87
0.90 - 1.2
NA
1.0-5.2
ND-3.5
NA
1.0 - 1.6
2.6 - 14
ND-3.6
2.7 - 21
Gng/kg)
ND
ND
ND
ND-0.11
ND-2.9
4.3 - 7.0
ND-1.4
ND-1.9
12-21
0.42 - 0.43
1200-4400
ND
ND-12
ND-1.8
11-68
(pCi/g)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
(nog/kg)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
80 - 430 NA
data for comparison to obtain
(pCi/m>)
1.4E-08 - 1.4E-06
7.2E-06 - 8.1E-04
0.64 - 4.9
4.4E-08 - 6.0E-06
5.3E-07 - l.OE-04
NA
7.7E-07-1.1E-04
1.8E-05-2.2E-03
1.3E-06 - 1.4B-04
1.8E-05-1.9E-03
(mg/m3)
NA
2.2E-12 - 2.6E-10
4.5E-14 - 5.3E-12
1.6E-12 - 1.8E-10
4.7E-10 - 4.5E-08
2.8E-10 - 2.9B-08
3.0E-11 -3.3E-09
1.2E-10-1.3E-08
l.OE-09 - 1.2E-07
1.6E-11-2.0E-09
2.7E-08 - 3.1E-06
1.1E-11 - 1.2E-09
2.2E-10 - 2.4E-08
2.0E-10 - 2.0E-08
4.8E-08 - 5.1&06
4.5E-09 - 4.9E-07
greatest range is the
(pCi/g)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Gog/kg)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Final OU5 RI
(pCi/L)
NA
8.8E-16 - 1.3
NA
9.5E-11 - 0.59
5.9E-03 - 1500
NA
NA
0.013 - 600
5.8E-04 - 27
0.012 - 590
(mg/L)
NA
NA
NA
NA
1.3E-16 - 1.6E-03
1.9E-20 - 5.4E-06
NA
NA
0.27 -0.97
3.8E-19 - 0.44
4.3B-13 - 5.8E-10
NA
NA
3.7E-05 - 1.8
NA
Report, Appendix A
(pCi/L)
NA
• 0.41
NA
0.11
130
NA
5.6E-03
73
4.5
86
(mg/L)
NA
5.1E-07
1.6E-07
NA
1.3E-04
2.5E-04
3.3E-06
NA
NA
0.012
0.025
1.4E-04
NA
NA
0.17
NA
(DOE 1995d):
a Table A.3-3 and Table A.3-4.
b Table A.3-9; these are modeled values.
Table A.3-17
d Table A.3-16
e Table A.3-5
f Table A.3-10 and Table A.3-llb; these are modeled values.
8 Table A.3-16
EER\CRU5\ROD\NMG\TBLfr4.ROD\Decanber 11, 1995 2:13pm
6-18
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-4
(Continued)
h Table A.3-13
1 Table A.3-16
J Table A.3-6
k Table A.3-8
1 Table A.3-11
m Table A.3-19; modeling was used to obtain representative concentrations for the waste pit area, the southwest area, and the
southeast area.
n Table A.3-14; these are modeled values.
Table A.3-18
p Table A.3-7
q Table A.3-12; these are modeled values.
* Table A.3-1S; these are modeled values.
* Table A.3-18; modeling was used to obtain concentrations for surface water at the southwest area and the Great Miami River
at confluence with Paddys Run.
ND - Contaminant is not a CPC for this scenario. For radiological chemicals, there is a difference in the CPC list for current
versus future land use scenarios. This difference is a function of the assumptions made regarding the equilibrium and the
properties of the radiologicals. See Section A.3.3. In accordance with EPA Risk Assessment Guidance, nondetected
values were estimated at one-half the sample quantitation limit for calculations involving nondetects.
NA - Contaminant was not evaluated.
FER\CRU5\ROD\NMG\TBL6-4.ROD\Decanber 11, 1995 2:13pm 6-19
-------
FEMP-05ROD-6 FINAL
December 15, 1995
models were not available from EPA, models developed by the U.S. Nuclear Regulatory Commission
(NRC) Regulatory Guide 1.109 (NRC 1977) were used.
The method used to quantify chronic exposures at the FEMP employs the concept of reasonable
maximum exposure (RME) for each of the four land use/source-term scenario combinations. If the
RME is determined to be acceptable, then it is likely that all other lesser exposures represented by
other hypothetical receptors at the site will also be acceptable. Exposures for the on-property resident
are also evaluated using the central tendency (CT) analysis. The CT analysis represents exposures
under more typical situations and exposure parameters are selected accordingly.
The initial step of a quantitative exposure assessment is determining the exposure routes for each
environmental media. For example, exposure routes for soil include incidental ingestion, skin
(dermal) contact, and direct external radiation. The equations used with each exposure route to
estimate dose include a set of exposure parameters. For the incidental ingestion exposure route, some
of the parameters included in the calculations are exposure-point concentration, ingestion rate
(grams/day), exposure duration in years, exposure frequency in days per year, and body weight.
The equations and exposure parameters are unique to each exposure pathway. Exposure model
equations and parameters used hi the baseline risk assessment are presented in Tables A.3-20,
A.3-21a, and A.3-21b in Appendix A of the RI Report. They are summarized in Table 6-5.
Because exposures depend on measured or predicted concentrations of chemicals in environmental
media and local land use practices, they are subject to change over time. This produces a large
number of possible combinations of media, receptors, exposure pathways, and constituent
concentrations. The exposure pathways selected for this baseline risk assessment are reasonable in
light of the current and anticipated future land use scenarios and with regard to the contamination
detected hi the environmental media.
FER\CRUS\NMG\ROD\SEC6.ROD\Deconber 11, 1995 2:13pm 6-20
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-5
EXPOSURE PARAMETERS IN THE OPERABLE UNIT 5 BASELINE RISK ASSESSMENT
Exposure Duration
Receptor (year)
Current Land Use Receptors
Off-property RME adult fanner
Off-property RME child
User of meat and milk grown within
OU5
On-property groundskeeper
On-property visitor
Trespassing/Exploring youth
Critical subpopulations
Grades K-8
Grades 9-12
Great Miami River user
Future Land Use Receptors
Off-property adult fanner
Off-property RME child
User of Great Miami River water
On-property CT adult fanner
On-property RME child
On-property home builder
On-property groundskeeper
Future Land Use Recreational Receptors'
Wildlife reserve
Child
Youth
Adult
Senior
Undeveloped park
Child
Youth
Adult
Senior
Developed park
Child
Youth
Adult
Senior
701
6'
701
25'
25'
12f
9
4
701
70*
6'
701
70*
61
lk
25d
6
12
38
14
6
12
38
14
6
12
38
14
Exposure Frequency
(day/year)
350*
350*
350*
250/39°
2501
52f
180"
180*
350"
3501
3501
350-
3501
3501
175"
250/39"
26
39
52
26
40
104
40
26
64
104
40
40
Exposure Time
(hour/day)
5.7b
2"
NA
8d
T
4f
2"
2"
NA
5.7"
2"
NA
4.9*
21
8"
8d
1
2
2
1
1
2
2
1
4
4
4
2
FER\CRU5\NMG\ROD\SEC6.ROD\Deconber 11, 199S 2:13pm
6-21
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-5
(Continued)
• DOE1992a
* A«mnv.« the reasonable ma-rimum exposure farmer works outdoors 2000 hours/year, (5.7 bra/day), and a resident child spends 700
hn/yr outdoors, (2 hn/day).
c Assumes a groundskeeper spends 250 days/yr in the production area and 39 days/year in peripheral areas while the groundskeeper is
assumed to spend 6.4 hn/day indoors and 1.6 hn/day outdoors. The groundskeeper in peripheral areas spends 8 hn/day outdoors during
39 days/yr.
« EPA1991b
* Assumes a visitor (delivery person) who comes on property 250 days/year for 2 hour/day.
' DOE 1993d, Comment Responses - Site-Wide Characterization Report: assumes a youth trespasses on site 3 days/week for the months of
June, July and August (36 days while the youth is not in school) plus 1 day/week for the months of April, May, September and October
(16 days) for a total of 52 days, 4 hn/day. The trespassing youth trespasses on peripheral areas due to access controls. The exploring
youth can gain access to all areas.
' According to the State of Ohio, school year is 180 days.
1 Assumes elementary and high school rti'fontt spend 1/2 hr walking to school, 1/2 hr walking home from school, and approximately 1
hour in recess or outdoor activities, for a total of 2 hn/day outdoors.
' EPA 1991b; assumes the central tendency farmer spends 1155 cumulative hours fanning. Therefore 115 hrs/234 days = 4.9 hr/day
spent ouldoon. Indoor duration is the remaining time in a day = 19.1 hn/day.
' Assumes a resident small child spends 700 houn/yr outdoors (2 hn/day x 350 days/yr).
k Assumes a home builder spends 175 eight-hour days building a home, spending 50 percent of her/his time working on the exterior of the
house, and 50 percent of her/his time working on die interior of the house.
1 See section A.3.4.6.2 of the Operable Unit 5 RI Report for an explanation of these terms.
NA - Not applicable
FER\CRU5\ROD\NMG\TBL6-S.ROD\December 11. 1995 2:13pm 6-22
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FEMP-05ROD-6 FINAL
December 15, 1995
6.1.3 Toxicity Assessment
The toxicity assessment, the third primary component of the baseline risk assessment, addresses two
primary human health hazards — cancer induction and chemical toxicity. Cancer is a genotoxic effect
and may be induced by exposure to a chemical carcinogen or ionizing radiation from a radionuclide
undergoing decay. Chemical noncarcinogenic toxicity refers to general toxicity that does not affect
the genetic material. It includes organ tissue effects, which are numerous and range from systemic
effects such as kidney or liver damage to localized effects such as skin or eye irritation.
Dose-response data from human and animal studies are used by the EPA to develop cancer slope
factors and reference doses which allow an estimation of cancer and noncancer risk, respectively.
Cancer slope factors (CSFs) have been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic chemicals
and numerous radionuclides. CSFs, which are expressed in units of (mg/kg-day)"1, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of
the excess lifetime cancer risk associated with exposure at that intake level. The term "upper-bound"
reflects the conservative estimate of the risks calculated from the CSF. This approach makes it highly
unlikely the actual cancer risk will be underestimated. CSFs are derived from the results of human
epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health
effects from exposure to chemicals exhibiting noncarcinogenic effects. RfD is expressed in units of
mg/kg-day. An RfD is defined as an estimate of a daily exposure level for the human population,
including sensitive subpopulations, that is likely to be without an appreciable risk of deleterious
effects. Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) can be compared to the RfD. RfDs are derived from
human epidemiological studies or animal studies to which uncertainty factors have been applied (e.g.,
to account for the use of animal data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for adverse noncarcinogenic effects to occur.
FER\CRU5\NMG\ROD\SEC6.ROD\Dcconber 11, 1995 2:13pm 6-23
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Cancer risks (the ILCRs) from exposure to chemical carcinogens and ionizing radiation are expressed
as a unitless probability, and are calculated as follows:
• For internal radiation exposures, ILCR = intake of radionuclide times its CSF
• For external radiation exposures, ILCR = the dose from exposure intake of the radionuclide
times its CSF
• For chemical carcinogenic risk, ILCR = intake of a chemical times its CSF.
Quantitative toxicity factors (i.e., CSFs and RfDs) for radionuclides and chemical constituents are
presented in Appendix A of the RI Report and in Tables 6-6 and 6-7.
6.1.4 Risk Characterization
The fourth primary component of the baseline risk assessment is risk characterization. In this
component, risk assessors combine the results of the exposure assessment and the toxicity assessment
to quantitatively estimate the degree of hazard associated with exposure to CPCs. The results are
characterized based on ranges of generally acceptable risk under CERCLA, an ILCR of 10"4 to 10"6 or
a HI equal to or less than 1 (EPA 1990).
For cancer induction, it is assumed that no dose threshold exists, so for any dose of a carcinogen
there exists a possibility of developing cancer. ILCRs are expressed in terms of the probability that a
given person (receptor) will develop cancer as a result of estimated exposures. For example, an
excess lifetime cancer risk of 1 x 10"* indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of exposure to a carcinogen under the
conditions specified in the exposure assessment. Risks below 1 x 10~* (a risk less than 1 hi 1 million)
are generally considered to be acceptable by the EPA, and risks greater than 1 x KT* (1 in 10,000)
are generally considered to be unacceptable by the agency (EPA 1989).
Potential concern for noncarcinogenic effects of a single contaminant hi a single medium is expressed
as the hazard quotient (HQ), which is the ratio of the estimated intake derived from the contaminant
concentration hi a given medium to the contaminant's reference dose. By adding the HQs for all
contaminants within a medium or across all media to which a receptor may reasonably be exposed,
the HI can be generated.' The HI provides a useful reference point for gauging the potential
EER\CRU5\NMG\RQD\SEC6.RQD\Decanber 11. 1995 2:13pm 6-24
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-6
CANCER SLOPE FACTORS FOR FEMP RADIOLOGICAL CONTAMINANTS CONTRIBUTING
MORE THAN 99 PERCENT OF TOTAL INCREMENTAL LIFETIME CANCER RISK AND
HAZARD INDEX
Radionuclide
Cesium- 137
Cesium-137 + ldc
Radium-226
Radium-226 +5dc
Radium-226 + 8dc>d
Radon-222
Radon-222 + 4dc
Strontium-90
Strontium-90 + ldc
Technetium-99
Thorium-228
Thorium-228 + 7dc
Thorium-232
Thorium-232 + 10dc-d
Uranium-234
Uranium-235
Uranium-235 + Id0-6
Uranium-236
Uranium-238
Uranium-238 + 2dc
SF0'
(Risk/pCi)
2.8 x ID'11
2.8 x lO'11
1.2 x 10'10
1.2 x 10-'°
7.8 x 10'10
1.4 x 10-12
1.7 x 10-'2
3.3 x 10"11
3.6 x ID'11
1.3 x 10-'2
1.1 x 10'11
5.5 x 10-11
1.2xlO-u
1.7 x 10-'°
1.6 x ID'11
1.6x lO'11
1.6 x 10'11
1.5 x lO"11
1.6 x 10'11
2.0 x 10-11
SFi'
(Risk/pCi)
1.9 x lO'11
1.9 x 10-11
3.0 x 10-09
3.0 x 10^
7.0 x 10"09
7.3 x lO'13
7.7 x ID"12
5.6 x 10-11
6.2 x lO'11
8.3 x 10-'2
7.7 x ICT08
7.8 x 10*8
2.8 x 10-°"
1.1 x ID"07
2.6 x lO^08
2.5 x 1008
2.5 x 10-08
2.5 x 10™
2.4 x 10-08
2.4 x 10*8
SFe •*
(Risk-g/yr-pCi)
0.0 x 10+0°
2.0 x 1046
1.2 x 10"08
6.0 x 10"06
6.0 x 10^
1.2x ID"09
5.9 x 10^
0.0 x 10+0°
0.0 x 10+fl°
6.0 x ID'13
5.5 x lO'10
5.6 x 10-06
2.6 x ID'11
8.5 x 10-06
3.0 x 10'1 '
2.4 x 10-07
2.4 x 10*7
2.4 x 10-"
2.1 x lO'11
5.1 x 10^8
* SF0 = Oral cancer slope factor; SF; = Inhalation cancer slope factor; SF. = External radiation cancer slope factor. SF0, SF,
and SF. acquired from U.S. EPA, Health Effects Assessment Summary Tables, March 1994.
b SF. incorporates a soil depth and density of 0.1 m and 1430 kg/m', respectively.
' "+d" Indicates that the slope factors (SFs) presented incorporate SFs that are available for the individual primary decay chain
products, from U.S. EPA, Health Effects Assessment Summary Tables, March 1994. (EPA 1994b)
' Slope factors to be used to evaluate future exposure scenarios involving parent radionuclide in equilibrium with progeny
• Slope factors for U-235+Id were used to evaluate exposures to U-235/236.
FER\CRU5\ROD\NMG\TBL&-6.ROD\Deconber 11, 1995 2:13pm
6-25
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-7
ORAL AND INHALATION SLOPE FACTORS AND REFERENCE DOSES
FOR INORGANIC AND ORGANIC CHEMICAL CONTAMINANTS
Reference Dose
Chemical
Inorganics
Antimony
Arsenic
Beryllium
Cadmium
Copper
Cyanide
Manganese
Mercury
Molybdenum
Silver
Zinc
Uranium
Organics
Aroclor-1254
Aroclor-1260
Benzo(a)pyrene
1,2-Dichloroethane
Oral Route of
Exposure
(mgflcg/day)
4.0xl(r04b
3.0xl(T04b
S.OxlO-03 b
S.OxlO-04 (water)6
l.Oxlfr05 (food)0
S.TlxKT0211
2.0xlO-a2e
1.4X10-01 (water) e
1.4X10-01 (food) e
3.0X10"04 e
S.OxKT03 b
S.OxlO48 b
3.0x10*' b
S.OxlO03
NA
NA
NA
NA
Inhalation Route
of Exposure
(mg/kg/day)
NA
NA
NA
NA
NA
NA
1.4x10^ b
8.6x10* **
NA
NA
NA
NA
NA
NA
NA
2.9x10^'
Cancer Slope Factor
Oral Route of
Exposure
(mg/kg/day)-1
NA
1.75xlO+w
4.3xlO+0° k
NA
NA
NA
NA
NA
NA
NA
NA
NA
7.7xlO+0° «
7.7xlO+0° *
7.3xlO+oob
9.1X10-02"
Inhalation Route
of Exposure
(mg/kg/day)-1
NA
1.5xlO+w b-c
8.4xlO+0° b-e
6.3xlO+0° b-c
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
6.1X10*00"
9.1xlO-°2b-'
U.S. EPA
Weight of
Evidence2
D
A
(lung cancer, skin
cancer)
B2
(lung cancer in
rats, monkeys;
tumors of the bone
in rabbits)
Bl
(respiratory system
tumors in humans;
inhalation/
occupational)
D
D
D
D
D
D
D
D
B2«
(liver tumors in
rats; suggestive
evidence of liver
cancer in humans)
B2«
(liver tumors in
rats; suggestive
evidence of liver
cancer in humans)
B2
(forestomach
tumors in rats,
mice; respiratory
tract tumors in
hamsters)
B2
(lung tumors in
mice)
FmCRU5\ROD\NMG\TBL6-7.ROD\D«anber 11, 1995 2:13pm
6-26
-------
FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 6-7
(Continued)
* U.S. EPA Carcinogen Classification:
Group A: Human Carcinogen (sufficient evidence of carcinogenicity in humans).
Group B: Probable Human Carcinogen (Bl-limited evidence of carcinogenicity in humans; B2-sufficient evidence of
carcinogenicity in «n;m«l« with inadequate or lack of evidence in humans).
Group C: Possible Human Carcinogen (limited evidence of carcinogenicity in animals and inadequate or lack of human data).
Group D: Not Classifiable as to Human Carcinogenicity (inadequate or no evidence).
Group E: Evidence of Noncarcinogenicity for Humans (no evidence of carcinogenicity in adequate studies).
b Dose-response parameter obtained from the U.S. EPA Integrated Risk Information System (IRIS). September 1994.
c Dose-response parameter calculated from a unit risk value.
d Reference dose derived from action level of 1.3 mg/L, which represents the maximum contaminant level goal (MCLG).
c Dose-response parameter obtained from the U.S. EPA Health Effects Assessment Summary Tables (HEAST), Annual FY 1994 (EPA
1994b)
f Dose-response parameter calculated from a reference concentration.
8 Cancer slope factor for polychlorinated biphenyls in general.
* Cancer slope factor derived by application of EPA toxicity equivalency factors (TEFs) to benzo(a)pyrene CSF (7.3/mg/kg-day). See
Table A.4-5 of the OU5 RI Report for TEFs.
1 EPA1994d
NA - Information not available.
FER\CRU5\ROD\NMG\TBLS-7.R0D\Decanber 11, 199S 2:13pm 6-27
-------
FEMP-05ROD-6 FINAL
December 15, 1995
significance of multiple contaminant exposures within a single medium or across media. An HQ or
HI equal to or less than 1 indicates that adverse noncarcinogenic health effects are not anticipated.
Due to the large quantity of information regarding each exposure medium and pathway, not all risk
characterization results are provided in the ROD. A comprehensive risk characterization for the
baseline risk assessment is provided in Appendix A of the RI Report. Estimated carcinogenic and
noncarcinogenic risks and His are presented by receptor and land use scenario in Tables 6-8
through 6-11. Descriptions for the maximum exposures for current and future land use scenarios
follow the tables.
Risk Estimate for RME - Current Land Use Scenario
The maximally exposed receptor for current land use scenarios (without access controls) is the
off-property farmer for whom total carcinogenic risk (the sum of radiological and chemical risks) is
estimated to be between 6.8 x 10"* (at the west property boundary) and 2.9 x 10'2 (at the south
property boundary). Over 60 percent of carcinogenic risk in the east, norm, and south areas of the
FEMP is due to CPCs in groundwater, primarily through ingestion of drinking water. Over
90 percent of carcinogenic risk hi the west, northeast, and southeast areas is due to CPCs hi soil,
primarily through ingestion of meat, milk, vegetables and fruit, incidental ingestion of soil, and
external radiation. The main carcinogenic drivers are isotopes of uranium, radium, and thorium;
strontium-90; technetium-99; and arsenic, beryllium, 1,1-dichloroethene, and 1,2-dichloroethane.
Noncarcinogenic risk (His) ranges from 3.0 for the receptor at the southeast corner of the FEMP to
77 on the southern boundary of the site. Uranium, antimony, arsenic, and cadmium are the dominant
chemicals contributing to noncarcinogenic health effects.
Risk Estimate for RME - Future Land Use Scenario
The maximally exposed receptor for future land use scenarios (without access controls) is the
on-property farmer living hi the former production area using perched groundwater (agricultural use).
The total estimated carcinogenic risk to this receptor is 5.2 x 10~2. The dominant carcinogenic
constituents are the isotopes of uranium. CPCs hi the groundwater contribute approximately
60 percent of this risk. The HI developed for the hypothetical exposures incurred by this receptor
was 1500, with uranium being the primary chemical toxicant. These risk results must be evaluated in
light of the fact that although the perched water zone could be a potential (but limited) drinking water
source, it would not support continuous domestic use by a family over a prolonged period of time.
FER\CRU5\ROD\NMG\TBL6-7.ROD\Decanber 11, 1995 2:13pra 6-28
-------
TABLE 6-8
ESTIMATED CARCINOGENIC RISKS AND POTENTIAL
NONCARCINOGENIC EFFECTS FOR CURRENT LAND USE WITH ACCESS CONTROLS
s
Range of Estimated Carcinogenic Risks
Receptor
Radiological
Chemical
Primary Source of
Primary Source of Range in Estimated Hazard Estimated
Estimated Risk Indicies Noncarcinogenic Effects
8
M
K>
-------
TABLE 6-8
(Continued)
Range of Estimated Carcinogenic Risks
Receptor
Radiological
Chemical
Primary Source of
Estimated Risk
Primary Source of
Range in Estimated Hazard Estimated
Indicies Noncarcinogenic Effects
*
(0
H*
1
Off-Property Receptors'" (Continued)
Great Miami River User 3.8E-05 to 3.9E-05
- household
Great Miami River User
- agricultural
Great Miami River User
- recreational
7.9E-06
2.1E-05to2.2E-05
5.2E-04 to l.OE-03 Ingestion of drinking
water, vegetables and
fruit, fish; dermal
contact when bathing
1 .OE-04 to 2.SE-04 Same as above
2.7E-04 to 4.5E-03 Same as above
l.OE+00 to 8.6E+00
2.5E+00 to 1.7E+01
4.2E-01 to 2.0E+02
Ingestion of drinking
water, vegetables and
fruit, meat, milk, and
fish; dermal contact
when bathing
Same as above
Same as above
•Source is Table A.7-1, final OU5 RI Report.
''Source is Table A.7-3, final OUS RI Report. Critical subpopulations were evaluated only under current land use conditions. Air was the only medium evaluated for
these receptors. Cancer risk estimates fell between 1.0 x 10"09 and 2.0 x 10"08, which are well below the acceptable risk level of 10"*. His were under 1.0 for all locations
evaluated. Therefore, it can be concluded that health impacts to children at local schools are minimal and insignificant under the current land use scenario. Tables A.5-19
and A.5-20 present the risk summaries for critical subpopulations.
-------
TABLE 6-9
ESTIMATED CARCINOGENIC RISKS AND POTENTIAL
NONCARCINOGENIC EFFECTS FOR CURRENT LAND USE WITHOUT ACCESS CONTROLS
jS-9.RQD\December
11, 1995 2:1;
1
z
*""*
Receptor
On-Property Receptors'
Groundskeeper
Visitor
Exploring youth
Off-property receptors'*
Consumer of meat
and milk products
Range of Estimated
Radiological
9.3E-06 to 1.1E-03
2.7E-05 to 4.6E-04
7.8E-07 to 7.7E-05
9.0E-05 to 6.3E-04
Carcinogenic Risks
Chemical
3.7E-07 to 1.7E-04
1.1E-09 to 1.9E-09
1.6E-07 to 1.1E-05
7.6E-06 to 9.9E-03
Primary Source of
Estimated Risk
External exposure to
radionuclides in soil
Same as above
Same as above
Ingestion of meat and
milk
Range in Estimated Hazard
Indicies
4.3E-02 to 5.4E+00
9.9E-04 to 1.2E-03
6.8E-02 to 2.6E+01
7.0E+00 to 2.3E+01
Primary Source of
Estimated
Noncarcinogenic Effects
Dermal contact with and
incidental ingestion of
soil
Inhalation of CPCs in air
Dermal contact with
surface water and soil
Ingestion of meat and
milk
Off-property RME
farmer
Off-property child
5.1E-04 to 9.7E-04
l.lE-08to2.8E-02
5.2E-05 to l.OE-04
3.6E-09 to 7.3E-03
Ingestion of drinking
water; ingestion of meat,
milk, vegetables and
fruit; incidental ingestion
of soil; external radiation
from CPCs in soil
Ingestion of milk (soil);
ingestion of drinking
water, vegetables and
fruit
3.0E+00 to 7.7E+01
1.6E+01 to2.9E+02
Ingestion of drinking
water, meat, milk,
vegetables and fruit;
incidental ingestion of
and dermal contact with
soil
Ingestion of meat, milk,
vegetables and fruit;
ingestion of drinking
water
IS
-------
TABLE 6-9
(Continued)
Range of Estimated Carcinogenic Risks
Receptor
Radiological
Chemical
Primary Source of
Estimated Risk
Primary Source of
Range in Estimated Hazard Estimated
Indicies Noncarcinogenic Effects
v*i
I
to
Off-property receptors'* (Continued)
Great Miami River
user - household
Great Miami River
user - agricultural
Great Miami River
user - recreational
3.8E-05 to 3.9E-05
7.9E-06
2.1E-05to2.2E-05
•Source is Table A.7-2, final OU5 RI Report.
bSource is Table A.7-4, final OU5 RI Report.
5.2E-04to l.OE-03
1.0E-04to2.5E-04
2.7E-04 to 4.5E-03
Ingestion of drinking
water, vegetables and
fruit, fish; dermal
contact when bathing
Same as above
Same as above
l.OE+OOto 1.1E+01
2.5E+00 to 1.8E+01
4.2E-01 to2.9E+02
Ingestion of drinking
water, vegetables and
fruit, meat, milk, and
fish; dermal contact
when bathing
Same as above
Same as above
-------
TABLE 6-10
ESTIMATED CARCINOGENIC RISKS AND POTENTIAL
NONCARCINOGENIC EFFECTS FOR FUTURE LAND USE WITH ACCESS CONTROLS
p
1
Range of Estimated Carcinogenic Risks
Receptor
Radiological
Chemical
Primary Source of
Estimated Risk
Range in Estimated
Hazard Indicies
Primary Source of
Estimated
Noncarcinogenic Effects
On-Property Receptors*
Groundskeeper 1.5E-05 to 1.1E-03
| Recreational - developed 2.3E-06 to 4.SE-04
park
Recreational -
undeveloped park
1.0E-06to2.0E-04
Recreational - wildlife 9.1E-07 to 1.8E-04
reserve
Off-Property Receptorsb
Off-property farmer 1.6E-05 to 2.2E-03
3.4E-06 to 6.3E-05
1.7E-06 to 3.3E-OS
1.1E-06 to2.5E-05
8.8E-07to2.1E-05
1.1E-08 to9.5E-05
External exposure to 3.4E-01 to 4.5E-I-00
radionuclides in soil;
inhalation
External exposure to 7.0E-02 to 1.7E+00
soil and sediment
External exposure to 5.9E-O2 to 1.7E+00
radionuclides in soil
and sediment
External exposure to 4.9E-02 to 1.6E+00
radionuclides in soil
Ingestion of milk, 3.1E-02 to 3.7E+01
meat, and vegetables;
external exposure to
soil; ingestion of
drinking water
Dermal contact with soil
Dermal contact with soil
and sediment
Same as above
Same as above
Ingestion of milk and
meat, drinking water, and
vegetables and fruit
1
I
-------
TABLE 6-10
(Continued)
Range of Estimated Carcinogenic Risks
Receptor
Radiological
Chemical
Primary Source of Range in Estimated
Estimated Risk Hazard Indicies
Primary Source of
Estimated
Noncarcinogenic Effects
g Off-Property Receptors'" (with and without access controls)
f Off-property child 4.2E-07 to 1.8E-04 3.9E-09 to 5.3E-05
Great Miami River user - 1.7E-04
household
.
Great Miami River user - 4.0E-05
agricultural
Great Miami River user - 1.4E-05
recreational
2.2E-05
4.8E-06
9.7E-05
Ingestion of drinking 7.9E-02 to 1 .5E+02
water; ingestion of
milk and meat;
ingestion of
vegetables and fruit
Ingestion of drinking 1. 8E+00
water
Same as above
Same as above
5.3E-01
8.5E-01
Ingestion of drinking
water; ingestion of milk,
meat, vegetables, and
fruit
Ingestion of drinking
water
Same as above
Same as above
• Source is Table A.7-5, final OU5 RI Report.
b Source is Table A.7-7, final OU5 RI Report.
\0
vo
-------
p
1
TABLE 6-11
ESTIMATED CARCINOGENIC RISKS AND POTENTIAL
NONCARCINOGENIC EFFECTS FOR FUTURE LAND USE WITHOUT ACCESS CONTROLS
Range of Estimated Carcinogenic Risks
Receptor
Radiological
Chemical
Primary Source of Estimated
Risk
Range in Estimated
Hazard Indicies
Primary Source of Estimated
Noncarcinogenic Effects
1
OJ
Oil-Property Receptors"
RME fanner
CT farmer
RME child
4.7E-04 to 1.5E-02 4.1E-04 to 8.7E-03 External exposure and ingestion
of milk; ingestion of drinking
water
2.3E+01 to 3.7E+02
2.8E-05 to 1.2E-03 2.4E-05 to 3.3E-04 Same as above; ingestion of meat 1.2E+01 to l.SE+02
Ingestion of milk and meat;
dermal contact; ingestion of
vegetables, fruit, and drinking
water
Ingestion of drinking water;
ingestion of milk and meat
4.9E-05 to 1.1E-03 9.5E-05 to 3.4B-03
RME farmer using 3.6E-02
perched
groundwater
Home builder 5.0E-07 to 3.8E-05
Off-Property Receptors1*
1.7E-02
Ingestion of drinking water;
external exposure to soil and
ingestion of milk
Ingestion of drinking water and
external exposure to soil
1.1E+02 to 8.4E+02 Ingestion of milk and meat
1.5E+03
Ingestion of drinking water
3.2E-07 to 1.2E-05 External exposure to soil
8.2E-01 to 3.5E+00 Dermal contact with soil
a Source is Table A.7-6, Final OU5 RI Report.
b See Table 6-10; off-property receptors are the same as those listed under future land use with access controls. Source is Table A.7-7, final OU5 RI Report.
5- O
12
-------
FEMP-05ROD-6 FINAL
December 15, 1995
A more representative hypothetical receptor for this scenario is the on-property RME farmer who uses
water from the Great Miami Aquifer rather than perched water. In addition, the risk assessment
assumes the receptor has access to all areas of the FEMP, not just the former production area. This
receptor had total estimated carcinogenic risks ranging from 6.0 x 10~3 to 2.2 x 10~2. The
predominant carcinogenic contaminants are isotopes of uranium, radium, thorium, beryllium, as well
as arsenic, the carcinogenic polycyclic aromatic hydrocarbons (PAHs), and Aroclor-1254 and -1260.
Noncarcinogenic risk for mis receptor ranged from 23 to 37. Uranium, magnesium, antimony,
mercury, silver, arsenic, and zinc are the dominant chemical toxicants. It should be noted that the
majority of estimated risk to this receptor is through the food pathways, which have the greatest range
of uncertainty among all exposure pathways due to the conservative assumptions used to develop
exposure parameters.
The tables in Attachment A.Vn in the RI Report contain the quantified carcinogenic risks and hazard
quotients of each CPC in each exposure medium for each exposure pathway according to current and
future land use scenarios.
Background Risks
Risks and hazard quotients are calculated for background concentrations of CPCs (taken from
Attachment A.I of the OUS RI Report) hi soil, groundwater, surface water, and sediment and then
compared with risks and HQs calculated for areas of high concentrations. The baseline risk
assessment calculates all site-related risks without separating the contribution from natural background
when, hi fact, the contribution from background concentrations for certain CPCs may yield an ILCR
greater than 10~* or an HI exceeding 1.0. Although the CPC selection includes a statistical
comparison to background, hi many cases the concentrations of CPCs in the environmental media of
Operable Unit 5 are at or only slightly above natural background concentrations. Some CPCs are
retained because the statistical procedures used to identify CPCs tend to select a CPC if there is any
question that it may be above background. Therefore, background contributions provide a useful
point of comparison for site-related risk estimates.
Carcinogenic and noncarcinogenic risks and HQs have been calculated for background concentrations
of CPCs hi Operable Unit 5 environmental media and are presented in Tables A.7-8 through A.7-19
hi Appendix A of the RI Report. The ILCRs and HQs for the major contaminants are summarized hi
Table 6-12. Exposure assumptions and models used for background calculations are the same as
FER\CRU5\AEM\ROD\SEe6.ROD\Deconber 11. 1995 2:13pm 6-36
-------
TABLE 6-12
INCREMENTAL LIFETIME CANCER RISKS (ILCRs) AND HAZARD QUOTIENTS (HQs) FROM EXPOSURE TO BACKGROUND
CONCENTRATIONS OF MAJOR CONTAMINANTS DETECTED IN ENVIRONMENTAL MEDIA ACCORDING TO CRITICAL RECEPTOR
?
Background Exposure and Critical Receptor
§ On-Property RME
g Farmer
f
§* Surface
„ Soil*
y Conrtituent (ILCR)
§ Radlonuclldw
S Cesium-137+ld 4.2E-OJ
Radium-226+4d 3.1E-04
Radon-222 NA
^J Strontium-90+d 1.8E-05
Technetium-99 ND
Thorium-228+7d NA
Thorium-232+10d 3.8E-04
Uranium-234 1.9E-07
Uranium-235/236+d 9.1E-07
Uranium-238+2d 2.6E-06
Inorganic*
Antimony NA
Arsenic l.OE-04
Beryllium 1.7E-05
Cadmium NA
Copper NA
Cyanide NA
Manganese NA
Mercury NA
Molybdenum NA
Silver NA
Surface
Soil1
(HQ)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
2.0E-01
9.9E-03
1.1E-01
l.OE-01
6.4E-01
4.1E-01
1.2E-01
ND
ND
Off-Property
Groundwatei*
(ILCR)
NA
1.1E-05
NA
2.1E-06
3. IE-OS
6.2E-07
6.7E-08
6.1E-07
8.6E-08
7.7E-07
NA
5.7E-04
8.30-03
NA
NA
NA
NA
NA
NA
NA
RME Farmer
Groundwater1'
(HQ)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
1.1E+00
8.3E-03
9.7E-01
S.7E-02
ND
1.7E+00
2.5E-01
5.9E-02
5.5E-01
On-Property
Perched
Groundwaterc
(ILCR)
NA
1.9E-05
NA
3.6E-06
1.9E-06
NA
1.7E-06
4.7E-07
ND
5.1E-07
NA
9.1E-04
2.7E-04
NA
NA
NA
NA
NA
NA
NA
RME Farmer
Perched
Groundwater0
(HQ)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4.2E-01
1.7E+00
1.3E-02
1.7E-01
2.1E-02
ND
2.8E-01
3.7E-02
9.4E-02
6.0E-02
Exploring
Surface
Water11
(ILCR)
NA
9.1E-10
NA
7.6E-10
ND
ND
ND
2.5E-10
ND
3.2E-10
NA
ND
ND
NA
NA
NA
NA
NA
NA
NA
Youth
Surface
Water11
(HQ)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
ND
ND
ND
4.8E-03
4.8E-03
ND
ND
ND
Exploring
Sediment*
(ILCR)
NA
2.3E-06
NA
ND
ND
ND
3.9E-11
5.7E-10
ND
3.7E-09
NA
7.0E-08
1.5E-08
NA
NA
NA
NA
NA
NA
NA
Youth
Sediment'
(HQ)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
8.2E-04
1.6E-05
l.OE-02
3.3E-06
ND
1.4E-02
NA
NA
ND
Great Miami River
U»er
GMR
Surface
Water5
(ILCR)
NA
4.5E-06
NA
NA
NA
1.9E-06
NA
l.OE-06
2.3E-07
6.7E-07
NA
3.2E-04
ND
NA
NA
NA
NA
NA
NA
NA
GMR
Surface
Water*
(HQ)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
6.1E-05
ND
2.6E+00
8.0E-02
1.2E-06
3.4E-02
NA
NA
NA
|
ft O
g ss
§• O
n O
S -
5 1
-------
FER\CRU5\]
TABLE 6-12
(Continued)
5
§ Background 'Exposure and Critical Receptor
NMGVIBL6-12,
§
|
|
K
1
;i
1
On-Property RME
Farmer
Inorganic* (cont.)
Uranium-total
Zinc
Organic*
Aroclor-1254
Aroclor-1260
Benzo(a)pyrene
1 ,2-Dichloroethane
NA
NA
NA
NA
NA
NA
2.4E-06
1.6E+00
NA
NA
NA
NA
Off-Property RME Farmer
NA
NA
NA
NA
NA
NA
6.8E-03
4.0E+00
NA
NA
NA
NA
On-Property RME Farmer
NA
NA
NA
NA
NA
NA
1.4E+01
2.9E-02
NA
NA
NA
NA
Exploring Youth
NA
NA
NA
NA
NA
NA
1.7E-01
ND
NA
NA
NA
NA
Exploring Youth
NA
NA
NA
NA
NA
NA
1.3E-02
2.8E-05
NA
NA
NA
NA
Great Miami River
User
NA
NA
NA
NA
NA
NA
1.1E-02
2.4E-06
NA
NA
NA
NA
oo
* Background risk and HQ calculations are based on exposure to surface soil to the on-property RME farmer (critical receptor for surface soil). The source tables for this information are
Table A.7-8 and Table A.7-9 in the final OUS RI Report.
b Background risk and HQ calculations are based on the off-property RME farmer (critical receptor for groundwater). The source tables for this information are Table A.7-10 and Table A.7-11 in
the final OUS RI Report.
c Background risk and HQ calculations are based on exposure to perched groundwater to the on-property RME farmer (critical receptor for perched groundwater). The source tables are
Table A.7-12 and Table A.7-13 in the final OUS RI Report.
d Background risk and HQ calculations are based on exposure to surface water to the exploring youth (critical receptor for perched groundwater). The source tables are Table A.7-14 and
Table A.7-15 in the final OUS RI Report.
e Background risk and HQ calculations are based on exposure to sediment by the exploring youth (critical receptor for sediment). The source tables are Table A.7-16 and Table A.7-17 in the final
OUS RI Report.
f Background risk and HQ calculations are based on exposure to surface water to the Great Miami River user (critical receptor for Great Miami River surface water). The source tables are
Table A.7-18 and Table A.7-19 in the final OUS RI Report.
NA - not analyzed/not applicable
ND - not detected
D 7
!
S O
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FEMP-05ROD-6 FINAL
December 15, 1995
those used for evaluating site-related risks to a critical receptor of that media. Soil concentrations
used for background risk calculations are the upper confidence limit values determined for the
site-specific background soil sample analytical results.
External radiation — specifically from radium-226, thorium-228, and radium-228 — is the primary
pathway for background cancer risks from radionuclides and their short-lived progeny present in soil.
Generally, the concentrations of these constituents on site present a risk level which is approximately
one order of magnitude greater than that of background concentrations. A greater difference can be
noted between background risk and on-site risk from uranium-234, uranium-235/236, and
uranium-238 (approximately two orders of magnitude). Risks from arsenic hi soil at background
concentrations exceed 1 x 10~*. Background concentrations of beryllium in soil present a potential
risk level of 1.7 x 10's. It should be noted that the highest representative concentrations of beryllium
and arsenic on site demonstrate risks nearly equivalent to the risks demonstrated from background
concentrations of these constituents.
HQs were calculated for naturally occurring concentrations of inorganic chemicals in soil based on
representative concentrations calculated from site-specific background soil sample analytical results.
The HQs for mercury and zinc exceed 0.1 while the HQ for cadmium exceeds 1.0.
Calculated background risks appear to be a very significant factor to consider when determining risk
levels to receptors from soil and sediment hi the Operable Unit 5 study area because background risks
for many CPCs are close to site risks. However, naturally occurring background concentrations of
surface water and groundwater, including perched groundwater, generally present acceptable risk
levels. In contrast, on-site groundwater and surface water risk are considerably greater than
background; they are not likely to be naturally occurring. Based on these results, background risks
from surface water and groundwater are, for the most part, less significant than for the other media.
On-site perched water and groundwater, as expected, had a generally higher level of constituents than
background groundwater.
6.1.5 Uncertainty Analysis
It is generally recognized that uncertainty is inherent in quantitative risk assessment and is a factor in
each stage of the risk assessment process. The cumulative impacts of uncertainties on the results of
the exposure and risk assessments are judged to be minor because the majority of the risk for most
FmCRU5\NMG\ROD\SEC6.ROD\Deconber 11, 1995 2:13pm 6-39
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December 15, 1995
receptors (particularly the on-property receptors) is attributable to exposures to uranium, thorium, and
radium and their progeny in the surface soil and groundwater. (The majority of risk for most off-
property receptors is attributable to exposure to the radionuclides and metals in groundwater.) The
relative contribution from this group of radionuclides to the total risk is so great, hi most instances,
that the total risk would not change significantly if most of the other constituents were added or
deleted from the list of constituents selected for evaluation in the baseline risk assessment.
Section A.6.0 in the RI Report discusses Operable Unit 5-specific uncertainties in detail. The
following paragraphs summarize uncertainty for the various stages of the baseline risk assessment.
6.1.5.1 Uncertainty hi the Selection of CPCs
Constituents to be quantitatively addressed in the risk assessment are selected using an iterative
process. The resulting CPCs are those constituents representing the greatest potential significance in
the overall risk assessment based on toxicity, concentration, and frequency of detection. CPCs were
screened out only if the maximum concentration for a media was less than a toxicity screening value.
Therefore, toxicity screening is intended to retain all constituents that have potential for risk. The
resulting probability of underestimating risk, based on CPC selection, is assumed low.
6.1.5.2 Uncertainty Exposure Assessment
The primary sources of uncertainty associated with scenario development are the definition of current
and future land uses within the boundaries of Operable Unit 5 and the receptor source-term
configuration selected as a basis for the risk assessment evaluation. The exposure scenarios and
receptors evaluated in the risk assessment are conservative and are expected to result hi significant
overestimation of potential health risk.
As described in Appendix A, Section A.3.0 of the RI Report, the future site configuration for
Operable Unit 5 assumes that engineering controls hi the area will not be maintained In addition, the
surface water runoff control system is assumed to have become nonfunctional, resulting hi increased
contaminant loading to Paddys Run. This particular combination of site conditions was selected as
feasible and representative of reasonable, maximum, source-term conditions. It is important to note,
however, that there are a wide variety of potential future site configurations that could have been
applied hi the risk assessment, and a degree of uncertainty is introduced by the selection of this
FER\CRU5\NMG\RDD\SEC6.ROD\Deconber 11. 1995 2:13pm 6-40
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FEMP-05ROD-6 FINAL
December 15, 1995
particular configuration over another. Nevertheless, confidence is high that the major sources,
exposure pathways, and important constituents have been identified using this configuration.
The inherent uncertainty associated with future land use and site configuration is addressed in the
Operable Unit 5 risk assessment by using a wide range of potential receptors and exposure conditions.
The receptors evaluated represent exposure conditions considered as both reasonable maximum and
average cases. Based on this conservatism and the diversity inherent in the evaluated scenarios, the
resulting risk estimates are unlikely to underestimate potential health risks associated with exposure to
site-related constituents.
Each exposure factor selected for use in this risk assessment has uncertainties associated with it.
Standard assumptions regarding exposure frequency, duration, population characteristics, and
activities may not be representative of exposure conditions for all receptors. To avoid
underestimation of exposure, the Operable Unit 5 risk assessment follows EPA's recommendation and
uses RME assumptions that correspond to the 95th percentile for most of the exposure factors. In
other words, the values used generally target the habits of a small percentage of the population
representing the upper-bound exposure conditions.
The availability of site characterization data (i.e., contaminant types, levels, and distribution) has a
direct impact on the estimation of exposure concentrations. Specific and potentially significant
sources of uncertainty with relevance to the calculation of exposure-point concentrations are the
adequacy of characterization data on an area as large as Operable Unit 5; assignment of validation
qualifiers on data which indicate their usability for quantitative risk assessment; lack of data
characterizing some environmental media that represent source terms for exposure; and the positive
bias associated with some of the radiological sampling locations.
The analytical data for many chemical constituents varied among the sampled areas. This
demonstrates the difficulty in obtaining accurate information-based data acquired from separate
sampling episodes across a large operable unit.
There is less analytical data for concentrations of organic parameters (versus analytical data available
for radiological parameters) measured across the entire FEMP site. This is due in part to the
difficulties encountered while conducting organic sampling and analysis (i.e., reduced holding tunes,
FER\CRU5\NMG\ROD\SEC6.ROD\Dcconbcr 11, 1995 2:13pm 6-41
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FEMP-05ROD-6 FINAL
December 15, 1995
volatilization and biodegradation in environmental media), and historical emphasis of the site sampling
programs on radiological constituents. This limitation introduces some degree of uncertainty into the
selection of CPCs and the calculation of exposure-point concentrations for organics in the
environmental media, particularly in surface soil. In instances where data sets were limited, the
maximum detected concentrations were used as the exposure-point concentrations. These specific data
limitations are of low to moderate significance in comparison with other sources of uncertainty, such
as those associated with the toxicity assessment and the fate and transport modeling hi the risk
analysis.
Estimation of exposure-point concentrations using environmental fate and transport modeling
introduces a number of potentially significant uncertainties into the risk assessment results. This
uncertainty results from the use of general assumptions regarding contaminant distribution and
intermediate transfer processes, as well as from intrinsic uncertainties in the models applied to
estimate environmental concentrations. Section 5.0 and Appendix F of the Operable Unit 5 RI Report
provide detailed discussions of the inputs and uncertainties associated with the modeling process.
The partitioning of contaminants between soil and vegetation (crops for human consumption and food
for livestock) is not well characterized for most compounds. Available data are used to make
order-of-magnitude estimates of plant/soil partitioning relationships. The biotransfer factors that
express contaminant partitioning between animal intake and animal-based food products (such as meat
and dairy products) can only be estimated to within about 2 orders of magnitude (McKone and
Ryan 1989). These limitations have important implications for Operable Unit 5, where food-related
pathways are significant for some receptors.
6.1.5.3 Uncertainty in Toxicity Assessment
Considerable uncertainty is associated with the qualitative (hazard assessment) and quantitative (dose
response) toxicity assessment process. The uncertainty associated with the toxicity assessment is
chemical specific because it depends on the existing information used to derive the dose-response
factor. In general, this uncertainty tends to be high (overestimates risks by 2 or more orders of
magnitude) for the chemical risk assessment, but tends to be lower (overestimates risks by one order
of magnitude or less) for radionuclides. This difference is the result of animal versus human data
used for chemical and radiological compounds, respectively.
FER\CRU5\NMG\ROD\SEC6.ROD\Deconber 11, 199S 2:13pm 6-42
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FEMP-05ROD-6 FINAL
December 15, 1995
6.1.5.4 Uncertainty in Risk Characterization
High uncertainty exists hi risk characterization results when summing ILCRs or His for several
constituents across different exposure pathways. This assumes that each substance has a similar effect
and/or mode of action. Often dissimilar compounds affect different target organs, have different
mechanisms of action, and differ in their ultimate fate and clearance in the body. Because the types
of interaction (additive, synergistic, or antagonistic) between different chemicals have generally not
been quantified, risk characterization does not consider antagonistic or synergistic effects and assumes
additivity. The summing of contaminant-specific ILCRs and His to produce total carcinogenic and
noncarcinogenic risk estimates, respectively, has the potential to either overestimate or underestimate
potential human health risks.
In summary, the receptors hi the current land use scenarios with the highest uncertainty are the
off-property resident fanner and off-property user of meat/milk from livestock grazed on site. The
off-property resident farmer was evaluated based on modeled concentrations for the air pathway
which results in high uncertainty. For the second receptor, the bioaccumulation of CPCs into meat
and milk was modeled and results in high uncertainty. The receptors in the future land use scenarios
with the highest uncertainty include the on-property RME resident farmer, the Great Miami River
user, and the off-property user of meat and milk. The highest uncertainty for the fanner and the off-
property user of milk and meat products is associated with the potential exposure pathways from
fanning on the FEMP property as well as from the modeled concentrations of contaminants in food.
Uncertainty associated with the other two receptors is primarily the result of surface water,
groundwater, and air modeling used to support those scenarios. The modeling assumptions were
conservative, and this resulted hi conservative estimates for the exposure-point concentrations.
The cumulative uncertainties identified with site data, exposure parameters, fate and transport
modeling, toxicity assessment, and risk characterization are judged to be moderate and may
potentially result in an overestimation of Operable Unit 5 risk by 2 or more orders of magnitude.
6.2 SITE-WIDE ECOLOGICAL RISK ASSESSMENT
Following guidance provided by Region 5 of the EPA, Operable Unit 5 prepared a Site-Wide
Ecological Risk Assessment as part of its RI Report (found hi Appendix B) to determine if
radiological and nonradiological constituents associated with actions at the FEMP represent a current
or future risk to ecological receptors inhabiting this facility and nearby off-property areas. These
FER\CRU5\NMG\ROD\SEC6.R.OD\Decanber 11, 1995 2:13pm 6-43
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FEMP-05ROD-6 FINAL
December 15, 1995
receptors include all organisms, exclusive of humans and domestic animals, that may be potentially
exposed to FEMP contaminants. EPA's guidelines emphasize that the development of the ecological
risk assessment considers factors such as the nature and extent of contamination, the physical and
lexicological properties of contaminants, and the quantity and quality of ecological resources.
In order to evaluate potential exposure of ecological receptors to CPCs, habitat (e.g., grassland) and
the size of the home range of receptor species (those modeled to quantify total radiation doses) were
used to subdivide on-property portions of the FEMP into seven study areas (see Figure 6-3). This
approach provided for a more meaningful evaluation of potential risks to ecological receptors than
examining the risks associated with the entire 1050-acre site, because media-specific contaminant
concentrations within a given habitat were quantified, allowing a separate evaluation of those study
areas that may have received greater amounts than other study areas.
For the ecological risk assessment, contaminants of greatest concern were those present in surface
water and sediment in Paddys Run and the Great Miami River as well as in surface soil.
Contaminants are likely to have entered Paddys Run through uncontrolled contaminated runoff, the
Great Miami River by the permitted discharge through the outfall line and from Paddys Run, and
were deposited in soil through airborne emissions.
This discussion of the ecological risk assessment begins with a description of the ecological setting of
the FEMP followed by the summary of the exposure assessment. Next, the process of identifying
nonradiological CPCs and risk characterization are discussed. Because radiological constituents were
evaluated through modeling, they are discussed separately.
6.2.1 Ecological Setting
As noted in Appendix B of the Operable Unit 5 RI Report, a number of studies have been conducted
to characterize the biota both on and off FEMP property. Biological surveys and studies designed
and conducted hi 1986 and 1987 by Miami University and summarized by Facemire et al. (1990)
remain the broadest in scope. They identify habitats and biota, determine species abundance and
distribution, and noted apparent stress-induced differences between on-property and off-property
biota.
FER\CRU5\NMG\BOD\SEC6.ROD\Deceniber 11. 1995 2:13pm 6-44
-------
ninnn
PADDYS
RUN
RETENTION BASIN
••K-" SOUTH .-.T:
FELOvX
INACTIVE
FLYASH
PILE
STORM SEWER
OUTFALL DITCH
ACTIVE
FLYASH
PILE
WOOOLOT / WETLAND
PINE PLANTATION
GRASSLAND
GRASSLAND
GRASSLAND '
PAOOrs RUN
PINE PLANTATION
APPROXIMATE BOUNDARIES
FOR OU's 1-4
FIGURE 6-3. STUDY AREAS FOR THE SITE-WIDE
ECOLOGICAL RISK ASSESSMENT
6-45
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FEMP-05ROD-6 FINAL
December 15, 1995
Vegetation on the site is typical of the Western Mesophytic forest region, and biological communities
on the site appear similar to those found in southwestern Ohio where similar land use practices occur.
No species or group is conspicuously low or absent in any available habitat niches; the ecological
communities on the FEMP are typical of those found in the region.
The Facemire et al. (1990) survey indicated possible stress on ecological receptors, including
suppressed growth in FEMP American robin nestlings. However, recent studies suggested that this
observed suppression may have been a result of land management practices and not related to the
presence of contaminants hi food items collected near nesting sites (Osborne et al. 1992).
Facemire et al. (1990) attributed apparent stress on macroinvertebrate communities and other
ecological receptors hi Paddys Run to the prolonged dry periods that are typical during the summer
months.
Facemire et al. (1990) also characterized the fish community in Paddys Run, and indicated that both
the number of taxa and the species composition were comparable to the results of studies performed
on other small streams hi southwestern Ohio.
Avifauna inhabiting the FEMP have been surveyed several tunes. Pomeroy (1977) conducted a
survey in June 1977, while Facemire et al. (1990) conducted three separate surveys during 1986
and 1987. The data indicated that many of the species observed by Pomeroy hi 1977 were also
observed almost 10 years later during the surveys conducted by Miami University. These data
indicate that the avian species composition at the FEMP appeared stable during this period.
Based on the review of these studies, there is apparent stability hi species composition at the FEMP.
These studies do not, however, permit an evaluation of changes hi abundance and dominance of
species.
6.2.2 Exposure Assessment for Ecological Receptors
As described in the EPA Region 5 guidelines, the major objective of the exposure assessment is to
estimate, as accurately as possible, the media-specific chemical concentrations to which ecological
receptors hi each study area might be exposed (EPA 1992). Estimated environmental concentrations
were based on measured site-specific data. The representative concentrations of media-specific
nonradiological contaminants were compared to concentration-based benchmark toxicity values (e.g.,
FER\CRU5\NMG\KOD\SEC6.ROD\Deconbcr 11, 1995 2:13pm 6-46
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FEMP-05ROD-6 FINAL
December 15, 1995
water quality criteria) that protect ecological receptors. Contaminants exceeding these values were
regarded as final CPCs and their relative risks to FEMP ecological receptors were evaluated. This
risk assessment did not calculate the total dose of nonradiological constituents which individual
ecological receptors might receive; therefore, dose estimates due to nonradiological contaminants were
not made for specific ecological receptors.
The ecological risk assessment evaluated the potential impact of contaminants in surface water to both
freshwater biota and terrestrial receptors that may inhabit these various bodies of water or use them as
sources of drinking water. Exposures to contaminants in sediment were evaluated by examining
sediment contaminant concentrations or by employing partitioning coefficients to determine the
concentrations of CPCs present in the interstitial water. Only limited data were available for
evaluating the bioavailability of surface soil CPCs. Therefore, the concentrations of CPCs hi surface
soil used in this assessment were based on individual contaminant concentrations per unit of soil
without adjustment for bioavailability.
Ecological receptors may come hi contact with contaminants by a number of pathways. Terrestrial
receptors may be exposed to direct radiation from contaminated soil, ingestion of radionuclides and
other contaminants contained hi water and various food items, or incidental ingestion of contaminated
soil during grooming or burrowing. Aquatic receptors may come hi contact with contaminants that
are dissolved hi solution, adsorbed to sediment particles, or through consumption of contaminated
prey.
6.2.3 Determining Nonradiological CPCs
Determination of nonradiological CPCs for ecological receptors relied on the supporting information
and environmental data used to determine nature and extent of contamination as presented hi the
Operable Unit 5 RI Report. Media-specific contaminant concentrations were compared to
media-specific benchmark values that are protective of ecological receptors. Concentrations of
constituents exceeding these values were regarded as final CPCs and their lexicological properties
summarized. Finally, the relative risks that each of these final CPCs might pose to FEMP ecological
receptors were evaluated. The CPCs for the ecological receptors were determined for surface water,
drinking water, sediment, and soil.
FER\CKU5\NMG\KOD\SEC6.ROD\Deconber 11, 1995 2:13pm 6-47
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FEMP-05ROD-6 FINAL
December 15, 1995
Identifying Final CPCs in Surface Water
The process began by considering all inorganic contaminants present in concentrations statistically
greater than background concentrations to be CPCs. All organic chemicals detected in surface water
samples were also considered CPCs. The representative concentrations of these constituents (the
process to determine representative concentrations is described hi Appendix A of the Operable Unit 5
RI Report) were then compared to benchmark values that are protective of aquatic biota.
The primary benchmark values used to identify final CPCs in surface water were chronic ambient
water quality criteria (CAWQC), which are developed to protect sensitive aquatic species from
exposures to chronic, sublethal contaminant concentrations. Actual exposures of FEMP aquatic
receptors to CPCs are assumed to be primarily chronic (long-term) exposures, usually at sublethal
concentrations. These CAWQCs were selected as conservative and appropriate screening criteria.
Where chronic toxicity data were not available, surrogate chronic benchmark values were estimated
from acute toxicity data. Complete details of the process can be found in Appendix B, Section 8.2.2
of the Operable Unit 5 RI Report (DOE 1995d).
Even though mercury's concentration hi the Great Miami River is below its background value, it is
retained as a CPC because of its well-documented propensity to bioaccumulate and biomagnify. The
following constituents are the final ecological CPCs hi surface water hi Paddys Run and the Great
Miami River with respect to aquatic biota:
• Paddys Run — on-property are aluminum, cadmium, lead, manganese, silver,
bis(2-ethylhexyl)phthaltate, di-n-octyl phthalate; off-property are lead,
bis(2-ethylhexyl)phthaltate and di-n-octyl phthalate
• Great Miami River — above the effluent line are ammonia and mercury; between the effluent
line and Paddys Run are aluminum, cadmium and cyanide; below Paddys Run are aluminum,
barium, cadmium, cyanide, lead, manganese, and bis(2-ethylhexyl)phthaltate.
Complete tables are found hi Attachment B.n of Appendix B of the RI Report.
Identifying CPCs in Drinking Water
Exposure of terrestrial mammalian and avian receptors to surface water contaminants is primarily
through ingestion of water. Currently, surface water criteria for the protection of terrestrial species
are not available. Therefore, the potential hazards for terrestrial species ingesting contaminants hi
FER\CRU5\NMG\ROD\SEC6.ROD\Deconber 11, 1995 2:13pm 6-48
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FEMP-05ROD-6 FINAL
December 15, 1995
surface water are evaluated by comparing surface water contaminant concentrations measured in
filtered and unfiltered samples to various benchmarks selected from the following:
• Available drinking water toxicity data for avian and mammalian species
• EPA Region 3 Risk-Based Contaminant Tables, Second Quarter (EPA 1994c)
• OEPA's (1993) or EPA's (1994a) criteria for public water supplies
• Benchmarks selected for assessment of risk to aquatic life.
Toxicity data for avian and terrestrial ecological receptors generated as a result of ingestion of
contaminants in drinking water are summarized in Table B.ffl-l of the RI Report.
As a screening method for identifying CPCs in drinking water for ecological receptors, the most
conservative human health criterion was selected as a drinking water benchmark. Human health
criteria such as the OEPA's criteria for public water supplies were considered when selecting drinking
water benchmarks because human health criteria are typically based on laboratory studies using
annuals (usually rodents). These standards for drinking water are more protective than those used to
assess risk to aquatic life.
In the Operable Unit 5 RI Report Appendix B, Tables B.HI-3 to B.ffl-lO summarize representative
surface water contaminant concentrations for each study area and compare these concentrations to the
drinking water benchmarks selected for each contaminant. It was conservatively assumed that
terrestrial ecological receptors relied exclusively on individual bodies of water (for example, drainage
ditches, Paddys Run, the Great Miami River) for sources of drinking water. This screening process
identified the following constituents as final CPCs in drinking water for terrestrial ecological
receptors:
• On-property drainage ditches — aluminum, cadmium, mercury, uranium, 1,2-Dichloroethene,
and trichloroethylene
• Paddys Run — Aluminum, raHmiimi lead, bis(2-ethylhexyl)phthalate and di-n-octyl phthalate
• Great Miami River — aluminum, beryllium, cadmium, mercury and bis(2-
ethylhexyl)phthalate.
Identifying Final CPCs in Sediment
The limited nature of the background database precluded the performance of statistical comparisons of
constituents present in sediment collected from various study areas to background concentrations.
Therefore, unlike the other media, all inorganic and organic constituents were considered CPCs and
FER\CRU5WMG\ROD\SEC6.RDD\Deconber 11. 199S 2: 13pm 6-49
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FEMP-05ROD-6 FINAL
December 15, 1995
compared directly to appropriate benchmark values and final CPCs in sediment were identified
(Table B.2-2 of Appendix B of the RI Report).
Unlike surface water, national criteria have yet to be established for contaminants in sediment largely
because of the difficulties associated with identifying biologically available concentrations. Models
have been developed to predict the concentration of nonpolar organic contaminants that may be
dissolved into interstitial water and therefore become biologically available. However, no equivalent,
widely accepted models exist for predicting the partitioning of metals or polar organics between water
and sediment particles. As a result, separate approaches were used to identify sediment benchmarks
in the Site-Wide Ecological Risk Assessment.
Although calcium, magnesium, potassium, and sodium were detected in sediment samples in
concentrations exceeding background concentrations, they are considered to be nontoxic and were
eliminated from further consideration. The remaining inorganic chemicals were then compared to
benchmark values developed by Long and Morgan (1991). Long and Morgan developed apparent
effects data sets for various toxicants hi sediment by compiling biological effects data (e.g., reductions
in benthic populations associated with the presence of a contaminant) for a specific toxicant.
Long and Morgan have not developed benchmark values for all of the inorganic chemicals considered
in this assessment. Therefore, surrogate values were selected, including sediment quality criteria
established by various government agencies. If sediment-specific criteria could not be identified,
these inorganic contaminants in sediment were retained as CPCs (e.g., aluminum and uranium) or
compared to published soil concentrations that are indicative of contamination (e.g., cobalt). For
nonpolar organic CPCs, equilibrium partitioning was used to extrapolate from contaminant
concentrations in sediment to concentrations present in interstitial water.
Chemicals measured hi sediment at concentrations greater than the Long and Morgan benchmark (or
surrogate) values were considered to be inorganic CPCs. Uranium was retained for consideration as
a CPC because toxicity-based benchmark values were not available. The results of this screening
process are summarized in Appendix B, Attachment B.IV of the RI Report. The final inorganic
CPCs hi sediment for Paddys Run and the Great Miami River are barium, cadmium, cyanide, iron,
lead, manganese, uranium, phenanthrene and zinc.
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Since no widely recognized models have been developed to predict the concentration of polar organic
contaminants present in interstitial water it was assumed mat these contaminants were completely
dissolved in the interstitial water (e.g., fig/kg = pg/L) and, like nonpolar organics, were then
compared to CAWQC (or surrogate values). This screening process is summarized in Appendix B,
Attachment B.IV of the RI Report.
Phenanthrene was the only organic contaminant present hi sediment collected from the Great Miami
River (downstream of die effluent outfall) identified as a final CPC; no organic CPCs were identified
in Paddys Run.
Identifying Final CPCs hi Soil
Inorganic chemicals that exceeded background concentrations in soil were compared to benchmark
toxicity values; those constituents exceeding benchmark values were considered final CPCs in soil.
All organic chemicals detected in soil were automatically considered CPCs.
Inorganic chemicals whose concentrations were statistically greater than background concentrations
and all organic chemicals detected in soil were compared to concentrations considered to be protective
of receptors. These contaminant threshold values were obtained from a number of sources, including:
• Quebec Ministry of the Environment for soil (Direction des Substances Dangereuses 1988)
• Maximum allowable concentrations established by various regulatory agencies for amending
farm soil with sewage sludge
• Proposed action levels for contaminated soil at Resource Conservation and Recovery Act sites
(EPA 1990)
• EPA Region 3 Risk-Based Contamination Tables, Second Quarter (EPA 1994c).
Whenever possible, the ecological risk assessment preferentially selected benchmark values that
considered impacts to ecological receptors. In many instances, surface soil benchmarks developed to
protect human health had to be employed. To the extent possible, these values were checked against
ecological toxicity data published hi the literature to ensure that they also protected ecological
receptors.
Calcium, iron, magnesium, potassium, sodium, and vanadium were eliminated from further
consideration as CPCs because they are considered nontoxic in soil. Although generally considered
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nontoxic, benchmark criteria were available for aluminum, barium, cobalt and manganese and these
four contaminants were therefore retained for further assessment.
Summary tables identifying CPCs in soil that were significantly greater than background
concentrations and were greater than benchmark values appear in Appendix B, Attachment B.V of the
RI Report. The final CPCs in surface soil for on-property locations are aluminum, antimony,
cadmium, lead, manganese, molybdenum, silver, thorium, uranium, zinc and several organics. Only
manganese and lead present in samples collected off property exceeded soil benchmark values.
Although detected in soil collected from other study areas, only soil collected from Study Areas A, C,
and E contained organic chemicals with concentrations that exceeded benchmark criteria. PAHs
identified as final CPCs are summarized in Attachment B.V of the RI Report.
6.2.4 Risk Characterization of Final CPCs
Risk characterization relates exposure concentrations of final CPCs to concentrations of CPCs that are
known to cause adverse effects; it is essentially the integration of exposure and toxicity. The toxicity
quotient method was selected to characterize risks associated with the final CPCs. Toxicity quotient
values are derived by dividing the representative concentration for each final CPC for each media by
the same benchmark toxicity values used to identify media-specific CPCs. A toxicity quotient value
of less than 1.0 is considered to be associated with insignificant risk. The resulting toxicity quotients
for media- and study area-specific final CPCs are listed in Appendix B, Attachments B.n - B.V and
all quotient values > 1.0 are summarized hi Tables B.2-4 to B.2-6 of the RI Report.
The toxicity quotient method is commonly used in risk characterization for ecological risk assessments
because it is relatively easy to implement, is generally accepted, and can be applied to any data. In
addition, it is useful when a large number of chemicals must be screened (Barnthouse et al. 1986).
Cumulative toxicity can be evaluated by summing the individual representative concentration/toxicity
value quotients for various CPCs (Barnthouse et al. 1986). Those contaminants with quotient values
> 0.3 were included in the assessment of cumulative risk because they may contribute to chronic
effects resulting from additivity or synergism (Cardwell et al. 1993). Estimates of cumulative toxicity
were confined to surface water; it was assumed that contaminants present in these water bodies were
thoroughly mixed and equally available to aquatic receptors. Similar assumptions were not applied to
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contaminants present in sediment and soil. The cumulative risk values calculated for surface water
examined in this study are summarized in Table B.2-4 of the RI Report.
It should be emphasized that the individual toxicity quotient values presented do not represent the
absolute probability of risk in themselves, but are representative of the relative probability of risk;
that is, the greater the toxicity quotient value the greater the likelihood that ecological receptors
coming in contact with a given contaminant may be adversely affected.
Risk Associated with Final CPCs in Surface Water
The highest cumulative risk values for Paddys Run were calculated for on-property locations. Lead
accounted for the single largest source of risk associated with Paddys Run on property, followed by
bis(2-ethylhexyl)phthalate. Cumulative risks determined for off-property sections of Paddys Run were
also largely associated with lead and bis(2-ethylhexyl)phthalate.
Although the representative quotient values determined for total lead measured in samples from
on-property and off-property locations in Paddys Run and the Great Miami River below its confluence
with Paddys Run exceeded 1.0, filtered concentrations of this metal were relatively low. These data
suggest that the concentration of lead that is biologically available to aquatic biota hi these two bodies
of water is less than indicated by the concentration measured in the unfiltered sample, effectively
lowering the risk indicated by the toxicity quotient values.
For the Great Miami River, the greatest calculated cumulative risk value was for that portion of the
river downstream from its confluence with Paddys Run. Aluminum accounted for almost all of the
risk posed to aquatic biota inhabiting this section of the river, followed by bis(2-ethylhexyl)phthalate.
The assessment of potential risk posed to ecological receptors by ingesting surface water is very
conservative in that it is assumed that a given body of water represents the only drinking water source
available. In addition, the risk assessment assumes that ecological receptors had year-round access to
these various water bodies. However, with the exception of the Great Miami River and the upper
sections of Paddys Run, the other on-property water bodies contain water intermittently, thereby
limiting potential exposure (and risk) to ecological receptors.
The concentrations of aluminum and uranium exceeded the aquatic biota benchmark values; however,
toxicity information indicates that neither metal is readily absorbed from the gastrointestinal tract and
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the small quantities absorbed are rapidly excreted (Venugopal and Luckey 1978). Studies performed
on movement of uranium through terrestrial foodchains (Mahon 1982) reported that this heavy metal
exhibited no sign of biomagnification. This information, coupled with the representative
concentrations of aluminum and uranium reported for Study Area A (232 and 930 /tg/L, respectively)
indicate that these two heavy metals do not represent a risk to terrestrial ecological receptors.
Risk Associated with Final CPCs hi Sediment
Although uranium was retained for consideration as a final CPC in sediment, studies conducted on
various uranium-contaminated aquatic systems suggest that this metal does not biomagnify and that it
is not generally bioavailable. It is probable that the risk posed to benthic organisms is limited as a
result of the low bioavailability associated with this metal.
Risk Associated with Final CPCs in Soil
Toxicity quotient values derived from the surface soil concentration/Quebec threshold values (or other
soil threshold values) for surface soil can only be applied in a broad sense (i.e., potentially hazardous
or nonhazardous) because information on the effects of contaminated soil on ecological receptors is
limited.
Uranium is not generally biologically available; transfer coefficients through various food chains
indicate an order of magnitude decline at every trophic level. Based on the results of several recent
studies, concentrations of uranium present in all surface soil samples except those collected from
Study Area C are well below concentrations associated with adverse biological effects (e.g.,
phytotoxicity, decreased earthworm survival). This information indicates that concentrations of
uranium outside of Study Area C, although greater than the background soil concentrations, are less
than values reported to adversely impact terrestrial ecological receptors. Therefore, with the
exception of Study Area C, it is not likely that uranium is adversely impacting organisms inhabiting
the remainder of the FEMP.
6.2.5 Assessing Radiological Constituents
The Site-Wide Ecological Risk Assessment evaluates potential risks to ecological receptors due to
chronic exposure to low-levels of radiological contaminants present in the FEMP study areas. To
calculate the internal and external doses, media- and site-specific data are evaluated in a model and
the results are compared to a target-level dose published in 1992 by the International Atomic Energy
Agency (IAEA). The basis for the target-level dose is presented in the publication, Effects of
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Ionizing Radiation on Plants and Animals at Levels Implied by Current Radiation Protection
Standards. Among the conclusions reached in the report is that there is no convincing evidence from
the scientific literature that chronic radiation dose rates below 1 mGy/day (36.5 rad/year) will harm
animal or plant populations.
The methods and assumptions used to model the available RI/FS data indicate that the absorbed doses
to ecological receptors fall below the target level dose (36.5 rad/year). It can be concluded that,
based on the measured levels of radioactivity on and around the FEMP site, there is no threat of
radiation effects to populations of terrestrial or aquatic biota. The methods, assumptions, and
calculations used in this determination are presented in the following sections.
6.2.5.1 Selection of Receptor Organisms
White-footed deer mice (Peromyscus leucopus noveborensis) and meadow voles (Microtus
pennsylvanicus) were selected as the reference mammals for several reasons. First, they are known to
occur on the FEMP, and the small size of their home ranges makes it likely that individuals would
spend their entire life on the site. These mammals live in direct contact with the soil, increasing the
probability that they will come in contact with contaminants in this particular medium. In addition,
mice and meadow voles are potential prey for a number of species that feed at the FEMP. Finally,
studies have documented that they are sensitive to radioactivity (IAEA 1992).
A generic pine was selected as the indicator plant for two reasons. First, studies of terrestrial
vegetation have shown that pine trees are among the plant species most sensitive to radiation and,
secondly, because of the large number of white pines (Pimis strobus) and Austrian pines (Pinus nigra)
on the FEMP. Some Norway spruce (Picea excelsa) also occur on site.
Shiners (Notropis sp.) were selected as the indicator fish species because the genus is common in the
Great Miami River and comprises more than 50 percent of the fish community in Paddys Run. In
addition, there is adequate information in the literature to characterize men: sensitivity to radiation.
6.2.5.2 Selection of Pathways
Selected pathways include the internal pathways described in the Risk Assessment Work Plan
Addendum (DOE 1992), as supplemented, as well as additional external pathways to ensure that the
actual dose received by the organisms would not exceed the calculated values. Mathematical
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equations used to calculate absorbed dose through each of these pathways are provided hi
Appendix B, Attachment B.VI of the RI Report.
For mammals inhabiting each of die terrestrial study areas, including the two off-property locations,
the exposure pathways are:
Direct irradiation from soil
Inhalation of resuspended soil
Digestion of insects
Incidental ingestion of soil (e.g., through grooming)
Ingestion of vegetation
Ingestion of water (only for study areas where water monitoring results were available).
For aquatic animals in Paddys Run and the Great Miami River, the exposure pathways are:
• Direct irradiation from sediment
• Uptake of contaminants from water (all pathways)
• Direct irradiation from submersion hi water
• Ingestion of benthic macroinvertebrates.
For pine trees hi all study areas, the exposure pathways are direct irradiation from soil and uptake of
contaminants from soil.
6.2.5.3 Selection of Calculation Parameters
Parameters used in the calculations and their source(s) include ingestion and inhalation rates, receptor
mass, plant-to-soil concentration ratios, bioconcentration factors, and soil density. The complete lists
are found hi Appendix B, Tables B.3-1 through B.3-3 of the RI Report.
6.2.5.4 Calculation of Absorbed Dose Due to External Exposure
The representative concentration values for each radionuclide and medium hi each study area were
derived from the RI/FS database and are presented hi Attachment Vn of Appendix B. The
calculations for absorbed dose to the white-footed deer mouse, the meadow vole, pine trees, and
shiners were performed using the computer program MicroShield™ (Grove Engineering 1988). While
this program is designed primarily for use as a shielding calculational tool, it provides estimates for
external exposure scenarios where attenuating media are involved. Following the entry of data
regarding source and shield materials and geometry, the program determines the exposure rate hi
milliroentgen per hour, which is converted to milliroentgen per year.
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6.2.5.5 Calculation of Absorbed Dose Due to Internal Exposure
To calculate absorbed dose due to ingested or inhaled radioactive contaminants, dose conversion
factors were derived using methods similar to that La Sections 7.4.2 and 7.4.3 of the Risk Assessment
Work Plan Addendum (DOE 1992). Doses were calculated for representative environmental
concentrations as representative doses to individual organisms in each study area. Data used in the
calculation of dose conversion factors are listed in Tables B.3-5 through B.3-7 of the RI Report.
6.2.5.6 Analysis of Results
Calculated absorbed (internal and external) doses to the receptor organisms in each on- and
off-property study area, the Great Miami River, and Paddys Run are provided in Table B.3-9 of the
RI Report; the summation of absorbed dose by area and pathway based on representative
concentrations are presented in Attachment IX of Appendix B. The final calculated absorbed doses to
the receptor organisms were compared to the target-level dose of 36.5 rad/year (IAEA 1992). All
calculated doses are below the target-level dose of 36.5 rad per year. It can be concluded that, based
on the measured levels of radioactivity on the FEMP site, there is no threat of radiation effects to
populations of terrestrial plants or terrestrial or aquatic animals.
6.2.6 Uncertainty in the Ecological Risk Assessment
Uncertainties in the exposure assessment include the limited number of nonradiological samples,
which may increase or decrease risk estimation. Concentrations of uranium, thorium, and
radiological isotopes were based on RI samples collected at depths up to 2 feet. These data were
compared to background samples collected at 0-6 inch depths; impact of this comparison on
assessment is unknown. Appendix Table B.2-1 of the RI Report presents exposure assessment
uncertainty.
Because complete toxicological databases do not exist for most chemicals, there are many
opportunities for uncertainty to impact the toxicological screening process. In addition, due to the
limited number of surface water samples collected for the RI, contaminants present in both filtered
and unfiltered samples were compared to benchmark values. However, these benchmark values are
expressed in terms of concentration of contaminant present in unfiltered samples. Comparing
contaminant concentrations detected in filtered samples to benchmark values based on analyses of
unfiltered water adds uncertainty to the interpretation of these results. It was also noted that a
number of chemicals were detected in surface water, sediment, and soil samples in concentrations
greater than concentrations reported for background samples but were eliminated from further
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consideration because they are generally regarded as nontoxic macronutrients (e.g., calcium and
potassium). Benchmark toxicity values could not be identified for these macronutrients. Elimination
of these chemicals present hi concentrations greater than background values without considering their
possible toxicity adds uncertainty to this assessment. Specific areas of concern and methods used to
reduce uncertainty are summarized in Appendix Table B.2-3 of the RI Report.
Because risk characterization is essentially the integration of the exposure assessment and toxicity
screening, sources of uncertainty associated with either of these two processes contribute to
uncertainty in the risk characterization. Uncertainty associated with the bioavailability of
contaminants, including uranium, also influences the risk characterization process. In addition,
elements of the risk characterization procedure itself should contribute to overall uncertainty. The
toxicity quotient method, which was selected to characterize risk, does not directly account for
incremental or cumulative toxicity. Areas of uncertainty associated with this risk characterization and
efforts to reduce uncertainty are summarized in Appendix Table B.2-7 of the RI Report.
6.2.7 Significant Habitat
About 10 acres of wetlands will likely be impacted by remedial actions. These wetlands are drainage
ditches in and near the former production area. Mitigation measures are being negotiated with
appropriate regulatory agencies. Habitat for threatened and endangered species is not directly
impacted by contamination; however, the habitat must be protected during remediation to control
surface water runoff and associated siltation into Paddys Run and to protect appropriate riparian
habitat along Paddys Run.
6.3 CONCLUSION
Estimates of risk presented hi the comprehensive baseline risk assessment for human health and
ecological risk assessment indicate that actual or threatened releases of hazardous substances from the
FEMP, if not addressed by implementing the response action selected hi the ROD, may present an
imminent and substantial endangennent to public health, welfare, or the environment. The results
support the decision to take remedial action.
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7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
From the many remedial technologies and process options considered for the cleanup of the affected
media at the FEMP, 10 alternatives were identified as suitable for the initial screening step of the FS.
These alternatives were compared against one another and then evaluated with respect to their
effectiveness, implementability and cost. This screening process resulted in the selection of seven
viable remedial alternatives which are discussed in Section 7.2.
7.1 FEATURES COMMON TO ALL ACTION ALTERNATIVES
There are five features that are common to all the action alternatives considered for the Operable
Unit 5 remedy; these are discussed below.
7.1.1 Remedial Action Objectives
Remedial action objectives are developed during the RI/FS process to set goals that ensure the
protection of human health and the environment. Goals were developed for Operable Unit 5 that
would mitigate the potential adverse effects of site contaminants present in environmental media,
which led to setting acceptable chemical-specific remediation levels (10"6, 10~3, etc.) for a range of
human and ecological receptors under differing land uses. A remediation level of 10"6 represents the
concentration of contaminants in media that would yield a calculated increase hi the chance of
acquiring cancer in a 70-year lifetime of 1 hi 1,000,000, incremental to the current l-in-4 chance of
acquiring cancer for U.S. residents. Operable Unit S's objectives include reducing or eliminating the
potential for human or ecological receptors to come hi contact with contaminated environmental media
and preventing contaminants from migrating off site. Operable Unit 5 remedial action objectives are
defined hi Section 2.12 of the FS Report.
All of the alternatives considered hi the FS were designed to achieve target land use objectives that
bracketed potentially viable future uses of FEMP property which, hi turn, provided the framework for
identifying risk-based exposure scenarios and land-use specific remediation levels.
Land Use Objective 1 returns the entire on-property area to full unrestricted use following cleanup;
i.e., establishes a hypothetical family farm anywhere on the FEMP property.
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December 15, 1995
Land Use Objective 2 places contaminated material in a consolidated, managed area and establishes a
hypothetical family farm on any of the remaining FEMP property.
Land Use Objective 3 places contaminated material in a consolidated, managed area but restricts the
potential uses (e.g., recreational, industrial, undeveloped park) of the rest of the property through
institutional controls.
Land Use Objective 4 minimally consolidates contaminated material and restricts access and future use
of the FEMP property.
These objectives were developed within the context of the existing land use of the local area,
residential farming, and in conjunction with the deliberations and resolutions of the Fernald Citizens
Task Force.
7.1.2 Target Risk Cases
To support calculation of volume estimates for affected soil, nine target risk cases were developed in
the FS Report (Section 2.13). Each risk case specified, for each medium, an associated land use, a
target receptor, a target risk range, and the resultant uranium preliminary remediation level (PRL).
The receptors considered represented the most restrictive credible receptor for each medium consistent
with the projected land use for a particular risk case. Table 7-1 displays the full range of the
evaluations.
7.1.3 Removal Actions
The Operable Unit 5 removal actions are described hi Section 2.4. These interim response actions
will be integrated with the selected remedy as follows:
No. 1 - Contaminated Water Beneath FEMP Buildings. Analysis of ttie hydrogeology of the
contaminated areas beneath the FEMP buildings, as well as contaminant fate and transport modeling
performed as part of the Operable Unit 5 RI/FS since the implementation of this removal action,
indicate it is not cost-effective to remediate the contaminated portions of the perched water system
through pump and treat methods. Additionally, all the remedial alternatives considered include the
excavation of affected perched water zones. Therefore, the wells pumping contaminated perched
groundwater for treatment will be retired from operation following final issuance of this ROD.
FER\CRU5\ROD\NMG\SEC-7.RQD\Deconber 11, 1995 2:3
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a
TABLE 7-1
TARGET RISK CASES EVALUATED IN FEASIBILITY STUDY
Preliminary Remediation Levels (PRLs)
SoilPRLs
Case(s)
On-Property
- Central Area (K, =
Target Risk Range
Lower Upper
Limit Limit
Target
Receptor1'
15 L/kg«)
PRLs
Total U
(ppm)
On-Property
Lower
Limit
- Border Area (K, = 325
Target Risk Range
Upper
Limit
Target
Receptor1"
L/kg*)
PRLs
Total U Lower
(ppm) Limit
Off-Property
Risk Target
Upper Target
Limit Receptor11
PRLs
Total U
(ppm)
1 1 x 10* 1 x 10s Resident 5
2 1 x 10's 1 x KV4 Resident 15
3 1 x 10-* 1 x 103 Industrial 15
4 1 x 10* 1 x 105 Dev. Park 20
5 1 x 10* 1 x 103 Undev. Park 20
6 1 x 10* 1 x 10s Undev. Park 20
7 1 x 10* 1 x 10s Undev. Park 20
8 1 x 10* 1 x 10s Trespasser 20
9 1 x 10* 1 x 10'5 Trespasser 20
Land Use Objectives 1 and 2
1 x 10* 1 x 10'5 Resident 5
1 x 10J 1 x 10^ Resident
15
1 x 10* 1 x 10-5 Resident
1 x 103 1 x 10-* Resident 15
Land Use Objective 3
1 x 10* 1 x 103 Industrial 15 1 x 103 1 x 10^ Resident 15
1 x 10* 1 x 10s Dev. Park 40 1 x 10J 1 x 10^ Resident 15
1 x 10* 1 x 103 Undev. Park 80 1 x 103 1 x 10^ Resident 15
1 x 10* 1 x 103 Undev. Park 80 1 x 105 1 x lO"4 Resident 50°
1 x 10* 1 x 103 Undev. Park 50d 1 x 103 1 x 10"4 Resident 50°
Land Use Objective 4 O
1x10* IxlO3 Trespasser 100 1 x 10s 1x10^ Resident 15 §"
y\
1 x 10* 1 x 10'5 Trespasser 100 1 x lO'5 1 x 10" Resident 50C S
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\M
f
TABLE 7-1
(Continued)
Surface Water and Sediment PRLs
Sediment
Target Risk
Lower Upper
Case(s) Limit Limit
1-2 1 x 10* 1 x 10s
3 1 x 10* 1 x 105
4 1 x 10* 1 x 103
5-7 1 x 10* 1 x 105
Range
PRLs
Target Total U Lower
Receptor (ppm) Limit
Land Use Objectives 1 and 2
Youth/Rec. User 2.1 x 102 1 x 10*
Land Use Objective 3
Youth/Rec. User 2.1 x 102 1 x 10*
Youth/Rec. User 2.1 x 102 1 x 10*
Youth/Rec. User 2.1 x 102 1 x 10*
Surface Water
Target Risk Range
Upper Target
Limit Receptor
1 x 10'5 Resident
1 x 10s Industrial
1 x 10s Dev. Park
1 x 10'5 Undev. Park
PRLs
Total U
(ppb)
5.4 x 102
5.4 x 102
5.4 x 102
5.4 x 102
8-9
Land Use Objective 4
1x10* 1 x 105 Youth/Rec. User 2.1 x 102 1x10*
1 x 10s Trespasser 5.4 x 102
VO
VO
-------
j
9
6
§
|
i-*
1
s
f
TABLE 7-1
(Continued)
Groundwater PRLs
Perched Groundwater
Target Risk Range
Lower Upper Target
Case(s) Limit Limit Receptor
1 1 x 10* 1 x 10 5 Resident
PRLs
Total U
(ppb)
Land Use Objectives
5
Great Miami Aquifer Groundwater
Target Risk Range
Lower Upper Target
Limit Limit Receptor
1 and 2
1 x 10* 1 x lO'3 Resident
PRLs
Total U
(ppb)
5
1 x 10'
1 x 10-»
Resident
20
PMCL"
PMCL
ARARf
20
Land Use Objective 3
3-7
NA
NA
NA
NA
PMCL
PMCL
ARAR
20
Land Use Objective 4
8-9
NA
NA
NA
NA
PMCL
PMCL
ARAR
20
* K, = teachability coefficient
b Resident is resident fanner
c Corresponds to an ILCR in the range of 1 x 10'3 to 1 x 10"4 with HQ of 1.0
d Uses the principle of as low as reasonably achievable (ALARA) to reduce on-property residual contamination
* Proposed maximum contaminant level
f Applicable or relevant and appropriate requirement; at residual risk level of 105 to the resident farmer, PMCLs are more restrictive and are therefore used in lieu of the
risk-based limits. O
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FEMP-05ROD-6 FINAL
December 15, 1995
No. 3 - South Groundwater Contamination Plume. The five parts of this removal action were
designed and implemented to minimize public risk of exposure to uranium-contaminated groundwater
south of the FEMP. This action will be integrated into the final remedy as follows:
Part 1 - no integration required; this completed part of the removal action involved providing an
alternate water supply to industries south of the FEMP.
Part 2 - the groundwater recovery well system will continue until it is integrated into the larger
pump and treat activities planned under the selected remedy.
Part 3 - the interim treatment system for site wastewater streams will continue to operate, as
necessary, as part of the Operable Unit 5 final remedy.
Part 4 - monitoring to prevent use of contaminated groundwater will continue through the time
frame of the groundwater remediation component of the remedy.
Part 5 - no integration required; investigations to identify the leading edge of the South Plume
are complete.
South Plume Interim Treatment project - these systems to reduce uranium discharges to the Great
Miami River will continue to operate, as necessary, as part of the final remedy.
No. 16 - Collect Uncontrolled Production Area Runoff. This completed action will be maintained as
part of the final remedy for as long as needed to control contaminated storm water runoff from the
former production area.
No. 17 - Improved Storage of Soil and Debris. This interim action provides guidelines for
management of soil and debris generated at the FEMP. Operable Unit 5 soil/sediment excavation and
interim storage will be conducted consistent with this removal action (including revisions) until such
time as the appropriate Operable Unit 5 remedial design/remedial action documentation is approved
by EPA.
No. 30 - KC-2 Warehouse/Well 67. Sampling and monitoring of Well 67 will continue until
Operable Unit 3 demolishes the structure and the well is plugged and abandoned.
FER\CRU5\ROD\NMG\SEC-7.ROD\December 15. 1995 9:25«m 7-6
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FEMP-05ROD-6 FINAL
December 15, 1995
7.1.4 Institutional Controls
During implementation of the Operable Unit 5 remedial action the appropriate protective strategies
will be built into the remedial design/remedial action work plans and implemented as part of the
selected remedy to ensure worker and site neighbor health and safety.
Institutional measures including the following would be applied as part of each remedial alternative
during remedy implementation:
• Access controls, through the use of fencing and guards, to the more heavily contaminated
areas on the FEMP property
• Continued federal ownership of the FEMP property
• Alternate water will be supplied to potential users of groundwater within the areas of the
aquifer exhibiting contaminant concentrations exceeding final remediation levels.
Following remedy implementation and attainment of remedial objectives, institutional controls,
including continued federal ownership of all or portions of the FEMP property, would continue as
part of remedies contemplating on-property disposal of contaminated material.
7.1.5 Five-Year CERCLA Reviews
As mandated by CERCLA, if contaminated materials remain at a site as envisioned for the Operable
Unit 5 action alternatives involving on-property disposal, EPA will conduct reviews of the
performance of the selected remedy at least once every five years from the date the remedial action is
initiated, to ensure the continued protection of human health and the environment.
7.2 REMEDIAL ALTERNATIVES
The Proposed Plan for Operable Unit 5 discussed seven alternatives that met the initial screening
criteria. Along with the no-action alternative, each of these and the associated land use objectives are
summarized below. Table 7-2 provides a summary of the various components of the alternatives for
ease of comparison.
The following statutes and regulations define the primary applicable or relevant and appropriate
requirements (ARARs) and to be considered (TBC) criteria for each of the Operable Unit 5
FER\CRU5\TOD\NMG\SEC-7.ROD\Decanber 11, 1995 2:3«pm 7-7
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TABLE 7-2
SUMMARY OF ALTERNATIVES
oo
Land Use
Objective
None
Full
unrestricted use
Establishment of
a consolidated
waste
management
area with
unrestricted use
of the remaining
areas of the
property
Establishment of
a consolidated
waste
management
area with
restricted use of
the remaining
areas of the
property
Alternative1
No action
1 Excavation and
off-property
disposal of soil
2A Excavation
and on-property
disposal of soil in
cell; off-site
disposal of soil
not meeting cell
waste acceptance
criteria (WAC)
2C Excavation,
off-site disposal of
heavily
contaminated soil,
consolidation of
slightly
contaminated soil
3A Excavation,
on-property
disposal in cell;
off-site disposal of
soil not meeting
WAC
Risk
Ca*eb
None
1
2
1
2
1
2
3
4
5
6
7
On-Site Soil
Excavation
(million yd3)
0
4.45
2.34
4.45
2.34
4.45
2.34
1.99
1.80
1.79
1.79
1.80
Off-Site
Excavation
(million yd3)
0
5.20
0.40
5.20
0.40
V.
5.20
0.40
0.40
0.40
0.40
0.001
0.001
Soil Shipped
Off-Site
(million yd3)
0
9.35
2.40
0.05
0.03
9.35
1.16
0.03
0.03
0.03
0.03
0.03
On-Property
Backfill0
(million yd3)
0
0.30
0.34
0.30
0.340
0.30
0.34
0.03
0.43
0.42
0.02
0.03
Disposal
Facility
(million yd3)
0
0
0
9.30
2.37
0
0
2.34
1.75
1.75
1.75
1.75
Consolidation
Area
(million yd3)
0
0
0
0
0
0
1.24
0
0
0
0
0
Present
Worth
(million $)
0
4330
1240
2290
720
4330
910
690
630
610
580
580
Total Cost
(Escalated)
(million $)
0
13,900
3020
12,000
2580
13,900
2780
2510
2220
2180
2110
2110
Time to Implement
(yrs.)
Aquifer
0
75
27
75
27
27
27
27
27
27
27
27
Soil
0
22
22
22
22
22
22
22
22 S
22 /tt J-n
22 Sg
a
22 |1 &
-------
| TABLE 7-2
8 (Continued)
f
3
S
9
I?
|
X
8
*•
5
*o
to
1
1
SO
Land Use
Objective Alternative*
3C Excavation,
off-property
disposal of
heavily
contaminated soil;
consolidation of
slightly
contaminated soil
Restricted use of 4A Excavation,
entire on- on-property
property area disposal of soil in
cell
4C Excavation,
off-property
disposal of soil
Risk
Caseb
3
4
5
6
7
8
9
8
9
On-Sile Soil
Excavation
(million yd3)
1.99
1.80
1.79
1.80
1.80
1.79
1.80
1.79
1.80
Off-Site
Excavation
(million yd3)
0.40
0.40
0.40
0.001
0.001
0.40
0.001
0.40
0.001
Soil Shipped
Off-Site
(million yd3)
1.15
1.13
1.12
1.12
1.12
0.03
0.03
1.12
1.12
On-Property
Backfill"
(million yd3)
0.02
0.42
0.42
0.02
0.03
0.42
0.02
0.42
0.02
Disposal
Facility
(million yd3)
0
0
0
0
0
1.75
1.75
0
0
Consolidation
Area
(million yd3)
1.22
0.65
0.65
0.65
0.65
0
0
0.65
0.65
Present
Worth
(million $)
880
820
800
770
770
610
580
800
780
Total Cost
(Escalated)
(million S)
2690
2290
2210
2170
2170
2180
2110
2240
2170
Time to Implement
(yrs.)
Aquifer
27
27
27
27
27
27
27
27
27
Soil
22
22
22
22
22
22
22
22
22
* All action alternatives include extraction, treatment, and discharge of groundwater.
b For a complete discussion of risk cases see Section 7.1.2, Table 7-1, and the Feasibility Study Report for Operable Unit 5, Section 2.0.
' This is the estimated volume of clean soil to be excavated to reach contaminated soil at depth (e.g., under pipelines).
»1
9 O
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FEMP-05ROD-6 FESTAL
December 15, 1995
alternatives; a summary of the pertinent ARARs/TBCs is included with the descriptions of the
alternatives:
• Safe Drinking Water Act national primary drinking water regulations
• Ohio Water Quality Standards for surface water
• Ohio general radiation protection standards
• Clean Water Act
• National Emission Standards for Hazardous Air Pollutants
• Resource Conservation and Recovery Act (RCRA) hazardous waste management regulations
• Uranium Mill Tailings Radiation Control Act (UMTRCA)
• Protection of wetlands, flood plains, and threatened and endangered species under the
National Environmental Policy Act
• Department of Transportation requirements for transport of hazardous materials.
ARARs for the selected remedy are cited hi Appendix B, Tables B.I through B.3. The methods of
compliance with ARARs for the selected remedy are described hi Tables B.4.A through B.4.C of
Appendix B. Detailed descriptions of ARARs for each alternative can be found hi the Operable
Unit 5 FS Report, Section 4.0.
7.2.1 No-Action Alternative
In order to adequately compare the final alternatives and select an appropriate remedy, the NCP
requires that a no-action alternative be developed and used as a baseline against which other
alternatives are evaluated. Under this alternative, no remedial actions would be taken for Operable
Unit 5 contaminated media. The no-action alternative would not decrease the toxicity, mobility, or
volume of hazardous substances through treatment or reduce public health or environmental risks.
Compliance wift Primary ARARs
Remedial actions pursuant to Sections 104 or 106 of CERCLA must meet the cleanup standards of
Section 121 of CERCLA, including attainment of (or justification of a waiver from) ARARs.
FER\CRU5\ROD\NMG\SEC-7.ROD\Deconber 11, 1995 2:2gpm 7-10
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A no-action decision can only be made when no remedial action is necessary to reduce, control, or
mitigate exposure because the site is already protective of human health and the environment.
The no-action alternative is not protective of human health and the environment and also does not
comply with ARARs for Operable Unit 5. With no further action (according to the Operable Unit 5
Baseline Risk Assessment), the continued release of contaminants could result in exceeding limits for
airborne emissions of radionuclides under 40 CFR 61, Subparts H and I, and exposure limits to the
public established under DOE Order 5400.5. Releases of radionuclides and organic and inorganic
contaminants would violate State of Ohio water quality standards (Ohio Administrative Code
[OAC] 3745-1) for receiving surface waters. Drinking water maximum contaminant levels (MCLs)
and maximum contaminant level goals (MCLGs) under the Safe Drinking Water Act would also be
exceeded hi the long term if the released material were to continue to migrate into the Great Miami
Aquifer.
7.2.2 Alternative 1 - Excavation and Off-Site Shipment
Land Use Objective 1: Full Unrestricted Use
Contaminated soil and sediment exceeding remediation levels would be excavated and shipped by rail
to an off-site licensed disposal facility. Contaminated perched groundwater zones that represent
unacceptable risks to potential human receptors or to the Great Miami Aquifer would also be
excavated and disposed of off site. Water collected from the perched water zones during excavation
would be treated at the FEMP's wastewater treatment facility before discharge to the Great Miami
River. Remediation levels for two cases were examined; Case 1 would protect the projected future
receptors at an ILCR level of 10* and Case 2 would protect at a 10~5 level.
Equivalent restoration of the Great Miami Aquifer would occur. For Case 1, contamination residing
in the aquifer would be remediated to a level of 3 ppb (i.e., 10"6 ILCR level) of uranium and for
Case 2, to 20 ppb (the proposed federal drinking water standard). These cleanup levels would be
attained by the installation and pumping of groundwater extraction wells to pull the contaminated
water from the aquifer. Modeling of pumping rates and time frames produced estimates for the two
cases of 7500 gpm and 75 years for the 10"* level and 4000 gpm and 27 years for the 20 ppb level.
FmCRU5\BQD\NMG\SEC-7.RQD\Deconber 11,1995 2:28pni 7-11
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The FEMP's advanced wastewater treatment facility would reduce the uranium concentration hi the
extracted groundwater before discharging it to the Great Miami River.
Compliance with Primary ARARs
The following subsections summarize the manner by which Alternative 1 will comply with the
primary ARARs, according to chemical-, location-, or action-specific requirements.
Chemical-Specific ARARs - Alternative 1 would comply with the chemical-specific ARARs/TBCs.
ARARs associated with penetrating radiation and potential releases of contaminants to air, surface
water, and groundwater would be met through the removal of all contaminated material from the site.
The material would be disposed of at a permitted, off-site commercial disposal facility. Water
encountered during pumping and excavation would be treated to meet the Ohio Water Quality
Standards (OAC 3745-1) before off-site discharge. Contaminated portions of the Great Miami
Aquifer would be restored to meet proposed and final MCLs promulgated under the Safe Drinking
Water Act.
Location-Specific ARARs/TBCs - Location-specific requirements associated with this alternative relate
to the protection of four principal natural features or resources: floodplains, wetlands, endangered
species, and the sole-source aquifer underlying the FEMP site.
Restrictions on activities conducted in wetlands and floodplains are specified in 40 CFR 6.302,
10 CFR 1022 and Executive Orders 11990 and 11988. Compliance with these requirements would be
met through the prior assessment of potential impacts associated with activities conducted in these
locations and the implementation of mitigative measures. This assessment would result in appropriate
planning, siting, design, and operational procedures. The methods for handling dredged and
excavated material would comply with the provisions of 33 CFR 323 and 40 CFR 230, which state
that dredged or excavated material will not be discharged into waters of the United States.
Protection of threatened and endangered species is mandated by 16 U.S. Code 1531, 50 CFR 17
and 402, and Ohio Revised Code (ORC) 1531.25, 1518.02 and OAC 1501:18-1. Studies have been
conducted to determine if these species are present and/or if suitable habitat for the threatened and
endangered species exists at the FEMP. If the habitat of any endangered species is disturbed,
appropriate mitigative measures will be taken.
FER\CKU5\ROD\NMG\SEC-7.RQD\Decaiiber 11. 1995 2:28pm 7-12
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The provisions of 16 U.S. Code 469, 36 CFR 800, 40 CFR 6.301; 42 U.S. Code 1996 and
43 CFR 7 require federal agencies undertaking an action to implement measures to avoid adverse
impacts to historic and cultural properties. Alternative 1 would comply with these provisions because
any cultural resources identified would be either avoided or managed appropriately.
Action-Specific ARARs - Alternative 1 would comply with all pertinent action-specific ARARs for
waste removal, treatment and off-site disposal.
The specific implementation measures and engineered controls incorporated into Alternative 1 would
need to meet all action-specific ARARs regarding air quality from 40 CFR 50.6 and
OAC 3745-17-08. These ARARs would be pertinent during remedial actions and the postclosure care
period.
Waste removal actions would be conducted in compliance with 40 CFR 192.02(b) and 192.12 under
UMTRCA to provide reasonable assurance that residual radioactive materials do not exceed the
specified concentrations above proposed final remediation levels. During implementation of the
remedial action (including waste removal, facility construction and waste treatment), appropriate
engineered features and procedures would be implemented to comply with the requirements of the
Clean Air Act, 40 CFR 50.6, and Ohio's requirements for fugitive dust control, OAC 3745-17-08.
Off-site disposal of Operable Unit 5 media containing greater than 50 ppm of polychlorinated
biphenyls would require management, in accordance with 40 CFR 761, Subpart G.
Any listed or characteristic hazardous wastes to be disposed of off site would have to meet the waste
acceptance criteria for off-site disposal, including the treatment standards appropriate for the land
disposal restrictions (LDRs) under RCRA (40 CFR 268.40 through 268.44). All storage,
containment, management, and manifesting requirements for listed and characteristic hazardous waste
would be performed in accordance with 40 CFR 261, 262, and 265.
FER\CRU5\ROD\NMG\SEC-7.ROD\Deconber 11, 1995 2:28pm 7-13
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7.2.3 Alternative 2A - Engineered Disposal Facility
Land Use Objective 2: Establishment of a Consolidated Waste Management Area with Unrestricted
Use of the Remaining Areas of the Property
Contaminated soil exceeding remediation levels would be excavated and placed in an engineered
above-grade disposal facility. This facility would be placed on the location with the best available
geologic conditions and be designed with a multilayered lining and capping system. The fenced
disposal facility would remain under the continued ownership of the federal government and other
measures taken to prevent human intrusion. The performance of the facility would be monitored on a
long-term basis.
The design and construction of the site-wide engineered disposal facility is the province of Operable
Unit 2 and is discussed in the Operable Unit 5 FS in general terms. The Operable Unit 5 Proposed
Plan described the proposed site-wide facility hi more detail, giving approximate dimensions of
2400 x 1300 feet x 62 feet high (about 71 acres). The size is based upon the consolidation of soil and
debris from Operable Units 1-4 hi addition to the soil from Operable Unit 5 and would accommodate
2.4 million cubic yards of material. A disposal facility with the dimensions of approximately
1610 x 1610 feet x 37 feet high (about 60 acres) would accommodate Operable Unit 5 material (about
1.8 million cubic yards).
Contaminated soil exceeding the waste acceptance criteria for the disposal facility would be shipped to
an off-site disposal facility unless a cost/effective technology emerged that could treat the soil and
reach concentrations below the criteria. The same remediation levels used in Alternative 1 were
considered, 10* and 10'5 ILCR levels.
Extraction and treatment of contaminated perched water and the Great Miami Aquifer are the same as
under Alternative 1.
Compliance with Primary ARARs
Alternative 2A would comply with all the primary ARARs as described for Alternative 1.
Alternative 2A, however, also requires on-property disposal of excavated soil, triggering the Ohio
Solid Waste Disposal Regulations as an additional primary ARAR. In order to site a disposal facility
over the Great Miami Aquifer, a waiver would be required to carry out this alternative, as described
FER\CRU5\ROD\NMG\SEC-7.KOD\Deconber 11. 1995 2:28pm 7-14
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FEMP-05ROD-6 FINAL
December 15, 1995
below under location- specific ARARs. Other action- and chemical-specific requirements would be
identical to those described in Alternative 1, except those pertinent to on-property disposal.
Chemical-Specific ARARs
Alternative 2A would comply with the chemical-specific ARARs/TBCs. ARARs associated with
penetrating radiation and potential releases of contaminants to air, surface water and groundwater
would be met through the excavation and placement of contaminated material in an on-property
disposal facility, provided the contaminants in the material meet the facility's waste acceptance
criteria. Material exceeding the waste acceptance criteria would be disposed of off site. The
prescribed engineering controls for the on-property disposal facility would ensure that Safe Drinking
Water Act proposed and final MCLs in the Great Miami Aquifer, air emission standards, and radon
protection standards would be met.
Extraction and treatment of contaminated perched water and the Great Miami Aquifer are the same as
under Alternative 1.
Location-Specific ARARs
Alternative 2A would meet the primary location-specific ARARs with the exception that a CERCLA
waiver would be required for two State of Ohio solid waste disposal siting restrictions. These
restrictions prohibit the siting of disposal facilities over 1) sole-source aquifers designated under the
Safe Drinking Water Act and 2) aquifers capable of providing 100 gpm or more of sustained yield for
consumptive use.
The on-property disposal of soil containing RCRA hazardous wastes would be performed in
accordance with the provisions of the RCRA Subtitle C corrective action management unit (CAMU)
regulations for management of environmental media containing listed or characteristic hazardous
waste. Excavated soil would be considered "remediation waste" for management within the CAMU,
as defined in 40 CFR 260.10. The use of the CAMU would not trigger LDR treatment standards or
minimum technology requirements (MTRs).
Compliance with location-specific ARARs for floodplains, wetlands, dredging, endangered species,
and historical preservation would be met as described for Alternative 1.
FER\CRU5«OD\NMG\SEC-7.ROD\Decanber 11. 1995 2:28pm 7-15
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Action-Specific ARARs
Alternative 2A would meet the primary action-specific ARARs discussed for Alternative 1. Because
the FEMP contains low-level radioactive waste/residual radioactive material, solid waste, and
hazardous waste, the engineering design of the on-property disposal facility would meet the more
stringent requirements for disposal of low-level radioactive waste/residual radioactive material. EPA
states in 40 CFR 192(a) for uranium mill tailings that the disposal facility must be designed to be
effective for up to 1000 years, to the extent reasonably achievable, and hi any case, for at least 200
years, and provide protection of groundwater. This disposal facility would also exceed the
engineering design criteria for the less-stringent OEPA and RCRA technical requirements for the
disposal of solid and hazardous waste, respectively.
7.2.4 Alternative 2C - Consolidation with Off-Site Shipment
Land Use Objective 2: Establishment of a Consolidated Waste Management Area with Unrestricted
Use of the Remaining Areas of the Property
Contaminated soil exceeding remediation levels would be excavated and, depending on contaminant
concentration levels, dispositioned either hi an on-property earthen-covered consolidation area or at an
off-site licensed disposal facility. The consolidation area would remain under the continued
ownership of the federal government with measures taken to prevent human intrusion. Waste
acceptance criteria for the consolidation area would be set at levels protective of the Great Miami
Aquifer.
The perched groundwater and Great Miami Aquifer remedial actions would be identical to those
described for Alternative 1.
Compliance with Primary ARARs
The ARARs for Alternative 2C are identical to those for 2A, and a waiver from the Ohio Solid Waste
Disposal restrictions would be necessary to site the consolidation area over the Great Miami Aquifer.
Alternative 2C would comply with all remaining primary ARARs in a manner identical to
Alternative 2A.
FER\CRU5«DD\NMG\SEC-7.ROD\Deeaiiber 11, 1995 2:28pm 7-16
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December 15, 1995
7.2.5 Alternative 3A - Engineered Disposal Facility
Land Use Objective 3: Establishment of a Consolidated Waste Management Area with Restricted Use
of the Remaining Areas of the Property
Under Alternative 3A, contaminated soil exceeding final remediation levels would be excavated and
placed in an on-property engineered disposal facility; excavated soil or sediment not meeting the
waste acceptance criteria would be shipped to an off-site licensed disposal facility. Perched water
zones exhibiting concentrations of contaminants that threaten the water quality of the underlying Great
Miami Aquifer to a level above proposed or final Safe Drinking Water Act MCLs would also be
excavated. Groundwater restoration of the Great Miami Aquifer would be accomplished as in
Alternative 1.
The disposal facility would remain under the continued ownership of the federal government with
measures taken to prevent human intrusion. The remaining areas made available for use would have
institutional controls applied to ensure that the restricted (nonfanning) land use was maintained. An
on-going environmental monitoring program would be put in place.
Compliance with Primary ARARs
The remedial action components of Alternative 3A are identical to Alternative 2A, and compliance
with primary ARARs for this alternative would be identical to those described for Alternative 2A.
7.2.6 Alternative 3C - Off-Site Disposal
Land Use Objective 3: Land Use Objective 3: Establishment of a Consolidated Waste Management
Area with Restricted Use of the Remaining Areas of the Property
Contaminated soil exceeding remediation levels (the same as for Alternative 3A) would be excavated,
with the soil exhibiting contaminant levels greater than the consolidation area waste acceptance criteria
shipped by rail to a licensed off-site disposal facility. The remedial strategy for soil, perched
groundwater, and the Great Miami Aquifer is consistent with Alternative 2C.
FER\CRU5\ROD\NMG\SEC-7.ROD\Deconber 12, 1995 10:04mi 7-17
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Compliance with Primary ARARs
The remedial action components of Alternative 3C are identical to Alternative 2C; thus compliance
with primary ARARs for Alternative 3C would be the same as previously described for
Alternative 2C.
7.2.7 Alternative 4A - Engineered Disposal Facility
Land Use Objective 4: Restricted Use of the Entire On-Property Area
Contaminated soil exceeding remediation levels would be excavated, consolidated, and placed in an
engineered disposal facility; excavated soil or sediment not meeting the waste acceptance criteria
would be shipped to an off-site licensed disposal facility. This alternative is similar to
Alternatives 2A and 3A in that it specifies the construction of an on-property engineered disposal
facility. Restricting access to the entire FEMP property is the primary difference between
Alternative 4A and Alternatives 2A and 3A, where portions of the FEMP outside the disposal facility
buffer area could be used.
Compliance with Primary ARARs
The remedial action components of Alternative 4A are identical to Alternatives 2A and 3A; thus
compliance with primary ARARs for Alternative 4A would be the same as previously described for
Alternatives 2A and 3A.
7.2.8 Alternative 4C - Consolidation with Off-Site Disposal
Land Use Objective 4: Restricted Use of the Entire On-Property Area
Contaminated soil exceeding remediation levels would be excavated and dispositioned either on
property hi an earthen-covered consolidation area or off site at a licensed disposal facility depending
on contaminant concentration levels. This alternative is similar to Alternatives 2C and 3C in that it
specifies the construction of an on-property earthen-covered consolidation area. Restricting access to
the entire FEMP property is the primary difference between Alternative 4A and Alternatives 2C
and 3C, where portions of the FEMP outside the consolidation area buffer zone could be used.
FER\CSU5\ROD\NMG\SEC-7.ROD\Deeen>ber 12, 1995 10:04«m 7-18
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Compliance with Primary ARARs
The remedial action components of Alternative 4C are identical to Alternatives 2C and 3C; thus
compliance with primary ARARs for Alternative 4C would be the same as previously described for
Alternatives 2C and 3C.
FER\CRU5\ROD\NMG\SEC-7.ROD\Dectmber 12, 1995 10:04«m 7-19
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8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP identifies nine evaluation criteria against which final remedial alternatives must be
evaluated. The NCP also requires a comparative analysis that focuses upon the relative performance
of each alternative against the criteria. The nine criteria are:
1. Overall protection of human health and the environment - Addresses protection achieved, in
both the short and long term, from unacceptable risks posed by contaminants at the site by
eliminating or controlling exposures.
2. Compliance with ARARs - Addresses compliance with federal environmental laws and state
environmental or facility-siting laws.
3. Long-term effectiveness and permanence - Addresses the magnitude of residual risk associated
with untreated waste or treatment residuals remaining at the conclusion of remedial activities;
also addresses the adequacy and reliability of controls that are necessary to manage treatment
residuals and untreated wastes.
4. Reduction oftoxicity, mobility, or volume through treatment - Addresses the degree to which
treatment reduces the hazards posed by the principal threats at the site, the amount of material
treated, the expected reduction in toxicity, mobility, or volume, the degree to which the
treatment is irreversible, and the type and quantity of treatment residuals.
5. Short-term effectiveness - Addresses short-term risks to the public during remedial action,
potential impacts on workers during remedial action and the effectiveness and reliability of
protective measures for workers, and potential environmental impacts of the remedial action
and the effectiveness and reliability of mitigative measures; also addresses the time until
protection is achieved.
6. Implementability - Addresses the technical and administrative feasibility of implementing an
alternative and the availability of needed services and materials, including adequate off-site
disposal capacity.
7. Cost - Addresses capital and operation and maintenance costs and their net present value.
8. State acceptance - Addresses state concerns, including concerns related to the preferred
alternative and other alternatives as well as ARARs and any proposed use of waivers.
9. Community acceptance - Addresses concerns of the community relative to alternatives under
consideration.
The first two are threshold criteria that must be met by an alternative in order to be eligible for
selection as the remedy for a site (unless a waiver condition applies to the second criterion). The next
five are primary balancing criteria that are used to identify relative advantages and disadvantages
FER\CRU5\ROD\MCM\SEC-8.ROD\Deconber 11, 1995 3: llpm 8-1
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December 15, 1995
among the alternatives. The last two are modifying criteria that must be considered in remedy
selection.
The following sections provide a comparative analysis of the alternatives using the nine evaluation
criteria. The comparative analysis of the alternatives using the threshold and balancing criteria is
summarized in Table 8-1.
8.1 THRESHOLD CRITERIA
8.1.1 Overall Protection of Human Health and the Environment
All of the action alternatives provide for overall protection of human health and the environment. It
cannot, however, be ensured that the no-action alternative would be protective of human health and
the environment in the long term. For each of the action alternatives, the potential for human and
environmental exposures to contaminants would be reduced in several ways. The major sources of
contamination would be removed: contaminated groundwater would be removed and treated;
contaminated soil would be placed in a consolidation area with an earthen cover ("C" alternatives) or
in an engineered, on-property disposal facility ("A" alternatives) that would prevent the release of
contaminants into the environment for at least 200 to 1000 years or they would be removed to an
off-site, licensed disposal facility (Alternative 1). All action alternatives would be implemented in
such a manner as to protect human health and the environment in the short term.
8.1.2 Compliance with ARARs
Alternative 1 and Risk Case 1 of Alternative 2C would comply with all federal and state ARARs. All
other action alternatives would meet all ARARs except for State of Ohio siting requkements for solid
waste disposal facilities. Implementing any of these action alternatives would requke a waiver from
the state siting requkements.
The no-action alternative would not comply with all federal and state ARARs. With no action,
continued release of contaminants could result in exceeding limits for akborne emissions of
radionuclides, exceeding radiological exposure limits for the public, violation of water quality
standards, and exceeding MCLs in the Great Miami Aquifer.
FER\CRU5\ROD\MCM\SEC-8.RQDYDeconber It, 1995 3:llpm 8-2
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TABLE 8-1
COMPARATIVE ANALYSIS OF OPERABLE UNIT 5 REMEDIAL ALTERNATIVES
Overall
Protection of
Human Health
and
Alternative* Environment
1. Excavate and Protective of
dispose of soil/sediment human health
off property. and the
environment.
2A. Excavate and Same as Alt.
dispose of soil/sediment 1.
in an on-property
disposal facility; off-
property disposal of
material not meeting
WAC* for disposal
facility.
Compliance
with ARARsb
Complies with
all ARARs.
Requires
waiver of
requirements
related to on-
property
disposal.
Long-Term
Effectiveness and
Permanence
Effective and
permanent;
provides the
lowest residual
risk of all
alternatives.
Effective and
permanent;
however,
residual risk
higher than for
Alt. 1 because
contaminated soil
would remain in
an on-property
disposal facility.
Reduction of
Toxicity, Mobility or
Volume Through
Treatment
Groundwater is
treated following
extraction; no
treatment of
soil/sediment.
Same as Alt. 1.
Short-Term
Effectiveness
Risks to public
higher than for
Alt. 2A
because
transportation
of all waste
off-site
required.
Otherwise
similar to Alt.
2A.
Acceptable
risks to
workers and
public;
acceptable
environmental
impacts.
Implementability
Technically
implementable;
however,
uncertainties
associated with
off-site disposal
capacity make
this alternative
the most difficult
to implement.
Possible difficulty
with access to
off-property soil.
Technically
implementable.
Possible difficulty
with access to
off-property soil;
otherwise, low
administrative
difficulty.
Estimated
Present-Worth
Cost/Risk Case0
(Millions of
Dollars)
$4330/Case
1240/Case
$2290/Case
720/Case
1
2
1
2
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TABLE 8-1
(Continued)
Overall
Protection of
Human Health
and
Alternative* Environment
2C. Excavate and Same as Alt.
dispose of soil/sediment 1.
not meeting WAC for
an on-property
consolidation area off
property. On-property
disposal of material
meeting WAC for unit.
3A. Excavate and Same as Alt.
dispose of soil/sediment 1.
in an on-property
disposal facility; off-
property disposal of
material not meeting
WAC for disposal
facility.
3C. Excavate and Same as Alt.
dispose of soil/sediment 1.
not meeting WAC for
an on-property
consolidation area off
property. On-property
disposal of material
meeting WAC for unit.
Reduction of
Long-Term Toxicity, Mobility or
Compliance Effectiveness and Volume Through Short-Term
with ARARsb Permanence Treatment Effectiveness
For Risk Case Effective and Same as Alt. 1. Similar to Alt.
1, same as permanent. For 1.
Alt. 1. For Risk Case 1,
Risk Case 2, residual risk
same as Alt. same as for Alt.
2A. 1. For Risk
Case 2, residual
risk is between
that provided by
Alt. 1 and 2A.
Same as Alt. Similar to Alt. Same as Alt. 1. Similar to Alt.
2A. 2A. 2A.
Same as Alt. Effective and Same as Alt. 1. Similar to Alt.
2A. permanent. 1.
Provides residual
risk between that
provided by Alt.
1 and 2A.
Implemenlability
Similar to Alt. 1;
however, ARAR
waiver may not
be available for
the consolidation
area for Risk
Case 2.
Similar to Alt.
2A, except that
Risk Cases 6 and
7 have no
difficulty related
to access to off-
property soil.
Similar to Alt. 1,
although less off-
site disposal
capacity is
needed, except
that Risk Cases 6
and 7 have no
difficulty related
to access to off-
property soil.
Estimated
Present-Worth
Cost/Risk Case0
(Millions of
Dollars)
$4330/Case 1
910/Case 2
$630/Case 3
630/Case 4
610/Case 5
580/Case 6
580/Case 7
$820/Case 3
800/Case 4
770/Case 5
830/Case 6
770/Case 7
B
-------
oo
Overall
Protection of
Human Health
and Compliance
Alternative* Environment with ARARsb
4A. Excavate and Same as Alt. Same as Alt.
dispose of soil/sediment 1. 2A.
in an on-property
disposal facility; off-
property disposal of
material not meeting
WAC for disposal
facility.
4C. Excavate and Same as Alt. Same as Alt.
dispose of soil/sediment 1. 2A.
not meeting WAC for
an on-property
consolidation area off
property. On-property
disposal of material
meeting WAC for unit.
TABLE 8-1
(Continued)
Estimated
Reduction of Present-Worth
Long-Term Toxicity, Mobility or Cost/Risk Case0
Effectiveness and Volume Through Short-Term (Millions of
Permanence Treatment Effectiveness Implementability Dollars)
Similar to Alt. Same as Alt. 1. Similar to Alt. Same as Alt. 3A, $610/Case 8
2A. 2A. Risk Cases 6 and 580/Case 9
7.
Similar to Alt. Same as Alt. 1. Similar to Alt. Similar to Alt. $800/Case 8
3C. 1. 3C, Risk Cases 6 780/Case 9
and 7.
No action
Cannot ensure
that alternative
would be
protective of
human health
and the
environment
in the long
term.
Does not meet
all ARARs.
Provides
unacceptable
residual risk; not
effective over the
long term.
No treatment.
No short-term
risks to
workers or the
public; no
short-term
environmental
impacts.
Easiest to
implement
because no action
is required.
$0
More detail on alternatives is given in Section 7.2. Differences between similar alternatives.(e.g., 2A, 3A, 4A) relate to different land-use objectives and
associated risk scenarios. For all action alternatives, groundwater would be extracted, treated, and discharged.
Applicable or relevant and appropriate requirements.
Risk cases are defined in Section 7.1.2 and Table 7-1.
Waste acceptance criteria.
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FEMP-05ROD-6 FINAL
December 15, 1995
8.2 PRIMARY BALANCING CRITERIA
8.2.1 Long-Term Effectiveness and Permanence
All of the action alternatives would reduce the residual risks associated with contaminated soil or
treatment residuals to an acceptable level. Remedial alternatives employing off-site disposal would
leave the least amount of contaminated materials at the FEMP. Alternatives 1 and 2C (Risk Case 1)
would be most effective because they would leave no contaminated material above remediation levels
on site. Alternatives 2C (Risk Case 2), 3C and 4C would remove less contaminated soil from the site
than Alternatives 1 and 2C (Risk Case 1) but more than Alternatives 2A, 3A and 4A, which rely
primarily on on-property disposal. All action alternatives would include pumping and treating
contaminated groundwater from the Great Miami Aquifer and removing contaminated perched water
zones that threaten the Great Miami Aquifer through cross-media pathways. For all action
alternatives, verification and certification sampling would ensure remediation of contaminated soil to
appropriate levels.
The residual risk for Alternatives 2A, 3A and 4A would be the highest for the action alternatives.
Because the no-action alternative would remove no contaminated soil or groundwater, it would have
the highest residual risk of all the alternatives.
Each of the alternatives employing a disposal facility or consolidation area relies on engineering
measures or institutional controls to ensure the long-term performance of the remedy and maintain the
protection of human health and the environment over time. These measures and controls are adequate
to provide reliable, long-term protection for up to 1000 years. For Alternative 1 and Risk Case 1 of
Alternative 2C, no long-term management of the site would be necessary because of the removal and
off-site shipment of all materials above remediation levels.
8.2.2 Reduction of Toxicity. Mobility, or Volume Through Treatment
All of the action alternatives rely on treatment to address contaminated storm water and recovered
groundwater before discharge to the Great Miami River. Treatment options were studied for
application to contaminated soil but were not adopted as a main component of any of the remedial
alternatives due to lack of cost effectiveness. During the remedial action, DOE will continue to
evaluate emerging technologies for potential application to the selected remedy to promote cost
effectiveness, waste minimization, and successful on- and off-property disposal of wastes.
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The no-action alternative provides no treatment.
8.2.3 Short-Term Effectiveness
Because no remedial activity would be taken, the no-action alternative would cause the least short-
term impact. Each of the other alternatives involves earth moving and other construction activity,
operation of treatment facilities, and material transport. Thus, all action alternatives would pose some
risk to the environment, workers, and the public. However, these impacts can be effectively
controlled through the application of mitigative measures such as the suppression of dust, restoration
of wetland areas, rigorous worker health and safety programs, and monitoring.
The lowest short-term risks for the action alternatives are associated with those alternatives (2A, 3A,
and 4A) relying on disposal in an engineered on-property facility. Those remedial alternatives
(1, 2C, 3C, and 4C) relying on off-site disposal as a major means for material disposition present the
highest overall short-term risks due to the added potential for injuries and fatalities associated with
transporting large quantities of material to an off-site disposal location.
All action alternatives except Risk Case 1 of Alternatives 1, 2A, and 2C would require 27 years to
implement. Risk Case 1 would require 75 years to implement because of the additional tune required
to achieve groundwater remediation levels.
i
8.2.4 Implementability
The no-action alternative would be the most readily implemented because it requires no remedial
activity.
The soil remediation component of all the action alternatives is generally technically feasible and
implementable-using existing technologies and construction methods. In particular, on- and off-
property disposal of soil and sediment is considered readily implementable. However, excavating soil
to achieve a 10~* residual risk level for residential farming (Risk Case 1 for Alternatives 1, 2A
and 2C) may prove difficult because it would be hard to distinguish cleanup levels from natural
background concentrations. Excavation boundaries could not be delineated using real-time field
monitoring due to the insensitivity of available techniques at the required detection levels. At the 10"*
residual risk level, all analysis would need to be conducted using a conventional analytical laboratory.
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December 15, 1995
The typical turnaround times for such a facility would interfere with the continuity of field activities,
including excavation and backfilling.
The groundwater restoration component of all the action alternatives is considered implementable
using available technology. There is considerable uncertainty hi the amount of time required to attain
groundwater remediation levels for uranium and several other contaminants; however, 27 years is
estimated for all action alternatives except Risk Case 1 of Alternatives 1, 2A, and 2C, which is
estimated to require 75 years. This uncertainty is due to difficulty predicting the rate at which
contaminants will be released to groundwater from the silt, sand, and gravel that make up the aquifer.
DOE will continue to investigate technologies, such as water reinjection, to enhance contaminant
recovery and reduce the time required to attain groundwater remediation levels. Reinjection would
potentially involve the pumping of treated groundwater back into the aquifer to increase the rate of
flow and create a flushing effect that would speed contaminant release.
The administrative feasibility of alternatives relying primarily on an on-property engineered disposal
facility is higher than that of other action alternatives. Administratively, alternatives involving off-
site disposal of a major portion of the contaminated material (1, 2C, 3C, and 4C) may be less readily
implementable than those involving primarily on-property disposal in an engineered disposal
(2A, 3A, and 4A) because the availability of disposal capacity at an off-site location is unclear, with
the uncertainty compounded by the potential 22-year duration of soil remediation. In addition,
obtaining a waiver from the State of Ohio's solid waste disposal siting requirements is unlikely for
alternatives that rely on a consolidation area (2C, 3C, and 4C).
At the 10"6, and to a lesser extent at the 10"5 residual risk level, access to off-property locations to
conduct remedial activities would be required. Gaming such access may prove difficult and cause
delays. In the event voluntary access could not be acquired, access to the private properties would
need to be sought through legal action, a time-consuming and relatively unpredictable process.
Administrative feasibility would be higher for those risk cases that involve less stringent cleanup
levels for off-property soil; i.e., Alternatives 3A (Risk Case 6), 3C (Risk Case 7), and 4A and 4C
(Risk Cases 8 and 9).
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8.2.5 Cost
No costs are associated with the no-action alternative.
The lowest estimated costs for the action alternatives are for Alternatives 3A and 4A, which involve
on-property disposal of virtually all contaminated material and which generally have the highest
cleanup levels for soil. The highest estimated costs are associated with Risk Case 1 of Alternatives 1,
2A, and 2C, which involve off-property disposal and/or the lowest cleanup levels for soil.
Intermediate in terms of estimated costs are Alternatives 3C, 4C, and Risk Case 2 of Alternatives 1,
2A, and 2C, which have higher cleanup levels for soil than does Risk Case 1.
Total estimated present-worth costs for all alternatives are given in Table 8-1.
8.3 MODIFYING CRITERIA
8.3.1 State Acceptance
As discussed hi detail hi Section 9.0, DOE has selected Alternative 3A as the most appropriate
remedy for Operable Unit 5 at the FEMP. Alternative 3A provides the best balance among the
remedy selection criteria provided by the CERCLA NCP. The State of Ohio supports DOE's selected
alternative and has issued a letter documenting this support (provided hi Appendix A). In their letter,
the State of Ohio has requested that DOE agree to certain stipulations for obtaining state concurrence
on the selected remedy. The principal stipulations are:
• No disposal or long-term storage of off-site waste hi the proposed engineered disposal facility
or any other facility on the FEMP site
• The disposal facility waste acceptance criteria should be set at a maximum of 1030 parts per
million total uranium with the flexibility to be lowered based upon other operable unit
decisions and volumes
• The waste acceptance criteria must represent an upper limit and not be used as an average limit
• No characteristic hazardous waste should be disposed of hi the facility
• DOE must not use dilution to meet waste acceptance criteria or remediation levels
• DOE should commit to being open to consider new technologies which may reduce the
volume, toxicity, or mobility of waste being disposed of on site.
FER\CRU5\ROD\MCM\SEC-8.ROD\Decanber 11, 1995 3:llpm 8-9
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DOE has responded to the issues raised by the State of Ohio in the Responsiveness Summary. In
Section 9.0 and the Responsiveness Summary, DOE has incorporated an implementation approach to
satisfy each of the stipulations requested by the State of Ohio.
The State of Nevada and the State of Utah concur with the balanced approach to site remediation
(shipping the higher-level contaminated material off site combined with management of lower-level
contaminated material on site) adopted for Operable Unit 5. Both states conveyed that by taking a
balanced approach, their support for the receipt of out-of-state wastes would continue. Letters of
support from both the State of Nevada and the State of Utah are provided in the Responsiveness
Summary.
8.3.2 Community Acceptance
Community input on the alternatives for remedial action for Operable Unit 5 was solicited during the
public comment period from May 1 to June 30, 1995. Many members of the local community are
personally opposed to on-property disposal and expressed their preference for off-site disposal of all
of Operable Unit 5's soil, regardless of cost and implementability considerations. Other members of
the community (including the Fernald Citizens Task Force) expressed an understanding of the
necessity of taking a balanced approach to site cleanup. In general, all commentors were hi
agreement to restore the Great Miami Aquifer to full beneficial use. While expressing reservations
about on-property disposal, the comments received did not identify any technical omissions or errors
in the development of the alternatives for Operable Unit S or the technical basis for the selection of
the preferred alternative. Responses to community comments are found hi the Responsiveness
Summary.
FER\CRU5\ROD\MCM\SEC-8.ROD\December 11. 1995 3:llpm 8-10
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9.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the results of the detailed analysis of
alternatives using the nine criteria, and public comments, DOE and EPA have determined that
Alternative 3A is the most appropriate remedy for Operable Unit 5 at the FEMP.
Alternative 3A provides for the protection of existing and projected future human and environmental
receptors through the implementation of remedial actions involving: the excavation of soil, sediment
and perched water zones containing concentrations of COCs above the final remediation levels
(presented in Section 9.2); on-property disposal of the excavated materials in an engineered disposal
facility; restoration of the Great Miami Aquifer through pump and treat technologies to attain the final
remediation levels; collection of contaminated storm water; treatment of collected storm water and
process wastewater generated through remedial activities and recovered contaminated groundwater to
the extent necessary to ensure that discharge limits are attained and final remediation levels for the
receiving surface water streams are not exceeded; long-term groundwater monitoring; and continued
federal ownership of the FEMP, or portions thereof, to the extent necessary to ensure the continued
protection of human health and the environment.
During the remedial design and remedial action processes new information may be developed that
supports enhancing or making a change to the remedy selected in this ROD. This information could
be a result of additional investigations at the site or the processes of design or value engineering
following issuance of the ROD. If a nonsignificant or minor change to the ROD is deemed
necessary, it will be recorded in a postdecision document file; nonsignificant changes are those that do
not significantly affect the scope, performance or cost of a remedy. If a significant change to a
component of the remedy in the ROD is warranted, it will be documented in an Explanation of
Significant Differences. If a fundamental change to the overall remedy is deemed appropriate, it will
be made through issuance of a ROD amendment. A fundamental change to a remedy typically
involves a reconsideration of the overall management approach for addressing the hazardous
substances in the environment. Any changes deemed necessary to the remedy selected in this ROD
will be implemented hi a manner consistent with applicable EPA guidance, and the technical and
public participation requirements of the NCP.
FER\CRU5\NMG\ROD\SEC-9.ROD\December 11. 1995 3:34pm 9-1
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This ROD provides for the on-property disposal of contaminated materials originating on-site.
Contaminated materials to be placed into the on-property disposal facility (following any necessary
demonstration of the attainment of waste acceptance criteria) include: contaminated soil and
sediment; water and wastewater treatment sludges, spent resins and filter media; miscellaneous rubble
from the construction, demolition and maintenance of water, wastewater and storm water conveyance,
equalization, and treatment systems; investigation-derived waste from Operable Unit 5 investigation,
sampling and analysis efforts; miscellaneous waste (i.e., respirators, protective clothing, etc.,)
generated consequentially to the planning and implementation of remedial actions; and sludges and
other wastes derived during the conduct of engineering studies (i.e., treatability, proof-of-process,
etc.,) on Operable Unit 5 materials.
This ROD provides an explicit prohibition to the placement of any waste generated off of the FEMP
hi the on-property disposal facility. Specifically excluded from this prohibition are laboratory.wastes
generated at off-site facilities resulting directly from the chemical, radiological and engineering
analysis of FEMP waste materials/contaminated media or wastes generated at off-site facilities during
the conduct of treatability or demonstration type studies on FEMP material.
9.1 KEY COMPONENTS
The selected remedy consists of 10 key components: soil and sediment; perched water; regional
groundwater aquifer; storm water/wastewater; treatment of discharges; measures to minimize
environmental impacts; institutional controls/monitoring; the corrective action management unit
(CAMU) rule; cost; and community involvement. Each is discussed below.
9.1.1 Soil and Sediment
Soil and sediment exceeding final remediation levels (discussed in Section 9.2) will be excavated with
conventional construction equipment. Figure 9-1 provides a planning-level estimate of the projected
footprint of soil and sediment requiring excavation as part of the selected remedy. The exact
boundary of required excavation will be established through the completion of a verification sampling
program before field activities begin. Excavation is projected to generally proceed from the
northeastern portion of the facility toward the southwest to take maximum advantage of natural
drainage patterns to minimize the potential for the recontamination of previously excavated areas
resulting from contact with contaminated runoff. Appropriate mitigative measures will be used during
excavation activities to minimize the resuspension of dust particles. Excavation will continue until a
FER\CRU5\KMG\ROD\SEC-9.ROD\Deconber 11. 1995 3:34pm 9-2
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a
a:
o
o
o
o
o
1/1
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FEMP-05ROD-6 FINAL
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certification sampling program indicates with reasonable confidence that the concentrations of
contaminants at the entire site are statistically less than the final remediation levels. Excavated areas
will be regraded, backfilled (as necessary) and a vegetative cover reestablished. Environmental and
worker health and safety monitoring will be provided during excavation activities.
Figure 9-1 indicates the need for substantial excavation activities in the former production area.
Consequently, a necessary integration of remedial activities must take place between Operable Units 3
and 5. The excavation of soil within this area must be properly sequenced with building demolition
activities. It is envisioned that the excavation of contaminated soil will take place coincidental with
building foundation and subsurface utility removals. The specific sequencing of remedial activities
will be developed during the remedial action phase of the project.
Excavated soil will be placed into an on-property engineered disposal facility using conventional
construction equipment. The facility will be situated at a location on the FEMP property which
exhibits the best available geology. A field investigation is currently underway to establish the best
location for the disposal facility. The disposal facility will be designed such that the contents are
placed at or above grade with minimal potential for human or biotic intrusion. The disposal facility
design will include an engineered lining and capping system to minimise water infiltration and provide
for the long-term protection of the Great Miami Aquifer. Contaminant-specific waste acceptance
criteria have been established for the disposal facility (see Section 9.2). Soil exhibiting contaminant
concentrations that exceed these waste acceptance criteria will be shipped off site for disposal.
Off-site disposal will be conducted consistent with the terms of the Amended Consent Agreement and
EPA's Off-Site Rule (see Appendix B.5.1 of the Operable Unit 5 FS Report (DOE 1995a). In the
event off-site disposal capacity becomes unavailable or cost prohibitive, physical or chemical
techniques will be examined to treat the soil to attain the waste acceptance criteria. Approval will be
sought from EPA before the application of any soil treatment technology.
The selected remedy consists of the following key components for soil and sediment:
• Performance of a verification sampling program to establish the specific horizontal and
vertical boundaries of required excavation to attain the final remediation levels.
FER\CRU5\NMG\ROD\SEC-9.ROD\Deconber 11, 1995 3:34pm 9-4
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• Excavation of site soil and sediment to the extent necessary to attain the final remediation
levels. Excavation will be performed in such a manner as to minimize the potential
short-term impacts to human health and the environment through the implementation of
mitigative measures such as dust suppression and storm water run-on/runoff control.
• Performance of a certification sampling program following excavation activities to
demonstrate that the final remediation levels have been attained.
• Application of DOE's as low as reasonably achievable (ALARA) principles through the
use of hand-held instruments to support the verification sampling and excavation
processes. To the extent economically practical, detection limits achievable with
hand-held instruments will be used to reduce the final remediation level for on-property
soil containing relatively nonleachable forms of uranium from 80 ppm to 50 ppm.
• Establishment of waste acceptance criteria for the on-property disposal facility (see
Section 9.2) for Operable Unit 5 materials. These criteria include a maximum waste
acceptance criteria of 1030 ppm of total uranium for the on-property disposal facility.
• Transportation and on-property disposal of excavated material attaining the waste
acceptance criteria.
• Transportation and off-site disposal of excavated material exceeding the waste acceptance
criteria. For soil that exceeds the waste acceptance criteria due to the presence of
nonradiological constituents, cost-effective treatment (e.g., thermal desorption) will be
applied in order for the soil to meet the criteria. If deemed necessary for excavated
materials or water treatment residuals that exceed the waste acceptance criteria for
radiological constituents, treatment will be applied in order for the material to meet the
criteria.
• Continuation of efforts to examine and apply, where practical, emerging technologies
pertaining to treatment of soil and sediment. These technologies will include potential
methods to reduce the quantity of material requiring disposal in the on-property facility
provided they are demonstrated to be cost effective and implementable. Engineering
studies will be performed on two emerging technologies to assess their viability for
application to the Operable Unit 5 remedy: soil amendment with phosphate additives and
physical separation techniques.
• Continuation of efforts to examine and apply, where practical, throughout the duration of
remedial activities, new methods or technologies to mitigate environmental releases
occurring as a result of the implementation of remedial actions.
• Site-wide restoration of impacted areas following excavation and certification sampling.
Restoration will include regrading to blend with the surrounding topography and to
promote positive drainage, seeding, fencing, and reestablishment of wetlands, as required.
• Operable Unit 5 soil and sediment excavation and interim storage will be conducted
consistent with the requirements of the EPA-approved Removal Action 17 Work Plan
(Improved Storage of Soil and Debris) until such time as the appropriate Operable Unit 5
remedial design is approved by EPA. The Operable Unit 5 remedial design deliverable
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December 15, 1995
addressing soil management practices during remedial action will contain the final strategy
for excavation and interim storage/staging of contaminated materials originating from
Operable Unit 5. At that point, Removal Action 17 will be terminated and soil and
sediment excavation activities will be conducted in accordance with the approved remedial
design plan.
• Based on historical process knowledge and soil contaminant concentration levels identified
through the Operable Unit 5 remedial investigation, six geographic areas of the FEMP
have been identified where a reasonable potential exists for the presence of soil that
qualifies as RCRA characteristic waste (see Table 9-1) and provides a reasonable
opportunity for treatment. Within these six geographic areas, additional efforts will be
made to identify and segregate for treatment (as needed) the soil that qualifies as RCRA
characteristic waste. As soil is excavated from within these areas based upon exceedances
of final remediation levels, follow-up analytical testing will be performed to determine if
the soil demonstrates a RCRA characteristic. If the soil does not demonstrate a RCRA
characteristic and it satisfies the on-property numerical waste acceptance criteria it will be
placed hi the disposal facility. If a representative volume of the soil hi question
demonstrates a characteristic it will be preferentially segregated for treatment (to remove
the characteristic property) before disposition either on or off site. DOE, EPA, and
OEPA agree that sufficient existing data and historical process knowledge are available to
identify the boundaries of the six geographic areas as those that represent a reasonable
opportunity for cost-effective soil treatment. Outside of these geographic areas, DOE,
EPA, and OEPA all concur that there is no reasonable basis to conclude that an increased
potential for the presence of RCRA characteristic waste exists that would provide
additional opportunity for cost-effective soil treatment. Therefore, outside the boundaries
of the six geographic areas, no additional analytical data will be required to screen for the
presence of characteristic waste before placement in the disposal facility. Treatment is
expected to involve EPA-approved stabilization technologies (for inorganic constituents) or
low temperature thermal destruction techniques (for organic constituents), as necessary.
The EPA's toxicity characteristic leaching procedure (TCLP) will be used to guide the
identification of material requiring treatment from within the boundaries of the six
geographic areas. The remedial design effort will provide the details of 1) the statistical
and testing protocols necessary to establish representative soil volumes requiring
treatment; 2) the treatment processes to be employed; and 3) the procedures for verifying
the treatment's effectiveness.
• A best management approach will also be applied during all excavation activities to
identify, segregate (and treat as necessary) soil containing concentrations of organic
compounds at levels that potentially could jeopardize the integrity of the earthen liners
that are built into the on-property disposal facility. To accomplish this objective, DOE
will employ hand-held organic vapor analyzers during the excavation process to identify
material exhibiting elevated concentrations of organic compounds. The materials so
identified will be preferentially segregated and treated before on-property disposal.
Treatment is expected to involve EPA-approved low temperature thermal destruction
FER\CRU5\NMG\ROD\SEC-9.ROD\Deeonber 15, 1995 12:25pm
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TABLE 9-1
RCRA CHARACTERISTIC SOIL AREAS DESIGNATED FOR IDENTIFICATION,
SEGREGATION, AND TREATMENT*
Area Description
Justification
Inactive HWMUs to be Closed Under CERCLA:
Abandoned sump west of pilot
plant
Non-HWMU Areas:
Sump contents failed TCLP for metals. Barium exceeded the 20 times
rule* at a soil sample depth of 10-10.5 ft.
Area between KC-2 warehouse and Several samples showed surficial contamination for lead exceeding the
railroad tracks 20 times rule.
Trap range
Paddys Run streambank: fill
material west of silos
Scrap metal pile area
RI data showed that lead contamination from lead shot exceeds the 20
times rule.
RI data indicated that concentrations of the following constituents may
exceed the 20 times rule: lead, nitrobenzene, hexachloroethane,
hexachlorobutadiene, hexachlorobenzene, heptachlor, and heptachlor
epoxide.
Surficial soil samples exceeded the 20 times rule for toxaphene,
heptachlor, methoxychlor, heptachlor epoxide, endrin and lead.
Area north of maintenance building Subsurface samples exceeded the 20 times rule for vinyl chloride,
endrin, heptachlor, heptachlor epoxide, endrin, and lead.
'Areas for which RCRA characteristic testing and soil treatment (if needed) will be implemented to satisfy the
regulatory preference for treatment contained in Section 264.552 of the CAMU Rule. These areas were
identified based on process knowledge and existing data obtained through the Operable Unit 5 remedial
investigation, and represent locations where sufficient quantities of material may be present to consider cost-
effective treatment.
"The "20 times rule" is a conservative suggestion in EPA guidance whereby soil with contaminant
concentrations numerically exceeding 20 times the TCLP limit is considered to have increased potential to
demonstrate a RCRA characteristic.
FER\CRU5\NMG\ROD\SEC-9.ROD\December IS, 1995 12:26pm
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FEMP-05ROD-6 FINAL
December 15, 1995
techniques and the EPA's TCLP will be used as the benchmark for determining the extent
of treatment necessary before disposal. The remedial design effort will outline the
specific testing protocols for employing the hand-held organic vapor analyzers and
verifying the effectiveness of treatment.
• In the event the Site Treatment Plan developed under the Federal Facilities Compliance
Act identifies treatment technologies other than low temperature thermal destruction that
may be appropriate for the treatment of organic compounds in soil, such alternate
technologies will be considered and evaluated during remedial design.
9.1.2 Perched Water
Perched water zones presenting an unacceptable threat (i.e., having a cross-media impact to the Great
Miami Aquifer that would produce concentrations in groundwater exceeding the existing or proposed
MCLs) to the underlying aquifer will be excavated with the contaminated soil. Excavation will take
place using conventional excavation equipment. Perched water zones requiring excavation as part of
the selected remedy are included in Figure 9-1 which delineates the projected footprint of excavations
for soil and sediment. Considerations associated with the excavation, staging and soil transportation
process are as discussed above for soil and sediment. Excavated subsurface soil removed to address
perched water may, if necessary, be temporarily staged at an appropriate location to permit excess
liquids to drain. Such drainage and water collected during perched water zone removal will be
transferred to the advanced wastewater treatment facility for treatment before discharge. Collected
perched water containing volatile organic compounds will be directed through a carbon absorption
treatment system (or equivalent) located at the advanced wastewater treatment facility. Perched water
collected during excavation at the fire training area and the sludge drying beds at the sewage
treatment plant will be segregated and pretreated, if necessary, to address any listed hazardous wastes
before joining the remaining FEMP wastewater streams. The perched water collected during
excavation from the vicinity of the fire training area and the sludge drying beds (both facilities are
designated RCRA-listed waste management units) will be pretreated to avoid introducing RCRA-listed
hazardous wastes into the main water treatment processes at the FEMP's advanced wastewater
treatment facility. The residuals resulting from this pretreatment step will be managed as RCRA-
listed hazardous waste.
Excavated subsurface soil will be placed into an on-property disposal facility. Subsurface soil
exhibiting contaminant concentrations which exceed the waste acceptance criteria for the disposal
facility will shipped off site for disposal. Considerations for the on-property disposal of contaminated
material are as previously discussed for soil and sediment.
FER\CRU5\NMG\ROD\SEC-9.ROD\Deconber 11, 1995 3:34pm 9~8
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In the event field conditions preclude the ability to effectively implement the excavation option to
address a given perched water zone, limited application of pumping or trenching may be used to
attain necessary remediation levels.
The selected remedy consists of the following key components for perched water:
• Excavation of perched water zones necessary to ensure the continued protection of the
regional groundwater aquifer.
• Disposition of the excavated soil generated during the removal of the impacted perched
zones in a manner consistent with the methods defined for soil.
• Treatment, as required, of contaminated perched water and storm water collected during
excavation operations.
9.1.3 Regional Groundwater Aquifer
Areas of the Great Miami Aquifer exceeding final remediation levels (see Section 9.2) will be
restored through extraction methods. The areas of the aquifer requiring remediation are identified in
Figure 9-2. Modeling conducted to support the FS identified the need for 28 extraction wells
distributed across the affected areas of the aquifer. These 28 wells are divided into four extraction
well systems and are identified in Figure 9-3. The final number and configuration of these extraction
wells will be established during remedial design.
The FEMP presently has an extraction well network located at the leading edge of the South Plume,
installed as part of a removal action. These wells are an integral part of the required recovery well
system for the selected remedy. The FEMP is in the process of installing additional extraction wells
hi the South Field that are part of the system contemplated by the selected remedy.
Modeling conducted to date suggests that a combined maximum pumping rate of 4000 gpm from the
extraction well system will be required for up to 27 years to fully attain the final remediation levels
throughout all portions of the aquifer. The DOE has committed, as part of the selected remedy, to
examine enhancement technologies to improve the extraction well system described in the FS. One
such technique is reinjection of treated or clean water into the aquifer to enhance the flushing effect.
Such a technique may reduce the projected time period to achieve full aquifer restoration.
Enhancement techniques will be examined during remedial design and will be applied only with the
specific approval of EPA.
HER\CRU5\NMG\ROD\SEC-9.ROD\Deconber 11. 1995 3:34pm 9-9
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ADMINISTRATIVE
^ '• r~ BOUNDARY FOR
\ AQUIFER RESTORATION
0 500\1000 2900 FEET
LEGEND:
• EXISTING EXTRACTION WELL
FEMP BOUNDARY
REGIONAL GROUNDWATER
FLOW DIRECTION
FINAL
AREAS ABOVE URANIUM
CLEANUP LEVEL
PADDYS RUN
ROAD SITE
PLUME
FIGURE 9-2. AREAS OF THE GREAT MIAMI AQUIFER REQUIRING REMEDIATION
9-10
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2
UJ
o
§
o
o
o
o
o
0
o
o
o
cr
ct
cc
cc
UJ
N
CC
LEGEND
F INAL
SYSTEM 1
EXTRACTION WELL
SYSTEM 2
EXTRACTION WELL
A SYSTEM 3
EXTRACTION WELL
SYSTEM 4 EXISTING
EXTRACTION WELL
FIGURE 9-3. PROJECTED EXTRACTION WELL LOCATIONS
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December 15, 1995
The selected remedy consists of the following key components for regional groundwater:
• Extraction of contaminated groundwater until such time as final remediation levels are
attained at all points in the impacted areas of the Great Miami Aquifer.
• Performance of an engineering study to examine the viability of applying reinjection
techniques to enhance contaminant recovery from the aquifer system; application of
reinjection to groundwater restoration activities where established to be economically and
technically viable.
• Collection of recovered groundwater for treatment and/or discharge to the Great Miami
River or reinjection (if deemed appropriate).
9.1.4 Storm Water/Wastewater
The FEMP maintains a storm water collection system which includes conveyance systems and
retention basins. This system is designed to prevent contaminated storm water from entering the
SSOD and Paddys Run. As part of the selected remedy, the FEMP will continue to operate this
system until such time as soil final remediation levels are attained on a site-wide basis or until jointly
deemed unnecessary by DOE and EPA.
Sanitary and process wastewater continue to be generated at the FEMP as a result of the occupancy of
the site by the work force and due to ongoing cleanup initiatives such as building decontamination.
Additionally, process wastewater is expected to be generated as a consequence of the implementation
of remedial actions for Operable Unit 5 and the other four operable units. The FEMP will continue
to collect and direct this wastewater for treatment, as necessary, as part of the selected remedy.
The selected remedy includes the following key components for storm water and wastewater:
• Collection of contaminated storm water, using the existing FEMP retention basin, as
necessary during the implementation of site-wide remedial, actions to minimize discharges
of contaminants to Paddys Run and the resultant impacts to the regional aquifer.
Sedimentation sludges from the basin will be dewatered to the extent necessary and placed
into the on-property disposal facility. In the event a portion or all of these sludges exceed
the waste acceptance criteria for the disposal facility they will be transported off the site
for disposal at an appropriate facility. Sludge treatment will be applied only with the
approval of EPA.
• Collection and treatment, as required, of wastewater generated during the conduct of
remedial actions at all FEMP operable units.
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9.1.5 Treatment of Discharges
The FEMP will construct and operate the treatment facilities necessary to attain mass-based discharge
limits to the Great Miami River. Storm water, wastewater and groundwater will be treated in existing
and expanded facilities such that the monthly average concentration in the combined discharges to the
river does not exceed the final remediation levels for surface water hi Paddys Run or the Great Miami
River (see Section 9.2). Additionally, treatment will be applied such that the total mass and blended
effluent concentration of uranium discharged to the Great Miami River does not exceed 600 pounds
per year or 20 ppb, as further defined below. Available wastewater treatment capacity will be applied
first to highest concentration streams to effectively minimize the concentration and mass of uranium
present in the blended effluent discharged to the Great Miami River.
Treatment will be applied to storm water, wastewater and recovered groundwater to the extent
necessary to limit the total mass of uranium discharged through the FEMP outfall to the Great Miami
River to 600 pounds per year and to ensure that the levels necessary to ensure the protection of
human health (i.e., 530 ppb total uranium outside the mixing zone) for concentrations of uranium and
other COCs hi the Great Miami River are not exceeded. This mass-based discharge limit will become
effective upon issuance of the ROD. Additionally, the necessary treatment will be applied to these
streams to limit the concentration of total uranium hi the blended effluent to the Great Miami River to
20 ppb. The 20 ppb discharge limit has been adopted as a performance-based requirement of the
selected remedy as it is considered reasonably attainable with the application of a sensible and cost-
effective level of treatment. The 20 ppb discharge limit for uranium will be based on a monthly
average and will become effective January 1, 1998.
The FEMP will be allowed to by-pass storm water directly from the site's storm water retention basin
to the river for up to 10 days per year to accommodate periods of significant precipitation. The intent
of allowing the by-pass of these flows is to provide the relief needed during periods of excessive
precipitation when the quantities of storm water exceed retention and treatment capacities. The
uranium concentration hi the blended discharge during these 10 days will be considered hi the 600
pound per year mass-based limit, but will not be included hi the monthly averaging for purposes of
demonstrating compliance with the 20 ppb performance-based concentration limit. Uranium
concentrations hi the effluent discharged to the river for these 10 days will not permit an exceedance
of the final remediation level (530 ppb total uranium outside the mixing zone) for the river.
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Notification will be provided to EPA and OEPA within seven days of the implementation of such a
direct by-pass.
Additionally, needed relief from the discharge limits will be provided to the FEMP to accommodate
scheduled treatment plant maintenance activities. The uranium concentration in the blended discharge
during these periods will be considered in the 600 pound per year mass-based limit. EPA approval
will be obtained hi advance when notification of these planned maintenance periods is accompanied by
a request that the uranium concentrations in the discharge not be considered in the monthly averaging
performed to demonstrate compliance with the 20 ppb limit.
To attain these mass-based and concentration-based discharge limits, DOE has committed to
expanding the design capacity of the existing advanced wastewater treatment facility by a minimum of
an additional 1800 gpm. Schedules for designing and constructing this additional treatment capacity
will be defined as part of the RD/RA process. The process for reporting and instituting corrective
measures for the groundwater extraction and treatment systems, in the event discharge limits are
exceeded, will be established as part of remedial design.
Treatment sludges will be placed into the on-property disposal facility to the extent they attain the
waste acceptance criteria for the facility. Sludges not attaining the waste acceptance criteria will be
transported off site for disposal. Off-site disposal will be conducted consistent with the terms of the
Amended Consent Agreement and EPA's Off-Site Rule. In the event off-site disposal capacity
becomes unavailable or cost prohibitive, physical or chemical techniques will be examined to treat the
sludges to attain the waste acceptance criteria. Approval will be sought from EPA before the
application of any sludge treatment technology.
The selected remedy includes the following key components for treatment of discharges:
• Treatment of collected storm water, wastewater, and recovered groundwater before
discharge to the Great Miami River to the extent necessary so as not to exceed final
remediation levels for surface water hi the Great Miami River.
• Treatment of the necessary wastewater, storm water and groundwater to ensure that the
maximum annual mass discharge of uranium to the Great Miami River from the FEMP
effluent does not exceed 600 pounds. The 600 pound per year discharge limit for
uranium will become effective upon issuance of the ROD.
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• Treatment of the necessary wastewater, storm water and groundwater to ensure that the
maximum concentration of total uranium in the blended effluent discharged to the Great
Miami River does not exceed 20 ppb based upon a monthly average concentration. This
limit will become effective January 1, 1998.
• Expansion of the advanced wastewater treatment facility within the confines of existing
Building 51. This expansion will have a minimum additional design capacity of 1800
gpm. Utilization of this treatment capacity to first address the highest concentration
wastewater streams to effectively minimize the concentration and mass of uranium present
hi the blended effluent discharged to the river.
• Disposal of treatment sludges generated from site wastewater, storm water and
groundwater treatment activities which meet the waste acceptance criteria hi the
on-property disposal facility. Conventional sludge thickening and dewatering techniques
will be applied to the sludges to the extent necessary to facilitate placement hi the
on-property disposal facility.
• Disposal of treatment sludges which do not attain the waste acceptance criteria for the
on-property disposal facility at an appropriate off-site disposal facility.
9.1.6 Measures to Minimize Environmental Impacts
All practical measures will be employed to minimize environmental impacts during implementation of
the Operable Unit 5 remedial action. DOE has factored environmental impacts into the
decision-making process for the remedial action as discussed below.
Measures to minimize environmental impacts to on-property natural resources (e.g., wildlife and
wildlife habitat, wetlands, floodplains, surface water, groundwater) have been identified hi the final
Operable Unit 5 FS Report and Proposed Plan. Remedial activities are not expected to alter flow
patterns or uses of the 100- and 500-year floodplain of Paddys Run at the FEMP. The
implementation of engineering and/or natural controls (e.g., silt fences and hay bales) will minimize
indirect impacts such as runoff and sediment deposition to the floodplain.
Impacts to on-property vegetation and wildlife habitat will result from the removal of contaminated
soil and sediment and construction of support facilities. Approximately 115 acres of on-property
grassland will be impacted and later restored by revegetation.
Approximately 7.5 acres of early to mid-successional woodlands, 16.5 acres of riparian habitat along
1375 feet of Paddys Run, and 50 acres of pine plantation will be impacted. These impacts will be
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offset by implementing mitigative measures such as revegetation with native tree species in
consultation with appropriate federal and state agencies.
Because habitat of the Sloan's crayfish, listed as threatened in Ohio, could be impacted from
increased sediment load into Paddys Run, control measures will be used to minimize the impact of
sediment deposition to Sloan's crayfish habitat. If necessary, Sloan's crayfish will be relocated
upstream of remedial activities hi pooled sections of Paddys Run.
A total of approximately 10 acres of wetlands will be impacted as a result of the implementation of
the Operable Unit 5 remedial action. Mitigation for wetland impacts will be determined using the
Section 404 (b)(l) guidelines of the Clean Water Act. The need for compensatory mitigation will be
determined after all practicable steps to avoid and minimize adverse impacts to wetlands have been
applied.
To avoid impacts to cultural resources, Phase 1 and 2 archaeological surveys will be performed to
determine the presence of historic and prehistoric (archaeological) sites eligible for the National
Register of Historic Places. If a remedial action is found to have an adverse impact, consultation with
the Advisory Council on Historic Preservation and the State Historic Preservation Office would be
required under the National Historic Preservation Act, Section 106, process. If an adverse impact to
a cultural resource cannot be avoided, a memorandum of agreement or programmatic agreement
would be negotiated among the Advisory Council, the State Historic Preservation Office, and DOE
which will identify mitigative measures.
The natural resource Trustees for the FEMP site include the Department of the Interior, DOE, and
OEPA. The Trustees' role is to act as guardian for natural resources at or near the FEMP site that
may have been injured as a result of a release of a hazardous substance or an oil spill. Negotiations
with the Trustees are ongoing. Input from the Trustees is anticipated to be factored into the natural
resource mitigation activities contemplated by the Operable Unit 5 selected remedy.
9.1.7 Institutional Controls/Monitoring
One element of the selected remedy that will be used to ensure protectiveness is institutional controls,
including continued access controls at the site during the remediation period, alternate water supplies
to affected residential and industrial wells, continued federal ownership of the disposal facility and
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necessary buffer zones, and deed restrictions to preclude residential and agricultural uses of the
remaining regions of the FEMP property. Additionally, proper notifications, as mandated by
CERCLA, will be provided before the transfer of any federal real property which is known to contain
or have been used hi the processing of hazardous substances. These measures will minimize the
potential for human exposure to contaminated soil and groundwater during the implementation of
site-wide remedial actions, and to the contaminated material contained hi the on-property disposal
facility following completion of remedial activities at the site. Specific institutional control measures
to be implemented at the site will be established during the remedial design and remedial action
processes.
The Fernald Citizens Task Force issued recommendations regarding future use of the FEMP property
hi May of 1995. The Task Force recommended that the area of the FEMP containing the disposal
facility and associated buffer zone remain under the continued ownership of the federal government.
Additionally, the Task Force recommended that the remaining portions of the FEMP property be
made available for the uses that are deemed most beneficial to the surrounding communities. The
Task Force encouraged DOE to consult with the local communities to establish their preferences for
future use and ownership of these areas of the site. Consistent with this recommendation, the DOE
will work with the local communities during remedial design on establishing a final land use and
ownership plan for the FEMP property. An institutional control plan, focused on specifying the
short-term (i.e., during remedy implementation) and long-term institutional control measures to be
applied at the site, will be developed during remedial design to complement this final land use plan.
Long-term environmental monitoring will also be conducted as part of the selected remedy. This
monitoring will be designed to detect and quantify, to the extent practical, releases from the site
attributable to the implementation of remedial actions and will include monitoring of the air, surface
water and groundwater pathways. Monitoring devices providing real-time or near real-time data will
be evaluated and applied, if practical. Monitoring will also be conducted following the completion of
remedial actions to assess the continued performance of the remedy; groundwater monitoring will be
continued for, at a minimum> the area of the disposal facility. The type and frequency of monitoring
activities will be established during remedial design, with necessary modifications to the program
applied during or following remedy implementation.
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Long-term maintenance will be provided as part of the selected remedy for the on-property disposal
facility to ensure the continued protectiveness of the remedy. Additionally, reviews will be conducted
every five years by EPA to evaluate the effectiveness of the remedy and the continued attainment of
the media-specific final remediation levels (see Section 9.2). If, upon such review, it is the judgment
of EPA that additional action or modification of remedial actions is appropriate in accordance with
Section 104 or 106 of CERCLA, DOE may be required to implement additional actions or modify the
existing action.
The selected remedy includes the following key components for institutional controls and monitoring:
• Continuation of access controls at the FEMP, as necessary, during the conduct of
remedial actions. Property ownership will be maintained by the federal government of the
area comprising the disposal facility and associated buffer areas.
• Maintenance of remaining portions of the FEMP property (outside the disposal facility ,
area) under federal ownership or control (e.g., deed restrictions) to the extent necessary to
ensure the continued protection of human health commensurate with the cleanup levels
established by the remedy. If portions of the FEMP property are transferred or sold at
any future time, restrictions will be included in the deed, as necessary, and proper
notifications will be provided as required by CERCLA.
• Maintenance of the on-property disposal facility will be performed to ensure its long-term
performance and the continued protection of human health and the environment.
• Conduct an environmental monitoring program during and following remedy
implementation to assess the short- and long-term effectiveness of remedial actions.
• Provision of an alternate water supply to domestic, agricultural and industrial users
relying upon groundwater from the area of the aquifer exhibiting concentrations of
contaminants exceeding the final remediation levels. The alternate water supply will be
provided until such time as the area of the aquifer impacting the user is certified to have
attained the final remediation levels.
9.1.8 Corrective Action Management Unit Rule
The CAMUs and Temporary Units (TUs) Final Rule (58 FR 8658 et seq., Vol. 58, No. 29,
February 16, 1993, codified at 40 CFR §260.10 and 40 CFR §264.552) was promulgated to meet the
objectives of a cleanup program under RCRA, as amended. Management of remediation (and
investigation) waste within a CAMU is not subject to the strict RCRA Subtitle C requirements.
Specifically, waste management activities within a CAMU are not subject to LDRs and MTRs. As
defined at 40 CFR §260.10, remediation waste includes "all solid and hazardous wastes, and all
media (including groundwater, surface water, soil, and sediment) and debris, which contain listed
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hazardous wastes, or which themselves exhibit a hazardous waste characteristic that are managed for
the purpose of implementing corrective action requirements ... under RCRA." Remediation waste
"may originate only from within the facility boundary, but may include waste ... [from] releases
beyond the facility boundary" (i.e., on site under CERCLA).
The CAMU rule is identified as an applicable requirement for Operable Unit 5 (Appendix B,
Table B.3). The seven criteria stated at 40 CFR §264.552(c) were used to designate the CAMU for
the selected remedy (see Appendix B, Section B.I of the Operable Unit 5 FS Report.) The
boundaries of the CAMU are designated to be coincident with the FEMP property boundaries and
encompass the on-property engineered disposal facility. Consolidation or management of on-site
remediation wastes into or within the CAMU will not constitute the creation of a unit subject to
MTRs [OAC 3745-68-011 and 265.301(a)] and will not invoke LDRs (OAC 3745-59 and
40 CFR §268.40 through .44).
Site-specific risk-based concentration standards have been employed to establish 1) final remediation
levels to determine the extent of remediation, and 2) waste acceptance criteria of the on-property
engineered disposal facility for consolidation of those remediation wastes which are to be managed on
property. These site-specific remedial action objectives and cleanup levels are defined for the selected
remedy in Section 9.2. The design, groundwater detection and closure requirements for the
engineered on-property disposal facility will be finalized through the Operable Unit 2 remedial design
process.
DOE, EPA, and OEPA reviewed remedial investigation data and site process knowledge to determine
if areas of soil exhibiting a RCRA characteristic could be identified which offered a reasonable
opportunity for the application of a cost-effective level of treatment before disposal. This review was
conducted to farther satisfy the regulatory preference for treatment contained in Section 264.552 of
the CAMU rule. The review identified six geographic areas of the FEMP where a reasonable
potential exists for the presence of RCRA characteristic waste in soil. These areas are summarized in
the remedy description for soil provided in Section 9.1.1. Recognizing that a protective remedy has
been selected for Operable Unit 5 soil, coupled with the desire on the part of DOE, EPA and OEPA
to satisfy the regulatory preference for treatment, consensus has been reached by DOE, EPA, and
OEPA that these six geographic areas represent the locations where a reasonable opportunity exists
for cost-effective treatment of RCRA characteristic soil. DOE is committed to identifying,
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segregating and treating, as necessary, contaminated soil from within the six geographic areas that
exhibits one or more RCRA characteristics. Additional details of this commitment and the procedures
for its implementation are provided in Section 9.1.1. As a result of the commitment to identify and
treat RCRA characteristic soil from the six designated geographic areas, no significant quantities of
RCRA characteristic wastes from Operable Unit 5 are envisioned to be disposed of in the on-property
disposal facility.
The Operable Unit 5 remediation waste that is destined for on-property disposal may contain these
listed RCRA constituents (shown with their waste codes): methylene chloride (F002),
tetrachloroethylene (F002), toluene (F005), trichloroethylene (F002), 1,1,1-trichloroethane (F002),
and xylene (F003). Under the provisions of the CAMU rule, these constituents will not be placed in
the on-property disposal facility at concentration levels that exceed the health-protective waste
acceptance criteria levels established for each constituent. Materials that are contaminated above the
waste acceptance criteria for the listed constituents will either be 1) treated to meet the criteria or 2)
shipped off site for disposal.
9.1.9 Cost
Table 9-2 presents the estimated costs for the selected remedy. The construction costs include:
verification surveys to establish the boundaries of excavation; the excavation of contaminated soil and
sediment; storm water controls; installation of the groundwater extraction system; expansion of the
FEMP wastewater treatment facility; construction of the on-property disposal facility; and
backfilling/regrading following attainment of final remediation levels. Operations and maintenance
costs include: the labor, materials, fuel, utilities, chemicals and parts required to operate and
maintain remedial systems; and transportation and disposal of contaminated materials.
Postremediation costs include: the decontamination and demolition of remediation facilities;
decontamination and free-release of equipment; and long-term monitoring.
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TABLE 9-2
ESTIMATED COSTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Construction $430,000,000
Operation & maintenance $340,000,000
Postremediation $ 70.000.000
Total cost (in constant 1995 dollars) $840,000,000
Present-worth cost $580,000,000
Total cost with escalation $2,110,000,000
Table 9-2 presents the estimated cost of the selected remedy in three different manners; total cost,
present worth cost, and total cost with escalation. The total cost of the remedy ($840,000,000)
represents the total amount, in constant 1995 dollars, necessary to implement the selected remedy
assuming no escalation or inflation occurs over the life of the remedy. The present worth cost
($580,000,000) represents the total estimated present worth cost of the remedy assuming a discount
rate of 2.8 percent. The present worth cost represents the sum of money which must be placed into a
bank at the onset of remedial activities at an interest rate of 2.8 percent to progressively pay for the
entire scope and duration of remedial actions. The total cost with escalation ($2,110,000,000)
represents the total estimated cost of remedial actions assuming that funding is provided on an annual
basis and an annual escalation rate of 3.7 percent prevails throughout the duration of the remedy.
9.1.10 Community Involvement
The DOE and EPA are committed to continuing the active community involvement program currently
in place at the FEMP throughout the duration of remedial activities at the site. This program will
include: public meetings; public comment periods (as needed); newsletters; tours; and small focused
group sessions assessing specific cleanup issues.
9.2 REMEDIAL ACTION OBJECTIVES AND CLEANUP LEVELS
Remedial action objectives were developed in accordance with the NCP and EPA guidance with the
intention of setting goals to ensure the protection of human health and the environment. The
objectives are designed to mitigate the potential adverse effects of site contaminants present in
environmental media.
FER\CRU5\NMG\ROD\SEC-9.ROD\Deconber 11, 1995 3:J4pm 9-21
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FEMP-05ROD-6 FINAL
December 15, 1995
The remedial action objectives for Operable Unit 5 include eliminating, or reducing to acceptable
levels, the potential for human or ecological receptors to come into contact with contaminated
environmental media and prevention of off-property migration of contaminants in excess of the
contaminant-specific final remediation levels. From these objectives, final remediation levels were
developed for each of the environmental media to ensure that remedial actions reduce the projected
risk to humans and ecological receptors to protective levels consistent with anticipated future uses of
the land or water.
While it is not the intent of this decision document to establish a future land use for the FEMP
property, final remediation levels have been defined as part of the selected remedy for each of the
environmental media. These final remediation levels establish the permissible concentration of
contaminants which could remain at the site following the completion of remedial actions. The
remaining (or residual) concentrations of these contaminants will present a potential for exposure and
risk to future users of the FEMP. The degree of exposure and risk associated with these remaining
concentrations would be directly linked to the type and duration of future land use of the facility.
Future land uses contemplating more direct contact for longer intervals, such as residential farming,
would be expected to yield a higher calculated exposure and risk than would future uses which
involve less opportunities for long-term exposure, such as recreational use of the FEMP.
The Fernald Citizens Task Force has made the following recommendations for consideration by the
DOE regarding the future use of the FEMP property:
• The area of the FEMP containing the disposal facility and associated buffer zone remain
under the continued ownership of the federal government
• The remaining portions of the FEMP property be made available for uses that are
the most beneficial to the surrounding communities
• Any agricultural or residential uses of the FEMP property be prohibited.
Consistent with these recommendations, the final remediation levels presented in Tables 9-3 through
9-6 have been designed to attain the following postremediation risk levels:
• A carcinogenic risk level of 10"5 and a HI of 1 to an off-property farmer
FER\CRU5\NMG\ROD\SEC-9.RDD\Decanber 12, 1995 10:33«n 9-22
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-3
FINAL REMEDIATION LEVELS FOR SOIL
Constituent
Radionudides (pCi/g)
Cesium-137+ld
Neptunium-237 + Id
Lead-210+2d
Plutonium-238
Plutonium-239/240
Radium-226+8d
Radium-228+ld
Strontium-90+ld
Technetium-99
Thorium-228+7d
Thorium-230
Thorium-232+10d
Uranium, total (^=325 L/kg*) (ppm)
Uranium, total (K^IS L/kg") (ppm)
Chemicals (mg/kg)
Acetone
Antimony
Aroclor-1254
Aroclor-1260
Arsenic
Barium
Benzene
Benzo(a)anthracene
Benzo{a)pyrene
Benzo{b)fluoranthene
Benzo(k)fluoranmene
Beryllium
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
Boron
Bromodichloromethane
Bromoform
Bromomethane
Cfit^nrfi
Carbazole
Carbon disulfide
Carbon tetrachloride
On-Property
Final Remediation Levels
1.4 x 10°
3.2 x 10°
3.8 x 101
7.8 x 101
7.7 x 101
1.7 x 10°
1.8 x 10°
1.4 x 101
3.0 x 101
1.7 x 10°
2.8 x 102
1.5 x 10°
8.2 x 101
2.0 x 101
4.3 x 104
9.6 x 101
1.3 x 10-1
1.3 x 10'1
1.2 x 101
6.8 x 10*
8.5 x 102
2.0 x 101
2.0 x 10°
2.0 x 101
2.0 x 102
1.5 x 10°
4.2 x 102
8.2 x 102
7.4 x 103
4.0 x 10°
3.1 x 101
8.2 x 103
8.2 x 101
1.2 x 101
' 5.0 x 103
2.1 x 10°
Off-Property
Final Remediation Levels
8.2 x 10-1
4.9 x ID"1
2.2 x 10°
9.3 x 10°
9.0 x 10°
1.5 x 10°
1.4 x 10°
6.1 x 10'1
1.0 x 10°
1.5 x 10°
8.0 x 10l
1.4 x 10°
5.0 x 101
NA
4.3 x 10'1
6.1x 10'1
4.0 x 10'2
4.0 x 10'2
9.6 x 10°
1.2 x 102
4.3 x 10-1
1.6 x 10"1
9.0 x 10-2
1.6 x ID"1
9.0 x lO"2
6.2 x 10'1
2.0 x lO'1
2.6 x 101
4.0 x 10°
1.8 x 10-1
1.6 x 10°
2.4 x 10'2
9.1 x 10"1
3.1 x 10°
6.2 x 10°
9.1 x 10-2
FER\CRU5WMG\ROD\SEC-9.ROD\Decemb€a- 12, 1995 10:33im 9-23
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-3
(Continued)
Constituent
Chemicals (Cont) (rag/kg)
Chlordane
Chlorobenzene
Chloroform
Chromium VI
Chrysene
Cobalt
Copper
Cyanide
Dibenzo(a,h)anthracene
3 ,3 '-Dichlorobenzidine
1 ,2-Dichloroethane
1 , 1-Dichloroethene
Dieldrin
Di-n-octylphthalate
Ethylbeazene
Fluoride
Heptachlorodibenzofuran
Heptachlorodibenzo-p-dioxin
Indeno(l ,2,3-cd)pyrene
Lead
Manganese
Mercury
Methyl-2-pentanone
Methylene chloride
4-Methylphenol
Molybdenum
Nickel
4-Nitroanaline
N-nitrosodiphenylamine
N-nitrosodipropylamine
Octachlorodibenzofuran
Octachlorodibenzo-p-dioxin
Pentachlorophenol
Selenium
Silver
Tetrachloroethene
Thallium
On-Property
Final Remediation Levels
1.9 x 10'1
3.4 x 102
4.5 x 101
3.0 x 102
2.0 x 103
7.4 x 102
2.2 x 10s
1.2 x 10s
2.0 x 10°
5.5 x 10'1
1.6 x 10"1
4.1 x 10'1
1.5 x l
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-3
(Continued)
On-Property Off-Property
Constituent Final Remediation Levels Final Remediation Levels
Chemicals (Cont) (mg/kg)
Toluene 1.0 x 10s 2.7 x 101
Tributyl phosphate 2.5 x 102 2.9 x 10°
1,1,2-Trichloroethane 4.3 x 10° 1.9 x 10'1
Trichloroethene 2.5 x 101 1.5 x 10°
Vanadium 5.1 x 103 5.8 x 101
Vinyl chloride 1.3 x 10'1 2.3 x 10'3
Xylenes, total 9.2 x 105 4.0 x 102
Zinc 1.2 x 105 8.2 x 101
a K! = leaching coefficient
FER\CRU5\NMG\RDD\SEC-9.RDD\Deccmber 12. 1995 10:33«m 9-25
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FEMP-OSROD-6 FINAL
December 15, 1995
TABLE 9-4
FINAL REMEDIATION LEVELS FOR GREAT MIAMI AQUIFER GROUNDWATER
Constituent Final Remediation Levels
Radionudides (pCi/L)
Neptunium-237(+Id) 1.0 x 10°
Radium-226(+8d) 2.0 x 101
Radium-228(+ld) 2.0 x 101
Strontium-90(+Id) 8.0 x 10°
Technetium-99 9.4 x 101
Thorium-228(+7d) 4.0 x 10°
Thorium-230 1.5 x 101
Thorium-232+(10d) 1.2 x 10°
Uranium, total (mg/L) 2.0 x 10'2
Chemicals (mg/L)
Alpha-chlordane 2.0 x 10'3
Antimony 6.0 x 10'3
Aroclor-1254 2.0 x 10"4
Arsenic 5.0 x 10'2
Barium 2.0 x 10°
Benzene 5.0 x 10'3
Beryllium 4.0 x 10'3
Bis(2-chloroisopropyl)ether 5.0 x 10"3
Bis(2-ethylhexyl)phthalate 6.0 x 10'3
Boron 3.3 x 10'1
Bromodichloromethane 1.0 x 10*1
Bromomethane 2.1 x 10"3
Cadmium 1.4 x W2
Carbazole 1.1 x 10'2
Carbon disulfide 5.5 x 10'3
Chloroethane 1.0 x 10'3
Chloroform 1.0 x 10'1
Chromium VI 2.2 x 10'2
Cobalt 1.7 x 10'1
FER\CRUS\ROD\MCM\9 3.1BL\Decanber 12. 1995 10:33«m 9-26
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-4
(Continued)
Constituent
Final Remediation Levels
Chemicals (Cont) (mg/L)
Copper
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane
Fluoride
Lead
Manganese
Mercury
Methylene chloride
4-Methylphenol
Molybdenum
Nickel
Nitrate
4-Nitrophenol
Octachlorodibenzo-p-dioxin
Selenium
Silver
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Trichloroethene
Vanadium
Vinyl chloride
Zinc
1.3 x 10°
2.8 x 10'1
7.0 x lO'3
5.0 x 10'3
8.9 x lO'1
2.0 x 10'3
9.0 x 10"1
2.0 x lO'3
5.0 x lO'3
2.9 x 1C'2
1.0 x 10-1
1.0 x 10-1
1.1 x 101
3.2 x lO"1
1.0 x Itr7
5.0 x 10-2
5.0 x 10-2
1.0 x 10-5
5.0 x 1(T3
3.8 x 10-2
2.0 x 10-3
2.1 x ID'2
FER\CRU5\ROD\MCM\9 S.TBIADeconber 12, 1995 10:33im
9-27
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-5
FINAL REMEDIATION LEVELS FOR SURFACE WATER IN PADDYS RUN AND THE
GREAT MIAMI RIVER*
Constituent Final Remediation Levels
Radionuclides (pCi/L)
Cesium-137+ld 1.0 x 101
Neptunium-237+ld 2.1 x 102
Lead-210+2d 1.1 x 101
Plutonium-238 2.1 x 102
Plutonium-239/240 2.0 x 102
Radium-226+8d 3.8x10'
Radium-228+ld 4.7 x 101
Strontium-90+ld 4.1 x 101
Technetium-99 1.5 x 102
Thorium-228+7d 8.3 x 102
Thorium-230 3.5 x 103
Thorium-232+10d . 2.7 xlO2
Uranium, total (mg/L) 5.3 x 10'1
Chemicals (mg/L)
Alpha-chlordane 3.1 x 1CT*
Antimony 1.9 x 10'1
Aroclor-1254 2.0 x 10"4
Aroclor-1260 2.0 x Iff4
Arsenic 4.9 x 10'2
Barium 1.0 x 102
Benzene 2.8 x 10'1
Benzo(a)anthracene 1.0 x 10"3
Benzo(a)pyrene 1.0 x 10"3
Beryllium 1.2 x 1(T3
Bis(2-chloroisopropyl)ether 2.8 x 10'1
Bis(2-ethylhexyl)phthalate 8.4 x 10'3
Bromodichloromethane 2.4 x 10'1
Bromomethane 1.3 x 10°
Cadmium 9.8 x 10'3
Chloroform 7.9 x 10'2
FER\CRU5\ROD\MCM\9 S.TOLXDeccmber 12, 1995 10:33«m 9-28
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TABLE 9-5
(Continued)
FEMP-05ROD-6 FINAL
December 15, 1995
Constituent
Final Remediation Levels
Chemicals (Cont.) (mg/L)
Chromium VI
Copper
Cyanide
Dibenzo(a,h)anthracene
3,3-Dichlorobenzidene
Di-n-butylphthalate
1,1-Dichloroethene
Dieldrin
Di-n-octylphthalate
Fluoride
Lead
Manganese
Mercury
Methylene chloride
4-Methylphenol
Molybdenum
Nickel
Nitrate
4-Nitrophenol
Selenium
Silver
Tetrachloroethene
1,1,1 -Trichloroethane
1,1,2-Tricholoroethane
Vanadium
Zinc
The point of compliance is outside the mixing zone.
1.0 x 10'2
1.2 x ID"2
1.2 x 10'2
1.0 x 10'3
7.7 x 10"3
6.0 x 10°
1.5 x 10"2
2.0 x 10'5
5.0 x lO'3
2.0 x 10°
1.0 x 10'2
1.5 x 10°
2.0 x lO"4
4.3 x 10"1
2.2 x 10°
1.5 x 10°
1.7 x 10'1
2.4 x 103
7.4 x 103
5.0 x 10'3
5.0 x lO"3
4.5 x 10'2
1.0 x 10'3
2.3 x lO'1
3.1 x 10°
1.1 x 10'1
EER\CRU5\ROD\MCM\9 3.TBL\December 12. 1995 10:33un
9-29
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE
FINAL REMEDIATION LEVELS FOR SEDIMENT
Constituent Final Remediation Levels
Radionuclides (pCi/g)
Cesium-137(+ld) 7.0x10°
Neptunium-237(+ld) 3.2 x 101
Lead-210(+2d) 3.9 x 102
Plutonium-238 1.2 x 103
Plutonium-239/240 1.1 x 103
Radium-226(+8d) 2.9 x 10°
Radium-228(+ld) 4.8 x 10°
Strontium-90(+ld) 7.1 x 103
Technetium-99 2.0 x 105
Thorium-228(+7d) 3.2 x 10°
Thorium-230 1.8 x 104
Thorium-232(+10d) 1.6x10°
Uranium, total (mg/kg) 2.1 x 102
Chemicals (mg/kg)
Aroclor-1254 6.7 x 10"1
Aroclor-1260 6.7 x 10"1
Arsenic 9.4 x 101
Benzo(a)anthracene 1.9 x 102
Benzo(a)pyiene 1.9 x 101
Benzo(b)fluoranthene 1.9 x 102
Benzo(k)fluoranthene 1.9 x 103
Beryllium 3.3 x 101
Bis(2-ethylhexyl)phthalate 5.0 x 103
Bromofonn 1.6 x 102
Cadmium 7.1 x 101
Carbazole 6.3 x 101
Chromium VI 3.0 x 103
Chrysene 1.9 x 10*
Cobalt 3.6 x 104
IndenoCl.l^-cd^pyrene 1.9 x 102
FER\CRU5\ROD\MCM\9 3.1BL\December 12, 1995 10:33«m 9-30
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-6
(Continued)
Constituent Final Remediation Levels
Chemicals (Cont.) (mg/kg)
Manganese 4.1 x 102
4-Methyl-2-pentanone 2.1 x 103
N-Nitrosodiphenylamine 2.6 x 102
Phenathrene 3.0 x 10'3
Thallium 8.8 x 101
FER\CRU5\ROD\MCM\9 3.TBL\Deconber 12, 1995 10:33«n 9-31
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FEMP-05ROD-6 FINAL
December 15, 1995
• A carcinogenic risk level of 10"6 and a HI of 1 for recreational users of the FEMP property
• A carcinogenic risk level of 10*6 and a HI of 1 for trespassers in the disposal facility area.
The final remediation levels for the individual carcinogenic contaminants presented in Table 9-3 for
on-property soil represent the 1 x 10"6 BLCR level to a hypothetical undeveloped park user. For the
noncarcinogenic constituents, the final remediation levels for each constituent present in on-property
soil represent a concentration equivalent to a HQ of 0.2 to a hypothetical undeveloped park user. As
identified hi Table 9-3, final remediation levels are presented for on-property soil for uranium present
hi both leachable and relatively nonleachable forms. Soil exhibiting relatively leachable forms of
uranium have been detected within the former production area beneath the retired processing
buildings. For on-property soil exhibiting less leachable forms of uranium, the final remediation level
is 82 ppm of uranium. For soil exhibiting these less leachable forms of uranium, the selected remedy
has adopted an ALARA goal of 50 ppm of uranium in soil. The FEMP will apply available hand-
held instruments to help guide excavation and assist hi identifying any isolated areas of higher
contamination to help attain this ALARA goal.
The final remediation levels for off-property soil represent the 1 x 10"5 ILCR level (3.5 x 10'5 for
uranium) to the resident fanner receptor for individual carcinogenic constituents. The final
remediation levels for noncarcinogenic constituents potentially present in off-property soil represent
the concentration equivalent to a HQ of 0.2 to a resident fanner receptor.
It should be noted that the constituents identified hi Table 9-3 for on and off-property soil are not
uniformly distributed across the site. Available data indicate that many of these constituents are
exclusively located hi soil within the former production area close to the generating source.
Verification and certification sampling programs conducted as part of remediation will be designed to
accommodate the relative spatial distribution of each of these site-introduced contaminants.
Operable Unit 5 is the fourth of the five FEMP operable units to proceed through the remedy
selection process. The three FEMP operable units (i.e., 1, 2 and 4) preceding Operable Unit 5
similarly established soil remediation levels hi their RODs for the constituents of concern occurring
within the respective boundaries of these source operable units. The final remediation levels hi these
RODs were derived on the basis of operable unit-specific information regarding the physical,
chemical, radiological and geochemical characteristics of the contaminants and the environmental
FER\CRU5\ROD\MCM\9 S.TBUDeccmber 12. 1995 ll:17«n 9-32
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FEMP-05ROD-6 FINAL
December 15, 1995
setting in which they reside. Where the final soil remediation level for a specific constituent
established through the Operable Unit 5 remedy decision process is more restrictive (i.e., lower) than
that defined in an individual ROD for Operable Units 1, 2 or 4, the final Operable Unit 5 remediation
level will serve as the soil cleanup criteria within the boundary of the source operable unit.
The final remediation levels for the Great Miami Aquifer (Table 9-4) represent the Safe Drinking
Water Act MCLs or, in the absence of MCLs, the 1 x 10"5 BLCR or HQ of 0.2 values for individual
constituents through the drinking water pathway. The final remediation levels for surface water and
sediment (Tables 9-5 and 9-6) represent the 1 x 10"6 ILCR or HQ of 0.2 values for individual
constituents to recreational users of surface water resources or consumers of meat and milk
irrigated/watered with flows from the Great Miami River and/or Paddys Run.
Additionally, a key component of the remedy is the establishment of waste acceptance criteria for the
on-property disposal facility. These criteria are defined in Table 9-7. The waste acceptance criteria
were derived to establish mass-based or activity-based operational limits for soil or sludge
contaminant concentrations to ensure the long-term protection of the Great Miami Aquifer underlying
and downgradient of the on-property disposal facility. The waste acceptance criteria were derived to
ensure that the water quality in those portions of the aquifer potentially impacted by the on-property
disposal facility do not exceed the groundwater final remediation levels over the long term.
Several of the RCRA constituents shown in Table 9-7, including a number of the RCRA organic
solvents, do not have a calculated waste acceptance criteria value (i.e., indicated as solubility or pure
product in the tables) because the modeling simulations show that these constituents do not have the
capability to exceed designated Great Miami Aquifer action levels within the 1000-year simulation
period, regardless of the starting concentrations for these constituents in the disposal facility.
It is recognized that for the organic solvents shown in the tables, the mass balance approach applied
in the modeling for determining the waste acceptance criteria does not consider the potential
deleterious effects that full-strength solvents can have on the earthen material comprising the disposal
facility liners or the underlying native clays. Full strength solvents have been proven to cause
shrinking of clays with a resulting potential for increases in clay liner permeability. As a best
management practice for these compounds, the FEMP acknowledges that it cannot place any RCRA
FER\CRU5\ROD\MCM\9 S.TBLVDeconber 12, 1995 ll:17«m 9~33
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FEMP-05ROD-6 FINAL
December 15, 1995
TABLE 9-7
OPERABLE UNIT 5 ON-PROPERTY DISPOSAL FACILITY
WASTE ACCEPTANCE CRITERIA
Constituent of Concern Maximum Concentration
Radionuclides: (pCi/g)
Neptunium-237 3.12 x 109
Strontium-90 5.67 x 1010
Tecnnetium-99 2.91 x 101
Total uranium - (mg/kg) 1.03 x 103
Organics (mg/kg):
1,2-Dichloroethane *
Carbazole 7.27 x 104
Bis(2-chlorisopropyl)ether 2.44 x Itf2
Alpha-chlordane 2.89 x 10°
Bromodichloromethane 9.03 x 10"1
4-Nitroaniline 4.42 x 10"2
Chloroethane" 3.92 x 10s
1,1,1-Trichloroethane11 *
1,1 -Dichloroethane* *
Carbon tetrachloride" *
Chloroform" *
Methylene chloride* *
Chloromethane" *
Vinyl chloride" 1.51 x 10°
Tetrachloroethene" 1.28 x 102
Trichloroethene" 1.28 x 102
1,1-Dichloroethene" 1.14 x 101
1,2-Dichloroethene" 1.14 x 101
Acetone" *
Benzene" *
Endrin" *
Ethylbenzene" *
Heptachlor" *
FER\CRU5\NMG\ROD\SEC-9.ROD\Deconber 12. 1995 ll:17«m 9-34
-------
TABLE 9-7 FEMP-05ROD-6 FINAL
(Continued) December 15, 1995
Constituent of Concern Maximum Concentration
Organics (Cont.) (mg/kg):
Heptachlor epoxide* *
Hexachlorobutadiene* *
Methoxychlor* *
Methyl ethyl ketone* *
Methyl isobutyl ketone" *
Toluene* *
Toxaphene" 1.06x10*
Xylenes* *
Inorganics (mg/kg):
Boron IXMxlO3
Mercury* 5.66 x 10*
Chromium VF *
Barium* *
Lead* *
Silver1 *
* RCRA-based constituent of concern
* Denotes compounds that will not exceed designated Great Miami Aquifer action level within
1000-year performance period, regardless of starting concentration in the disposal facility.
EER\CRU5\NMG\ROD\SEC-9.ROD\December 12, 1995 ll:17«m 9-35
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FEMP-05ROD-6 FINAL
December 15, 1995
COCs into the disposal facility at concentrations that are incompatible with the clay liners or the
underlying native clays beneath the liners. To track these concentrations during the excavation
control surveys, the FEMP will rely on field screening methods to identify the soil that is
contaminated with RCRA organics. This soil will be segregated for treatment before placement in the
on-property disposal facility or shipped for off-site disposal.
FER\CRU5\NMG\ROD\SEC-9.ROD\Decanber 12, 1995 ll:17an 9-36
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FEMP-05ROD-6 FINAL
December 15, 1995
10.0 STATUTORY DETERMINATIONS
In accordance with the statutory requirements of Section 121 of CERCLA, remedial actions taken at a
CERCLA site pursuant to Sections 104 and 106 must:
• Protect human health and the environment
• Comply with all ARARs established under federal and state environmental laws (or justify a
waiver)
• Be cost-effective
• Use permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable
• Satisfy the statutory preference for treatment as a principal element to permanently and
significantly reduce the toxicity, mobility, and volume of hazardous wastes (or explain why
this preference cannot be satisfied).
CERCLA Section 121(c) also requires the use of five-year reviews to determine if adequate protection
of human health and the environment is being maintained in those instances where remedial actions
result in hazardous substances remaining on site above health-based levels.
The subsections below summarize the basis for determining that the selected remedy for Operable
Unit 5 achieves the CERCLA Section 121 statutory requirements listed above.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected site remedy is designed to achieve target land use objectives upon completion of the
cleanup. The target land use objectives provide the basis for establishing receptor-specific, health-
protective remediation levels for each environmental media pathway comprising Operable Unit 5.
These objectives also provide the basis for determining the institutional controls necessary to maintain
the intended land use following completion of the cleanup. For the off-property area, full unrestricted
use represented by residential fanning (the predominant land use of the surrounding area) was
selected as the target land use objective. On property, a restricted use represented by an undeveloped
park was selected as the target land use objective.
FER\CRU5\MCM\ROD\SECT-10.ROD\December 12, 1995 10:35«m 10-1
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FEMP-O5ROD-6 FINAL
December 15, 1995
The following subsections describe how the risks posed through each environmental media pathway
(soil and sediment, perched groundwater, Great Miami Aquifer groundwater, and surface water) will
be eliminated, reduced, or controlled by the components of the selected site remedy and thereby
protect human health consistent with the target land use objectives.
In addition to human health requirements, the selected remedy is protective of the environment
because it addresses all concerns identified by the ecological risk assessment and will achieve all
ecological benchmark toxicity values for all media upon completion of the remedy. A certification
sampling program will be conducted to ensure that the benchmark toxicity values are met following
completion of the remedy and achievement of human-health-protective goals.
10.1.1 Soil and Sediment
The selected site remedy protects human health through.excavation of soil and sediment contaminated
above established final remediation levels that are protective of the undeveloped park user (on
property) and the residential fanner (off property). Following excavation, the soil and sediment will
be placed hi an on-property disposal facility that will remain under institutional control by the federal
government. Soil and sediment that are contaminated above waste acceptance criteria for the disposal
facility will be shipped off site.
For the on-property area (land use represented by the undeveloped park), the selected remedy protects
human health by reducing ILCR levels for individual contaminants to 1 x 10"*, and cumulative risk for
all contaminants to between 1 x 10~* to 1 x 10"6. Similarly, a cumulative HI of less than 1 will be
achieved for all contaminants that present a noncarcinogenic health threat. These risk levels are
within the health-protective range specified by the NCP.
For the off-property area (land use represented by residential fanning), the selected remedy protects
human health by reducing ILCR levels for uranium to 3.5 x 10*5 and the HQ for uranium to less
than 1. Based on the findings of the RI/FS, site-introduced contaminants other than uranium are not
present hi off-property soil and sediment at concentrations requiring remedial action. (Therefore, the
selected remedy reduces the HI to less than 1 as well). Verification sampling will be conducted as
part of the selected remedy to confirm this finding and certify that additional off-property excavation
is not required. In the event that additional contaminants are detected, risk levels consistent with
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those established for uranium (HQ less than 1 and an ILCR hi the range of 1 x 10"4 to 1 x 10"5) will
be applied to each individual contaminant to determine the extent of additional excavation necessary.
Institutional controls will be employed as part of the remedy to maintain the on-property area for
appropriate postremediation uses. Consistent with the recommendations of the Fernald Citizens Task
Force, the actual designated land use for the on-property area outside of the disposal facility (if
different from the representative scenario used to guide the development of remediation levels) will be
decided following completion of the remedy, achievement of on-property remediation goals, and
planning input from the local citizenry. Upon completion of the remedy and determination of
appropriate land use, any deed restrictions will be assigned. The disposal facility area will remain
under federal ownership with access restrictions.
The final remediation levels for soil and sediment are also protective of human health through cross-
media pathways of exposure and will protect the Great Miami Aquifer over the long term at levels
consistent with Safe Drinking Water Act MCLs or, in the absence of MCLs, 1 x 10~5 ILCR and
HI = 0.2 levels for individual contaminants.
10.1.2 Perched Groundwater
Perched groundwater zones that are contaminated above levels protective of the underlying Great
Miami Aquifer will be excavated concurrently with contaminated soil. The health-protective levels
and resultant excavation limits established for the perched groundwater zones are intended to prevent
cross-media impacts to the underlying Great Miami Aquifer at levels consistent with Safe Drinking
Water Act MCLs or, in the absence of MCLs, 1 x 10"5 ILCR and HQ=0.2 levels for individual
contaminants. All of the contaminated perched groundwater zones requiring action reside on property
and are accounted for hi the excavation footprints for soil. The cleanup levels established for soil
take into account cross-media pathways of exposure through the perched groundwater system and will
be used to ensure that the perched groundwater zones that pose an unacceptable risk to the Great
Miami Aquifer are successfully remediated.
10.1.3 Great Miami Aquifer
The selected remedy is designed to reduce existing contaminants hi the Great Miami Aquifer to levels
below the MCLs (including the proposed MCL for uranium) stipulated in the Safe Drinking Water
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Act, or, in the absence of MCLs, to levels providing an ILCR of 1 x 10~5 and a HQ = 0.2 for
individual contaminants.
As discussed above, soil and perched groundwater zone excavation will address cross-media impacts
to the Great Miami Aquifer and eliminate the potential for future recontamination of the aquifer.
During the time that active restoration of the aquifer takes place, alternate water supplies will continue
to be provided to affected water users (i.e., those users whose supplies are contaminated with uranium
above the proposed 20 ppb MCL).
Following certification that cleanup goals are met, all areas of the aquifer will have been restored to
levels that potentially allow unrestricted use. However, consistent with the target land use objective
for the on-property area (restricted use as an undeveloped park), institutional control measures will be
implemented, as necessary, to prevent the use of the aquifer as an on-property drinking water supply.
At all off-property locations the aquifer will be available for full beneficial use, including use as a
drinking water supply, following completion of the remedy.
The performance standards for the on-site disposal facility also have a direct bearing on the long-term
protection of the aquifer. The waste acceptance criteria established for the facility are formulated to
be protective of the aquifer over a targeted 1000-year performance period. Consistent with the cross-
media-based remediation levels established for soil, the waste acceptance criteria for the disposal
facility will protect the aquifer by not allowing the introduction of contaminants into the aquifer at
levels above Safe Drinking Water Act MCLs or, in the absence of MCLs, 1 x 10"5 ILCR and HQ =
0.2 levels for individual contaminants.
10.1.4 Surface Water
Surface water resources of the site (Paddys Run and the Great Miami River) will not require direct
remediation as a consequence of the selected remedy. Paddys Run is a pathway for contaminant
migration and the Great Miami River a receiving body for treated water discharges from the FEMP's
water treatment operations. Final remediation levels are established for surface water to delineate
protective requirements for the discharge of treated storm water, groundwater, and remediation
wastewater to the Great Miami River and to control runoff to Paddys Run. These final remediation
levels are protective of surface water receptors (represented by recreational users of the river and
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consumers of meat and milk products derived from cattle that directly consume surface water) at a
cumulative ILCR of between 1 x 10"4 and 1 x KT6 and a HI of less than 1.
Storm water runoff control will continue throughout the site remediation time period. Collected storm
water, wastewater generated during remediation, and extracted groundwater will be treated in the
advanced wastewater treatment facility before discharge to the Great Miami River. As a result of
treatment, the total uranium mass loading to the river will not exceed 600 pounds per year, and a
monthly average discharge limit of 20 ppb (as stipulated in Section 9.1.5) and in-stream final
remediation levels of 530 ppb will not be exceeded. Although a health-protective limit (530 ppb total
uranium measured outside the mixing zone) was established, the total uranium discharge limit (20 ppb
measured at the outfall to the Great Miami River) has been adopted as a performance-based
requirement because it is considered attainable with the existing and planned modifications to the
FEMP's advanced wastewater treatment facility.
10.1.5 Cumulative Risks from all Media Pathways
A comprehensive site-wide risk assessment was conducted to verify that the Operable Unit 5 remedy,
in conjunction with the selected or leading alternatives from the other four operable units, will
provide for the protection of human health over the long term, considering the collective contributions
of residual risks from all environmental media pathways. The assessment demonstrated that the site-
wide remedy for the FEMP will result in a total residual ILCR of 2.1 x 10"5 and a total HI of 0.05
for the undeveloped park user from all pathways of exposure.
10.1.6 Risks During Remedy Implementation
There will be no unacceptable short-term risks during remedy implementation. Appropriate controls
for air emissions and surface water runoff will be incorporated into the design of the remedy to
minimize short-term impacts and the potential for contaminant release during construction. Health
and safety measures will be employed as appropriate to minimise risk to workers during
implementation. Site monitoring will track the effectiveness of remedy implementation control
measures.
10.2 COMPLIANCE WITH ARARS
Under Section 121 (d)(l) of CERCLA, remedial actions must attain standards, requirements, or
criteria that are "applicable or relevant and appropriate" (i.e., ARARs) under the circumstances of the
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release at a site. All ARARs will be met upon completion of the selected remedy, with the exception
of two OEPA solid waste disposal facility siting criteria (contained hi OAC 3745-27-07 and -20) that
restrict the siting of a disposal facility over a high yield and/or a sole-source aquifer regulated under
the Safe Drinking Water Act. A waiver to the OAC 3745-27-07 and -20 requirements is necessary in
order to locate the on-property disposal facility over the Great Miami Aquifer.
A definitive list of the ARARs and TBC criteria that will be attained by the selected remedy is
provided in Appendix B, organized by chemical-specific, location-specific, and action-specific
requirements. The justification supporting issuance of an ARAR waiver to the OAC 3745-27-07
and -20 solid waste disposal facility siting restrictions is provided below. EPA grants the waiver and
concurs with DOE that the selected remedy will attain a standard of performance equivalent to that
required by the ARAR being waived, hi accordance with the ARAR waiver provisions provided by
the NCP (40 CFR 300.430).
10.2.1 Solid Waste Disposal Facility Siting Requirements
The contaminated soil to be excavated and placed in the on-property disposal facility as part of the
selected remedy is considered by OEPA to be solid waste. The OEPA disposal facility siting criteria
from Ohio solid waste disposal regulations are pertinent ARARs for on-property disposal.
OAC 3745-27-07 and -20 list the following areas where a solid waste disposal facility may not be
located:
• In surface and subsurface areas surrounding a public water supply well through which
contaminants may move toward and may reach the public water supply well within a period
of five years
• Above an aquifer declared by the federal government under the Safe Drinking Water Act to
be a sole-source aquifer
• Above an unconsolidated aquifer capable of sustaining a yield of 100 gallons per minute for
a 24-hour period to an existing or future water supply well located within 1000 feet of the
limits of solid waste placement
• In a regulatory floodplain
• Within 1000 feet of an existing water supply well or developed spring
• Within 300 feet of the facility's property line
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• Within 1000 feet of an existing residence whose owner has not consented in writing to the
location of the facility
• Within 200 feet of a stream, lake, or wetland
• The isolation distance between the uppermost aquifer system and the bottom of the
recompacted soil liner of the disposal facility cannot be less than IS feet of in situ or added
geologic material.
The proposed feasible location of the on-property disposal facility is on the eastern side of the FEMP
which is not: in a floodplain; near a stream, lake, or wetland; within 1000 feet of an existing water
supply well or developed spring; near enough to an existing public water supply well so that
contaminants may reach the well within a period of 5 years. The facility will not be placed within
300 feet of the FEMP property line or within 1000 feet of an existing residential house. The isolation
distance between the uppermost aquifer system and the bottom of the recompacted soil liner will be
greater than 15 feet.
The remaining two siting criteria (bullets two and three) cannot be met because of the FEMP's
location over a sole-source aquifer that is capable of sustaining a yield of 100 gallons per minute for a
24-hour period. OEPA has established two specific policies (GD202.101 and GD202.102) that
identify conditions that would be acceptable to allow an exemption to the siting criteria. While these
policies state that several factors will be considered hi evaluating an exemption, the specific factors
identified indicate that the protection of human health and the environment should be provided solely
by the existing hydrogeologic conditions. This has been reaffirmed by OEPA hi several meetings.
The primary hydrogeologic standards established by these policies are:
• Significant thickness of low permeable material between the disposal facility and the aquifer
• Lack of niter-connection between the sole-source aquifer and any significant zones of
saturation
• Significant amount of sediment [soil] between the disposal facility and the high-yield aquifer
to prevent leachate from migrating to the high-yield aquifer during the life of the landfill
and the post-closure care period. The post-closure care period for a solid waste landfill is a
minimum of 30 years [OAC 3745-17-14(A)].
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It has been determined, based on existing hydrogeologic information, that the existing hydrogeologic
conditions at the FEMP do not fully meet these conditions. This is based on the possibility that some
granular soils are interbedded in the till and the need to protect the aquifer for significantly longer
than 30 years (at least for 200 years; an ARAR under 40 CFR 192).
Because the aquifer underlies the entire site, a waiver was requested to locate an on-property disposal
facility on the FEMP. The waiver request was based on the ability of the selected remedial action,
through the use of another method or approach, to attain a standard of performance that is equivalent
to that required by the ARARs. The criteria in determining a CERCLA ARAR waiver based on an
equivalent standard of performance [40 CFR 300.430 (f)(l)(ii)(C)(4)] are: degree of protection, level
of performance, reliability into the future, and time required for results.
10.2.2 Equivalent Standard of Performance
The preamble to the NCP states that the purpose of this waiver is for the use of alternative but
equivalent technologies and comparison based on risk is only permitted where the original standard is
risk-based. The Ohio exemption guidance, with its focus on geological conditions, is for the most
part analogous to a technology standard but also appears to be, with respect to level of performance,
risk and technology based. Therefore the following analysis of the CERCLA waiver criteria uses a
technology-based comparison, except for level of performance, which is a risk-based comparison.
The circumstances of the selected alternative are considered equivalent to the OEPA requirements and
thereby warrant the granting of a CERCLA ARAR waiver. The basis for equivalency is identified for
each of the identified criteria:
Degree of protection:
• OEPA standard
The justification to allow a solid waste landfill over a high-yield sole-source aquifer is that
the existing hydrogeology will provide adequate protection to the high-yield sole-source
aquifer from the effects of a release of leachate and thereby protect the aquifer from
contamination. The approach spelled out by the pertinent policies is to prevent leachate
from reaching the aquifer during the active life of the landfill and the postclosure period of
30 years. The active life of the disposal facility for Operable Unit 5 wastes is estimated to
be 22 years.
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Equivalent standard
The combination of engineering controls and existing hydrogeology proposed in this
alternative will provide the same degree of protection to the aquifer as the hydrogeologic
conditions described in the OEPA policy alone. Modeling with the combined controls
shows that the leachate will not reach the aquifer during the active life of the landfill and a
postclosure period of 30 years.
It should be noted that the modeling performed hi the Operable Unit 5 FS Report
(Appendix F) was performed for 1000 years and assumed that the liner system and
man-made materials (e.g., leachate collection, leak detection, and synthetic liners) of the
disposal facility would fail. This modeling showed that with the enhanced cap to reduce
infiltration and the existing hydrogeology, leachate that may eventually reach the aquifer
will not cause the constituent concentrations in the aquifer to exceed the promulgated and
proposed MCLs.
Level of performance (method based):
• OEPA standard
Significant thickness of low permeable material between the disposal facility and the aquifer
• Equivalent standard
Modeling has shown that the combination of 20 feet of gray clay with a minimum Kj of
3.1 L/kg and a maximum waste acceptance criteria of 346 pCi/g of uranium-238 or
1030 ppm total uranium will not exceed the proposed MCL for total uranium at the
boundary of the disposal facility or a concentration level based on the 10"6 ILCR at the
boundary of the FEMP. Only the layers hi the engineered cap and the gray clay and
unsaturated Great Miami Aquifer hydrogeologic layers were used hi this modeling. The
liner system and brown clay will increase the protection of the aquifer.
• OEPA standard
Lack of interconnection between the sole-source aquifer and any significant zones of
saturation
• Equivalent standard
Any interconnections will be minimized by:
1) Locating the disposal facility hi an area with the greatest thickness of gray clay and the
least occurrence of interbedded granular material; and
2) Providing an increase hi die engineered controls to compensate for any reduction of
protection due to interbedded granular material; and/or
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3) Providing engineering control of lateral movement of water in an area of interbedded
granular material by removing the granular material affecting the geologic protection of
the aquifer or by preventing the movement of water from these areas to the aquifer.
• OEPA standard
Significant amount of sediment (soil) must exist between the disposal facility and the high-
yield aquifer to prevent leachate from migrating to the high-yield aquifer during the life of
the landfill and the postclosure care period. The postclosure care period for a solid waste
landfill is a minimum of 30 years [OAC 3745-27-14(A)].
• Equivalent standard
At a minimum, a total of four additional layers will be added to the standard solid waste
cap and liner [OAC 3745-27-08(C)]. These layers are a sand filter, biotic barrier and
bentonite composite layers in the cap to reduce infiltration and to protect the integrity of the
cap. A leak-detection layer will be provided in the liner to monitor the integrity of the
containment system and to provide early warning to allow corrective action prior to any
adverse impact to die aquifer. These additional engineering controls together with the
natural hydrogeology will prevent leachate from reaching the aquifer during the postclosure
care period.
Level of performance (risk based):
• OEPA standard
ORC 3734.01(G) allows exemptions of OEPA regulations if an alternative is unlikely to
adversely affect the public health or safety or the environment. The pertinent policies
mirror mis requirement using an approach which requires existing hydrogeologic conditions
to provide this protection.
OEPA does not propose a specific definition for die protection of human health and the
environment. However, OAC 3745-27-10(F)(7)(a)-(d), which specifies solid waste landfill
operating requirements, sets forth concentration levels for constituents detected in the
groundwater for which a corrective action is required. This standard provides an
appropriate framework for risk analysis hi this case because the waiver concerns the
establishment of a solid waste disposal unit. These levels are concentrations that are at a
statistically significant level to be:
- Protective of human health and the environment; and
- The promulgated MCL; or
- Background concentrations for constituents that do not have a promulgated MCL; or
- The alternative groundwater protection standard for a known or suspected
carcinogen, concentration levels that represent a cumulative excess upper-bound
lifetime cancer risk to an individual within the 1 x 10"4 to 1 x 10"6 range.
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Equivalent standard
This same definition has been used as a threshold criteria hi evaluating alternatives in the
CERCLA decision-making process at the FEMP and specifically hi the Operable Unit 5 FS
with the addition that constituents hi groundwater should not be higher than the proposed
MCLs. The selected remedy meets this threshold criteria.
Protection of human health has been determined through the risk assessment process based
on contaminant transport modeling and the NCP-acceptable ILCR range of 1 x 10"4 to
1 x 10"6 and hi compliance with promulgated and proposed MCLs.
Reliability hi the future:
The combination of hydrogeologic and engineering controls (including additional controls beyond the
requirements for a solid waste disposal facility) provides increased reliability into the future because
of the following:
• The biotic barrier hi the cap will prevent burrowing animals or vegetative roots from
compromising the integrity of the cap and thereby increasing the infiltration
• Leak-detection monitoring will provide an early warning of any problem in leachate
containment and allow corrective measures to be undertaken prior to adverse impact to the
aquifer.
Tune required for results:
Construction of a disposal facility with additional engineering controls will not take significantly
longer than the time required for a disposal facility which strictly meets the Ohio Solid Waste
Disposal Regulations.
A CERCLA ARAR waiver of the OEPA prohibition of siting a disposal facility over a high-yield
sole-source aquifer is justified based on an equivalent standard of performance
[40 CFR 300.430(f)(l)(ii)(C)(4)] to the OEPA policies allowing an exemption to the siting
requirements. This waiver is applicable only to Operable Unit 5 on-site remediation wastes. If on-
property disposal is chosen as the selected remedy for other FEMP operable units, separate waivers
from this Ohio requirement would be necessary.
The disposal facility location and design will be subject to review and approval during the remedial
design phase. DOE intends to construct only one disposal facility at the FEMP. Therefore, should
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on-property disposal be selected for additional FEMP operable units, the disposal facility capacity
and location will be adjusted accordingly during the remedial design process.
10.3 COST EFFECTIVENESS
The selected remedy (Alternative 3A) is cost-effective because it has been determined to provide
overall effectiveness proportional to its costs, the net present-worth value being $580 million. Overall
the selected remedy achieves the remedial action objectives established for Operable Unit 5 for the
least cost. The selected remedy represents less man one-third the cost of meeting the cleanup levels
associated with full unrestricted use (Alternative 1).
Alternative 2A proposes the same major elements of remediation as the selected remedy, but is
applied to the resident farmer. The net present-worth cost of this scenario was estimated at
$720 million. Alternative 2A is not considered proportionally cost-effective relative to the difference
in protectiveness of the selected remedy.
Alternative 3C has a projected cost'of $770 million and uses an on-property earthen cover for some
of the contaminated soil, with the contaminated soil that exceeds the on-property waste acceptance
criteria being shipped off site for disposal. The cost for Alternative 3C would be higher than for 3A
and Alternative 3C would be potentially less implementable considering the uncertainty of future off-
site disposal capacity. The engineered disposal facility hi Alternative 3A will provide greater long-
term protectiveness and permanence than consolidation with an earthen cover (Alternative 3C).
Alternative 2C shares the same drawbacks as 3C at even greater expense ($910 million).
Alternatives 4A ($580 million) and 4C ($780 million) are nearly identical hi present-worth costs to
Alternatives 3A ($580 million) and 3C ($770 million), but provide less opportunity for productive use
of the on-property area following remediation. Alternatives 4A and 4C result in the dedication of the
entire 1050-acre on-property area of the FEMP as an access-controlled waste management area,
whereas Alternatives 3A and 3C provide opportunities to make over 90 percent of the on-property
area available for productive use. Alternatives 3A and 3C are therefore more cost-effective compared
to 4A and 4C.
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EPA and DOE have determined that the selected remedy (Alternative 3A) will provide the best
overall effectiveness proportional to its costs and therefore is cost-effective in accordance with
Sections 300.430(f)(l)(i)(B) and (D) of the NCP.
10.4 USE OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT OR RESOURCE
RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
EPA has determined that the selected remedy for Operable Unit 5 uses permanent solutions and
alternative treatment technologies, or resource recovery technologies, to the maximum extent
practicable because it 1) uses state-of-the-art treatment technologies for groundwater, storm water and
wastewater treatment, and 2) incorporates an ongoing commitment on the part of DOE to evaluate and
employ, where cost-effective, emergent technologies for the treatment of soil over the life of the
remedial action. Although the selected remedy for soil is in large part a containment remedy, the
remedy offers the best mix of tradeoffs among the five balancing criteria and further use of existing
treatment technologies (as evaluated in the RI/FS) is not practicable as an alternative to the
on-property containment facility for the soil.
While the selected site remedy for soil does not offer as high a degree of long-term effectiveness and
permanence as the off-site disposal alternative, it will significantly reduce the risks from the
contaminated material through excavation and placement in an engineered on-property disposal
facility. By combining all of the remediation waste into one disposal location, it can be managed
more effectively over the long term.
The selected remedy provides for a reduction of toxicity, mobility, and volume through
treatment for the soil contaminated with RCRA-regulated substances. RCRA-regulated contaminants
present in the soil will be treated as necessary to meet LDR treatment levels before shipment to an
off-site disposal facility (for the soil destined for off-property disposal) or to meet on-property waste
acceptance criteria, including the criterion to treat soil containing RCRA characteristic waste from six
designated geographic areas (for the soil destined for on-property disposal).
The selected remedy will also provide substantial reduction of toxicity, mobility, and volume through
treatment by extracting and selectively treating contaminated groundwater from the Great Miami
Aquifer before discharge to the Great Miami River. In addition, the selected remedy will provide for
the treatment of perched groundwater collected during the excavation of contaminated surface and
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subsurface soils, and storm water and remediation wastewater collected as part of the site-wide
remedial program for the FEMP.
The selected remedy provides adequate short-term effectiveness and is administratively and technically
implementable. The services and materials required to implement this remedy are readily available
and use current technologies. Because die majority of the contaminated soil to be excavated is present
on property within an area under DOE access control, there is little opportunity for public exposure to
the contaminants during the remedial activity. The exposure potential to remediation workers will be
managed hi accordance with a health and safety plan and is, therefore, considered acceptable. The
on-property disposal alternative provides more short-term effectiveness and is more implementable
than off-site disposal.
The major tradeoffs that provide the basis for the selection of on-property disposal (with off-site
disposal of the soil fraction exceeding waste acceptance criteria) are short-term effectiveness,
implementability, and cost. The selected remedy provides the most reliable method of managing and
monitoring the disposal of Operable Unit 5 soil and permanently restoring the affected portions of the
Great Miami Aquifer for the least cost. For this reason, the selected remedy (Alternative 3A) is
determined to be the most appropriate remedy for the contaminated environmental media that
comprise Operable Unit 5.
DOE has considered state and community input hi the selection of Alternative 3A as the remedy for
Operable Unit 5. The selected remedy mirrors the recommendations of the Fernald Citizens Task
Force and has received State of Ohio concurrence. As part of their concurrence hi the selected
remedy, the State of Ohio has requested that DOE agree to certain stipulations for implementation of
the selected remedy (see the OEPA letter hi Appendix A). DOE has incorporated implementation
strategies to address all of the state's stipulations into the remedy description provided hi Section 9.0.
Responses to the state's letter are documented in the Responsiveness Summary.
Many members of the local community are personally opposed to on-property disposal and expressed
their preference for off-site disposal of all of Operable Unit 5*s soil, regardless of cost and
implementability considerations. Other members of the community (including the Fernald Citizens
Task Force) expressed an understanding of the prudence of taking a balanced approach to site
cleanup, noting the disproportionate costs, implementability concerns, and transportation safety
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concerns associated with full off-site disposal. In general, all commentors were in agreement to
restore the Great Miami Aquifer to full beneficial use. While many members of the community
expressed reservations about on-property disposal, the comments received did not identify any specific
technical omissions or errors in the development of the alternatives for Operable Unit 5 or the basis
for selection of the remedy. Therefore, hi light of the remedy selection factors provided by the NCP,
DOE believes the selected remedy, Alternative 3A, is the most appropriate remedy for Operable
Unit 5. Responses to community comments are found in the Responsiveness Summary to this ROD.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The NCP states in 40 CFR 300.430 (a)(iii)(A) and (B) that "EPA expects to use treatment to address
the principal threats posed by a site" and "to use engineering controls, such as containment, for waste
that poses a relatively low long-term threat." From a site-wide perspective, Operable Unit 5 soil is
considered to pose a relatively low long-term threat and will not undergo treatment. The lower
volume, higher toxicity materials from the site's other operable units (e.g., the Operable Unit 4 K-65
silo contents, the Operable Unit 1 waste pit materials, and the Operable Unit 3 nuclear product and
process waste inventories) constitute the principal threat materials at the site, and the majority of these
materials will undergo treatment to meet off-site waste acceptance criteria before being sent for
disposal. EPA has determined that this balanced site-wide approach, wherein the principal threat
materials are sent off site for disposal following necessary treatment to achieve off-site waste
acceptance criteria, meets the statutory preference for remedies that employ treatment as a principal
element.
DOE is entering into a commitment through this ROD to evaluate emerging technologies for the
treatment of soil before placement in the on-property engineered disposal facility. This commitment
extends over the life of the remedy and is focused on identifying cost-effective technologies, should
they become available in the future, that can further enhance the long-term permanence of the on-
property engineered disposal facility. Two technologies (physical separation and phosphate treatment)
have been identified by EPA for initial evaluation by DOE as part of the remedial design process for
the Operable Unit 5 remedy. DOE is committing to an engineering evaluation of these two
technologies for applicability to the Operable Unit 5 remedy before placement of Operable Unit 5 soil
in the engineered disposal facility.
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The Operable Unit 5 remedy includes:
• Treatment of contaminated groundwater collected from the Great Miami Aquifer to health-
protective levels before discharge to the Great Miami River
• Treatment of perched groundwater, intercepted during the excavation of contaminated
surface and subsurface soils, to health-protective levels before discharge to the Great Miami
River
• Treatment of contaminated storm water and remediation wastewater collected from the other
operable units to health-protective levels before discharge to the Great Miami River
• Treatment of soil contaminated with RCRA-regulated substances as necessary for off-site
disposal (soil that exceeds the on-property waste acceptance criteria for radiological
constituents). Additionally, RCRA characteristic wastes located within six geographic areas
designated hi Section 9.0 of this ROD will be treated to the extent necessary to remove the
characteristics that cause them to be regulated before on-property disposal.
Because mis remedy will result in CERCLA hazardous substances remaining on the FEMP site above
health-based levels established for unrestricted use, a review will be conducted at least every five
years after commencement of remedial actions to ensure that the remedy continues to provide
adequate protection of human health and the environment.
10.6 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
Natural resources and associated services will be permanently committed as a result of implementing
the selected remedy for Operable Unit 5. These not onltf include the land and resources, but the
services they provide as well.
Based on the estimated volumes and contaminant concentration levels of soil requiring action,
implementing the selected remedy will permanently commit 137.6 acres of land at the FEMP for
on-property disposal along with 0.5 acre of land at the Clive, Utah Envirocare facility for off-
property disposal.
Approximately 7.5 acres of early to mid-successional woodlands and 50 acres of pine plantation will
be permanently disturbed during soil excavation activities. An example of mitigation activities that
could restore these terrestrial habitats includes the planting of native tree species upon completion of
remedial activities and installation of wildlife boxes to reestablish mammal and bird populations.
FER\CRU5\MCM\KDD\SECT-10.BOD\Deconber 11. 1995 3:38pm 10-16
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FEMP-05ROD-6 FINAL
December 15, 1995
Based on the estimated areas requiring action, remedial activities will impact 9 acres of wetlands
including isolated scrub-shrub/persistent emergent and drainage ditch/swale wetlands. Mitigation for
wetland impacts will be determined using the 404 (b)(l) guidelines of the Clean Water Act. The need
for compensatory mitigation will be determined after all practicable steps to avoid and minimize
adverse impacts to wetlands have been applied. No wetlands or floodplains are present at the off-
property disposal site.
Consumptive use of geological resources (e.g., quarried rock, sand, and gravel) and petroleum
products (e.g., diesel fuel and gasoline) will be required for removal, construction, and disposal
activities. Additional fuel use will result from off-site transport of materials. However, adequate
supplies are available without affecting local requirements for these products.
FER\CHU5ynCM\ROD\SECT-10.ROD\Decanber 11. 1995 3:38pm 10-17
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FEMP-05ROD-6 FINAL
December 15, 1995
REFERENCES
Barnthouse, L.W., G.W. Suter, S.M. Bartell, J.J. Beauchamp, R.H. Gardner, E. Under, R.V. 2
O'Neill and A.E. Rosen, 1986, "User's Manual for Ecological Risk Assessment," No. 2679. Oak 3
Ridge National Laboratory, Environmental Sciences Div., Oak Ridge, TN. 4
Cardwell, R.D., B.R. Parkhurst, W. Warren-Hicks, and J.S. Volosin, 1993, "Aquatic Ecological s
Risk," Water Environment and Technology. Vol. 12, No. 4, pp. 47-51. 6
Consent Decree between Ohio and DOE. Civil Action C-l-86-0217, December 1988, with changes by ?
Stipulated Amended Consent Decree, January 1993. See Vm, 8.2, p. 25. 8
Direction des Substances Dangereuses, 1988, Contaminated Sites Rehabilitation Policy. Gouveraement 9
du Quebec, Ministere de L'Environment, Sainte-Foy, Quebec, Canada. 10
Facemire, C. F., S. I. Guttman, D. R. Osborne, and R. H. Sperger, 1990, "Biological and n
Ecological Site Characterization of the Feed Materials Production Center," FMPC-SUB 018. Prepared 12
for Westinghouse Materials Co. of Ohio, Cincinnati, OH. 13
Grove Engineering, 1988, MicroShield Version 3 Manual. Grove Engineering, Inc., Rockville, MD. u
International Atomic Energy Agency, 1992, Effects of Ionizing Radiation on Plants and Animals at is
Levels Implied by Current Radiation Protection Standard. IAEA, Vienna, Austria. ie
Long, E.R. and L.G. Morgan, 1991, "The Potential for Biological Effects of Sediment-Sorbed n
Contaminants Tested in the National Status and Trends Program," NOAA Technical Memorandum n
NOS OMA 52. National Oceanic and Atmospheric Administration, Seattle, WA. 19
Mahon, D.C., 1982, "Uptake and Translocation of Naturally Occurring Radionuclides of the Uranium 20
Series," Bulletin of Environmental Contamination and Toxicology. Vol. 29, pp. 697-703. 21
McKone, T.E. and P.B. Ryan, 1989, "Human Exposure to Chemicals through Food Chains: An -a
Uncertainty Analysis," Environmental Science and Technology. Vol. 23, pp. 1154-1163. 23
Ohio Environmental Protection Agency, 1993, Ohio Water Quality Standards. OEPA, Div. of Water •u,
Quality Planning and Assessment, Columbus, OH. 25
Osborne, D.R., D.M. Ambrose and J.C. Simpson, 1992, "Characterization of Reproduction and 25
Growth of American Robins at the Fernald Environmental Management Project, 1991," FEMP/SUB- 2?
059 UC-702. prepared for Westinghouse Environmental Management Co. of Ohio, Cincinnati, OH. 2s
Pomeroy, 1977, Final Report on the Ecological Assessment of the Feed Materials Production Center. 29
Cincinnati. Ohio. Prepared for NLO, Inc., by Battelle National Laboratory, Columbus, OH. »
State of Ohio, ex Rel. v. United States Department of Energy. C-l-86-0217, March 11, 1986. See 31
Count Two, p. 15. 32
FER\CRU5\len\ROD\REF.ROD\ December 15, 1995 10:14am R-l
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FEMP-05ROD-6 FINAL
December 15, 1995
U.S. Dept. of Energy, 1992, "Risk Assessment Work Plan Addendum," Final Draft, FEMP,
Remedial Investigation and Feasibility Study, DOE, Fernald Office, Cincinnati, OH. 2
U.S. Dept. of Energy, 1993, "Responses/Actions to U.S. EPA and Ohio EPA Technical Comments 3
on Part II of the Site-Wide Characterization Report Response Document issued November, 1992," 4
DOE, Fernald Field Office, Cincinnati, OH. 5
U.S. Dept. of Energy, 1995a, "Feasibility Study Report for Operable Unit 5," Final, Fernald 6
Environmental Management Project, DOE, Fernald Area Office, Cincinnati, OH. 7
U.S. Dept. of Energy, 1995b, "Operable Unit 5 Kj Sampling and Analysis Results," Draft, Fernald s
Environmental Management Project, DOE, Fernald Area Office, Cincinnati, OH. 9
U. S. Dept. of Energy, 1995c, "Proposed Plan for Operable Unit 5," Final, Fernald Environmental 10
Management Project, DOE, Fernald Area Office, Cincinnati, OH. n
U.S. Dept. of Energy, 1995d, "Remedial Investigation Report for Operable Unit 5," Final, Fernald 12
Environmental Management Project, DOE, Fernald Area Office, Cincinnati, OH. is
U.S. Environmental Protection Agency, 1989, "Risk Assessment Guidance for Superfund: Human u
Health Evaluation Manual, Part A, Interim Final," EPA/540/1-89/002. EPA, Office of Emergency is
and Remedial Response, Washington, DC. 16
U.S. Environmental Protection Agency, 1990, "40 CFR Part 300, National Oil and Hazardous
Substances Pollution Contingency Plan; Final Rule," as presented in the Federal Register. Vol. 55,
No. 46, p. 8848. 19
U.S. Environmental Protection Agency, 1991a, "Risk Assessment Guidance for Superfund: Human 20
Health Evaluation Manual, Vol. I, Supplemental Guidance, Standard Default Exposure Factors, 21
Interim Final," EPA, Office of Emergency and Remedial Response, Washington, DC. 22
U.S. Environmental Protection Agency, 1991b, "Standard Default Exposure Factors," (OSWER 23
Directive 9285.6-03), EPA, Washington, DC. 24
U.S. Environmental Protection Agency, 1992, "Regional Guidance for Conducting Ecological 25
Assessments," EPA, Region 5, Office of Superfund, Chicago, IL. 2*
U.S. Environmental Protection Agency, 1994a, "Drinking Water Regulations and Health Advisories," 2?
EPA 822/R-94-001. Office of Water, Washington, DC. 2*
U.S. Environmental Protection Agency, 1994b, "Health Effects Assessment Summary Tables 29
(HEAST), Annual Update FY 1994," EPA 540-R-94-020. prepared by the Office of Health and 30
Environmental Assessment for the Office of Solid Waste and Emergency Response and the Office of 31
Water, Washington, DC. 32
U.S. Environmental Protection Agency, 1994c, "Selecting Exposure Route and Contaminants of 33
Concern by Risk-Based Screening," EPA/903/R-94-001. Region 3, Technical Guidance Manual, 34
Philadelphia, PA.
FER\CRU5\len\RODVREF.ROD\ December IS, 1995 10:14im R-2
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FEMP-05ROD-6 FINAL
December 15, 1995
U.S. Environmental Protection Agency, Environmental Criteria and Assessment Office, 1994d,
Memorandum from Joan Dollarhide to Pat Van Leeuwen, Sept. 21, 1994, Subject: Systemic and
Carcinogenic Toxicity Information for Benzene, Carbon Tetrachloride, Chloroethane, 1,2-
Dichloroethane, Kepone, Perchloroethylene, and Styrene, Cincinnati, OH.
U.S. Nuclear Regulatory Commission, 1977, "Calculation of Annual Doses to Man from Routine
Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50,"
Appendix I, Regulatory Guide 1.109. NRC, Office of Standards Development, Washington, DC.
Venugopal, B. and T.D. Luckey, 1978, Metal Toxicity in Mammals - Volume 2 - Chemical Toxicitv
of Metals and Metalloids. Plenum Press, New York, NY.
FER\CRU5\len\ROD\REF.ROD\ December 15, 1995 10:14«m R-3
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APPENDIX A
OPERABLE UNIT 5 RESPONSIVENESS SUMMARY
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TABLE OF CONTENTS
A. 1.0 Overview A. 1-1
A. 1.1 Description of Selected Remedy A. 1-1
A. 1.2 Community Response to the Selected Remedy A. 1-2
A.2.0 Background on Community Involvement A.2-1
A.2.1 History of Community Interest in the FEMP . A.2-1
A.2.2 Operable Unit 5's Public Affairs Efforts A.2-2
A.2.3 Key Issues Identified by the Public A.2-2
A.2.4 State and Community Input to the Operable Unit 5 Remedy A.2-3
A.3.0 Summary of Comments Received and Responses A.3-1
Anon. 1 A.3-2
Anon. 2 A.3-4
Anon. 3 A.3-5
Anon. 4 A.3-7
Anon. 5 A.3-8
Anon. 6 A.3-10
Anon. 7 0ater identified as T. & L. Baker) A.3-11
Anon. 8 A.3-12
Anon. 9 A.3-14
Anon. 10 A.3-15
Anon. 11 A.3-16
Anon. 12 " A.3-18
Anon. 13 A.3-20
Anon. 14 A.3-21
Anon. 15 . A.3-22
Anon. 16 A.3-23
Anon. 17 A.3-24
Anon. 18 A.3-25
Anon. 19 A. 3-26
Anon. 20 A.3-27
Anon. 21 A.3-28
Anon. 22 A.3-29
Beckner, M. A.3-30
BeddowAValden, J. A. 3-31
Blake, J. A.3-34
Bommer A. 3-36
CRU5\NMG\APX-A.ROD\Deccmber 11, 1995 ll:34am
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TABLE OF CONTENTS
(Continued)
Boudreau, D. A.3-39
Brown, J. A.3-41
Clawson, M. A.3-43
Crawford, L. A.3-44
Dastillung, V. A.3-54
Dunn, P. A.3-74
Fender, A. A.3-83
Kallile, J. A.3-85
Nevada Div. of Environmental Protection A.3-86
Nevada State Clearinghouse A.3-87
Nevada Test Site Community Advisory Board A.3-88
OEPA " A.3-89
Renck, D. A.3-101
Renck, J. M. A.3-103
Renck, T. E. A.3-106
Ross Area Merchants Assn. A.3-126
Schulte, A. A.3-128
Schulte, J. A.3-132
Storer, G. . A.3-134
Utah Dept. of Environmental Quality A.3-139
Walther, J. A.3-140
Willeke, G. A.3-143
Yocum, E. A.3-148
A.4.0 Remedial Design/Remedial Action Concerns A.4-1
Attachment A.I Transcript of the Operable Unit 5 Public Meeting
CRU5\NMG\APX-A.ROD\December 11, 1995 ll:34«m A-H
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December 15, 1995
A.1.0 OVERVIEW
This responsiveness summary, the third component of the Record of Decision (ROD) for Operable
Unit 5, provides the U.S. Environmental Protection Agency (EPA) and the U.S. Department of
Energy (DOE) with information about community preferences regarding both remedial alternatives
and general concerns about the Fernald Environmental Management Project (FEMP). It demonstrates
how public comments were integrated into the decision-making process and provides a record of
EPA's responses to the comments. The responsiveness summary has been prepared pursuant to the
terms of the 1991 Amended Consent Agreement between EPA and DOE as well as the following
guidance:
• The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
as amended by the Superfund Amendments and Reauthorization Act, 42 U.S. Code,
Section 9601, et seq.
• National Oil and Hazardous Substances Pollution Contingency Plan, 40 Code of Federal
Regulations Part 300
• Guidance on Preparing Superfund Decision Documents
• Community Relations in Superfund: A Handbook.
A.1.1 Description of Selected Remedy
The agencies have selected Alternative 3A for the remediation of environmental media at the FEMP
as summarized below; see Section 9.0 for full details:
• Excavation of contaminated soil and sediment
• Excavation of contaminated perched water zones
• Placement of contaminated soil and sediment that attain concentration-based waste
acceptance criteria in an on-property disposal facility; contaminated material that exceeds
the criteria will be treated before placement or shipped off site for disposal
• Extraction of contaminated groundwater from the Great Miami Aquifer
• Treatment of contaminated groundwater, storm water and wastewater
• Application of institutional controls during and after remedial activities
• Implementation of long-term environmental monitoring and maintenance programs.
CRU5\MCM\APX-A.ROD\December 11, 1995 ll:34«m A. 1-1
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A. 1.2 Community Response to the Selected Remedy
Fifty-two separate comments were received from 49 commentors; three people made formal
comments at the public meeting in addition to submitting written comments. One local group (the
Ross Area Merchants Association) and two state agencies (the Ohio EPA [OEPA] and the Ohio
Department of Health) submitted comments. The Utah Department of Environmental Quality and the
Nevada Test Site Community Advisory Board wrote to express approval of the selected remedy and
the Nevada State Clearinghouse said they had reviewed the Operable Unit 5 Proposed Plan and had
no comments.
Twenty-nine commentors expressed varying levels of opposition to the construction of an on-property
disposal facility while 11 commentors expressed acceptance of such a facility; seven of the 11
supported this aspect of title remedy as truly the best solution for dealing with contaminated soil and
sediment. For the groundwater component of the remedy, several commentors questioned the
selected cleanup and/or treatment levels, seeing them as too stringent and hence unnecessarily
expensive. Other commentors stated that the cleanup levels were appropriate and at least one
commentor suggested that the groundwater cleanup should be taken as far below proposed or final
drinking water standards as is reasonably achievable.
It is clear from the comments that the community is having trouble accepting the construction of a
disposal facility on the FEMP property. This facility was proposed and selected as the preferred
remedy for Operable Unit 2 waste material (at a size of approximately 14 acres) and then expanded
four-fold to accommodate contaminated soil and sediment from Operable Unit 5 (to approximately 60
acres) plus the residual soil and construction debris from Operable Units 1, 3 and 4 (for a total of
approximately 71 acres). There is strong "not hi my backyard" sentiment. A segment of the
community believes that placing the disposal facility (often referred to as a "dump") in their midst
will be very detrimental for reasons of health, safety, property values, and aesthetics. There is doubt
that any such facility can truly protect the Great Miami Aquifer from further contamination for the
very long term (i.e., 1000 years). However, from among the 11 supportive comments came
acceptance (somewhat reluctant) of the scientific merit and reasonableness of the 'balanced approach'
to solving the FEMP's problems that the disposal facility represents.
CRU5\MCM\APX-A.ROD\December 11. 1995 ll:34am A. 1-2
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December 15, 1995
A.2.0 BACKGROUND ON COMMUNITY INVOLVEMENT
A.2.1 History of Community Interest in the FEMP
Community involvement at DOE's FEMP site has developed remarkably over the last decade.
Environmental issues became the center of public controversy in late 1984 when it was reported that
nearly 300 pounds of enriched uranium oxide had been released to the atmosphere from the Plant 9
dust collector system. It was also disclosed that three off-property wells south of the site were found
(in 1981) to be contaminated with uranium. By early 1985 DOE had publicly confirmed that the
FEMP was responsible for the contamination in the wells.
A local citizens group, Fernald Residents for Environmental Safety and Health (FRESH), formed in
1984 to monitor FEMP activities. That same year area residents filed a class action lawsuit seeking
damages for emotional distress and decreased property values.
In 1985, in response to growing public interest in the FEMP, DOE opened reading rooms at the site
and at Lane Public Library hi Hamilton to enable the public to better understand FEMP operations.
In early 1986, two signal events - unauthorized venting of the K-65 Silos 1 and 2 and a crack hi a
pilot plant reactor vessel - brought more public scrutiny. Then, in July, EPA and DOE signed the
Federal Facility Compliance Agreement which initiated the remedial investigation/feasibility study
(RI/FS) at the FEMP.
The FEMP came under increasingly heavy scrutiny hi 1987 by various federal and state entities as
environmental and safety problems throughout DOE's nuclear weapons complex were regularly
covered by the news media. Over one 10-day period hi 1988, 150 reporters came to the FEMP site.
The class action lawsuit was settled hi 1989 after a summary trial; DOE agreed to pay $73 million for
emotional distress, medical monitoring, residential real property diminution, and legal and
administrative costs and an additional $5 million for commercial and industrial real property
diminution claims. Regular public meetings began that year to update the community on the progress
of the RI/FS and related topics and, to encourage dialogue between area residents and FEMP
personnel, community roundtables were initiated.
CRU5\MCM\APX-A.ROD\December 11, 1995 ll:34am A.2-1
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December 15, 1995
In 1993 the Fernald Citizens Task Force was chartered to provide DOE, EPA and OEPA with
recommendations about cleanup solutions and future courses of action at the FEMP. The Task Force
provided recommendations on future use of the site, waste disposal options, and cleanup objectives
and priorities.
Throughout the decade, DOE has responded to demands for varying levels of public involvement with
focused agendas and innovative meeting formats, notification agreements, person-to-person
communication, the envoy program to area groups, and has committed to providing continued public
participation opportunities beyond the RI/FS phase, into the remedial design and remedial action
process.
A.2.2 Operable Unit 5's Public Affairs Efforts
DOE's public affairs efforts for the RI/FS in general and Operable Unit 5 in particular are detailed in
Section 3.0 and summarized below:
• Held workshops in June and November, 1993 on the initial screening of alternatives
process and groundwater issues
• Held workshops in November 1994 (on the RI Report) and March 1995 (on the FS Report
and Proposed Plan)
• Met with local groups and township trustees both before and during the public comment
period on the Proposed Plan; made an extra ^ffort to widely distribute the Proposed Plan
(more than 850 copies of the Proposed Plan were circulated for comment)
• Held a public meeting in May 1995 on the Proposed Plan.
A.2.3 Key Issues Identified by the Public
Those members of the public who offered comments identified the following issues as being of major
importance to them:
• The on-property disposal facility is generally undesirable but, if it must be part of the
remedy for Operable Units 2 and 5, the public advocates these conditions:
No additional waste can be brought from off site for disposal at the FEMP
Buffer zone and fencing must be as protective as possible
DOE remains responsible for the disposal facility and environs far, far into the future
The best possible protective measures must be used during facility construction and
movement of material for placement
CRU5\MCM\APX-A.ROD\December 11, 1995 ll:34«m A.2-2
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FEMP-05ROD-6 FINAL
December 15, 1995
• DOE's commitment to a complete and safe cleanup of the FEMP site is not trusted and this
sentiment runs deep, particularly as it applies to long-term funding for implementation and
monitoring of the remedy
• Protection of the Great Miami Aquifer is a prime concern
• Several comments were received that indicated the discharge requirements for the release
of treated groundwater and wastewater to the Great Miami River may be overly stringent;
the commentors questioned the rationale and cost-effectiveness of treating wastewater
streams to drinking water quality before release to the river.
• Several commentors indicated that the cost estimates for the remedial alternatives provided
in the Proposed Plan did not allow for a fair comparison between off-site and on-site
disposal options or cannot be trusted for decision making
• Several commentors wanted a restriction placed on the disposal of characteristic waste
regulated by the Resource Conservation and Recovery Act (RCRA) in the disposal facility;
others recognized that the waste acceptance criteria developed for these constituents
provide a suitable level of protection to the Great Miami Aquifer and offer an acceptable
threshold for managing the disposal of RCRA-regulated substances in the on-property
disposal facility
• DOE received several comments on the need to maintain the active public involvement
process throughout the remedial design and remedial action phases of the Operable Unit 5
remedy
• Several members of the public expressed an interest in reviewing site closeout information
hi the future to confirm that cleanup levels had been attained following completion of the
Operable Unit 5 remedy.
Responses to each comment received during the public comment period are provided in Section 3.0 of
this Responsiveness Summary.
A.2.4 State and Community Input to the Operable Unit 5 Remedy
DOE has considered state and community input in the selection of Alternative 3A as the remedy for
Operable Unit 5. The selected remedy mirrors the recommendations of the Fernald Citizens Task
Force and has received State of Ohio concurrence.
Many members of the local community are personally opposed to on-property disposal and expressed
their preference for off-site disposal of all of Operable Unit 5's soil, regardless of cost and
implementability considerations. Other members of the community (including the Fernald Citizens
Task Force) expressed an understanding of the prudence, of taking a balanced approach to site
cleanup, noting the disproportionate costs, implementability concerns, and transportation safety
CRUS\MCM\APX-A.ROD\December 11, 1995 ll:34sm A.2-3
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FEMP-05ROD-6 FINAL
December 15, 1995
concerns associated with full off-site disposal. In general, all commentors were in agreement to
restore the Great Miami Aquifer to full beneficial use.
While expressing reservations about on-property disposal, the comments received did not identify any
technical omissions or errors in the development of the alternatives for Operable Unit 5 or the
technical basis for the selection of the preferred alternative.
No significant changes were made to the selected remedy described in the Proposed Plan as a result of
public comments.
CRU5\MCM\APX-A.ROD\December II, 1995 ll:34»m A.2-4
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FEMP-05ROD-6 FINAL
December 15, 1995
A.3.0 SUMMARY OF COMMENTS RECEIVED AND RESPONSES
This section contains EPA's and DOE's responses to all comments received from the public regarding
the Operable Unit 5 Proposed Plan and selected remedy. The comments are sorted alphabetically by
the last name of the commentor with the anonymous comments (1 through 22) at the beginning. A
copy of the actual comment is followed by the response to the various issues raised in the comment.
For those who made their comments at the public meeting on May 23, the applicable page of the
meeting transcript is used. For ease of reading, the part of the comment being answered is typed
almost verbatim and a number assigned to it; this number appears hi the margin on the copy of the
actual comment outside a bracket that encompasses the portion of the comment being answered.
For example, if Anonymous 3 commented on three distinct issues, the copy of the comment would
have three sequentially numbered brackets down the right margin. The next page would repeat the
bracketed text and the number, followed by the response. Pagination throughout this section is
continuous and the Table of Contents for Appendix A, the Responsiveness Summary, lists the name
of each identified commentor and the page number where her/his comment can be found. Those who
commented anonymously will need to look among the first 22 comments in order to find their
response.
Only the few acronyms listed below are used in the responses to comments to provide easier reading
and understanding:
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
DOE U.S. Department of Energy
EPA U.S. Environmental Protection Agency
FEMP Fernald Environmental Management Project.
FRESH Fernald Residents for Environment, Safety and Health
FS feasibility study
OEPA Ohio Environmental Protection Agency
RCRA Resource Conservation and Recovery Act
ROD record of decision.
CRU5\MCM\AFX-A.ROD\Decanber 11, 1995 ll:34am A.3-1
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Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513).648-3153.
• ro cj/? a i
Loc.^ ,-^g,.
'-\
h A- ?O
_o . Poll
\-y ^Vl
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OoSTf
.0 c,
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) (J ro it
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hi A
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"C i~t~ O
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(Below information is optional)
Name: ANONYMOUS »1
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-2a
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FEMP-05ROD-6 FINAL
December 15, 1995
SECTION A.3
Anon. 1 At the meeting with OEPA on May 15 they suggested that members of the public
1 should be aware of several issues surrounding the disposal cell. One of these issues is
the disposal of hazardous waste in the cell. At the public meeting on May 23, a
member of FRESH spoke out against allowing hazardous waste in the cell. FRESH
made it clear that their concern... was not limited to flammable, corrosive and
ignitable waste, which clearly should not be placed in the cell, but included toxic
hazardous waste. Toxic hazardous wastes include relatively low concentrations of
some metals (low relative to the uranium WAC). Uranium, also a metal, has similar
properties (including mobility) as some of these metals. It is inconsistent to believe
that the cell can safely contain radioactive waste if it cannot safely contain hazardous
waste. The disposal cell is either protective or it is not! How can OEPA endorse this
alternative after implying that the cell is not safe for the disposal of similar type
waste?
Response:
DOE agrees with the technical issues raised by this comment concerning the disposal of
RCRA hazardous waste (in particular, the disposal ofRCRA characteristic waste that was
raised by OEPA) in the on-property disposal facility. The Operable Unit 5 remedy
proposed by DOE is fully protective of human health and the environment for all
contaminants of concern that are present in the soil, including those contaminants that
qualify (and require management) as regulated hazardous waste under RCRA. Specific
waste acceptance criteria have been developed for the on-property disposal facility to
ensure that all of the materials placed in the facility will be consistent with the need for a
fully protective remedy. In particular, the waste acceptance criteria are intended to limit
the placement in the facility ofRCRA contaminants exhibiting toxicity to levels that are
protective of the Great Miami Aquifer. (Along with the waste acceptance criteria
developed for the materials exhibiting toxicity, DOE proposes to prohibit the placement of
materials which qualify as ignitable, corrosive, or reactive characteristic waste under
RCRA.) The approach used to develop limits for the placement of these RCRA
contaminants in the facility is the same as that used to establish limits on radiological
contaminants, such as uranium. The waste acceptance criteria developed for the RCRA
contaminants satisfy the regulatory requirements of EPA's RCRA corrective action
management unit rule, which has been adopted as an applicable or relevant and
appropriate requirement for Operable Unit 5.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 11, 1995 9:34am A.3-2
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FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 1 In addition to the requirement that a health-protective remedy be adopted for a site
1 (Contd.) undergoing cleanup for RCRA-regulated substances (which is satisfied by the health-
protective waste acceptance criteria and final remediation levels adopted for the Operable
Unit 5 contaminated media), the corrective action management unit rule requires that the
remedy satisfy a regulatory preference for methods that enhance the long-term effectiveness
of the remedy through the application, as appropriate, of treatment technologies that
reduce toxicity, mobility, or volume of wastes that will remain in place after site closure.
In their comments on the Operable Unit 5 Proposed Plan, OEPA raised a stipulation
requiring treatment of the Operable Unit 5 soil materials that qualify as RCRA
characteristic hazardous waste (i. e., to remove the characteristic property associated with
the material) before placement in the disposal facility. Recognizing that DOE has
developed health-protective final remediation levels and waste acceptance criteria for all of
the Operable Unit 5 contaminants of concern, OEPA's additional stipulation concerning
the on-property disposal of characteristic waste has its origin in the need to satisfy, on a
site-specific basis, the regulatory preference for remedies that employ treatment. As stated
in the corrective action management unit rule, the decision to apply cost-effective treatment
is a case-by-case decision that must consider waste- and site-specific factors. OEPA has
designated the Operable Unit 5 soil that qualifies as RCRA characteristic waste as a site-
specific quantity of material that offers a reasonable opportunity to apply additional
treatment measures. Upon review of the.site characterization data from the Operable
Unit 5 remedial investigation coupled with historical process knowledge, six geographic
areas of the FEMP have been identified where a reasonable potential exists for the
presence of soil that qualifies as containing RCRA characteristic waste. DOE agrees that
these six areas offer a reasonable, site-specific, and cost-effective opportunity to treat
additional materials before on-property disposal, in the interest of enhancing the long-term
effectiveness of the remedy through treatment techniques. The remedy described in
Section 9.0 of the ROD includes a commitment by DOE to search for and employ treatment
as necessary for characteristic hazardous waste in soil that originates from within the six
geographic areas.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Deconber 8, 1995 10:4J«m A. 3-3
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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(Below information is optional)
Name: ANONYMOUS #2
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-4a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 2 I'm totally against this plan. Its not fair to our family. We're homeowners in the
1 Ross area. My children have to go to school right down the road from Fernald. I
think my family has the right to clean dirt, water, etc. Your plan will devastate my
family, our health the value of our property.
Response:
The proposed cleanup plan will correct an existing contamination problem and reduce the
levels of contamination within the environmental media at the site to levels deemed to be
health-protective by federal environmental regulation. It cleans up the FEMP by getting
the material with higher levels of contamination away from the site, and provides a
strategy for permanently protecting human health and the underlying Great Miami Aquifer
by isolating the remaining less contaminated material in an engineered disposal facility at
the site.
Anon. 2 I think Fernald should go to another state because it has devastated the whole area
2 around it people has died due to this Fernald plant. I think that people have the right
to say yes or no to this news about Fernald. We want it out of our community it has
damaged our (sic.) enough.
Response:
DOE understands that a segment of the community near the FEMP site wants all
contamination removed from the site and shipped to an off-site location. DOE realizes that
some members of the public will think that it is unfair to propose that some contaminated
FEMP material remain in an engineered on-property disposal facility. But it is equally
unfair to expect other communities located in other areas of the country to accept large
quantities of contaminated material from the FEMP site. The current site-wide remedial
approach, of which Operable Unit 5 is a component, involves balancing the off-site
disposal of the FEMP's inventory of highly contaminated wastes with on-property disposal
of less contaminated soil and rubble.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-site disposal. All material will have to pass stringent waste acceptance
criteria before being placed in the on-site disposal facility. These waste acceptance
criteria were conservatively developed for the long-term protection of the public and the
Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Dec«mber 8. 1995 10:43am A.3-4
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
(Below information is optional)
Name: ANONYMOUS #3
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
A.3-5a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 3 Please do not build a building to store contaminants in or haul contaminants here to
1 be cleaned. We have the largest aquifer in the nation and would like to keep it safe
for everyone. Why would anybody want a building full of contaminants close to their
house or any where else for that fact.
Response:
DOE acknowledges that no one wants contamination near where they live but contaminated
material already exists at the FEMP. The cleanup plan proposed for the FEMP will
address this existing contamination and reduce the levels in the soil and groundwater to
concentrations deemed to be health-protective by federal environmental regulation.
DOE has no plans to bring contaminants to the FEMP site to be cleaned and then placed
in the on-site disposal facility. However, DOE is evaluating the potential cost savings of
treating some materials from other DOE sites at the FEMP and then shipping them back to
the originating facility for final disposal. There is much public concern regarding
placement of off-site waste in the site engineered disposal facility. The facility is being
designed to correct a problem that already exists at the FEMP. No consideration is being
given to placing waste from other sites in the FEMP engineered disposal facility.
The selected cleanup remedy at the FEMP has three objectives related to the Great Miami
Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer to
maximum beneficial use in a reasonable time frame, and protect the aquifer from future
contamination originating from the FEMP property. DOE recognizes that the aquifer is an
important national and local resource and that the FEMP site has adversely impacted an
approximate 200-acre area of the aquifer system. DOE also recognizes that if the FEMP is
not cleaned up it poses continued contamination risk to the public and to the aquifer.
DOE intends to eliminate this unacceptable risk by moving forward with a balanced
remediation approach. This approach gets the most contaminated materials away from the
aquifer (by shipping them off-site), restores the aquifer, and limits the quantity and
disposal configuration of the contaminated material remaining at the site. Completion of
the selected remedy will also provide for more beneficial use of the FEMP property outside
the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Deccmber 8, 1995 10:43am A.3-5
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 3 Several different options were considered for the less contaminated material before the
1 (Contd.) excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
The waste acceptance criteria considers the hydrogedlogic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium outside
the former production area of the FEMP and 20 parts per million within the former
production area. Current estimates indicate that placing all of the lightly contaminated
soil together in the disposal facility will produce an average concentration of about 100
parts per million of uranium in the facility. This average concentration is one-tenth of the
waste acceptance criteria for disposal in the on-property disposal facility, a tenfold safety
factor. It should be noted that sophisticated computer model simulations used to derive the
waste acceptance criteria were completed assuming that there was no active maintenance
of the facility and that the synthetic barriers present in the facility (e.g., high-density
polyethylene membranes) were not functioning. These simulations indicate that even under
these extreme conditions, the facility would still be protective of the aquifer over the full
200- to 1000-year performance period envisioned by federal regulations.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-6
-------
ANONYMOUS #4
I formally submit the following comment:
At a recent Fernald Citizens Task Force Meeting, Mr. Willeke brought up the issue
that Operable Unit 5 was using a proposed drinking water standard for uranium.
Mr. Willeke further noted that the standard is expected to be finalized in the
next year and is anticipated to increase from the current 20 parts per billion.
I concur with Mr. Willeke's position that the Operable Unit 5 decision should
permit the adoption of the final uranium drinking water standard when available.
This approach is.consistent with the recommendations of the task force and with
the spirit and intent of federal environmental regulations. Such an approach
provides adequate protection to the aquifer and the public, and would save the
government in excess of $150 million. Such a savings must be taken seriously
in these times of financial crisis at the federal level.
A.3-7a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 4 At a recent Fernald Citizens Task Force Meeting, Mr. Willeke brought up the issue
1 that OU5 was using a proposed drinking water standard for uranium. Mr. Willeke
further noted that the standard is expected to be finalized in the next year and is
anticipated to increase from the current 20 ppb. I concur with Mr. Willeke's position
that the OU5 decision should permit the adoption of the final uranium drinking water
standard when available.
This approach is consistent •with the recommendations of the task force and with the
spirit and Latent of federal environmental regulations. Such an approach provides
adequate protection to the aquifer and the public, and would save the government in
excess of $150 million. Such a savings must be taken seriously in these times of
financial crisis at the federal level.
Response:
Consistent with Section 300.430(e)(2)(i)(C)ofthe National Contingency Plan, the DOE has
adopted the maximum contaminant levels under the Safe Drinking Water Act as relevant
and appropriate requirements to the restoration of the Great Miami Aquifer. Lacking a
final promulgated maximum contaminant level for uranium, DOE adopted, as pan of the
selected remedy, the maximum contaminant level proposed by EPA in July 1991 under the
Safe Drinking Water Act of 20 parts per billion as the final remediation level for
restoration of the aquifer. This proposed standard was adopted as a "To Be Considered"
requirement to the selected remedy.
The estimated costs for the restoration of the Great Miami Aquifer are, as would be
expected, very sensitive to the established final groundwater cleanup limits (final
remediation levels). While DOE is committed to fully restoring the aquifer to
health-protective levels, DOE must do so in full recognition of its role as a steward of
public funds. Within its stewardship role, the DOE must ensure that public funds are
committed only to remedial activities which yield a commensurate environmental or human
health-related benefit. As such, the DOE must evaluate the technical and economic
implications of pursuing adoption of the final maximum contaminant level for uranium,
once promulgated by EPA. Such a technical and economic evaluation will be warranted
regardless of whether the final maximum contaminant level for uranium represents a higher
or lower concentration-based limitation than the proposed 20 pans per billion standard.
In the event DOE considers it appropriate to pursue a change to the final remediation level
for uranium in groundwater identified in this decision document, DOE will initiate such a
change in a manner consistent with CERCLA, the National Contingency Plan and the terms
of the Amended Consent Agreement. As done throughout the remedial
investigation/feasibility study decision-making process, the DOE will involve the public in
any attempt to modify the final remedial level for uranium in the Great Miami Aquifer
from the 20 parts per billion value identified in Section 9 of this ROD.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 11, 1995 9:34«m A.3-7
-------
ANONYMOUS #5
I formally submit the following comment:
During the Operable Unit 2 Public Meeting a representative of Ohio EPA noted that
the disposal facility would not receive hazardous waste. Of issue was soil
containing lead from a firing range.
At the October 15 Ohio EPA meeting representatives of the agency again
recommended that the public submit comments requesting a prohibition of hazardous
waste in the disposal facility. For Operable Unit 5, again this appears focused
on lead contaminated soil from a trap range and possibly some other soils
containing metals.
I question the sensibility of the Ohio EPA position. It is inconceivable that
a disposal facility designed to contain uranium for a 1000 years cannot be
designed to address spent lead bullets and other metals. The Ohio EPA position
presents a inconsistent message to the public. It cuts at the foundation of the
disposal facility concept; that of long term performance.
At a recent Fernald Citizens Task Force Meeting, waste acceptance criteria for
the disposal facility were discussed. At this session it was noted that criteria
were being developed for uranium and a series of other contaminants. It would
seem appropriate that these criteria address lead and other metals.
In summary, I request that DOE develop waste acceptance criteria for all
contaminants found in soil at the site. I further request that soil received at
the facility be measured against these criteria, regardless of a regulatory label
(i.e., hazardous waste). This will provide a consistent message to the public
on the disposal facility.
A.3-8a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 5 During the Operable Unit 2 Public Meeting a representative of Ohio EPA noted that
1 the disposal facility would not receive hazardous waste. Of issue was soil containing
lead from a firing range. At the October 15 Ohio EPA meeting representatives of the
agency again recommended that the public submit comments requesting a prohibition
of hazardous waste in the disposal facility. For Operable Unit 5, again this appears
focused on lead contaminated soil from a trap range and possibly some other soils
containing metals. I question the sensibility of the Ohio EPA position. It is
inconceivable that a disposal facility designed to contain uranium for a 1000 years
cannot be designed to address spent lead bullets and other metals. The Ohio EPA
position presents a inconsistent message to the public. It cuts at the foundation of the
disposal facility concept; that of long term performance. At a recent Fernald Citizens
Task Force Meeting, waste acceptance criteria for the disposal facility were discussed.
At this session it was noted that criteria were being developed for uranium and a
series of other contaminants. It would seem appropriate that these criteria address
lead and other metals. In summary, I request that DOE develop waste acceptance
criteria for all contaminants found hi soil at the site. I further request that soil
received at the facility be measured against these criteria, regardless of a regulatory
label Q.e., hazardous waste). This will provide a consistent message to the public on
the disposal facility.
Response:
DOE agrees with the technical issues raised by this comment concerning the disposal of
RCRA hazardous waste (in particular, the disposal ofRCRA characteristic waste that was
raised by OEPA) in the on-property disposal facility. The Operable Unit 5 remedy
proposed by DOE is fully protective of human health and the environment for all
contaminants of concern that are present in the soil, including those contaminants that
qualify (and require management) as regulated hazardous waste under RCRA. Specific
waste acceptance criteria have been developed for the on-property disposal facility to
ensure that all of the materials placed in the facility will be consistent with the need for a
fully protective remedy. In particular, the waste acceptance criteria are intended to limit
the placement in the facility ofRCRA contaminants exhibiting toxicity to levels that are
protective of the Great Miami Aquifer. (Along with the waste acceptance criteria
developed for the materials exhibiting toxicity, DOE proposes to prohibit the placement of
materials which qualify as ignitable, corrosive, or reactive characteristic waste under
RCRA.) The approach used to develop limits for the placement of these RCRA
contaminants in the facility is the same as that used to establish limits on radiological
contaminants, such as uranium. The waste acceptance criteria developed for the RCRA
contaminants satisfy the regulatory requirements of EPA's RCRA corrective action
management unit rule, which has been adopted as an applicable or relevant and
appropriate requirement for Operable Unit 5.
CRU5\ROD\MCMVAPP-A\RSC-A-C.ROD\D«cembcr 11. 1995 9:34am A.3-8
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 5 In addition to the requirement that a health-protective remedy be adopted for a site
1 (Contd.) undergoing cleanup for RCRA-regulated substances (which is satisfied by the health-
protective waste acceptance criteria and final remediation levels adopted for the Operable
Unit 5 contaminated media), the corrective action management unit rule requires that the
remedy satisfy a regulatory preference for methods that enhance the long-term effectiveness
of the remedy through the application, as appropriate, of treatment technologies that
reduce toxicity, mobility, or volume of wastes that will remain in place after site closure.
In their comments on the Operable Unit 5 Proposed Plan, OEPA raised a stipulation
requiring treatment of the Operable Unit 5 soil materials that qualify as RCRA
characteristic hazardous waste (i.e., to remove the characteristic property associated with
the material) before placement in the disposal facility. Recognizing that DOE has
developed health-protective final remediation levels and waste acceptance criteria for all of
the Operable Unit 5 contaminants of concern, OEPA's additional stipulation concerning
the on-property disposal of characteristic waste has its origin in the need to satisfy, on a
site-specific basis, the regulatory preference for remedies that employ treatment. As stated
in the corrective action management unit rule, the decision to apply cost-effective treatment
is a case-by-case decision that must consider waste- and site-specific factors. OEPA has
designated the Operable Unit 5 soil that qualifies as RCRA characteristic waste as a site-
specific quantity of material that offers a reasonable opportunity to apply additional
treatment measures. Upon review of the site characterization data from the Operable
Unit 5 remedial investigation coupled with historical process knowledge, six geographic
areas of the FEMP have been identified where a reasonable potential exists for the
presence of soil that qualifies as containing RCRA characteristic waste. DOE agrees that
these six areas offer a reasonable, site-specific, and cost-effective opportunity to treat
additional materials before on-property disposal, in the interest of enhancing the long-term
effectiveness of the remedy through treatment techniques. The remedy described in
Section 9.0 of the ROD includes a commitment by DOE to search for and employ treatment
as necessary for characteristic hazardous waste in soil that originates from within the six
geographic areas.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\DecembCT 8, 1995 10:43am A.3-9
-------
ANONYMOUS #6
I formally submit the following comment:
The Operable Unit 5 Proposed Plan notes that treatment will be applied to
wastewater and groundwater streams such that the "blended" concentration is less
than the Federal drinking water standards. DOE needs to revise this position.
Why does DOE feel it necessary to spend hard earned taxpayer money to treat water
for drinking and then dump it to the river. This is inconceivable in this time
of shrinking budgets. We all need to tighten our belts. Here we need to simply
abandon such an idea and treat only as necessary to protect the river (fish,
etc.) and recreational users of the river. Anybody using the river for drinking
(NOTE: I don't know of any) would be required to treat the water anyway.
A.3-10a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 6 The OU5 Proposed Plan notes that treatment will be applied to wastewater and
1 groundwater streams such that the "blended" concentration is less than the Federal
drinking water standards. DOE needs to revise this position. Why does DOE feel it
necessary to spend hard earned taxpayer money to treat water for drinking and then
dump it to the river. This is inconceivable in this tune of shrinking budgets. We all
need to tighten our belts. Here we need to simply abandon such an idea and treat
only as necessary to protect the river (fish etc.) and recreational users of the river.
Anybody using the river for drinking (NOTE: I don't know of any) would be
required to treat the water anyway.
Anon. 6 Response:
1 (Contd.) DOE, EPA and OEPA consider it prudent to continue to strive for reduction of uranium
discharges to the Great Miami River. In 1989, the year production ceased at the FEMP,
uranium discharges to the Great Miami River were approximately 1800 pounds per year.
Through the construction of the storm water retention basin, the installation and operation
of two temporary treatment units, and the construction and operation of the advanced
wastewater treatment system, uranium discharges to the river have gradually decreased.
The current year's projected discharge is anticipated to be less than 600 pounds. As
full-scale aquifer restoration begins, it would be reasonably expected that the quantity of
water and the mass of uranium being discharged to the river will increase. Meetings were
held with the EPA and the OEPA regarding the need and advisability of imposing a
performance-based concentration discharge limit as pan of the ROD. A performance-
based concentration limit that could be reasonably attained with a cost-effective level of
treatment was considered necessary by EPA to supplement the human health-based final
remediation level of 530 ppb established for concentrations of total uranium in the Great
Miami River.
Modeling was performed by DOE to assess the cost and technical implications of adopting
a 20 ppb total uranium discharge limit. This modeling led to the conclusion that, for the
groundwater extraction/reinjection scenarios presently under consideration for the Great
Miami Aquifer, the 20 ppb discharge limit could be attained under average operating
conditions with the use of existing or proposed site treatment capacity. The modeling
identified that the actual application of such a limit would need to accommodate unusual
operating conditions.
It was agreed, as identified in Section 9.1.5, that 20 ppb total uranium would be adopted
as a reasonable, performance-based concentration discharge limit with the incorporation of
provisions to accommodate unusual operating conditions.
CRU5\ROD\MCM\APP-A\SSC-A-C.ROD\Deconber 11, 199S 9:34am A.3-10
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
OOP
ro
£'HQN*;
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\AJ^ U
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/
(Below information is optional)
Name: ANONYMOUS #7
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Femald Environmental Management Project.
Yes
A.3-lla
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 7 I know you help the Township out alot and do other things but when I herd (sic) that
1 you wanted to bring toxic waste into our little township I was shocked! Did our
government actulley (sic.) lie to us and tell us that the place was getting cleaned up
then just do the opposite. I can't believe it. I know you must be busy cantamuates
(sic., contaminating) our beatiful farm ground....
Response:
The proposed cleanup plan will correct an existing contamination problem and reduce the
levels of contamination within the environmental media at the site to levels deemed to be
health protective by federal environmental regulation. It cleans up the FEMP by getting
the material with higher levels of contamination away from the site, and provides a
strategy for permanently protecting human health and the underlying Great Miami Aquifer
by isolating the remaining less contaminated material in an engineered disposal facility at
the site.
DOE has no plans to bring contaminated materials from other sites to the FEMP to be
treated and then placed in the on-site disposal facility. However, DOE is evaluating the
potential cost savings of treating some materials from other DOE sites at the FEMP and
then shipping them back to the originating facility for final disposal. There is much public
concern regarding placement of off-site waste in the site engineered disposal facility, and
no consideration is being given to placing waste from other sites in the FEMP engineered
disposal facility.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 11, 1995 9:34«m A.3-11
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment perio{Lj>lease cornet Gary Stegner in pOE's PubUc Infonnation Office at (513) 64&-3153.
cn
. ^s^*^. -*?
a AJf/JL*^ G
2
(Below information is optional)
Name: ANONYMOUS #8
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Femald Mailing List to receive additional infonnation on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-l2a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 8 The aquifer must be protected above all. After all cost of building the cell and (if) the
1 cell would fail who would pay to fix or remove the material; move it now and save
money in the long run.
Response:
The selected cleanup remedy -at the FEMP has three objectives related to the Great Miami
Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer to
maximum beneficial use in a reasonable time frame, and protect the aquifer from future
contamination originating from the FEMP property. DOE recognizes that the aquifer is an
important national and local resource and that the FEMP site has adversely impacted an
approximate 200-acre area of the aquifer system. DOE also recognizes that if the FEMP is
not cleaned up it poses continued contamination risk to the public and to the aquifer.
DOE intends to eliminate this unacceptable risk by moving forward with a balanced
remediation approach. This approach gets the most contaminated materials away from the
aquifer (by shipping them off-site), restores the aquifer, and limits the quantity and
disposal configuration of the contaminated material remaining at the site. Completion of
the selected remedy will also provide for more beneficial use of the FEMP property outside
the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist oflightfy contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
The long-term cost effectiveness of the selected Operable Unit 5 remedy was evaluated
against other alternatives in the feasibility study's detailed evaluation of alternatives.
Comprehensive cost estimating in this evaluation indicated that even with the inclusion of
conservative long-term monitoring and maintenance costs of the on-property disposal
facility, it was still much more cost effective to dispose of some material on site rather than
ship all the material off site. The DOE (i.e., U.S. government) will have responsibility for
the long-term performance and maintenance of the on-property disposal facility.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-12
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 8 The Ross area has received enough bad press over the years and has had its problems
2 with growth; leave us alone and do what is right, protect land, water and the children
from future problems.
Response:
The DOE is committed to cleaning up the FEMP site in the most reasonable time period
possible. The proposed cleanup plan is designed to protect the land, water, and the
children from future problems involved with the FEMP.
Anon. 8 The tax base in the area and property values will be affected by the cell and the
3 schools will loose money to operate as well as they are now.
Response:
Although the Proposed Plan includes an on-property disposal facility, it is DOE's intention
to clean the remaining portions of the facility in order to accommodate some beneficial
reuse. It is not however, within the scope of the Proposed Plan/Record of Decision to
identify the specific future use of the facility. The community will be involved in future
use determinations. Although the DOE cannot speculate on whether future use of the
facility will expand the tax base, at a minimum the facility will be restored to be
aesthetically appealing and will encourage rather than deter development in this area.
CRU5\ROD\MCM\APP-A\SSC-A-C.ROD\December 8, 1995 10:43am A.3-13
-------
ANONYMOUS #9
OIJ 5 Comments
i
People with off-site contamination above background should be asked if they'
want it removed from their property. j^
A.3-14a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 9 People with off-site contamination above background should be asked if they want it
1 removed from their property.
Response:
The Proposed Plan supporting the Operable Unit 5 remedy decision process identified the
extent of uranium contamination in surface soil both on and adjacent to the FEMP. The
opening of the public comment period and notification of the availability of the Proposed
Plan was announced in local newspapers. The Proposed Plan was widely distributed
during the public comment period in an attempt to gain input from the public on the
remedial alternatives considered in the feasibility study and the proposed remedy for
Operable Unit 5. Additionally, both formal and informal public meetings were held during
the public comment period by FEMP representatives to help increase awareness in the
community of the pending decision and to solicit comment on proposed remedial actions.
The Fernald Citizens Task Force similarly deliberated on the proposed cleanup levels for
contaminated surface soil and recommended that the off-FEMP-property cleanup levels be
commensurate with an incremental lifetime cancer risk of 1O4 and not exceed a hazard
index of L The selected remedy for Operable Unit 5, documented in Section 9.0 of this
ROD, includes soil cleanup levels which are consistent with the recommendations of the
Task Force and fully accommodate pertinent public comments on the issue.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\D«xmber 8, 1995 10:43am A.3-14
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
flfc
\ I
T
\j ft-Li
. y
(Below information is optional)
Name: ANONYMOUS »10
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-15a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 10 Has your cost estimate been validated by any outside agency?
1
Response:
Both EPA and OEPA independently reviewed the adequacy and worthiness of DOE's cost
estimates. As part of their approval process, both agencies agreed with the
representativeness of the estimates for decisionmaking and concluded that the cost
implications of the off-site and on-site alternatives could be fairly compared. DOE also
obtained an independent review of the Operable Unit 5 feasibility study cost estimates from
Argonne National Laboratory that substantiated the adequacy of DOE's estimates.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43«m A.3-15
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed Final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
s\
\
7
/
(Below information is optional)
Name: ANONYMOUS
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-16a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 11 No dump
1
Response:
DOE's plans for remediation of the site as a whole include a conservative approach
regarding on-site and off-site disposal of contaminated material. It is important to
distinguish that this approach includes off-site disposal of all of the more highly
contaminated material found at the FEMP in all operable units.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1, 2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria-will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium outside
the former production area of the FEMP and 20 parts per million within the former
production area. Current estimates indicate that placing all of the lightly contaminated
soil together in the disposal facility will produce an average concentration of about 100
parts per million of uranium in the facility. This average concentration is one-tenth of the
waste acceptance criteria for disposal in the on-property disposal facility, a tenfold safety
factor. It should be noted that sophisticated computer model simulations used to derive the
waste acceptance criteria were completed assuming that there was no active maintenance
of the facility and that the synthetic barriers present in the facility (e.g., high-density
polyethylene membranes) were not functioning. These simulations indicate that even under
these extreme conditions, the facility would still be protective of the aquifer over the full
200- to 1000-year performance period envisioned by federal regulations.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\De«mbCT 8, 1995 10:43am A. 3-16
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 11 (Cont'd)
1 (Cont'd) The on-property disposal facility will not be an open dump, but a state-of-the-art
engineered facility consisting off a multiple layer liner, cap and leak detection system.
Movement of material to the facility will be managed to minimize dust. There will be no
odor from the disposal facility.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-17
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
'TH£ ' Ct-fA/V M. P ?
it f.
u /n
/SL
i
2
(Below information is optional)
Name: ANONYMOUS #12
Address: •' '. '•'"'•. •••• •''••-.•
City: . - '••' •••• ' " • '- • ''
Phone: ' - '••- -". ;
Mailing List Additions
Please add my name to the Femald Mailing List to receive additional information on the cleanup progress at the
Femald Environmental Management Project. - .
Yes
No
A.3-18a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 12 Where is the clean up?
1
Response:
DOE cleanup plans are to remove the materials that constitute about 97 percent of the
radioactivity present at the FEMPfor disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1, 2, 4, and 5 in
conjunction with the anticipated Operable Unit 3 remedy and the current plans to remove
the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed, with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
The selected cleanup remedy at the FEMP has three objectives related to the Great Miami
Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer to
maximum beneficial use in a reasonable time frame, and protect the aquifer from future
contamination originating from the FEMP property. DOE recognizes that the aquifer is an
important national and local resource and that the FEMP site has adversely impacted an
approximate 200-acre area of the aquifer system. DOE also recognizes that if the FEMP is
not cleaned up it poses continued contamination risk to the public and to the aquifer.
DOE intends to eliminate this unacceptable risk by moving forward with a balanced
remediation approach. This approach gets the most contaminated materials away from the
aquifer (by shipping them off site), restores the aquifer, and limits the quantity and
disposal configuration of the contaminated material remaining at the site. Completion of
the selected remedy will also provide for more beneficial use of the FEMP property outside
the disposal facility area.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43«m A.3-18
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 12 The dump is a cover up?
2
Response:
The DOE is very committed to cleaning up the FEMP and protecting the public from any
future FEMP-related contamination. The DOE has no hidden agenda concerning the
cleanup of the FEMP. The cleanup plans presented to the public and the agencies are
what -would be followed when approved, provided sufficient funding is made available to
the site.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-19
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31,1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
M.S
.
C.i\\i[> C A £
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\i
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(Below information is optional)
Name: ANONYMOUS #13
Address:
City: • ;
Phone:
Mailing List Additions
Please add my name to the Femald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-20a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 13 Did anyone contact local Business, churches, schools, governments, citizens and ask
1 their opinion. Don't talk about meeting the local people ... Ask straight up about
the dump.
Response:
As part of the overall site program for community involvement at Fernald, numerous
opportunities were provided to the public during the past few years for commenting on
proposed cleanup alternatives relating to the remediation of environmental media on and
off site. The public involvement strategy consisted of a combination of written information,
support of the Fernald Citizens Task Force, meetings with local trustees and activist
groups, and public workshops to solicit public input. Fernald management has consistently
sought more effective ways to involve the public. One example is the envoy program.
Local governmental, business, and activist group meetings attended by FEMP management
during the March-May time frame included:
March 22 — Ross Merchants'Meeting
April 17 — Morgan Township Trustee Meeting
April 18 — Ross Township Trustee Meeting
April 24 — Crosby Township Trustee Meeting
April 25 — Ross Lions Club Meeting
May 17 — Cooperative Planning & Training Committee.
DOE will continue to seek effective ways to involve the public.
Dialogue about the on-property disposal option has been ongoing for several months, and
discussions will continue. Several members of the local community and a majority of the
Fernald Citizens Task Force, an independent site-specific advisory board, have expressed
their acceptance of the on-property disposal facility with the view that waste disposal is a
global issue (technological, political, and practical considerations need to be factored into
decision-making) and members of the community in other states do not want Fernald
wastes in their back yards either. Community members felt DOE should adopt a practical
long-term solution and get the worst materials off site and take responsibility for the rest of
the waste that can be safely kept on site. However, these same commentors also stated
that certain conditions must be met (e.g., buffer zone, geologic support). Some of these
commentors, including OEPA, discussed specific requirements that they felt should be
committed to before on-property disposal is implemented.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Deconber 8, 1995 10:43am A.3-20
-------
Comment Sheet
DOE is interested in your-comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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1 ^ U' S L,'
(Below information is optional)
Name: ANONYMOUS #14
Address: ; •
City: : •
Phone: '
Mailing List Additions
j Please add my name to the Femald Mailing List to receive additional information on the cleanup progress at the
j. Fernald Environmental Management Project. . '
Yes
No
A.3-21a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 14 Who's idea was/is the dump? Do they live here? Hell no they don't. Put in someone
1 back yard and move on.
Response:
The idea to construct an on-property disposal facility for some of the less contaminated
FEMP waste resulted from over seven years of study and was developed by DOE, EPA,
and OEPA, with input by the Fernald Citizens Task Force and the public through numerous
round tables and open forums. Several members of the Fernald Citizens Task Force do
live near the FEMP site and are long-term members of the community.
DOE understands that a segment of the community near the FEMP site wants all
contamination removed and shipped to an off-site location. DOE realizes that some
members of the public will think that it is unfair to propose that some contaminated FEMP
material remain in an engineered on-property disposal facility. But it is equally unfair to
expect other communities located in other areas of the country to accept large quantities of
contaminated material from the FEMP site. The current site-wide remedial approach, of
which Operable Unit 5 is a component, involves balancing the off-site disposal of the
FEMP's inventory of highly contaminated wastes with on-property disposal of less
contaminated soil and rubble.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1, 2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43«m A.3-21
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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(Below information is optional)
Name: ANONYMOUS #15
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-22a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 15 FRESH has sold out. This is a done deal, why waste our time and money. Ohio EPA
1 has been bought. U.S. EPA has been bought. No one thinks long term. The Citizen
Task Force did not decide anything. It gave DOE what it wanted. Local citizen input
was not wanted/not asked. Get outsiders to dump it here.
Response:
Dialogue about the on-property disposal option has been ongoing for several months, and
discussions will continue. Several members of the local community and a majority of the
Fernald Citizens Task Force, an independent site-specific advisory board, have expressed
their acceptance of the on-property disposal facility with the view that waste disposal is a
global issue (technological, political, and practical considerations need to be factored into
decision-making) and members of the community in other states do not want Fernald
wastes in their back yards either. Community members felt DOE should adopt a practical
long-term solution and get the worst materials off site and take responsibility for the rest of
the waste that can be safety kept on site. However, these same commentors also stated
that certain conditions must be met (e.g., buffer zone, geologic support). Some of these
commentors, including OEPA, discussed specific requirements that they felt should be
committed to before on-property disposal is implemented.
CRU5\ROD\MCM\APP-A\I$C-A-C.ROD\December 8, 1995 10:43sm A.3-22
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
U UJ
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/T c/W Aii
(Below information is optional)
Name: ANONYMOUS #16
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project. '.
Yes
No
A.3-23a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 16 How do we know no outside waste will come in. At some point in the past didn't all
1 (material) waste past thru Fernald so therefore it can be brought back.
Response:
The DOE concurs with the comment, and has no intention of using the disposal facility
associated with the Operable Unit 5 remedy to address wastes generated at off-site
locations. Additionally, the DOE has no intention of using existing or newly constructed
storage facilities located at the FEMPfor the long-term storage of wastes generated at off-
site locations. Specifically excluded from this prohibition are laboratory wastes generated
at off-site facilities resulting directly from the chemical, radiological or engineering
analysis ofFEMP waste materials or generated during the conduct of treatability or
demonstration type studies on FEMP waste materials. Such analyses and studies are
typically performed as an integral part of implementing a selected remedy at a cleanup
site.
Language has been added to Section 10.0 of this ROD to specifically identify that the
FEMP storage and future disposal facilities shall not be used for the long-term storage or
disposal of wastes generated at off-site locations.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 11, 1995 9:34am A.3-23
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
T )S ft) & f) Pn L1
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(Below information is optional)
Name: ANONYMOUS #17
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
//I-
A.3-24a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 17 It is bad policy to put a nuclear dump over a water supply. The dump cost are low
1 balled and the off site cost are escalated. True real GO A cost accountants need to
look at this first before we waste more dollars.
Response:
The cost estimates for the remedial alternatives were prepared using EPA's approved
CERCLA remedial investigation/feasibility study cost estimating method and used, as
required, a present-worth approach to allow fair comparison of the costs of different
alternatives that may involve different time frames for completion. As part of their
oversight responsibility, both EPA and OEPA conducted independent reviews of the
adequacy and worthiness of DOE's cost estimates and agreed that the estimates provide for
a fair comparison between the off-site and on-site remedial alternatives. DOE also
obtained an independent review of the Operable Unit 5 cost estimates from Argonne
National Laboratory that substantiated the adequacy of DOE's estimates.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-24
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
C AR PS
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(Below information is optional)
Name: ANONYMOUS #18
•Address: .~ ••'••- .
City: -..•.•--'-. -'•''.,:
Phone: ' :' • • •' "••' •"• .."".••
Mailing List Additions
Please add my name to the Femald Mailing List to receive Additional information on the cleanup progress at the
Fernald Environmental Management Project. .- " -- . - . _:
Yes
No
A.3-25a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 18 Lisa Crawford . . . and FRESHS' opinion do not represent Ross.
1
Response:
Stakeholder input is absolutely critical to DOE's present and future mission. DOE actively
solicits and considers the views of people and groups from different backgrounds
representing a wide variety of interests. DOE cannot be successful at the FEMP — or
anywhere else for that matter — without continuing dialogue among various stakeholder
groups.
The interests and opinions of all stakeholder groups are viewed with equal importance.
DOE does not assume that one group's opinions are snared by others. DOE realizes that
each group has their own opinions and concerns about the FEMP site.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-25
-------
Comment Sheet
DOE is interested in your, comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
TJ-
u niv
(Below information is optional)
Name: ANONYMOUS #19
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-26a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 19 What will the site look like when clean up is done?
1
Response:
The commentor is referred to the Proposed Plan for Operable Unit 5, dated April 1995.
On page 42 there is an artist's rendition of the FEMP skyline with the proposed on-
property disposal facility drawn in at its approximate location. Standing on Willey Road
looking north, the outline of the facility, which could cover up to 71 acres, is barely
visible.
Various renditions of how the FEMP might look following cleanup from other viewpoints in
the area were presented at the May 1995 Operable Unit 5 public meeting and are available
for public inspection if desired.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43«m A.3-26
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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(Below information is optional)
Name: ANONYMOUS #20
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-27a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 20 The process wears citizens down and the results are not important to DOE. Just work
1 the process. The Citizens Task Force was not citizen. It was outsider. 7,000 cubic
yards and 3,800 barrels or 1,000 cubic yards get the same attention and process. No
one ask the local people do you want a dump.
Response:
The Department of Energy has made every effort to solicit the concerns and preferences of
a wide range of stakeholders during the two public comment periods and in subsequent
meetings and discussions with others. The DOE carefully considered the public's
comments as it developed its proposals for final remediation of the Fernald site.
As part of the overall site program for community involvement at Fernald, numerous
opportunities were provided to the public during the past few years for commenting on
proposed cleanup alternatives relating to the remediation of environmental media on and
off site. The public involvement strategy consisted of a combination of written information,
meetings with local trustees and activist groups, workshops to solicit public input, and
support of the Fernald Citizens Task Force. Several nearby residents are members of the
Task Force, including a township trustee and a Ross school teacher. Fernald management
has consistently sought more effective ways to involve the public. One example is the
envoy program,
DOE will continue to seek effective ways to involve the public. Local governmental,
business, and activist group meetings attended by FEMP management during the March-
May time frame included:
March 22 — Ross Merchants Meeting
April 17 — Morgan Township Trustee Meeting
April 18 — Ross Township Trustee Meeting
April 24 — Crosby Township Trustee Meeting
April 25 — Ross Lions Club Meeting
May 17 — Cooperative Planning & Training Committee.
/
Many factors such as availability of waste storage space, transportation issues, political
climate, and cost affect the final decision. CERCLA, which governs the FEMP site,
requires that cleanup alternatives be compared against nine criteria. A cleanup alternative
must first meet two "threshold criteria" — overall protection of human health and the
environment, and compliance with applicable or relevant and appropriate requirements (or
justification of a waiver from any of these requirements), before being evaluated against
the next five "primary balancing criteria. " These primary balancing criteria include long-
term effectiveness and permanence; reduction oftoxicity, mobility, or volume through
treatment; snort-term effectiveness; implementability; and cost. The last two criteria, state
acceptance and community acceptance, are the "modifying criteria" and are evaluated
after the public comment period. The on-property disposal option meets the two threshold
criteria; it will protect human health and the environment.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Decanber 8, 1995 10:43am A. 3-27
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
v
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(Below information is optional)
Name: ANONYMOUS *21
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
.No
A.3-28a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 21 Is this the only site in the U.S. considering a local dump?
1
Response:
A number of sites across the United States have selected on-property disposal for materials
similar to those proposed for dispositioning at the FEMP. As examples, the Weldon Spring
site in St. Louis has adopted on-property disposal as its preferred remedy, as has the
Cannonsburg site in Pennsylvania. The FEMP is not the first nor the only radiologically
contaminated site that has selected on-property disposal as part of a balanced approach to
site remediation. A number of nonradiological CERCLA sites also employ on-property
disposal as pan of their preferred remedy.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-28
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
HoW can you guarantee that there will be.money to pay for the
upKeep ana repair or trie disposal ceiiv will atrust fund be established
or some other runaing mecnanism?
(Below information is optional)
Name: ANONYMOUS #22
Address:
City:
Phone: .
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-29a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Anon. 22 How can you guarantee that there will be money to pay for the upkeep and repair of
1 the disposal cell? Will a trust fund be established or some other funding mechanism?
Response:
As pan of its review of DOE's preferred remedy, EPA has determined that the selected
remedy for Operable Unit 5 will be protective of human health and the environment, and
EPA will use the 5-year review process under Section 121 (c) of CERCLA to ensure that
the selected remedy remains so. If the agency determines during a S-year review that the
remedy is no longer protective, it may review additional contingency actions and evaluate
whether they are appropriate for implementation at the site.
Funding to address upkeep and repair of the disposal facility, or to address any health-
protective concerns raised by EPA during the ongoing 5-year review process, will be
secured on an annual basis through the annual federal budgeting and appropriation
process. A trust fund to secure funds in advance of need is not envisioned at this time.
Under Section 107 of CERCLA, the federal government remains liable for all response
costs associated with the site (including the costs associated with long-term care),
regardless of when incurred. The guarantee that the commentor is seeking is best
embodied in the likelihood that the federal government will exist indefinitely as a viable
entity to honor its obligations in the future .
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Decembcr 8, 1995 10:43am A. 3-29
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
i^f>Q srf~1j~^ -^^****.*S\ ft^Mf . t^L s-*—~ ^Jl X7 * . » ft V Jt 9 /T X^
(Below information is optional)
Name:
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
X
Yes
A.3-30a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Beckner, M. There is no guarantee that the liner in the disposal facility will last 500 years. Please
1 remove all contaminated material as promised and quit wasting time and money.
Response:
The primary concern to DOE that is embodied in the commentor's question would be the
long-term protection of the Great Miami Aquifer if the disposal facility no longer received
long-term care. As pan of the feasibility study, DOE conducted a number of disposal
facility performance analyses to determine health- and environment-protective waste
acceptance criteria for the facility. As a fundamental basis of these analyses, no credit
was taken for active maintenance measures in the development of the waste acceptance
criteria. In effect, the waste acceptance criteria conservatively assume that active
maintenance measures and long-term care activities have ceased and that the facility rests
in a passive (i. e., abandoned) mode with no human attention provided. For the analyses,
effectiveness was defined as ensuring that protective standards (drinking water maximum
contaminant levels) were not exceeded in the Great Miami Aquifer at any point beneath the
disposal facility footprint. It was assumed in the analyses that the synthetic liner materials
in the disposal facility cap and base had failed, the leachate collection systems were no
longer functioning, and the natural earthen materials in the cap began to degrade over
time, allowing infiltration intb the facility to steadily increase. Even under the hypothetical
failure modes evaluated through the analyses, the disposal facility was found to be reliable
and effective over the full 200- to 1000-year performance period envisioned by federal •
regulations. The performance assessment provides a reasonable level of assurance that the
on-property disposal facility will provide negligible impacts to the Great Miami Aquifer
even in the absence of funding to conduct operation and maintenance activities, as the
commentor asks.
The most heavily contaminated material (25,000 cubic yards) will be shipped off site for
disposal. It is not feasible or cost effective to ship the rest (1,750,000 cubic yards), as
demonstrated by the feasibility study process and report. On-property disposal can and
will be made effective and protective.
Beckner, M. I feel this situation since 1984 has caused me and my family enough stress.
2
Response:
EPA and DOE recognize that neighbors of the FEMP have experienced considerable
impacts from both the operation of the plant and the proposed cleanup. In 1989 DOE
settled the class action lawsuit brought by area residents and agreed to pay $73 million for
emotional distress, medical monitoring, and residential real property diminution. DOE is
also partially funding the new public water supply being installed by the Hamilton County
Department of Public Works. DOE is committed to maintaining public involvement during
the implementation of the selected remedy and the ongoing long-term monitoring of the
site.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-30
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
lie comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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(Below information is optional)
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Name: _
Address: ~7O
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
A.3-31a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Beddow/ *I do not think that any on-site disposal should even be considered. Level FernaJd's
Walden, J. remaining buildings and get that crap away from here.
1 * Excavate the contaminated soil and sediment - do not leave it on the property.
"The bedrock will have to be escavated also. Make a 17 mile deep gravel pit, fence it
off with trees and electric fence and burry Fernald's reputation somewhere else.
Response:
DOE acknowledges that no one wants contamination near where they live but contaminated
material already exists at the FEMP. The cleanup plan proposed for the FEMP will
address this existing contamination and reduce the levels in the soil and groundwater to
concentrations deemed to be health-protective by federal environmental regulation.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightfy contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
As noted above, the remedy for Operable Unit 3 has not been finalized. However, as
currently envisioned the Operable Unit 3 remedy would include removing all of the
buildings at the site. There is no reason to excavate the bedrock beneath the FEMP which
lies approximately 200 feet below the ground surface. Over six years of study indicate that
the bedrock is not contaminated.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-31
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Beddow/ The aquifer will flush itself out if left alone. Set up a treatment facility down stream
Walden, J. instead of trying to pump it backwards. Thats kind of stupid.
2
Response:
The DOE has studied, as part of the remedial investigation/feasibility study process, what
would happen if the aquifer were left alone and permitted to flush itself out. Conditions in
the Great Miami Aquifer would not improve greatly in the foreseeable future if left alone.
Existing federal environmental regulations do not permit, except under select site-specific
conditions, waste sites being addressed under CERCLA to adopt remedies which include
the use of natural attenuation to achieve health-protective levels in aquifer systems
presently supplying potable drinking water to domestic wells. The National Contingency
Plan defines that it is the expectation of EPA that usable groundwater will be restored to
their full beneficial use within a reasonable time frame. In situations where this objective
cannot be practically attained, the National Contingency Plan establishes that actions will
be undertaken to prevent the further migration of the contaminant plume. The results of
the modeling performed to evaluate natural attenuation of the contaminant plumes at the
FEMP are reported in the Operable Unit 5 Remedial Investigation Report. This modeling
indicates that the levels of uranium in the affected portions of the Great Miami Aquifer will
not attain the proposed drinking water maximum contaminant level ft. e., 20 parts per
billion) within 1000 years. It is anticipated that the proposed remediation pumping system
will clean up the aquifer to 20 parts per billion in approximately 27 years.
The DOE recently installed a series of groundwater extraction wells in the Great Miami
Aquifer south of the FEMP. These wells are presently withdrawing contaminated
groundwater at a rate of approximately 1400 gallons per minute. As part of this removal
action a 20-inch polyethylene force main pipeline was installed to convey the extracted
groundwater to the newly constructed advanced wastewater treatment facility. The
advanced wastewater treatment facility was situated on-property at the FEMP to use
available utilities and federal land. It should be recognized that the selected remedy will
require the extraction of groundwater from several locations on the FEMP property, in
addition to a continuation of pumping operations in the South Plume area. These
additional extraction well locations are both north and south of the new treatment facility.
Thus, the new advanced wastewater treatment facility is centrally located to planned
groundwater pumping activities associated with the selected remedy for Operable Unit 5.
CRU5\ROD\MCM\APP-A\SSC-A-C.ROD\Deconber 8, 1995 10:43«m A.3-32
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Beddow/
Walden, J.
3
Beddow/
Walden, J.
4
NO one should be allowed to go on the property after the demolition. Keep it
restricted.
Response:
It is not the intent of DOE to attempt to establish a final future land use for the FEMP
through this decision document. DOE does recognize that the final remediation levels
identified in Section 9.0 of this ROD do establish the permissible concentrations of
contaminants which could remain at the site following completion of remedial actions.
These remaining concentrations of contaminants will present a potential for exposure to
future users of the FEMP.
The Ferndld Citizens Task Force issued recommendations regarding future use of the
Fernald property in May of 1995. In these recommendations, the Task Force
recommended that the area of the FEMP containing the disposal facility and associated
buffer zone remain under the continued ownership of the federal government. Additionally,
the Task Force recommended that the remaining portions of the FEMP property be made
available for the uses that are the most beneficial to the surrounding communities. While
the Task Force recommended prohibiting any son of agricultural or residential uses of the
remaining portions of the FEMP property (outside the disposal facility area), the Task
Force encouraged DOE to consult with local communities to establish their preferences for
future use and ownership of these areas of the site. Consistent with this recommendation,
DOE does not consider it prudent to insert enforceable provisions within this ROD to
provide for the continued federal ownership of the entire FEMP property.
Additionally, DOE considers that final, enforceable institutional control measures for
postremedial conditions at the FEMP should be established based upon an analysis of the
actual residual concentrations as measured in site soil and groundwater following the
completion of remedial actions; the measured concentrations and spatial distribution may .
differ from feasibility study projections. This difference in estimated versus measured
concentrations could have a significant impact on the required institutional controls
necessary to maintain continued protectiveness. In this ROD, DOE has elected to define
that institutional controls are a necessary component of the remedy to ensure continued
protectiveness, but that the specific institutional control provisions necessary to be applied
to postremedial site conditions will be defined during remedial design. The institutional
control provisions defined during remedial design may be modified during the remedial
action phase to accommodate the progressive findings of the field certification efforts. As
with all remedial design and remedial action documentation, the plan for institutional
controls at the FEMP, and any necessary modifications to it, will be subject to approval by
EPA and review by OEPA.
My family and I have decided to move because of Fernald Uranium Processing Plant.
Allius: Fernald Environmental Protection. (Beddow/Walden, J.)
Response:
Comment acknowledged.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\D*ceniber 8, 1995 10:43am A.3-33
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels1 (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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(Below information is optional)
Name: _
Address:
City:
la. U
Phone: 7 3f.'--g> 7 ^.
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-34a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Blake, J. This community has had enough! We do not want the storage cell!! We will be lied
1 to again and Fernald will start to take contaminated materials from other places. It
will get out of control and we will become one big toxic-contamin. community. The
people of this town have been contaminated enough. We've had our share!!!. No
more!
Response:
DOE acknowledges that no one wants contamination near where they live but contaminated
material already exists at the FEMP. The cleanup plan proposed for the FEMP will
address this existing contamination and reduce the levels in the soil and groundwater to
concentrations deemed to be health protective by federal environmental regulation.
DOE has no plans to bring contaminants to the FEMP site to be cleaned and then placed
in the on-property disposal facility. However, DOE is evaluating the potential cost savings
of treating some materials from other DOE sites at the FEMP and then shipping them back
to the originating facility for final disposal. There is much public concern regarding
placement of off-site waste in the site engineered disposal facility. The facility is being
designed to correct a problem that already exists at the FEMP. No consideration is being
given to placing waste from other sites in the FEMP engineered disposal facility.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1, 2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8. 1995 10:43«m A.3-34
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Blake, J.
1 (Contd.) The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium outside
the former production area of the FEMP and 20 parts per million within the former
production area. Current estimates indicate that placing all of the lightly contaminated
soil together in the disposal facility will produce an average concentration of about 100
pans per million of uranium in the facility. This average concentration is one-tenth of the
waste acceptance criteria for disposal in the on-property disposal facility, a tenfold safety
factor. It should be noted that sophisticated computer model simulations used to derive the
waste acceptance criteria, were completed assuming that there was no active maintenance
of the facility and that the synthetic barriers present in the facility (e.g., high-density
polyethylene membranes) were not functioning. These simulations indicate that even under
these extreme conditions, the facility would still be protective of the aquifer over the full
200- to 1000-year performance period envisioned by federal regulations.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-35
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
k?ltUjL)> A
3
4
i
(Below information is optional)
Name:
C
City:
Phone:
Mailing List Additions
Please add my name to the Feraald Mailing List to receive additional information on the cleanup progress at the
Feraald Environmental Management Project.
Yes
No
A.3-36a •
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Bommer, I am opposed for several reason, 1st this is a farm community. Can you be 100%
1 sure this will not seep into our food and water.
Response:
The proposed cleanup plan will correct an existing contamination problem and reduce the
levels of contamination within the environmental media at the site to levels deemed to be
health protective by federal environmental regulation. It cleans up the FEMP by getting
the material with higher levels of contamination away from the site, and provides a
strategy for permanently protecting human health and the underlying Great Miami Aquifer
by isolating the remaining less contaminated material in an engineered disposal facility at
the site.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria-will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\D«ember 8, 1995 10:43«m A.3-36
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Bommer, (Contd.)
1 (Contd.)
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium outside
the former production area of the FEMP and 20 parts per million within the former
production area. Current estimates indicate that placing all of the lightly contaminated
soil together in the disposal facility will produce an average concentration of about 100
parts per million of uranium in the facility. This average concentration is one-tenth of the
waste acceptance criteria for disposal in the on-property disposal facility, a tenfold safety
factor. It should be noted that sophisticated computer model simulations used to derive the
waste acceptance criteria were completed assuming that there was no active maintenance
of the facility and that the synthetic barriers present in the facility (e.g., high-density
polyethylene membranes) were not functioning. These simulations indicate that even under
these extreme conditions, the facility would still be protective of the aquifer over the full
200- to 1000-year performance period envisioned by federal regulations.
Bommer, We live in a flood zone, what about earthquake, tornadoes, or someone just blowing it
2 up for a personal reason.
Response:
DOE shares the public concern in ensuring that the final remedy at the FEMP is protective
of the Great Miami Aquifer and the public in general. Regarding the potential implications
of a flood on the integrity of the disposal facility, current design requirements require the
facility to be situated above the 500-year Great Miami River flood plain. Being a land
mass structure, tornadoes should have little or no impact on the integrity of the facility.
The Cincinnati area is in a moderate risk earthquake zone. The potential impacts of an
earthquake will be considered during the design phase for the disposal facility. The DOE
cannot guarantee that the disposal facility would not ever be the target of a bomb;
however, it should be noted that the materials within the disposal facility do not possess
any apparent quality or value which would potentially render it the subject of terrorist type
activities. Additionally, it should be noted that the materials planned to be placed within
the on-property disposal facility do not pose an acute threat to human health upon direct
contact or exposure. The materials are being placed into the disposal facility to preclude
long-term chronic exposure to the contaminated soil and ensure the permanent protection
of the water quality in the underlying Great Miami Aquifer.
Bommer, ... not to mention trying to sell our property with a waste plant so close.
3
Response:
The evaluation of the implications of the remedy on local property values is outside the
technical criteria defined by environmental regulation and guidance for consideration in
the development and detailed analysis of remedial alternatives. At several public meetings
regarding other FEMP related issues, members of the local community have provided
commentary on the potential beneficial impact the final completion of cleanup at the
Fernald site will have on local property values.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\D«cember 8, 1995 10:43«m A.3-37
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Bommer, I would like to see my kids grow up in a safe and healthy place.
4
Response:
Comment Acknowledged. The DOE is committed to implementing the selected remedy in a
expedient manner based upon the availability of funding. The selected remedy will remove
media containing site-introduced contaminants to the extent necessary to achieve levels
deemed health protective by federal environmental regulation. The excavated materials
will be permanently isolated in an on-property disposal facility specifically designed to
ensure long-term protectiveness.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-38
-------
Alternative 1: EXCAVATION AND OFF-SITE SHIPMENT
Land Use Objective 1: Full Unrestrictive Use
This is the only means of insuring environmental stability and protecting the Great Miami Aquifer.
The soil is contaminated with uranium at 100 times background levels to a depth of 20 feet. The
highest level, 8000 ppm, is 1600 times background level. Contamination near processing facilities
of acidic uranium solutions is 400 ppm, which is 80 times background level. Another 11 square
miles which is approximately 2 times background levels has all contributed to contamination of
the Great Miami Aquifer. The radioactive half life of the uranium isotopes 234 to 238 is 2.45 x
105 to 4.46 x 109 years respectively (this is almost a million to many, many millions of years).
The contamination of groundwater in the Great Miami Aquifer ranges from 50 ppb at the former
production area to 2100 ppb at South Field, a solid waste disposal area. The highest projected
contamination levels in the aquifer will occur within 1000 years.
Consideration of Alternative^A: Engineered Disposal Facility (on-site) will place the Great
Miami Aquifer at an unacceptable risk to introduction of additional radioactive material
contamination over time.
Denis Boudreau
55A Jacob Drive
Harrison, OH 45030
513-367-5981
A.3-39a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Boudreau, Alternative 1: Excavation and Off-Site Shipment
D. Land Use Objective 1: Full Unrestrictive Use
1
This is the only means of insuring environmental stability and protecting the Great
Miami Aquifer.
Consideration of Alt. 3A ... will place the Great Miami Aquifer at an unacceptable
risk to introduction of additional radioactive material contamination over time.
Response:
Alternative 1 is not the only means of ensuring environmental stability and protecting the
Great Miami Aquifer. The uranium concentrations listed in the commentor's letter exist
now in soil and groundwater. The proposed cleanup plan will correct an existing
contamination problem and reduce the levels of contamination within the environmental
media at the site to levels deemed to be health protective by federal environmental
regulation. It cleans up the FEMP by getting the material with higher levels of
contamination away from the site, and provides a strategy for permanently protecting
human health and the underlying Great Miami Aquifer by isolating the remaining less
contaminated material in an engineered disposal facility at the site.
The selected cleanup remedy at the FEMP has three objectives related to the Great Miami
Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer to
maximum beneficial use in a reasonable time frame, and protect the aquifer from future
contamination originating from the FEMP property. DOE recognizes that the aquifer is an
important national and local resource and that the FEMP site has adversely impacted an
approximate 200-acre area of the aquifer system. DOE also recognizes that if the FEMP is
not cleaned up it poses continued contamination risk to the public and to the aquifer.
DOE intends to eliminate this unacceptable risk by moving forward with a balanced
remediation approach. This approach gets the most contaminated materials away from the
aquifer (by shipping them off-site), restores the aquifer, and limits the quantity and
disposal configuration of the contaminated material remaining at the site. Completion of
the selected remedy will also provide for more beneficial use of the FEMP property outside
the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-39
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Boudreau, (Contd.)
D. Several different options were considered for the less contaminated material before the
1 (Contd.) excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium outside
the former production area of the FEMP and 20 parts per million within the former
production area. Current estimates indicate that placing all of the lightly contaminated
soil together in the disposal facility will produce an average concentration of about 100
parts per million of uranium in the facility. This average concentration is one-tenth of the
waste acceptance criteria for disposal in the on-property disposal facility, a tenfold safety
factor. It should be noted that sophisticated computer model simulations used to derive the
waste acceptance criteria were completed assuming that there was no active maintenance
of the facility and that the synthetic barriers present in the facility (e.g., high-density
polyethylene membranes) were not functioning. These simulations indicate that even under
these extreme conditions, the facility would still be protective of the aquifer over the full
200- to 1000-year performance period envisioned by federal regulations.
Boudreau,
D.
2
The highest projected contamination levels in the aquifer will occur within 1000 years.
Response:
This commentor is correct, assuming that no remediation of the site occurs. As noted
above, plans are to remediate the site and to provide long-term protection to the Great
Miami Aquifer by shipping the more highly contaminated material off site and containing
the lower concentration material on site in an engineered disposal facility.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-40
-------
Comment Sheet
DOE is interested in your .comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
r f>t
o r>
r n r> r
r>rj
f-4.
T7iT
Name: _
Address:
City:
(Below information is optional)
o
1 Phone:
i :'••-,
Mailing List Additions
1 Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
1 Fernald Environmental Management Project. . .' , ', , .
Yes
No y
A.S^la
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Brown, J. To put this site over our aquifer is insane. You cannot possibly protect our water
1 from contamination. You must not be thinking this situation over very carefully.
Response:
The proposal to put an engineered disposal facility over the Great Miami Aquifer was very
carefully thought out. This proposal is the culmination of over seven years of study. The
proposed cleanup plan will correct an existing contamination problem and reduce the
levels of contamination within the environmental media at the site to levels deemed to be
health protective by federal environmental regulation. It cleans up the FEMP by getting
the material with higher levels of contamination away from the site, and provides a
strategy for permanently protecting human health and the underlying Great Miami Aquifer
by isolating the remaining less contaminated material in an engineered disposal facility at
the site.
The selected cleanup remedy at the FEMP has three objectives related to the Great Miami
Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer to
maximum beneficial use in a reasonable time frame, and protect the aquifer from future
contamination originating from the FEMP property. DOE recognizes that the aquifer is an
important national and local resource and that the FEMP site has adversely impacted an
approximate 200-acre area of the aquifer system. DOE also recognizes that if the FEMP is
not cleaned up it poses continued contamination risk to the public and to the aquifer.
DOE intends to eliminate this unacceptable risk by moving forward with a balanced
remediation approach. This approach gets the most contaminated materials away from the
aquifer (by shipping them off-site), restores the aquifer, and limits the quantity and
disposal configuration of the contaminated material remaining at the site. Completion of
the selected remedy will also provide for more beneficial use of the FEMP property outside
the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be accomplished
via completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be about
3 percent of the current quantity of radioactivity present at the site. This 3 percent is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist ofUghtfy contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy for
Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the public
and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-41
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Brown, J.
1 (Cont'd)
(Contd.)
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and costs
were judged to be unacceptable. The decision as to what less contaminated material would
remain on site was developed with input from the Fernald Citizens Task Force and the
public through numerous round tables and open forums. Waste acceptance criteria for the
less contaminated material were developed for the engineered disposal facility to help
ensure protection of the aquifer. Only material that falls below the contamination level of
the waste acceptance criteria will be disposed of in the engineered disposal facility.
Material that does not meet the criteria will have to be either treated or shipped off site.
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium outside
the former production area of the FEMP and 20 parts per million within the former
production area. Current estimates indicate that placing all of the lightly contaminated
soil together in the disposal facility will produce an average concentration of about 100
parts per million of uranium in the facility. This average concentration is one-tenth of the
waste acceptance criteria for disposal in the on-property disposal facility, a tenfold safety
factor. It should be noted that sophisticated computer model simulations used to derive the
waste acceptance criteria were completed assuming that there was no active maintenance
of the facility and that the synthetic barriers present in the facility (e.g., high-density
polyethylene membranes) were not functioning. These simulations indicate that even under
these extreme conditions, the facility would still be protective of the aquifer over the full
200- to 1000-year performance period envisioned by federal regulations.
Brown, J.
2
Remove the Contamination! Do not have anyone elses hi to cleanup. (Brown, J.)
Response:
As stated above, plans are to remove the materials that constitute about 97 percent of the
radioactivity present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1,2, 4, and 5 in
conjunction with the anticipated Operable Unit 3 remedy and the current plans to remove
the site legacy waste and uranium product.
DOE has no plans to bring contaminants to the FEMP site to be cleaned and then placed
in the on-site disposal facility. However, DOE is evaluating the potential cost savings of
treating some materials from other DOE sites at the FEMP and then shipping them back to
the originating facility for final disposal. There is much public concern regarding
placement of off-site waste in the site engineered disposal facility. The facility is being
designed to correct a problem that already exists at the FEMP. No consideration is being
given to placing waste from other sites in the FEMP engineered disposal facility.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-42
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
TT
-**^>. £•;
S
-
2
(Below information is optional)
Name:
Address: /
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-43a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Clawson, M. I agree with remedial action for OU5 is Alternative 3A. My concern is the 300 ft.
1 area around disposal cell should be planted in trees and fence on outside of 300 ft area
so it would make it difficult for a trespasser to enter area.
Response:
The actual dimensions of the buffer area and access controls will be determined during the
remedial design/remedial action phase and will be designed to protect the disposal facility
from the trespasser and the trespasser from the facility.
Clawson, M. DOE should monitor area and be responsible for upkeep of disposal cell forever.
2
Response:
The remedy for Operable Unit 5 includes continued federal government ownership for the
portion of the site used for the disposal facility and the buffer area. Additionally, the
selected remedy provides for long-term monitoring and maintenance of the on-property
disposal facility.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December II, 1995 9:34«m A.3-43
-------
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. I believe the alternative selected in the Proposed Plan is protective of human health
1 and the environment. I believe the preferred alternative is the appropriate one when
considered in the context of the overall site cleanup. I personally support the concept
of a balanced approach where the low volume high concentration wastes go off site for
disposal and high volume lower concentration waste are disposed of in an engineered
facility on-site. I believe this approach provides the most protective for remediation
of the FEMP site.
Response:
Statement acknowledged. The selected remedy for Operable Unit 5 is consistent with the
"balanced approach" whereby more heavily contaminated materials will be shipped for
off-site disposal, while the large volume of materials exhibiting low concentrations of
contaminants will remain in an engineered disposal facility at the site.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\D«cember 8, 1995 10:43«m A.3-44
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. a) No hazardous waste can be disposed of in the facility.
2
Response:
To properly respond to this comment it is first important to highlight some pertinent
background regulatory considerations related to the term "hazardous waste" in context
with the types of contaminated materials present in Operable Unit 5. Under the terms of
both the federal (RCRA) and state regulations, a waste is considered hazardous, in
general, through one of two ways; by listing or by exhibiting a characteristic. Simply put,
a waste would be considered a hazardous waste if it appears on a series of specific lists
identified in the federal and state hazardous waste regulations. Waste appearing on these
lists is typically referred to as listed hazardous waste; examples include spent industrial
solvents, dry cleaning fluids and types of unused pesticides and herbicides.
For a waste to be hazardous by characteristic it must exhibit at least one of four
characteristics. The regulations define these characteristics and the testing protocols by
which a material is judged to establish its compliance position. The characteristics
evaluated to establish whether a waste is hazardous under RCRA are ignitability,
reactivity, corrosivity and toxicity. An ignitable waste is one which will combust upon the
application of a defined ignition source, e.g., xylene. A reactive waste is typically a waste
which will readily react in a violent manner when contacting water or air, e.g., unused
sodium, A corrosive waste is one that is very acidic or basic and could corrode its
container, e.g., spent acidic solutions.
To protect the integrity of the disposal facility liners the waste acceptance criteria prohibits
disposal of corrosive, reactive, and ignitable materials.
The characteristic of toxicity is measured by the tendency of the waste to leach a given
constituent that is regulated under RCRA. This characteristic examines a list of
inorganics, organics, pesticides and pofychlorinated biphenyls. The regulation establishes
a standardized testing protocol to be applied and individual concentration-based limits for
each constituent. In effect, the toxicity of the waste is inferred indirectly by measuring the
leachability of the components comprising the waste.
Operable Unit 5 addresses environmental media which have become contaminated through
releases from production and waste management facilities located at the site. The scope of
Operable Unit 5 does not include the examination of high concentration residues generated
from production processing. The releases that contaminated environmental media
originated as process losses during normal production operations and spills which
occurred over the 37-year history of uranium production; It is speculated that some
limited portion of the media became contaminated as a direct result of releases from
designated hazardous waste management units at the facility; the media so contaminated
would be categorized as hazardous waste. These media are typically regulated as
hazardous waste in that they contain a listed hazardous waste which was released from a
designated unit. The regulations currently set no lower concentration limit below which
the media would be considered not to represent a listed hazardous waste. Sampling
conducted as part of Operable Unit 5 has identified a quantity of soil which is presumed to
contain low concentrations of listed hazardous waste constituents in addition to uranium
and other radionuclides. This volume of soil would be labeled as listed hazardous waste
regardless of the measured concentration of the listed hazardous waste contained in the
soil. The adoption of a position that hazardous waste could not be received at the on-
property disposal facility would require off-site disposal of this contaminated soil.
CRU5\ROD\MCM\APP-A\FSC-A-C.ROD\December 11, 1995 9:34am A.3-45
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. (Contd.)
2 (Contd.)
Additionally, a limited quantity of Operable Unit 5 soil is expected to exhibit the
characteristic of toxicity for one or more inorganic or organic constituents. The most
significant volume of this category of contaminated soil would be associated with the
former trap range at the site. The current test method for determining if the characteristic
of toxicity is present would require that the spent lead bullets/shot in the soil be ground
and then subjected to an acidic leach process. This test method would render the soil
characteristically hazardous due to the presence of the spent lead bullets/shot in the soil.
Again, adoption of a prohibition of hazardous waste in the disposal facility would require
this soil to be treated to remove the hazard or sent off site for disposal.
In February 1993 EPA promulgated a federal regulation pertaining to the management of
remediation waste within what they termed "corrective action management units. "
Remediation waste is defined as all solid and hazardous wastes, and all media (including
groundwater, surface water, soil, and sediments) and debris, which contain listed
hazardous wastes or which themselves exhibit a hazardous waste characteristic, that are
managed for the purpose of implementing corrective action requirements. The EPA clearly
indicated in the preamble to this final rule that the substantive requirements of the
regulations for corrective action management units are expected to be applicable or
relevant and appropriate requirements for the remediation ofCERCLA sites, including
federal facilities, involving remediation of hazardous wastes. In essence, the adoption of
this promulgated EPA regulation would permit placement in the on-property disposal
facility of contaminated soil containing listed hazardous wastes or soil exhibiting a
characteristic of a hazardous waste.
EPA established this regulatory framework for the use of corrective action management
units because remediation of existing contamination problems is inherently different from
the management of as-generated industrial hazardous waste (58 Fed. Reg. 8658). The
original hazardous waste management program under the RCRA was designed to prevent
new releases. EPA noted a number of differences between as-generated hazardous wastes
resulting from operating processes and remediation wastes. One significant difference was
that remediation often involves management of large volumes of contaminated media, such
as soil and groundwater, with physical and chemical characteristics that can be quite
different from those of as-generated wastes. EPA has found that applying the stringent
requirements for as-generated hazardous wastes to remediation wastes can act as a
disincentive to more protective remedies and limit flexibility in choosing the most practical
remedy at a particular site. The agency noted in the preamble to the corrective action
management unit rulemaking that "application of regulatory requirements designed for as-
generated wastes to remediation wastes has proven problematic. In essence, standards
designed to prevent releases from occurring and to force hazardous waste generators to
internalize the costs posed by hazardous waste management can be highly
counterproductive when applied to wastes generated during remediation, where the release
has already occurred and the desired incentive is to increase, rather than decrease, waste
production. " EPA therefore developed regulations "for management of remediation wastes
that are better tailored to the realities of remediation actions. " The agency notes that the
goal related to corrective action decisions is to select a remedy that is fully protective, yet
reflects the technical and practical realities of the site.
CRU5\ROD\MCM\APP-A\SSC-A-C.ROD\December 8, 1995 10:43
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. (Contd.)
2 (Contd.)
To ensure the long-term protection of human health and the environment, Section 9 of this
ROD defines a series of waste acceptance criteria for the on-property disposal facility.
The criteria establish the maximum concentration of a given constituent which can be
present in the contaminated media for receipt in the on-property disposal facility to ensure
the long-term protection of the underlying aquifer. The criteria, including those for
uranium and the other constituents present on the list, were developed in an equivalent
manner employing a consistent set of technical input parameters. To compile the list of
waste acceptance criteria, each of the contaminants found to occur in the Operable Unit 5
media were individually evaluated. This list of contaminants included those that would be
labeled as hazardous waste under the current regulatory framework. Concentration-based
waste acceptance criteria were derived for those constituents which had a potential to
leach to the underlying aquifer within the 1000-year time frame in a concentration which
would exceed existing or proposed federal drinking waste standards (or a risk level of Iff5
where a drinking water standard was not available for a given constituent). In essence,
the selected remedy does not necessarily consider the regulatory definition of whether the
soil would be labeled as hazardous waste, but focuses on the individual concentration of
all contaminants that are present to determine the viability for the soil to be placed in the
on-property disposal facility. The soil which exhibits a concentration of a contaminant that
exceeds the waste acceptance criteria would not be considered for on-property disposal
unless subjected to some form of treatment to render the soil suitable for placement in the
facility. Additionally, the concentration-based waste acceptance criteria has been extended
to preclude the acceptance in the on-property disposal facility of any material that exhibits
the characteristics of reactivity, ignitability, or corrosivity. These additional restrictions
were added as a best management practice to ensure worker safety and the integrity of the
disposal facility lining and capping systems. Through the application of these waste
acceptance criteria, the selected remedy provides for the long-term protection of human
health, while at the same time providing an implementable and cost-effective strategy for
addressing the permanent disposal of the contaminated environmental media at the FEMP.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43«m A.3-47
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. (Contd.)
2 (Contd.)
In addition to the requirement that a health-protective remedy be adopted for a site
undergoing cleanup for RCRA-regulated substances (which is satisfied by the health-
protective waste acceptance criteria and final remediation levels adopted for the Operable
Unit 5 contaminated media), the corrective action management unit rule requires that the
remedy satisfy a regulatory preference for methods that enhance the long-term effectiveness
of the remedy through the application, as appropriate, of treatment technologies that
reduce toxicity, mobility, or volume of wastes that will remain in place after site closure.
In their comments on the Operable Unit 5 Proposed Plan, OEPA raised a stipulation
requiring treatment of the Operable Unit 5 soil materials that qualify as RCRA
characteristic hazardous waste ft. e., to remove the characteristic property associated with
the material) before placement in the disposal facility. Recognizing that DOE has
developed health-protective final remediation levels and waste acceptance criteria for all of
the Operable Unit 5 contaminants of concern, OEPA's additional stipulation concerning
the on-property disposal of characteristic waste has its origin in the need to satisfy, on a
site-specific basis, the regulatory preference for remedies that employ treatment. As stated
in the corrective action management unit rule, the decision to apply cost-effective treatment
is a case-by-case decision that must consider waste- and site-specific factors. OEPA has
designated the Operable Unit 5 soil that qualifies as RCRA characteristic waste as a site-
specific quantity of material that offers a reasonable opportunity to apply additional
treatment measures. Upon review of the site characterization data from the Operable
Unit 5 remedial investigation coupled with historical process knowledge, six geographic
areas of the FEMP have been identified where a reasonable potential exists for the
presence of soil that qualifies as containing RCRA characteristic waste. DOE agrees that
these six areas offer a reasonable, site-specific, and cost-effective opportunity to treat
additional materials before on-property disposal, in the interest of enhancing the long-term
effectiveness of the remedy through treatment techniques. The remedy described in
Section 9.0 of the ROD includes a commitment by DOE to search for and employ treatment
as necessary for characteristic hazardous waste in soil that originates from within the six
geographic areas.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Deconber 8, 1995 10:43am A.3-48
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. The disposal facility WAC for Uranium-232 must be set at a maximum of 346 pCi/g
3 or 1030 ppm for total uranium. The WAC must be an upper limit of concentration
acceptable into the disposal facility and may not be used as an average limit.
Response:
The waste acceptance criteria for the engineered disposal facility defined in the Feasibility
Study and Proposed Plan have been adopted as pan of the selected remedy for Operable
Unit 5. These criteria, as defined in Section 9 of this ROD, include the establishment of a
concentration-based waste acceptance criteria for total uranium of 1030 pans per million.
Assuming a natural distribution of the major isotopes of uranium (i.e., uranium-238, -235,
and -234), the 1030 parts per million waste acceptance criteria would convert to 346
picocuries per gram of uranium-238. This limit has been set as an upper permissible
concentration level for contaminated soil to be received into the on-property disposal
facility, and as such will not be used as an average limit.
The selected remedy provides- that soil exceeding this waste acceptance criteria will be
shipped for off-site disposal at an appropriate facility. DOE is committed to implementing
this remedy as defined in this decision document. However, DOE must also bring to the
commentor's attention that the availability of off-site disposal capacity cannot be assured
over the 10- to 25-year cleanup program associated with Operable Unit 5. In the event
off-site disposal capacity becomes unavailable or cost prohibitive at some point in the
future, DOE considers it important that flexibility be maintained and indicated in the ROD
so as to permit the application of treatment technologies to soil exceeding these acceptance
criteria to convert them to a form suitable for on-property disposal. The application of
such technologies would only occur following receipt of approval from EPA and input from
OEPA.
Crawford, L. . No disposal or long-term storage of off-site waste in the proposed engineered disposal
4 facility or any other facility on the FEMP site.
Response:
The DOE concurs with the comment, and has no intention of using the disposal facility
associated with the Operable Unit 5 remedy to address wastes generated from off-site
locations. Additionally, the DOE has no intention of using existing or newly constructed
storage facilities located at the FEMP for the long-term storage of wastes generated from
off-site locations. Specifically excluded from this 'prohibition are laboratory wastes
generated at off-site facilities resulting directly from the chemical, radiological or
engineering analysis of FEMP waste materials/contaminated media or generated during the
conduct of treatability or demonstration type studies on FEMP waste materials/
contaminated media. Such analyses and studies are typically performed as an integral pan
of implementing a selected remedy at a cleanup site.
Crawford, L. While I understand the need for a USEPA waiver and reluctantly support it, it must
5 allow and follow my comments under #2.
Response:
Statement acknowledged. Please see responses to the comments labeled Crawford 2, 3 and
4 above.
CRUS\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43am A.3-49
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. DOE must make a commitment within the OU5 ROD regarding government
6 ownership. DOE must/will provide a commitment to ensure the land-use to develop
the clean up standards is maintained into the future. DOE ownership is essential.
Response:
The comment raises the need to properly align the necessary institutional control provisions
for the FEMP with the future land use for the facility to ensure the continued protection of
human health. DOE agrees with the need for this alignment. It is not the intent of DOE
to attempt to establish a final future land use for the FEMP through this decision
document. DOE does recognize that the final remediation levels identified in Section 9.0
of this ROD do establish the permissible concentrations of contaminants which could
remain at the site following completion of remedial actions. These remaining
concentrations of contaminants will present a potential for exposure to future users of the
FEMP.
The Fernald Citizens Task Force issued recommendations regarding future use of the
Fernald property in May of 1995, recommending that the area of the FEMP containing the
disposal facility and associated buffer zone remain under the continued ownership of the
federal government. Additionally, the Task Force recommended that the remaining
portions of the FEMP property be made available for the uses that are the most beneficial
to the surrounding communities. While the Task Force recommended prohibiting any sort
of agricultural or residential uses of the remaining portions of the FEMP property (outside
the disposal facility area), the Task Force encouraged DOE to consult with local
communities to establish their preferences for future use and ownership of these areas of
the site. Consistent with this recommendation, DOE does not consider it prudent to insert
enforceable provisions within this ROD to provide for the continued federal ownership of
the entire FEMP property.
Additionally, DOE considers that final, enforceable institutional control measures for
postremedial conditions at the FEMP should be established based upon an analysis of the
actual residual concentrations as measured in site soil and groundwater following the
completion of remedial actions; the measured concentrations and spatial distribution may
differ from feasibility study projections. This difference in estimated versus measured
concentrations could have a significant impact on the required institutional controls
necessary to maintain continued protectiveness. In this ROD, DOE has elected to define
that institutional controls are a necessary component of the remedy to ensure continued
protectiveness, but that the specific institutional control provisions necessary to be applied
to postremedial site conditions will be defined during remedial design. The institutional
control provisions defined during remedial design may be modified during the remedial
action phase to accommodate the progressive findings of the field certification efforts. As
with all remedial design and remedial action documentation, the plan for institutional
controls at the FEMP, and any necessary modifications to it, will be subject to approval by
EPA and review by OEPA.
The need for institutional controls during the conduct of remedial actions and the
requirement for continued federal ownership of the disposal facility area at the FEMP have
been specifically identified in this ROD. More specific detail on the actual implementation
of these controls will be defined during remedial design.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\Dccember 8, 1995 10:43«m A.3-50
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. DOE must ensure public participation through the RD/RA. DOE must commit to
7 continuing the public involvement program during this time.
Response:
DOE is committed to continuing the active community involvement program currently in
place at the FEMP throughout the duration of remedial activities at the site. This issue
has been discussed at public meetings and has been the subject of a more focused
roundtable held -with interested members of the local community. Language has been
added to Section 9 of this ROD to formalize the commitment to continue the ongoing public
involvement program during the remedial design/remedial action process.
Crawford, L. DOE should attempt to do pollution prevention as much as possible during OU5
8 remedial actions. All methods available to reduce or eliminate discharges and releases
from the excavation and disposal activities should be considered during the design of
the system.
Response:
Pollution prevention will be a key consideration during remedial design for Operable
Unit 5. Considerations during remedial design will include minimizing discharges to the
Great Miami River to the extent practical, applying appropriate mitigative measures during
excavation and soil transport and staging operations to minimize fugitive dust emissions,
and ensuring the necessary controls to reduce the migration of contaminated soil and
surface water out of controlled areas during rain events. DOE's planned actions will be
documented during remedial design and subject to approval by EPA, formal review by
OEPA, and will be available for public inspection.
CRU5\ROD\MCM\APP-A\RSC-A-C.ROD\December 8, 1995 10:43«m A.3-51
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. DOE should commit to using and developing real-time monitoring. Data obtained
9 from the real-time monitoring and any other monitoring will be provided to the public
in a timely manner.
Response:
DOE is committed to executing a responsible and technically defensible environmental
monitoring program during and following the conduct of remedial actions at the FEMP.
Language committing DOE to perform this monitoring has been included in Section 9 of
this ROD. Specific details on the type and frequency of monitoring will be defined during
the remedial design phase. It is also expected that, as the site moves through the remedial
action process, changes will be necessary to this monitoring program to reflect changed
conditions at the site (e.g., completion of remedial action for one area of the site) or to
address the progressive findings of the program. Recognition of the need to modify the
monitoring program during and after remedial actions has also been identified in this
ROD.
Commercially available and emerging monitoring techniques that could provide real-time
or near real-time data on environmental releases will be considered during the
development of this monitoring program during remedial design.
The DOE currently has in place a program for reporting upon environmental monitoring
data collected at the FEMP including nonroutine releases (such as spills) and more routine
environmental discharges generated by site cleanup activities. As pan of the Operable
Unit 5 remedial design process, the existing site reporting system will be evaluated and
necessary changes effected to ensure the program is properly aligned with proposed
remedial activities. One goal of the reporting system will be to continue to report
environmental discharges to the local community and involved regulatory agencies in a
prompt and responsible manner. The proposed mechanisms and frequency of reporting
will be defined in the remedial design documentation for Operable Unit 5 and be subject to
EPA approval, formal review by OEPA, and will be made available for public inspection.
Crawford, L. During the implementation of the preferred alternative, DOE must use excavation and
10 waste management techniques which will prevent the dilution of waste concentrations
to meet the WAC's. DOE will not use dilution to meet the WAC or remediation
levels. This is unacceptable and will not be tolerated.
Response:
DOE agrees that an important consideration during the remedy implementation phase is to
ensure that proper excavation control and waste management practices are applied to
prevent the dilution of contaminated soil and increase the volume of soil requiring
disposal. DOE has no intention of using dilution as a mechanism to attain the waste
acceptance criteria for the disposal facility. DOE is compiling detailed procedures to
guide site-wide excavation operations for contaminated soil. These procedures, which will
be developed during the remedial design phase for Operable Unit 5, will clearly define
intended excavation methods that will ensure against such dilution taking place.
CRU5\ROD\MCM\APP-A\KSC-A-C.ROD\Dcconber 8, 1995 10:43am A.3-52
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FEMP-05ROD-6 FINAL
December 15, 1995
Crawford, L. DOE should be open in considering new technologies which may reduce the volume,
11 toxicity or mobility of wastes being disposed of on-site. I am personally requesting
that DOE remain open minded to the idea of additional technologies which could
result in a safer waste for on-site disposal.
Response:
DOE agrees that the FEMP should continue to be open to new technologies that may
reduce the volume, toxicity or mobility of wastes being disposed of on site. Language
expressing this commitment was provided in the Proposed Plan in the description of the
preferred alternative and has been incorporated in Section 9 of this ROD.
Crawford, L. I greatly support DOE's use of the proposed MCL for total uranium of 20 ug/1 as the
12 groundwater remediation level. I personally believe that remediation to this standard
will ensure the Great Miami Aquifer is restored to it full beneficial use. Any
proposed changes to the 20 ug/1 total uranium remediation standard would necessitate
a ROD amendment including a formal public comment period.
Response:
Consistent with Section 300.430(e)(2)(i)(C)ofthe National Contingency Plan, the DOE has
adopted the maximum contaminant levels under the Safe Drinking Water Act as relevant
and appropriate requirements to the restoration of the Great Miami Aquifer. Lacking a
final promulgated maximum contaminant level for uranium, DOE adopted, as pan of the
selected remedy, the maximum contaminant level proposed by EPA in July 1991 under the
Safe Drinking Water Act of 20 parts per billion as the final remediation level for
restoration of the aquifer. This proposed standard was adopted as a "To Be Considered"
requirement to the selected remedy.
The estimated costs for the restoration of the Great Miami Aquifer are, as would be
expected, very sensitive to the established final groundwater cleanup limits (final
remediation levels). While DOE is committed to fully restoring the aquifer to
health-protective levels, DOE must do so in full recognition of its role as a steward of
public funds. Within its stewardship role, the DOE must ensure that public funds are
committed only to remedial activities which yield a commensurate environmental or human
health-related benefit. As such, the DOE must evaluate the technical and economic
implications of pursuing adoption of the final maximum contaminant level for uranium,
once promulgated by EPA. Such a technical and economic evaluation will be warranted
regardless of whether the final maximum contaminant level for uranium represents a higher
or lower concentration-based limitation than the proposed 20 parts per billion standard.
In the event DOE considers it appropriate to pursue a change to the final remediation level
for uranium in groundwater identified in this decision document, DOE will initiate such a
change in a manner consistent with CERCLA, the National Contingency Plan and the terms
of the Amended Consent Agreement. As done throughout the remedial
investigation/feasibility study decision-making process, the DOE will involve the public in
any attempt to modify the final remedial level for uranium in the Great Miami Aquifer
from the 20 parts per billion value identified in Section 9 of this ROD.
CRUS\ROD\MCM\APP-A\RSC-A-C.ROD\December 11, 1995 9:34«m A.3-53
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Comments on tne Proposed Plan for OU 5 at the FEMP
Once again, being a nearby resident, let me state up front
that my preterence would be tor a total cleanup of the site
that would return the site to background levels and leave no
waste on site. However, since tecnnological, political, and
practical considerations must also come into play, I realize
that this is.probanly not going to nappen.
However, oefore the final ROD is decided upon I would like
to see a more realistic evaluation of the costs of the
proposed alternative. The costs of 0 i M were only figured
tor 30 years. This may be a standard way ot estimating
costs, out it does not accurately rerlect the true costs of
operating and monitoring a disposal cell at the FEMP versus
disposing ot the waste off-site. Because of the extremely
long naif-life ot uranium the 0 & M costs will continue year
atter year indet mi tely. However, if the waste were
disposed ot in an arid climate, the 0 tt. M costs would be
considerably less and would also be just a portion of the
costs ot monitoring a facility in an arid climate wnich also
accepts other wastes. Also, inevitably the cell will fail,
and probably need repairs to prevent further contamination
ot the Great Hiami Aquifer. Were these repair costs
included in the cost estimates? For a true picture of costs
you must look way beyond a 30 year time frame.
If a cell were built, and Congress cut the 0 & M funding
out, what would oe the worst case scenario for the cell, the
community and the environment?
The rest ot my comments are aimed at bringing up concerns
and suggestions relative to tne Proposed Plan for OU 5.
The ROD tor OU 5 snould clearly deal witn or state tne
toliowing:
T"
* No otf-site waste will be brought onto FEMP property i
for storage or disposal, c Detine otf-site waste as anytning 3
not currently on the site, except tor samples that were sent j
ott-site tor cnaracterization or treatability studies) —
T"
* No characteristic hazardous waste snould be placed in 4
the eel 1. —
* The ROD snould state that DOE will tollow a sort ot
ALARA-princip1e in designing and executing the remediation.
The remediation levels should be as close to background as
possiole given the technological, risk, and cost
constraints. It an additional process or activity could get
us substantially closer to background at a reasonable cost
and risk, this should be pursued. The goal should be
background levels, not just staying witnin a remediation
1 evel .
With this in mind, please clarify how an ALARA goal
ot 50 ppm U for soil was chosen.
A.3-54a
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•* ii. a disposal eel 1 i s bu i 11, 11 wi 1 1 be p I aced over 6
the oest geology on the site. JL
* LI a disposal cell is built, there should be constant j
oversight by an independent expert as the engineering, 7
construction and rilling are perrormea to insure that they j
are aone properly. Reports from the independent expert j
snould be part or the public record. "
!
* Lt a disposal cell is built, it should be built in
such a way that the contents can be accessed tor ruture j
remediation ertorts if needed. This ooes not mean it must 8
be in containers in neat rows, but be stored in a way that !
heavy machinery could get to it without lotting it in the i
air or increasing the risks to workers, community or the ^
environment unnecessari1y.
* It a cell is built, the cell designers should meet
with the stakeholders before they start work and as they
progress so that tney adequately understand the concerns ot
the stakeholders and can design the cell to account for
them. Also, the designers can snare their concerns with the
stakeholders as they do their work. Frequent 2-way j
communication will save time, money and headaches in the j_
long run.
* In order to minimize the size or the cell, reduction 1
of waste volume technologies should be studied extensively ,
berore and during any cell construction and filling. J
* If a cell is ouilt, it inevitably will fail to some j
degree at a ruture date. Therefore it must be designed to j
keep any aquirer contamination as far beiow 2Uppo as j
possible. Treatment tecnnologies that would help achieve 11
this should be studied extensively Derore ana auring the
cell construction and tilling. Consideration or treatment
technologies <.sucn as v i tr i r icat ion; should oe considered
ror the portions or the waste that approach the upper WAG
1 imi t. """
T"
* Groundwater should be remediateo to as far below 20 i
ppo as reasonanly achievable. it drinKing water standards 12
change over the years, the 20 ppb level should not be raised j
for remediation purposes at the FEMP. —
* Groundwater pumping and remediation should not end 13
without stakeholder input being actively sought. —'
* The remediation or the FEMP should comply with all |
laws that exist on the date the RODs are signed and should 14
only be changed to incorporate any future more stringent J_
laws.
* The 5 year reviews or the ROD ror erfectiveness !
snould include an analysis of tne then current technologies^ !
aoility to pursue rurther remediation. If at a ruture time -«c
a technology would allow tor a way to truly deactivate the
radioactivity or hazardous chemicals or for a way to greatly
enhance the long-term storage ot the material, we would want
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to oe able to evaluate it it was desirable to pursue rurther '_
action. This process would also call attention to the 'p
tecnnology researcn needs ot the DOE. —'
* Copies of the annual reports ana the 5 year reviews
snould be mailed to:
i. Ross, Crosby, and Morgan Townsmps
2. butler ana Hamilton Counties
3. OEPA, USEPA, ODH 16
4. Congressional ana State Reps that have the FEhP
in their district
5. Any resident, group or agency that wishes to DC.
on the maiI ing Iist
* DOE will be responsible tor requesting proper levels
of runaing tor remediation and 0 & M (including tuture
repairs) so that the Consent Agreements will be met. If
Congress does not provide adequate tunding, letters of
inadequate funding should go out to those on the aoove
mailing list. Derining "inadequate runding" snould be
worked out with the stakeholders. It at some time in the ...
tuture anotner agency takes over tne remediation and 0 a, M
tunctions ot the site, it must accept the responsibilities
in the RODs as well. The tederal government must retain
ownership ot the disposal cell and any area necessary for
maintaining the cell and controlling access to it. It
should retain ownership of any area where the land use must
be restricted to provide protectiveness for tne public and
the environment.
* DOE snould commit to detailing the 0 & M process !
within its Administrative orders so that future DOE decision 18
makers wiI I be clear about the importance or this ongoing j_^
task.
* The RODs should be entorcable witn tines and lawsuits -|g
it necessary. _L
* A mecnanism tor the stakeholders to initiate a j
request for tuture review and possible amendment ot tne ROD 20
snould be included in tne ROD. Pernaps a petition witn a j_
certain number or signatures.'
* If for some reason, the ROD for OU 5 can't be i
implemented tully, the ROD should be reopened with full I
public participation. Also, notice of any "Explanations ot 21
Significant Difrerences" or "Amendments to the ROD" snould j
be mailed to stakenolders on tne mailing list in addition to J^
publishing a notice in an area newspaper.
* There neeas to be a commitment that all tne RODs will j
be rollea up into one "big picture" ROD tnat will j
incorporate any improvements in the wordings in tne RODs j
that have evolvea over time. For example, the ROD for OU j 22
may nave sometning in it tnat no one naa tnougnt or wnen |
tney were writing earlier RODs. If appropriate, tnere j
snould be a mechanism to incorporate it into all or the j
RODs. ~
-------
* Air monitoring data during excavation, drying and
transport will be extremely important to the community and
workers. The best available devices and techniques should
be used to give the workers and community a clear picture of 23
air emissions. Real time monitoring should be done on a
routine basis. Action levels should be developed (.with the
community) so that work can be halted if they occur.
* Excavation techniques should be used that will not
"dilute" the waste as it is being dug up tor disposal.
* Any waiver given so that a disposal cell can be
built, must include wording to keep all otf-site waste rrom
entering the FEMP tor storage or disposal. It must also be 25
so site-specific that it does not create a precedent tor
future rederal or commercial disposal sites in the vicinity
ot the FEMP.
* The WAC ot I030ppm U ror the waste cell should never
be raised, but should be allowed to be lowered to account 26
ror. other OU decisions and volumes. It should be a maximum
number tor the waste going into the cell and not an average.
* A commitment to continue the public involvement
process that has been developed over the years should oe 27
stated clearly in the ROD. This should extend througn
design, remediation, and out into the 0 S. M years.
While the government may feel that the remediation will be
protective ot human nealth and the environment, I teel that
the public has the right to know whenever materials are
above the background levels for their area. That way the
public can decide for itself if it wants to be in contact
with such materials. Also, it allows the puolic to have the
inrormation needed to determine ir any additive or
multiplicative risks need to be considered if sucn materials
will be combined with other so-called "clean" materials.
unce cleanup is considered complete, all areas wnere the
public will have access and that are above background (even
ir they are below the cleanup criteria) snould be posted so
that the public can make informed choices as to any
exposures they might incur.
Submitted by Vicky Dastillung
b/ 30/95
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. However, before the final ROD is decided upon I would like to see a more realistic
1 evaluation of the costs of the proposed alternative. The costs of O & M were only
figured for 30 years. This may be a standard way of estimating costs, but it does
not accurately reflect the true costs of operating and monitoring a disposal cell at the
FEMP versus disposing of the waste offsite. Because of the extremely long half-life
of uranium the O & M costs will continue year after year indefinitely. However, if
the waste were disposed of in an arid climate, the O & M costs would be
considerably less and would also be just a portion of the costs of monitoring a
facility in an arid climate which also accepts other wastes. Also, inevitably the cell
will fail, and probably need repairs to prevent further contamination of the Great
Miami Aquifer. Were these repair costs included in the cost estimates? For a true
picture of costs you must look way beyond a 30 year time frame.
Response:
DOE agrees with the concerns raised by the commentor regarding the need for the long-
term care of the disposal facility well into the future, and the need to consider the costs
of this care when comparing alternatives. As will be explained below, the cost estimates
prepared for Operable Unit 5 alternatives specifically consider the long-term care needs
of the on-property disposal options.
The cost estimates used to compare the off-site and on-property options use present-worth
methods that are designed specifically to allow for fair comparison of engineering
alternatives that extend over different time periods. The 30-year period provides a basis
for comparing remedial alternatives and is not intended to signify the length of the
remedial actions or DOE's commitment to their upkeep. The 30-year period of
evaluation is specified in EPA remedial investigation/feasibility study cost estimating
guidance because it is typically used to evaluate engineering alternatives that have long-
term performance periods or which are expected to perform indefinitely. Thirty years is
selected by EPA for the analysis because it typically represents the threshold point in a
present-worth calculation beyond which additional yearly costs (while still accounted for)
do not appreciably affect the magnitude of the present-worth cost estimate. As an
example, DOE has estimated that the annyal maintenance and monitoring costs for the
disposal facility may be on the order of $1.4 million per year, and this figure was
furnished to the Fernald Citizens Task Force for inclusion in their Toolbox. To illustrate
the concept, if one performs a present-worth cost estimate using this $1.4 million per
year annual expenditure, and employs a discount rate of 5 percent and considers
expenditure periods of 10, 30, 50, 100, and 500 years, the following present-worth cost
estimates result: 10 years — $10.8 million; 30 years — $21.5 million; 50 years — $25.5
million; 100 years -$27.8 million; and 500 years - $28.0 million. Clearly, as the
performance period extends longer into the future the net effect on the present-worth
estimate decreases significantly. This is the proper way to compare expenditures of
money that have different duration periods over which they are spent, and EPA's
remedial investigation/feasibility study cost estimating guidance employs such methods to
compare remedial alternatives that contain differing performance periods.
It is also important to note that off-site disposal costs also represent inherent uncertainty
over time, in that both prices and availability of capacity may change. DOE attempted to
represent the off-site costs fairly by using prices that are representative of today's market,
but this market can change over the next 10 to 20 years as competition for off-site
capacity increases.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-54
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. (Contd.)
1 (Contd.)
DOE recognizes that under Section 107 of CERCLA it is liable for all response costs
associated with the remedy, including the costs of long-term care. DOE further
recognizes that these costs will extend indefinitely into the future and do not end with a
30-year time frame. DOE believes the long-term care costs associated with on-property
disposal were properly considered in the cost comparisons conducted during the
feasibility study.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-55
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. IF a cell were built, and Congress cut the O & M funding out, what would be the
2 worst case scenario for the cell, the community and the environment?
Response:
The primary concern to DOE that is embodied in the commentor's question would be the
long-term protection of the Great Miami Aquifer if the disposal facility no longer received
long-term, care. As pan of the feasibility study, DOE conducted a number of disposal
facility performance analyses to determine health- and environment-protective waste
acceptance criteria for the facility. As a fundamental basis of these analyses, no credit
was taken for active maintenance measures in the development of the waste acceptance
criteria. In effect, the waste acceptance criteria conservatively assume that active
maintenance measures and long-term care activities have ceased and that the facility rests
in a passive ft. e., abandoned) mode with no human attention provided. For the analyses,
effectiveness was defined as ensuring that protective standards (drinking water maximum
contaminant levels) were not exceeded in the Great Miami Aquifer at any point beneath
the disposal facility footprint. It was assumed in the analyses that the synthetic liner
materials in the disposal facility cap and base had failed, the leachate collection systems
were no longer functioning, and the natural earthen materials in the cap began to
degrade over time, allowing infiltration into the facility to steadily increase. Even under
the hypothetical failure modes evaluated through the analyses, the disposal facility was
found to be reliable and effective over the full 200- to 1000-year performance period
envisioned by federal regulations. The performance assessment provides a reasonable
level of assurance that the on-property disposal facility will provide negligible impacts to
the Great Miami Aquifer even in the absence of funding to conduct operation and
maintenance activities, as the commentor asks.
With regard to other pathways of exposure that may be of concern — such as inadvertent
access to the contents of the facility — the design of the facility does not rely on
institutional controls or active measures to prevent contact with the contents. While
institutional controls provide an additional margin of safety to prevent intruder access (or
damage to ihe facility) and are planned for, sufficient physical barriers are included in
the design to prevent intruder access and minimize erosional degradation of the cap over
the long term, even if operating in a passive ft.e., "abandoned") mode. Finally, the
average soil uranium concentration in the disposal facility following completion of the
remedy is estimated to be approximately 100 parts per million (a result of the 1030 parts
per million waste acceptance criteria for protecting the aquifer and the volume vs.
concentration relationships for the site's contaminated soil). Thus, if an intruder were
able to access the materials at some point in the future, he/she would be exposed to
concentrations that, on average, are not much greater than the 80 parts per million soil
cleanup level for Operable Unit 5 (which, as shown in the Operable Unit 5 Proposed
Plan, is protective of the undeveloped park user at a 10^ incremental lifetime cancer risk
level). By design, the worst case scenario for the disposal facility, the community, and
the environment, if the facility were abandoned completely due to a lack of funding, is
not much different than the scenario of all active maintenance measures taking place. As
a point of interest, the vast-majority of the cost associated with active maintenance lies in
the analytical monitoring that is required by federal regulation, rather than the need for
intensive or complex maintenance procedures at the disposal facility.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-56
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. No off-site waste will be brought onto FEMP property for storage or disposal.
3 (Define off-site waste as anything not currently on the site, except for samples that
were sent offsite for characterization or treatability studies.)
Response:
The DOE concurs with the comment, and has no intent to use the disposal facility
associated with the Operable Unit 5 remedy to address wastes generated at off-site
locations. Additionally, the DOE has no intention of using existing or newly constructed
storage facilities located at the FEMP for the long-term storage of wastes generated at
off-site locations. Specifically excluded from this prohibition are laboratory wastes
generated at off-site facilities resulting directly from the chemical, radiological or
engineering analysis of FEMP waste materials or generated during the conduct of
treatability or demonstration type studies on FEMP waste materials. The FEMP is
contractually obligated to accept these lab-generated wastes. Such analyses and studies
are typically performed as an integral part of implementing a selected remedy at a
cleanup site.
Language has been added to Section 9 of this ROD to specifically identify that the FEMP
storage and future disposal facility shall not be used for the long-term storage or disposal
of wastes generated at off-site locations. Language regarding the identified exclusion has
also been added to Section 9.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-57
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. No characteristic hazardous waste should be placed in the cell.
4
Response:
To properly respond to this comment it is first important to highlight some pertinent
background regulatory considerations related to the term "hazardous waste" in context
with the types of contaminated materials present in Operable Unit 5. Under the terms of
both the federal (RCRA) and state regulations, a waste is considered hazardous, in
general, through one of two ways; by listing or by exhibiting a characteristic. Simply
put, a waste would be considered a hazardous waste if it appears on a series of specific
lists identified in the federal and state hazardous waste regulations. Waste appearing on
these lists is typically referred to as listed hazardous waste; examples include spent
industrial solvents, dry cleaning fluids and types of unused pesticides and herbicides.
For a waste to be hazardous by characteristic it must exhibit at least one of four
characteristics. The regulations define these characteristics and the testing protocols by
which a material is judged to establish its compliance position. The characteristics
evaluated to establish whether a waste is hazardous under RCRA are ignitability,
reactivity, corrosivity and toxicity. An ignitable waste is one which will combust upon
the application of a defined ignition source, e.g., xylene. A reactive waste is typically a
waste which will readily react in a violent manner when contacting water or air, e.g.,
unused sodium. A corrosive waste is one that is very acidic or basic and could corrode
its container, e.g., spent acidic solutions.
To protect the integrity of the disposal facility liners the waste acceptance criteria
prohibits disposal of corrosive, reactive, and ignitable materials.
The characteristic of toxicity is measured by the tendency of the waste to leach a given
constituent that is regulated under RCRA. This characteristic examines a list of
inorganics, organics, pesticides and pofychlorinated biphenyls. The regulation
establishes a standardized testing protocol to be applied and individual concentration-
based limits for each constituent. In effect, the toxicity of the waste is inferred indirectly
by measuring the leachability of the components comprising the waste.
Operable Unit 5 addresses environmental media which have become contaminated
through releases from production and waste management facilities located at the site.
The scope of Operable Unit 5 does not include the examination of high concentration
residues generated from production processing. The releases that contaminated
environmental media originated as process losses during normal production operations
and spills which occurred over the 37-year history of uranium production. It is
speculated that some limited portion of the media became contaminated as a direct result
of releases from designated hazardous waste management units at the facility; the media
so contaminated would be categorized as hazardous waste. These media are typically
regulated as hazardous waste in that they contain a listed hazardous waste which was
released from a designated unit. The regulations currently set no lower concentration
limit below which the media would be considered not to represent a listed hazardous
waste. Sampling conducted as pan of Operable Unit 5 has identified a quantity of soil
which is presumed to contain low concentrations of listed hazardous waste constituents in
addition to uranium and other radionuclides. This volume of soil would be labeled as
listed hazardous waste regardless of the measured concentration of the listed hazardous
waste contained in the soil. The adoption of a position that hazardous waste could not
be received at the on-property disposal facility would require off-site disposal of this
contaminated soil.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 11, 1995 9:42am A.3-58
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FEMP-05ROD-6 FINAL
December 15, 1995
DastUlung, V. (Contd.)
4 (Contd.)
Additionally, a limited quantity of Operable Unit 5 soil is expected to exhibit the
characteristic of toxicity for one or more inorganic or organic constituents. The most
significant volume of this category of contaminated soil would be associated with the
former trap range at the site. The current test method for determining if the characteristic
of toxicity is present would require that the spent lead bullets/shot in the soil be ground
and then subjected to an acidic leach process. This test method would render the soil
characteristically hazardous due to the presence of the spent lead bullets/shot in the soil.
Again, adoption of a prohibition of hazardous waste in the disposal facility would require
this soil to be treated to remove the hazard or sent off site for disposal.
In February 1993 EPA promulgated a federal regulation pertaining to the management of
remediation waste within what they termed "corrective action management units. "
Remediation waste is defined as all solid and hazardous wastes, and all media (including
groundwater, surface water, soil, and sediments) and debris, which contain listed
hazardous wastes or which themselves exhibit a hazardous waste characteristic, that are
managed for the purpose of implementing corrective action requirements. The EPA
clearly indicated in the preamble to this final rule that the substantive requirements of the
regulations for corrective action management units are expected to be applicable or
relevant and appropriate requirements for the remediation ofCERCLA sites, including
federal facilities, involving remediation of hazardous wastes. In essence, the adoption of
this promulgated EPA regulation would permit placement in the on-property disposal
facility of contaminated soil containing listed hazardous wastes or soil exhibiting a
characteristic of a hazardous waste.
EPA established this regulatory framework for the use of corrective action management
units because remediation of existing contamination problems is inherently different from
the management of as-generated industrial hazardous waste (58 Fed. Reg. 8658). The
original hazardous waste management program under the RCRA was designed to prevent
new releases. EPA noted a number of differences between as-generated hazardous wastes
resulting from operating processes and remediation wastes. One significant difference
was that remediation often involves management of large volumes of contaminated media,
such as soil and groundwater, with physical and chemical characteristics that can be quite
different from those of as-generated wastes. EPA has found that applying the stringent
requirements for as-generated hazardous wastes to remediation wastes can act as a
disincentive to more protective remedies and limit flexibility in choosing the most practical
remedy at a particular site. The agency noted in the preamble to the corrective action
management unit rulemaking that "application of regulatory requirements designed for as-
generated wastes to remediation wastes has proven problematic. In essence, standards
designed to prevent releases from occurring and to force hazardous waste generators to
internalize the costs posed by hazardous waste management can be highly
counterproductive when applied to wastes generated during remediation, where the
release has already occurred and the desired incentive is to increase, rather than
decrease, waste production. " EPA therefore developed regulations "for management of
remediation wastes that are better tailored to the realities of remediation actions. " The
agency notes that the goal related to corrective action decisions is to select a remedy that
is fully protective, yet reflects the technical and practical realities of the site.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\D«canber 8, 1995 I2:24pm A.3-59
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastffling, V. (Contd.)
4 (Contd.)
To ensure the long-term protection of human health and the environment, Section 9 of
this ROD defines a series of waste acceptance criteria for the on-property disposal
facility. The criteria establish the maximum concentration of a given constituent which
can be present in the contaminated media for receipt in the on-property disposal facility
to ensure the long-term protection of the underlying aquifer. The criteria, including
those for uranium and the other constituents present on the list, were developed in an
equivalent manner employing a consistent set of technical input parameters. To compile
the list of waste acceptance criteria, each of the contaminants found to occur in the
Operable Unit 5 media were individually evaluated. This list of contaminants included
those that would be labeled as hazardous waste under the current regulatory framework.
Concentration-based waste acceptance criteria were derived for those constituents which
had a potential to leach to the underlying aquifer within the 1000-year time frame in a
concentration which would exceed existing or proposed federal drinking waste standards
(or a risk level oflO~5 where a drinking water standard was not available for a given
constituent). In essence, the selected remedy does not necessarily consider the regulatory
definition of whether the soil would be labeled as hazardous waste, but focuses on the
individual concentration of all contaminants that are present to determine the viability for
the soil to be placed in the on-property disposal facility. The soil which exhibits a
concentration of a contaminant that exceeds the waste acceptance criteria would not be
considered for on-property disposal unless subjected to some form of treatment to render
the soil suitable for placement in the facility. Additionally, the concentration-based waste
acceptance criteria has been extended to preclude the acceptance in the on-property
disposal facility of any material that exhibits the characteristics of reactivity, ignitability,
or corrosivity. These additional restrictions were added as a best management practice
to ensure worker safety and the integrity of the disposal facility lining and capping
systems. Through the application of these waste acceptance criteria, the selected remedy
provides for the long-term protection of human health, while at the same time providing
an implementable and cost-effective strategy for addressing the permanent disposal of the
contaminated environmental media at the FEMP.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8. 1995 12:24pm A.3-60
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastilling, V. (Contd.)
4 (Contd.)
In addition to the requirement that a health-protective remedy be adopted for a site
undergoing cleanup for RCRA-regulated substances (which is satisfied by the health-
protective waste acceptance criteria and final remediation levels adopted for the Operable
Unit 5 contaminated media), the corrective action management unit rule requires that the
remedy satisfy a regulatory preference for methods that enhance the long-term.
effectiveness of the remedy through the application, as appropriate, of treatment
technologies that reduce toxicity, mobility, or volume of wastes that will remain in place
after site closure. In their comments on the Operable Unit 5 Proposed Plan, OEPA
raised a stipulation requiring treatment of the Operable Unit 5 soil materials that qualify
as RCRA characteristic hazardous waste ft. e., to remove the characteristic property
associated with the material) before placement in the disposal facility. Recognizing that
DOE has developed health-protective final remediation levels and waste acceptance
criteria for all of the Operable Unit 5 contaminants of concern, OEPA's additional
stipulation concerning the on-property disposal of characteristic waste has its origin in
the need to satisfy, on a site-specific basis, the regulatory preference for remedies that
employ treatment. As stated in the corrective action management unit rule, the decision
to apply cost-effective treatment is a case-by-case decision that must consider waste- and
site-specific factors. OEPA has designated the Operable Unit 5 soil that qualifies as
RCRA characteristic waste as a site-specific quantity of material that offers a reasonable
opportunity to apply additional treatment measures. Upon review of the site
characterization data from the Operable Unit 5 remedial investigation coupled with
historical process knowledge, six geographic areas of the FEMP have been identified
where a reasonable potential exists for the presence of soil that qualifies as containing
RCRA characteristic waste. DOE agrees that these six areas offer a reasonable, site-
specific, and cost-effective opportunity to treat additional materials before on-property
disposal, in the interest of enhancing the long-term effectiveness of the remedy through
treatment techniques. The remedy described in Section 9.0 of the ROD includes a
commitment by DOE to search for and employ treatment as necessary for characteristic
hazardous waste in soil that originates from within the six geographic areas.
CRUS\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-61
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Dastillung, V.
5
Dastillung, V.
6
Dastillung, V.
7
FEMP-05ROD-6 FINAL
December 15, 1995
The ROD should state that DOE will follow a sort of ALARA-principle in designing
and executing the remediation. The remediation levels should be as close to
background as possible given the technological, risk, and cost constraints.
If an additional process or activity could get us substantially closer to background at
a reasonable cost and risk, this should be pursued. The goal should be background
levels, not just staying within a remediation level. Please clarify how an ALARA
goal of 50 ppm U for soil was chosen.
Response:
Recognizing that the cleanup levels for Operable Unit 5 soil are set at health-protective
levels, DOE concurs with this comment and is committed to applying as low as
reasonably achievable principles during remedy implementation. Language has been
added to Section 9 of the ROD to provide a commitment on the part of DOE to employ as
low as reasonably achievable principles throughout all aspects of the remedy as a means
to further enhance the protectiveness of the remedy.
The as low as reasonably achievable goal of 50 parts per million total uranium that was
cited in the Proposed Plan was selected because it is coincident with the generally
accepted technology-based lower limit for which real-time hand-held characterization
equipment can be used to conduct field screening of soil uranium levels. Thus, although
the Operable Unit 5 cleanup level is set at 80 parts per million total uranium, the FEMP
believes it can effectively screen to 50 parts per million in the field. The incremental cost
to excavate to a 50 parts per million level above and beyond the 80 parts per million
level is considered by DOE to provide benefits that outweigh the additional cost.
If a disposal cell is built, it will be placed over the best geology on the site.
Response:
DOE agrees and language is contained in the ROD signifying this commitment.
If a disposal cell is built, there should be constant oversight by an independent
expert as the engineering, construction and filling are performed to insure that they
are done properly. Reports from the independent expert should be part of the
public record.
Response:
DOE expects to follow all CERCLA requirements for implementation of remedial
design/remedial action activities for the Operable Unit 5 remedy, including those that
pertain to the availability of remedial design/remedial action documents for public
inspection. All of these will be conducted under EPA oversight. DOE acknowledges that
EPA has oversight authority and will be conducting their oversight activities in
accordance with their recent "Guidance on EPA Oversight of Remedial Designs and
Remedial Actions Performed by Potentially Responsible Parties " (EPA/540/G-90/001
April 1990). This document outlines the information that needs to be furnished by DOE
for public inspection and the procedures to be implemented to ensure that quality design
and construction practices are used, and that independent construction acceptance testing
is conducted. DOE believes that this level of independent oversight is adequate and does
not envision that an additional oversight group (in addition to EPA and its technical
review contractors) will be necessary.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-62
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. If a disposal cell is built, it should be built in such a way that the contents can be
8 accessed for future remediation efforts if needed. This does not mean it must be in
containers hi neat rows, but be stored hi a way that heavy machinery could get to it
without lofting it in the air or increasing the risks to workers, community or the
environment unnecessarily.
Response:
While the design of the facility is to Junction as a permanent (rather than temporary or
interim) site and that the need for access to the materials is unlikely, the contents of the
disposal facility would be amenable to access if necessary, and conventional measures
could be implemented to retrieve the contents if additional remediation were found to be
necessary.
Dastillung, V. If a cell is built, the cell designers should meet with the stakeholders before they
9 start work and as they progress so that they adequately understand the concerns of
the stakeholders and can design the cell to account for them. Also, the designers can
share then* concerns with the stakeholders as they do their work. Frequent 2-way
communication will save tune, money and headaches in the long run.
Response:
DOE concurs with the comment and such stakeholder interactions are planned during the
remedial design and implementation phase of the project. DOE is committed to
continuing the active community involvement program currently in place at the FEMP
throughout the duration of remedial activities. This issue has been discussed at public
meetings and has been the subject of a more focused roundtable meeting held with
interested members of the local community. Language has been added to Section 9 of
this ROD to formalize the commitment to continue the ongoing public involvement
program during the remedial design/remedial action process.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-63
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. In order to minimize the size of the cell, reduction or waste volume technologies
10 should be studied extensively before and during any cell construction and filling.
Response:
DOE concurs with the comment that the FEMP should continue to be open to new
technologies that may reduce the volume, toxicity or mobility of wastes being disposed of
onsite. Language has been included in Section 9 of this ROD documenting DOE's
commitment to continue to evaluate new and emerging technologies for application to the
contaminated media associated with Operable Unit 5. Included within this language is a
commitment by DOE to evaluate two such technologies during remedial design: physical
separation (to potentially reduce volume) and a soil amendment process (to potentially
reduce contaminant mobility). DOE will conduct engineering studies of these two
technologies during remedial design to assess the viability of applying them as pan of the
Operable Unit 5 remedy.
Analysis of physical separation during the remedial investigation/feasibility study
identified significant constraints to applying the technique at the FEMP as a lead
component of the remedy. One of the most important constraints identified during the
remedial investigation/feasibility study was the determination that the contamination in
site soil was distributed across all size fractions making up the soil. This hindered the
ability to separate out one specific size fraction by physical methods and release this
portion of the soil, without further treatment, for unrestricted use as backfill at the site.
Much work is continuing through the DOE complex on soil washing and in particular on
physical separation methods. Process improvements may emerge that can improve the
viability of this or other techniques for application at the FEMP. DOE is committed to
applying such techniques if they enhance the overall performance and permanence of the
selected remedy.
Dastillung, V. If a cell is built, it inevitably will fail to some degree at a future date. Therefore it
11 must be designed to keep any aquifer contamination as far below 20 ppb as possible.
Treatment technologies that would help achieve this should be studied extensively
before and during the cell construction and filling. Consideration of treatment
technologies (such as vitrification) should be considered for the portions of the waste
that approach the upper WAC limit.
Response:
As mentioned in the previous response, DOE concurs that the FEMP should continue to
be open to new technologies that may reduce the volume, toxicity or mobility of wastes
being disposed of onsite. Language has been included in Section 9 of this ROD
documenting DOE's commitment to continue to evaluate new and emerging technologies
for application to the contaminated media associated with Operable Unit 5. The soil
amendment process is one technology cited in the ROD that DOE will be examining
during remedial design to further reduce the leachability of uranium from contaminated
soil placed in the disposal facility.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-64
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FEMP-O5ROD-6 FINAL
December 15, 1995
Dastillung, V. Groundwater should be remediated to as far below 20 ppb as reasonably achievable.
12 If drinking water standards change over the years, the 20 ppb level should not be
raised for remediation purposes at the FEMP.
Response:
DOE is committed to the application of as low as reasonably achievable principles in the
restoration of groundwater. DOE disagrees, however, that if the 20 parts per billion
proposed uranium standard for drinking water is raised in the future as part of final
standard setting, that consideration should not be given to raising the final remediation
level for the Great Miami Aquifer. Consistent with Section 300.430(e)(2)(i)(C)ofthe
National Contingency Plan, the DOE has adopted the maximum contaminant levels under
the Safe Drinking Water Act as relevant and appropriate requirements to the restoration
of the Great Miami Aquifer. Lacking a final promulgated maximum contaminant level for
uranium, DOE adopted, as part of the selected remedy, the maximum contaminant level
proposed for uranium by EPA in July 1991 under the Safe Drinking Water Act of 20
parts per billion as the final remediation level for restoration of the aquifer. This
proposed standard was adopted as a "To Be Considered" requirement to the selected
remedy.
The estimated costs for the restoration of the Great Miami Aquifer are, as would be
expected, very sensitive to the established final groundwater cleanup limits (final
remediation levels). While DOE is committed to fully restoring the aquifer to health-
protective levels, DOE must do so in full recognition of its role as a steward of public
funds. Within its stewardship role, the DOE must ensure that public funds are committed
only to remedial activities which yield a commensurate environmental or human health-
related benefit. As such, the DOE must evaluate the technical and economic implications
of pursuing adoption of the final maximum contaminant level for uranium, once it is
promulgated by EPA. Such a technical and economic evaluation will be warranted
regardless of whether the final maximum contaminant level for uranium represents a
higher or lower concentration-based limit than the proposed 20 parts per billion
standard. In the event DOE considers it appropriate to pursue a change to the final
remediation level for uranium in groundwater identified in this decision document, DOE
will initiate such a change in a manner consistent with CERCLA, the National
Contingency Plan and the terms of the Amended Consent Agreement.
CRU5\ROD\MCMV>iPP-A\RSC-D-F.ROD\December 11, 1995 9:42«m A.3-65
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. Groundwater pumping and remediation should not end without stakeholder input
13 being actively sought.
Response:
DOE agrees with the comment and acknowledges that the administrative process for final
site closeout accommodates public and stakeholder input. At the completion of the
remedy, once EPA has concluded that remedial levels have been attained, EPA will
initiate the formal process for project closeout. As pan of the process, DOE will be
required to submit a project closeout report for EPA's review and approval. This report
includes documentation that the performance standards have been met. Once EPA
approves the report, EPA initiates the site deletion process as described in EPA OSWER
Directive 9320.2-3A, "Procedures for Completion and Deletion of National Priority List
Sites " (April, 1989). The process is initiated by the EPA regional office and EPA
headquarters and the State of Ohio are given the opportunity to review and comment on
the delisting decision. A deletion administrative record (known as a "deletion docket")
that contains all pertinent information supporting the deletion recommendation is
assembled and made available to the public. A national notice of intent to delete the site
is published in the Federal Register and a similar notice is published in a local
newspaper of general circulation. A 30-day public comment period is required, during
which public and stakeholder input on the project closeout report, the deletion decision,
and all supporting information is sought.
CRUS\ROD\MCMVJ>P-A\RSC-D-F.ROD\D«wnbCT 8, 1995 12:24pm A.3-66
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. The remediation of the FEMP should comply with all laws that exist on the date the
14 RODs are signed and should only be changed to incorporate any future more
stringent laws.
Response:
This comment raises the issue of the "freezing" of legal requirements by the ROD process
that are in effect at the time of ROD signature. As required by CERCLA, DOE must
comply with all laws identified as applicable or relevant and appropriate requirements for
the selected remedy as they-exist at the time of ROD signature. These applicable or
relevant and appropriate requirements are identified in Appendix B of this Record of
Decision, and become binding upon ROD signature. During the 5-year review process,
EPA reviews each ongoing or completed remedy to determine if it continues to be health
protective. If a determination is made that additional response actions are warranted to
ensure protectiveness, EPA can require the ROD to be reopened. A future revision in a
law ft. e., an applicable or relevant and appropriate requirement) that results in a more
stringent performance standard would need to be evaluated on a site-specific basis by
EPA from the perspective of overall protection of human health and the environment.
Under EPA policy a revised applicable or relevant and appropriate requirement does not
automatically result in a ROD modification, unless EPA decides that the change renders
the remedy to be no longer protective. Similarly, if a future revision to an applicable or
relevant and appropriate requirement results in a less stringent performance standard •
than existed at the time of ROD signature, the ROD is not automatically revised
downward to account for the change. In this instance, DOE (or other stakeholder) would
need to request a revision to the ROD to accommodate the downward change, and EPA
would need to examine the request from a perspective of the overall effect on the
protectiveness of the remedy. As long as the change still met protectiveness requirements
defined in the National Contingency Plan, EPA could potentially accommodate the
request for a change through the ROD amendment process (which requires an
opportunity for public comment). EPA generally applies the National Contingency Plan
risk range as the benchmark for deciding whether an applicable or relevant and
appropriate requirement revision occurring after ROD signature requires a modification
to the ROD.
Dastillung, V. The 5 year reviews of the ROD for effectiveness should include an analysis of the
15 then current technologies' ability to pursue further remediation. If at a future tune
a technology would allow for a way to truly deactivate the radioactivity or hazardous
chemicals or for a way to greatly enhance the long-term storage of the material, we
would want to be able to evaluate if it was desirable to pursue further action. This
process would also call attention to the technology research needs of the DOE.
Response:
Generally, EPA's 5-year review process is focused on protectiveness to ensure that a
remedial action remains protective of public health and the environment and is
functioning as designed. The scope of the review is statutory in nature and is conducted
by EPA, rather than the responsible party. DOE will be conducting an ongoing review
of emerging technologies for the treatment of soil before placement in the engineered
disposal facility. DOE's commitment to evaluate such technologies extends over the life
of the remedy and is focused on identifying cost-effective technologies, should they
become available in the future, that can further enhance the long-term permanence of the
disposal facility. DOE will identify a schedule for reporting the results of the reviews to
EPA as part of the Operable Unit 5 Remedial Design Work Plan.
CRU5\ROD\MCMVU>P-A\RSC-D-F.ROD\Decanber 8, 1995 12:24pm A. 3-67
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastfflung, V.
16
Dastilluhg, V.
17
Copies of the annual reports and the 5 year reviews should be mailed to:
1. Ross, Crosby and Morgan Townships
2. Butler and Hamilton Counties
3. OEPA, USEPA, ODH
4. Congressional and State Reps that have the FEMP in their district
5. Any resident, group or agency that wishes to be on the mailing list.
Response:
DOE public affairs has been made aware of this request.
DOE will be responsible for requesting proper levels of funding for remediation and
O & M including future repairs) so that the Consent Agreements will be met. If
Congress does not provide adequate funding, letters of inadequate funding should go
out to those on the above mailing list. Defining "inadequate funding" should be
worked out with the stakeholders. If at some time in the future another agency
takes over the remediation and O & M functions of the site, it must accept the
responsibilities in the RODs as well. The federal government must retain ownership
of the disposal cell and any area necessary for maintaining the cell and controlling
access to it. It should retain ownership of any area where the land use must be
restricted to provide protectiveness for the public and the environment.
Response:
In accordance with Section XX of the Amended Consent Agreement, DOE is required to
pursue all necessary steps to obtain timely funding to meet its obligations under the
Agreement. Regarding the sending of letters to specific parties defining the adequacy of
funds, DOE public affairs has been made aware of this request.
Responsibility for the site and its institutional requirements will be retained by the federal
government regardless of what agency serves as the long-term site custodian. The need
for institutional controls during the conduct of the remedial actions and the requirement
for continued federal ownership of the disposal facility area at the FEMP have been
specifically identified in Section 9 of the ROD. The language in Section 9 provides for
the following institutional control provisions:
• Continuation of access controls at the FEMP during the period of remediation
• Provision of alternate water supply to residences and industrial users whose
current wells are located within an area of the aquifer exhibiting FEMP
contaminant concentrations exceeding final remediation levels for groundwater
• Continued federal ownership of the area comprising the disposal facility and
associated buffer zones
• Implementation of deed restrictions or continued federal ownership of the
remaining areas of the FEMP, as necessary to ensure continued protection of
human health. Jf ownership of portions of the FEMP is transferred in the future,
restrictions will be included in the deed, and proper notifications will be provided
as required by CERCLA.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\DecOTber 8, 1995 12:24pm A.3-68
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. DOE should commit to detailing the O & M process within its Administrative orders
18 so that future DOE decision makers will be clear about the importance of this
ongoing task.
Response:
The operations and management process for soil and groundwater will be defined in
future remedial design and implementation documents that are required under CERCLA.
Remedy performance monitoring and the verification/certification sampling activities that
will be used to certify that remedial goals have been met will be conducted under EPA
oversight. DOE recognizes the importance and enforceability of the CERCLA
requirements and believes that the CERCLA process adequately stresses the importance of
these activities.
Dastillung, V.
19
The RODs should be enforceable with fines and lawsuits if necessary.
Response:
EPA and DOE concur that the RODs are enforceable, legal instruments that are binding
by law.
Dastillung, V. A mechanism for the stakeholders to initiate a request for future review and possible
20 amendment of the ROD should be included in the ROD. Perhaps a petition with a
certain number of signatures?
Response:
As stated in the National Contingency Plan, EPA can consider additional, new
information if it comes to light to reopen the ROD in the future. Stakeholders, if they
identified new concerns, would need to bring such information to EPA's attention to
initiate the process. Generally, the new information would need to demonstrate that the
remedy was no longer protective in its current configuration, and that alternate actions
were necessary.
Dastillung, V. If for some reason, the ROD for Operable Unit 5 can't be implemented fully, the
21 ROD should be reopened with full public participation. Also, notice of any
Explanation of "Significant Differences" or "Amendment to the ROD" should be
mailed to stakeholders on the mailing list in addition to publishing a notice in an
area newspaper.
Response:
DOE concurs with this process, and the noted actions mirror National Contingency Plan
requirements and EPA's recent guidance on technical impracticability decisions (EPA
OSWER Directive 9234.2-25, "Guidance for Evaluating the Technical Impracticability of
Groundwater Restoration," October, 1993). As stated in this guidance, termination of a
CERCLA remedial action for technical impracticability reasons before attainment of
remediation levels constitutes a fundamental change in the remedy, requiring a ROD
amendment and a full 30-day public comment period.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-69
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. There needs to be a commitment that all the RODs will be rolled up into one "big
22 picture" ROD that will incorporate any improvements in the wordings in the RODs
that have evolved over tune. For example, the ROD for Operable Unit 3 may have
something in it that no one had thought of when they were writing earlier RODs. If
appropriate, there should be a mechanism to incorporate it into all of the RODs.
Response:
Generally, the Operable Unit 5 ROD provides the mechanism that the commentor is
seeking. The Operable Unit 5 ROD establishes site-wide cleanup levels that match the
representative final land use adopted for the site. Language has been added to the ROD
in Section 9 that states that the Operable Unit 5 cleanup levels apply to the footprints of
the other operable units. If new issues come to light during the development of the
Operable Unit 3 ROD that have site-wide implications, they can also be worded
accordingly to apply to the other operable units.
Dastillung, V. Air monitoring data during excavation, drying and transport will be extremely
23 important to the community and workers. The best available devices and techniques
should be used to give the workers and community a clear picture of air emissions.
Real tune monitoring should be done on a routine basis. Action levels should be
developed (with the community) so that work can be halted if they occur.
Response:
DOE is committed to executing a responsible and technically defensible environmental
monitoring program during and following the remedial actions at the FEMP. Language
committing DOE to perform this monitoring has been included in Section 9 of this ROD.
Specific details on the type and frequency of monitoring will be defined during the
remedial design phase. It is also expected that, as the site moves through the remedial
action process, changes will be necessary to this monitoring program to reflect changed
conditions at the site (e.g.,£ompletion of remedial action for one area of the site) or to
address the progressive findings of the program. Recognition of the need to modify the
monitoring program during and after remedial actions has also been identified in this
ROD.
Commercially available and emerging monitoring techniques which could provide real-
time or near real-time data on environmental releases will be considered during the
development of this monitoring program during remedial design.
The DOE currently has in place a program for reporting upon environmental monitoring
data collected at the FEMP, including nonroutine releases (such as spills) and more
routine environmental discharges generated by site cleanup activities. As pan of the
Operable Unit 5 remedial design process, the existing site reporting system will be
evaluated and necessary changes effected to ensure the program is properly aligned with
proposed remedial activities. One goal of the reporting system will be to continue to
report environmental discharges to the local community and involved regulatory agencies
in a prompt and responsible manner. The proposed mechanisms and frequency of
reporting will be defined in the remedial design documentation for Operable Unit 5 and
be subject to EPA approval, formal review by OEPA, and will be made available for
public inspection.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\Decanber 8. 1995 12:24pm A.3-70
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. Excavation techniques should be used that "will not dilute" the waste as it is being
24 dug up for disposal.
Response:
DOE agrees that an important consideration during the remedy implementation phase is
to ensure that proper excavation control and waste management practices are applied to
prevent the dilution of contaminated soil and increase the volume of soil requiring
disposal. DOE has no intention of using dilution as a mechanism to attain the waste
acceptance criteria for the disposal facility. DOE is planning to compile detailed
procedures to guide site-wide excavation operations for contaminated soil. These
procedures, which will be developed during the remedial design phase for Operable
Unit 5, will clearly define intended excavation methods that prevent such dilution from
taking place. Excavation protocols and procedures developed during remedial design
will take into consideration techniques to minimize the potential for dilution of
contaminated soil before final disposition.
Dastillung, V. Any waiver given so that a disposal cell can be built, must include wording to keep
25 all off-site waste from entering the FEMP for storage or disposal. It must also be so
site-specific that it does not create a precedent for future federal or commercial
disposal sites in the vicinity of the FEMP.
Response:
DOE concurs with the concept raised by the comment and notes that this concern mirrors
the concerns of OEPA.
The ROD is the mechanism by which EPA grants the waiver to the Ohio solid waste
disposal restrictions for siting the disposal facility over a sole-source aquifer. The issues
raised by the commentor are addressed in Section 9 of the ROD, and DOE believes that
the appropriate language is present that satisfies the commentor's concerns.
CRUS\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-71
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. The WAC of 1030 ppm U for the waste cell should never be raised, but should be
26 allowed to be lowered to account for other Operable Unit decisions and volumes. It
should be a maximum number for the waste going into the cell and not an average.
Response:
DOE concurs with the comment. The waste acceptance criteria for the engineered
disposal facility, defined in Section 9 of this ROD, include the establishment of a
concentration-based waste acceptance criteria for total uranium of 1030 parts per
million. This limit has been set as an upper permissible concentration level for
contaminated soil to be received into the on-property disposal facility, and as such will
not be used as an average limit.
The selected remedy provides that soil exceeding this waste acceptance criteria will be
shipped off site for disposal at an appropriate facility. DOE is committed to
implementing this remedy as defined in this decision document. DOE must, however, also
bring to the commentor's attention that the availability of off-site disposal capacity cannot
be assured over the 10- to 25-year cleanup program associated with Operable Unit 5. In
the event off-site disposal capacity becomes unavailable or cost prohibitive at some point
in the future, DOE considers it important that flexibility be maintained and indicated in
the ROD so as to permit the application of treatment technologies to soil exceeding these
acceptance criteria to convert them to a form suitable for on-property disposal. The
application of such technologies would only occur following receipt of approval of EPA
and input from OEPA.
Dastillung, V. A commitment to continue the public involvement process that has been developed
27 over the years should be stated clearly in the ROD. This should extend through
design, remediation, and out into the O & M years.
Response:
The DOE would like to thank local members of the public for their continued commitment
to providing meaningful input on the cleanup process at the FEMP. This long-term,
ongoing input, including the comments received during the formal public review period
on the Operable Unit 5 Proposed Plan, has played an important role in the formulation
of the remedial strategy embodied in this ROD.
DOE is committed to continuing the active community involvement program currently in
place at the FEMP throughout the duration of remedial activities at the site. This issue
has been discussed at public meetings and has been the subject of a more focused
roundtable meeting held with interested members of the local community. Language has
been added to Section 9 of this ROD to formalize the commitment to continue the ongoing
public involvement program during the remedial design/remedial action process.
CRU5\ROD\MCM\APP-A\RSC-I>F.ROD\December 8, 1995 12:24pm A.3-72
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FEMP-05ROD-6 FINAL
December 15, 1995
Dastillung, V. While the government may feel that the remediation will be protective of human
28 health and the environment, I feel that the public has the right to know whenever
materials are above the background levels for their area. That way the public can
decide for itself if it wants to be in contact with such materials. Also, it allows the
public to have the information needed to determine if any additive or multiplicative
risks need to be considered if such materials will be combined with other so-called
clean materials. Once cleanup is considered complete, all areas where the public will
have access and that are above background even if they are below the cleanup
criteria) should be posted so that the public can make informed choices as to any
exposures they might incur.
Response:
DOE concurs that the extent of FEMP-related above-background contamination should be
noted in documents that are available for public inspection. The Operable Unit 5
Remedial Investigation and Feasibility Study Reports and the Proposed Plan have
depicted areas surrounding the FEMP that have received above-background levels of
FEMP constituents. These documents have been made available to the public for
inspection and currently reside in the public record. Following completion of the
Operable Unit 5 remedy, a Project Completion Report will be prepared that will
document all of the new (post remedial investigation/feasibility study) analytical sampling
that will be conducted to confirm and certify that cleanup levels have been attained. This
information will be made available for public inspection as part of EPA's site closeout
process. Before final closeout and deletion of the site from the National Priorities List
(an activity performed by EPA), a 30-day public comment period is required, at which
time public and stakeholder review and comment of the supporting information regarding
the attainment of cleanup levels will be sought. DOE does not agree, however, that
areas that exceed background following remediation should be physically posted as such.
The cleanup levels that have been selected for the Operable Unit 5 remedy are health
protective and have been subject to review by the public and other stakeholders through
the public participation process. The information depicting the levels that remain in the
environment following remediation will be available for public review through the public
participation activities that accompany project closeout.
CRU5\ROD\MCMViPP-A\RSC-D-RROD\Deconber 8, 1995 12:24pm A.3-73
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F- D U t U 4 F P E '=•
(-' . 'J 1
Post-It'" brand fax transmlttal memo 7671 »oipag»«
Depi.1
Fax*
From —
Phone'*
Fax #
June 29, 1995
Mr. Gary Stegner
Director, Public Information
U.S. DOE Fernald Office
P.O. Box 538705 "
Cincinnati, Ohio 45253-8705
RE: Comments on the Proposed Plan for Remediation of OU 5
Dear Mr. Stegner,
The purpose of this letter is to submit comments on OU 5's Proposed
Plan. I support the decision to seek a balanced approach in the
remediation efforts for Fernald, with higher concentrations of
waste shipped off-site and lower concentrations of waste remaining
on-site in an engineered disposal facility. I can accept the
preferred alternative if the following issues are addressed and
implemented in the OU 5 ROD.
1. Meaningful public involvement beyond the ROD and throughout
the RD/RA process. DOE's commitment to this involvement is
essential due to the implications of this alternative and must
be included in the ROD.
2. Continued efforts in technology development should proceed in
an attempt to discover more effective methods for treatment
and disposal of the waste streams designated for the disposal
cell. Efforts should continue to develop technology that may
one day have the ability to remove additional contamination
from the soils without total destruction of the existing eco-
system present on the site.
3. The waste acceptance criteria (WAC) must be established at a
maximum of 346 pCi/g with the option to be lowered depending
on the decisions yet to be made regarding the other operable
units. The WAC is to be an upper limit maximum, no averaging
or dilution of contaminants will be permitted in meeting the
WAC.
4. The use of the proposed MCL for Uranium of 20 ppb as the
remediation level for groundwater should be maintained and not
increased. Any changes to this standard cannot occur without
public involvement in the decision making process. This must
be included in the OU 5 ROD.
5. Waste generated from outside the FEMP will not be allowed to
be disposed of within the FEMP boundaries under any
circumstances. This includes, but is not limited to hazardous,
toxic, radioactive, and any and all waste/contaminates which
were not a result of on-site activities.
2
i
i
4
i
i
5
A.3-74a
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Page -2-
OU 5 Comments
r™~
6. Additional discharges of contaminates during the remediation
of OU 5 should be avoided when possible. Methods to achieve -,
minimal releases during remediation should be conducted
throughout the RD/RA process.
7. Real time monitoring and other monitoring activities should be
implemented during remediation and for the period for which
the materials contained within the disposal cell pose a threat ,.
and risk to human health and the environment. These monitoring
activities should be conducted on a regular and frequent basis
with the results provided to the public in a timely manner.
8. The DOE or how it may evolve in the future under another
name and the federal government must retain ownership of the
FEMP property. This is necessary to provide adequate
institutional controls to protect the site and limit future
land use so as to not allow discharges of the contaminants
left in the soils. Full disclosure and restrictions of the
property must be included in the deed to the land. This must
be included in the OU 5 ROD.
hw«
9. ALARA principles must be utilized during the RD process. -|Q
j_^
10. A USEPA waiver of the Ohio solid waste siting criteria should ,—
only be granted if the DOE abides by the WAC upper limit
stipulations has described in comment J3 above, the waiver
specifically states that there will be no off-site waste 11
disposed of on the FEMP property and no on-site waste will be |
capped and left in place. i \
Should you have any questions or comments please feel free to
contact me.
Submitted by,
Dunn
7781 New Haven Rd.
Harrison, Ohio 45030
cc:file
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FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P. I support the decision to seek a balanced approach in the remediation efforts for
1 Fernald, with higher concentrations of waste shipped off-site and lower
concentrations of waste remaining on-site in an engineered disposal facility.
Response:
Statement acknowledged. The selected remedy for Operable Unit 5 is consistent with the
"balanced approach " whereby more heavily contaminated materials will be shipped for
off-site disposal, while the large volume of materials exhibiting low concentrations of
contaminants will remain in an engineered disposal facility at the site.
Dunn, P. Meaningful public involvement beyond the ROD and throughout the RD/RA process.
2 DOE's commitment to this involvement is essential due to the implications of this
alternative and must be included in the ROD.
Response:
The DOE would like to thank members of the public for their continued commitment to
providing meaningful input on the cleanup process at the FEMP. This long-term,
ongoing input, including the comments received during the formal public review period
on the Operable Unit 5 Proposed Plan, has played an important role in the formulation
of the remedial strategy embodied in this ROD
DOE is committed to continuing the active community involvement program currently in
place at the FEMP throughout the duration of remedial activities at the site. This issue
has been discussed at public meetings and has been the subject of a more focused
roundtable held with interested members of the local community. Language has been
added to Section 9 of this ROD to formalize the commitment to continue the ongoing
public involvement program during the remedial design/remedial action process.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-74
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December 15, 1995
Dunn, P. Continued efforts in technology development should proceed in an attempt to
3 discover more effective methods for treatment and disposal of the waste streams
designated for the disposal cell. Efforts should continue to develop technology that
may one day have the ability to remove additional contamination from the soils
without total destruction of the existing eco-system present on the site.
Response:
DOE agrees that the FEMP should continue to be open to new technologies that may
reduce the volume, toxicity or mobility of wastes being disposed ofonsite. Language
expressing this commitment was provided in the Proposed Plan in the description of the
preferred alternative, and has been incorporated in Section 9 of this ROD.
In the second sentence, the commentor is considered to be referring to the efforts to
investigate the viability of applying soil washing technologies at the FEMP. Attempts to
apply this technology led the principal investigators performing these treatability studies
to focus on chemical separation. In the performance of laboratory, bench- and pilot-
scale studies on chemical separation, the chemical extraction process typically led to the
generation of a washed soil that could no longer sustain biological life. The DOE is
continuing to examine the soil washing process as a support technology to the selected
Operable Unit 5 remedy. Tn Section 9 of this ROD, the DOE has committed to
specifically examine physical separation techniques to apply to contaminated soil. One
benefit of physical separation techniques is that the washed soil would retain its potential
to support biological activity. Analysis of physical separation during the remedial
investigation/feasibility study identified significant constraints to applying the technique at
the FEMP as a leading component of the remedy. One of the most important constraints
was the determination that the contamination in site soil was distributed across all size
fractions making up the soil. This hindered the ability to separate out one specific-size
fraction by physical methods and release this portion of the soil, without further
treatment, for unrestricted use as backfill at the site. Much work is continuing through
the DOE complex on soil washing and in particular on physical separation methods.
Process improvements may emerge that improve the viability of this, or other, techniques
for application at the FEMP.
CRU5\ROD\MCMWVPP-A\RSC-D-F.ROD\De«mber 8, 1995 12:24pm A.3-75
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P. The waste acceptance criteria (WAC) must be established at a maximum of 346
4 pCi/g with the option to be lowered depending on the decisions yet to be made
regarding the other operable units. The WAC is to be an upper limit maximum, no
averaging or dilution of contaminants will be permitted in meeting the WAC.
Response:
The waste acceptance criteria for the engineered disposal facility defined in the
Feasibility Study Report and Proposed Plan have been adopted as pan of the selected
remedy for Operable Unit 5. These criteria, as defined in Section 9 of this ROD, include
the establishment of a concentration-based waste acceptance criteria for total uranium of
1030 parts per million. Assuming a natural distribution of the major isotopes of uranium
(i.e., uranium-238, -235, and -234), the 1030 parts per million waste acceptance criteria
would convert to 346 picocuries per gram of uranium-238. This limit has been set as an
upper permissible concentration level for contaminated soil to be received into the on-
property disposal facility, and as such will not be used as an average limit.
The selected remedy provides that soil exceeding this waste acceptance criteria will be
shipped off site for disposal at an appropriate facility. DOE is committed to
implementing this remedy as defined in this decision document. However, DOE must also
bring to the commentor's attention that the availability of off-site disposal capacity cannot
be assured over the 10- to 25-year cleanup program associated with Operable Unit 5. In
the event off-site disposal capacity becomes unavailable or cost prohibitive at some point
in the future, DOE considers it important that flexibility be maintained and indicated in
the ROD so as to permit the application of treatment technologies to soil exceeding these
acceptance criteria to convert them to a form suitable for on-property disposal. The
application of such technologies would only occur following receipt of approval of EPA
and input from OEPA.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-76
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P. The use of the proposed MCL for Uranium of 20 ppb as the remediation level for
5 groundwater should be maintained and not increased. Any changes to this standard
cannot occur without public involvement in the decision making process. This must
be included in the OU 5 ROD.
Response:
Consistent with Section 300.430(e)(2)(i)(C)ofthe National Contingency Plan, the DOE
has adopted the maximum contaminant levels under the Safe Drinking Water Act as
relevant and appropriate requirements to the restoration of the Great Miami Aquifer.
Lacking a final promulgated maximum contaminant level for uranium, DOE adopted, as
pan of the selected remedy, the maximum contaminant level proposed by EPA in
July 1991 under the Safe Drinking Water Act of 20 parts per billion as the final
remediation level for restoration of the aquifer. This proposed standard was adopted as
a "To Be Considered" requirement to the selected remedy.
The estimated costs for the restoration of the Great Miami Aquifer are, as would be
expected, very sensitive to the established final groundwater cleanup limits (final
remediation levels). While DOE is committed to fully restoring the aquifer to
health-protective levels, DOE must do so in full recognition of its role as a steward of
public funds. Within its stewardship role, the DOE must ensure that public funds are
committed only to remedial activities which yield a commensurate environmental or
human health-related benefit. As such, the DOE must evaluate the technical and
economic implications of pursuing adoption of the final maximum contaminant level for
uranium, once promulgated by EPA. Such a technical and economic evaluation will be
warranted regardless of whether the final maximum contaminant level for uranium
represents a higher or lower concentration-based limitation than the proposed 20 parts
per billion standard. In the event DOE considers it appropriate to pursue a change to
the final remediation level for uranium in groundwater identified in this decision
document, DOE will initiate such a change in a manner consistent with CERCLA, the
National Contingency Plan and the terms of the Amended Consent Agreement. As done
throughout the remedial investigation/feasibility study decision-making process, the DOE
will involve the public in any attempt to modify the final remedial level for uranium in
the Great Miami Aquifer from the 20 parts per billion value identified in Section 9 of this
ROD.
CRU5\ROD\MCM\APP-A\SSC-D-F.ROD\De«mber II. 1995 9:42am A.3-77
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P. Waste generated from outside the FEMP will not be allowed to be disposed of within
6 the FEMP boundaries under any circumstances. This includes, but is not limited to
hazardous, toxic, radioactive, and any and all waste/contaminates which were not a
result of on-site activities.
Response:
The DOE concurs with the comment, and has no intention of using the disposal facility
associated with the Operable Unit 5 remedy to address wastes generated from off-site
locations. Additionally, the DOE has no intention of using existing or newly constructed
storage facilities located at the FEMP for the long-term storage of wastes generated from
off-site locations. Specifically excluded from this prohibition are laboratory wastes
generated at off-site facilities resulting directly from the chemical, radiological or
engineering analysis of FEMP waste materials/contaminated media or generated during
the conduct of treatability or demonstration type studies on FEMP waste materials/
contaminated media. Such analyses and studies are typically performed as an integral
pan of implementing a selected remedy at a cleanup site.
Language has been added to Section 9 of this ROD to specifically identify that the FEMP
storage and future disposal facility shall not be used for the long-term storage or disposal
of wastes generated from off-site locations. Language regarding the identified exclusion
has similarly been added to Section 9. For the other FEMP operable units, both 4 and 1
are committed to off-site shipment of their waste. The final ROD for Operable Unit 2
contains language clearly prohibiting off-site waste being brought to the FEMP for
disposal in their on-property disposal facility. When Operable Unit 3 prepares its ROD
next year, similar language will be included. DOE's commitment on this matter covers
the entire FEMP site.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 11, 1995 9:42«m A.3-78
-------
FEMP-05ROD-3 FINAL
December 15, 1995
Dunn, P. Additional discharges of contaminates during the remediation of OU 5 should be
7 avoided when possible. Methods to achieve minima] releases during remediation
should be conducted throughout the RD/RA process.
Response:
The design and implementation of measures to minimize releases during the conduct of
remedial action will be a key consideration of DOE during remedial design for Operable
Unit 5. Considerations during remedial design will include minimizing discharges to the
Great Miami River to the extent practical, applying appropriate mitigative measures
during excavation and soil transport and staging operations to minimize fugitive dust
emissions, and ensuring the necessary controls to reduce the migration of contaminated
soil and surface water out of controlled areas during rain events. DOE's planned actions
will be documented during remedial design and subject to approval by EPA, formal
review by OEPA, and will be available for public inspection.
In the second sentence, the commentor requests that DOE continue to implement
measures throughout remedial design/remedial action to minimize releases. Implicit in
this comment is the need for DOE to commit to continue to examine new or emerging
technologies during the 10-year or longer remediation time frame to find ways to improve
upon the mitigative measures originally laid out during remedial design. DOE agrees
that this is a prudent action which may help reduce overall environmental releases during
remedial action.
Language has been added to Section 9 of this ROD to identify a commitment on the part
of the DOE to continue to examine, throughout the duration of remedial action, new
methods or technologies to improve upon the mitigative measures being used to minimize
environmental releases.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-79
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P. Real time monitoring and other monitoring activities should be implemented during
8 remediation and for the period for which the materials contained within the disposal
cell pose a threat and risk to human health and the environment. These monitoring
activities should be conducted on a regular and frequent basis with the results
provided to the public in a timely manner.
Response:
DOE is committed to executing a responsible and technically defensible environmental
monitoring program during and following the conduct of remedial actions at the FEMP.
Language committing DOE to perform this monitoring has been included in Section 9 of
this ROD. Specific details on the type and frequency of monitoring will be defined during
the remedial design phase. It is also expected that, as the site moves through the
remedial action process, changes will be necessary to this monitoring program to reflect
changed conditions at the site (e.g., completion of remedial action for one area of the
site) or to address the progressive findings of the program. Recognition of the need to
modify the monitoring program during and after remedial actions has also been identified
in this ROD.
Commercially available and emerging monitoring techniques which could provide real-
time or near real-time data on environmental releases will be considered during the
development of this monitoring program during remedial design.
The DOE currently has in place a program for reporting upon environmental monitoring
data collected at the FEMP, including reporting upon nonroutine releases (such as spills)
and more routine environmental discharges generated by site cleanup activities. As pan
of the Operable Unit 5 remedial design process, the existing site reporting system will be
evaluated and necessary changes effected to ensure the program is properly aligned with
proposed remedial activities. One goal of the reporting system will be to continue to
report environmental discharges to the local community and involved regulatory agencies
in a prompt and responsible manner. The proposed mechanisms and frequency of
reporting will be defined in the remedial design documentation for Operable Unit 5 and
be subject to EPA approval, formal revieyf by OEPA, and will be made available for
public inspection.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A. 3-80
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P. The DOE or how it may evolve in the future under another name and the federal
9 government must retain ownership of the FEMP property. This is necessary to
provide adequate institutional controls to protect the site and limit future land use so
as to not allow discharges of the contaminants left in the soils. Full disclosure and
restrictions of the property must be included in the deed to the land. This must be
included hi the OU 5 ROD.
Response:
The comment raises the need to properly align the necessary institutional control
provisions for the FEMP with the fixture land use for the facility to ensure the continued
protection of human health. DOE agrees with the need for this alignment. It is not the
intent of DOE to attempt to establish a final future land use for the FEMP through this
decision document. DOE does recognize that the final remediation levels identified in
Section 9.0 of this ROD do establish the permissible concentrations of contaminants
which could remain at the site following completion of remedial actions. These
remaining concentrations of contaminants will present a potential for exposure to future
users of the FEMP.
The Fernald Citizens Task Force issued recommendations regarding future use of the
Fernald property in May of 1995, recommending that the area of the FEMP containing
the disposal facility and associated buffer zone remain under the continued ownership of
the federal government. Additionally, the Task Force recommended that the remaining
portions of the FEMP property be made available for the uses that are the most beneficial
to the surrounding communities. While the Task Force recommended prohibiting any son
of agricultural or residential uses of the remaining portions of the FEMP property
(outside the disposal facility area), the Task Force encouraged DOE to consult with the
local communities to establish their preferences for future use and ownership of these
areas of the site. Consistent with this recommendation, DOE does not consider it
prudent to insert enforceable provisions within this ROD to provide for the continued
federal ownership of the entire FEMP property.
Additionally, DOE considers that final, enforceable institutional control measures for
postremedial conditions at the FEMP should be established based upon an analysis of the
actual residual concentrations as measured in site soil and groundwater following the
completion of remedial actions; the measured concentrations and spatial distribution may
differ from feasibility study projections. This difference in estimated versus measured
concentrations could have a significant impact on the required institutional controls
necessary to maintain continued protectiveness. In this ROD, DOE has elected to define
that institutional controls are a necessary component of the remedy to ensure continued
protectiveness, but that the specific institutional control provisions necessary to be
applied to postremedial site conditions will be defined during remedial design. The
institutional control provisions defined during remedial design may be modified during
the remedial action phase to accommodate the progressive findings of the field
certification efforts. As with all remedial design and remedial action documentation, the
plan for institutional controls at the FEMP, and any necessary modifications to it, will be
subject to approval by EPA and review by OEPA.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-81
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Dunn, P.
9 (Contd.)
Dunn, P.
10
Dunn, P.
11
(Contd.)
The need for institutional controls during the conduct of remedial actions and the
requirement for continued federal ownership of the disposal facility area at the FEMP
have been specifically identified in this ROD. More specific detail on the actual
implementation of these controls will be defined during remedial design.
Section 9 of this ROD provides a discussion on the role of institutional controls as a
necessary component of the Operable Unit 5 remedy. The language of the ROD provides
for the following institutional control provisions:
• Continuation of access controls at the FEMP during the period of remediation
• Provision of alternate •water throughout the period of remediation to residences
and industrial users whose current wells are located within an area of the aquifer
which exhibit concentrations exceeding the final remediation levels for
groundwater
• Continued federal ownership of the area comprising the disposal facility and
associated buffer zones
• Implementation of deed restrictions or continued federal ownership of the
remaining areas of the FEMP, as necessary to ensure the continued protection of
human health. If ownership of portions of the FEMP is transferred in the future,
restrictions will be included in the deed, and proper notifications will be provided
as required by CERCLA.
ALARA principles must be utilized during the RD process.
Response:
DOE will consider as low as reasonably achievable principles throughout the remedial
design process for Operable Unit 5. Additionally, DOE will continue to evaluate the
ongoing remedial actions for viable methods to further reduce potential exposures to
workers and the public.
A USEPA waiver of the Ohio solid waste siting criteria should only be granted if the
DOE abides by the WAC upper limit stipulations has (sic., as) described in comment
#3 [coded at 6] above, the waiver specifically states that there will be no off-site
waste disposed of on the FEMP property and no on-site waste will be capped and
left in place.
Response:
Statement acknowledged. Please see responses and resolution to the comments labeled
Dunn 4 and 6 above. Regarding the provision that no waste shall be left in place and
capped, the selected remedy for Operable Unit 5 provides for the full excavation of all
soil and sediment exceeding the final remediation levels. Consistent with this remedy,
there is no intention to cap any soil or sediment exceeding the final remediation levels.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\Deconber 8, 1995 12:24pm A. 3-82
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
••lacement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.-,
T7
•^r^
V
_
A
//
v
Na
Address:
City:
Phone:
(Below information is optional)
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
A.3-83a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Fender, A. I cannot believe the DOE has given its permission so Fernald can put a garbage
1 dump for chemically and radiologically contaminated waste in our back yard. You
must be out of your mind to even consider putting something like this in this area. I
thought that we had closed it down permanently! Our water supply in this area is
one of the cleanest. Why would you even take a chance of polluting it.
Response:
Production of uranium metal at the FEMP is shut down permanently. The proposed
cleanup plan will correct an existing contamination problem and reduce the levels of
contamination within the environmental media at the site to levels deemed to be health
protective by federal environmental regulation. It cleans up the FEMP by getting the
material with higher levels of contamination away from the site, and provides a strategy
for permanently protecting human health and the underlying Great Miami Aquifer by
isolating the remaining less contaminated material in an engineered disposal facility at
the site.
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has adversely
impacted an approximate 200-acre area of the aquifer system. DOE also recognizes that
if the FEMP is not cleaned up it poses continued contamination risk to the public and to
the aquifer. DOE intends to eliminate this unacceptable risk by moving forward with a
balanced remediation approach. This approach gets the most contaminated materials
away from the aquifer (by shipping them off-site), restores the aquifer, and limits the
quantity and disposal configuration of the contaminated material remaining at the site.
Completion of the selected remedy will also provide for more beneficial use of the FEMP
property outside the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished by completion of the selected remedies for Operable Units 1,2, 4, and 5 in
conjunction with the anticipated Operable Unit 3 remedy and the current plans to remove
the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3 percent of the current quantity of radioactivity present at the site. This 3 percent
is distributed over an estimated 2.4 million cubic yards of soil and rubble at the site.
This material will consist of lightly contaminated materials; specifically Operable Unit 5
soil, Operable Unit 2 material, and Operable Unit 4 construction rubble. While the
remedy for Operable Unit 3 has not been finalized, rubble from this operable unit is also
being considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\Deconber 8, 1995 12:24pm A.3-83
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Fender, A. (Contd.)
1 (Contd.) Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste acceptance
criteria for the less contaminated material were developed for the engineered disposal
facility to help ensure protection of the aquifer. Only material that falls below the
contamination level of the waste acceptance criteria will be disposed of in the engineered
disposal facility. Material that does not meet the criteria will have to be either treated or
shipped off site.
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the 'engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium
outside the former production area of the FEMP and 20 pans per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal facility,
a tenfold safety factor. It should be noted that sophisticated computer model simulations
used to derive the waste acceptance criteria were completed assuming that there was no
active maintenance of the facility and that the synthetic barriers present in the facility
(e.g., high-density polyethylene membranes) were not functioning. These simulations
indicate that even under these extreme conditions, the facility would still be protective of
the aquifer over the full 200- to 1000-year performance period envisioned by federal
regulations.
Fender, A. I've lost a father because of Fernald and its radioactive garbage blowing over my
2 father for 31 years before he died! My step-daughter and step-son has low
anununities [sic., immunity] because of Fernald. You must be out of your mind to
even consider putting something like this in this area - I thought we had closed it
down permanently!
Response:
This comment is outside the scope of the Operable Unit 5 remedy decision. See response
to A. Fender 1.
Fender, A. One of our most attractive Girl Scout Council Camps in this area has been dosed
3 because of Fernald also - I was a G.S. leader for 9 yrs. and we used to use the
Camp Ross Trails at least once a year. Now the girls in this area can't even use it.
Response:
This comment is outside the scope of the Operable Unit 5 remedy decision.
CRU5\ROD\MCM\APP-A\RSC-D-F.ROD\December 8, 1995 12:24pm A.3-84
-------
57
1 things.
2 MR. STEGNER: Absolutely, we will
3 let you know.
4 MR. REISING: We will make a
5 decision within a couple of days.
6 MR. STEGNER: By your meeting this
7 week you should know.
8 MR. SARIC: Yeah, you can go ahead
9 and take your 30 days.
10 MR. STEGNER: Thank you, Jim. That
11 was pretty simple. There's your approval authority
12 right there.
13 MS. CRAWFORD: So we have until June
14 30th now?
15 MR. SARIC: That's right, 30. plus
16 one.
17 MR. STEGNER: So enjoy your weekend
18 everyone. Do we have anymore individuals wanting
19 to comment? Yes, sir.
20 MR. KALLILE: My name is Jim
21 Kallile, I'm with the Ohio Department of Health. I
22 would like to say that based upon our point of
23 view, we also endorse the alternative for building
24 an on-site disposal cell, and we believe when you
t^^
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
A.3-85a
-------
58
^^—
I
1 consider the risks and costs involved with J
i
2 remediation of the entire site, we believe this is 1
i
3 the appropriate remedy. i
j^
4 MR. STEGNER: Thank you. Anyone
5 else right now?
6 Again, be reminded that now we have
7 until June 30th to get your comments in. And also
8 be reminded that the document, a form for comment
9 is included in the proposed plan summary which are
10 available in the back of the room. I thank you all
11 for coming tonight. We appreciate your input. It
12 is very valuable to us and all your comments will
13 be responded to in the responsiveness summary.
14 Thank you all very, very much. Be
15 careful going home.
16 - - -
17 PUBLIC MEETING CONCLUDED
18 _ _ _
19
20
21
22
23
24
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Kallile, J., I would like to say that based upon our point of view, we also endorse the
ODH - alternative for building an on-site disposal cell, and we believe when you consider
Transcript the risks and costs involved with remediation of the entire site, we believe this is the
1 appropriate remedy.
Response:
Comment acknowledged. The selected remedy for Operable Unit 5 represents a
"balanced approach" whereby more heavily contaminated materials will be shipped for
off-site disposal, while the large volume of materials exhibiting low concentrations of
contaminants will remain in an engineered disposal facility at the site.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\D«cembcr 8, 1995 12:34pm A.3-85
-------
STATE OF NEVADA
PETER C. MORROS. D,r«tor BOB M|LLER Wute Mana8ement
l_H. DODCION. Administrator Governor Corrective Actions
_. Federal F»cilities
(702) 687-4670 ^efSCS'X.
-D 687-4678 /3&&&>. FaaimU, 88SO868
..ministration Efi%ji!lPfcJfe| Air Quality
Mining Regulation and Reclamation YWT"W»w7 Water Quality Plannn<
Water Po.lu.on Confro, ^^^/ Ac**, 687*396
Facsimile 687-5856 -^o^mc-K^r
Address Reply to: DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES
Capital Co«,ki
.Nv897,» DIVISION OF ENVIRONMENTAL PROTECTION c*"°*^
Capitol Complex
Carson City, Nevada 89710
May 19, 1995
MEMORANDUM
FROM: Paul J. Liebendorfer, P.E. ,0/f -/
Chief, Bureau of Federal Facilities j y x/
yy-
TO: Julie Butler
Clearinghouse
THROUGH: David Cowperthwaite
NDEP Coordinator
SUBJECT: Fernald Environmental Management Project
The Nevada Division of Environmental Protection (NDEP) has T
reviewed the document Proposed Plan for Operable Unit 5. The NDEP
concurs with the recommended and preferred alternative which
proposes to excavate the radioactive contaminated materials and
dispose of these materials on site. This proposed remediation
activity would not ship wastes to an off-site facility and is
consistent with national forum of States encouraging DOE to manage
all wastes on-site. Any other alternative would be inconsistent
with the national consensus building between the DOE and
representatives from States hosting DOE facilities conducted over
the past two years.
PJL/DC/db
cc: Tom Schneider
Mike Savage
A.3-g6a
-------
Nevada Div. of
Environmental
Protection
(NDEP)
1
FEMP-05ROD-6 FINAL
December 15, 1995
The Nevada Div. of Environmental Protection has reviewed the PP for OU5. The
NDEP concurs with the recommended and preferred alternative which proposes to
excavate the radioactive contaminated materials and dispose of these materials on
site. This proposed remediation activity would not ship wastes to an off-site facility
and is consistent with national forum of States encouraging DOE to manage all
wastes on-site. Any other alternative would be inconsistent with the national
consensus building between the DOE and representatives from States hosting DOE
facilities conducted over the past two years.
Response:
Comment acknowledged. While DOE has selected this remedy based on site-specific
factors, it is gratifying when the decision-making process validates and supports similar
work, such as the national consensus building done by the National Governors'
Association on the issue of waste disposal for all DOE sites.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\De«mber 8, 1995 12:34pm A.3-86
-------
BOB MILLER STATE OF NEVADA
Governor
JOHN P. COMEAUX
Director
DEPARTMENT OF ADMINISTRATION
Capitol Complex L : _
Carson City, Nevada 89710
Fax (702) 687-3983
(702) 687-4065
May 24, 1995
Jack R. Craig, Director
Department of Energy
Fernald Environmental Management Project
P.O. Box 398705
Cincinnati, Ohio 45239-8705 —
Re: SAINV # 95300157 Project: Proposed Plan for Operable Unit 5, Femald
^ '*""
Dear Mr. Craig:
Thank you for the opportunity to review the above referenced project. !
1
The State Clearinghouse, as per Executive Order 12372, has processed the proposal and has !
no comment. —
Sincerely,
Maud Naroll for
Julie Butler, Coordinator
Nevada State Clearinghouse/SPOC
JB/jbw
A.3-87a
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FEMP-05ROD-6 FINAL
December 15, 1995
Nevada State The State Clearinghouse, as per Executive Order 12372, has processed the proposal
Clearinghouse and has no comment.
1
Response:
Thank you for reviewing the Operable Unit 5 Proposed Plan.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:J4pm A.3-87
-------
M
May
[ f~\[ iryf"\/
' J
Department of
Comprehensive Planning
Nuclear Waste Division
CLARK COUNTV GOVERNMCI-JT
s GpiAfsjo CENTRAL PKV STE 3O1S
&>O BOX 551 751
LAS VCGAS MV saios-1751
(703)455-5173
FAy (7Qe)
U.S Department ul Energy
,j ^rr-
Fernrtld Area Office
P.O. Box 538705
Cincinnati, OH 45353-8705
Ann: Mr. Gary .Siagner, Director
Public Information
Subj: FERNALD, OHIO. REMEDIAL INVESTIGATION/FEASIBILITY
(Rl/FS) FOR OPERABLE UNIT 5
Dear Mr. Siagner:
The Nevada Test She (NTS) Community Advisory Board (CAB) apprecintes the opportunity to comment on the
Rl/FS for Operable Unit 5 at the Fernald, Ohio. Department of Energy (DOE) site. The CA13 is extremely
interested in all facets of the remediation work taking plnce at Fernald. Since the NTS has taken receipt of many
Fcrnald waste shipments in the past, and may be the recipient of others in the future, we obviously have a stake
in decisions being considered at Fernald. The Board has previously commented on the recommendations being
considered for Operable Units 2 and 4
The NTS CAB is supportive, of the recommendation for on-site remediation of the waste from Operable Unit 5'.
Protecting what we understand is an extremely important regional aquifer by removing the waste to a safer.
controlled site at Fernald would scorn to offer many benefits. It is fortunate that an onsite solution is available
We applaud the efforts nt Feniald and other sites to consider, where feasible, on-site remediation options. Given
the significant amounts uf waste present at Fernald and other locations throughout the nation, it is important that
we remediate, wherever possible, potential health and safety risks lo (he public. Minimizing the mnounts of
waste that need to be transported is important in ameliorating some of these risks.
As noted in our previous comments. Nevada and Ohio were major participants in developing the United Stales
nuclear dcterrant option. The apparent success of this endeavor offers the potential of a safer, more peaceful
world. Since many states and communities shared in the development of the nuclear deterrent, NTS CAB
members feel that it is also important that we all participate in providing solutions to the onerous waste problems
that are present at many DOE sites.
Once again, we appreciate the opportunity to provide input to the RI/FS for Operable Unit 5. The C'AB looks
forward to your incorporation of the Board's comments into remediation decisions at Operable Unit 5.
If you have questions or require clarification, please contact me.
liam Vas
Nevada Test
, hairman
;Community Advisory Board
WV/DB/JT
fernald.ou5
co. Nevada Congressional Representatives
Governor Robert Miller
COMMISSIONERS
j Atkinson GoCog. Cheir • Poul J. Cnriatenoe.'i.
Jay Singhem, Lorraine Hunt. Erin Kenny. N/1yrna Wiii.omo. tSruco L. Woodbury
DooalO L. "Pec" Snalmy. County ^ •
A.3-88a
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Nevada Test
Site
Community
Advisory Board
[CAB]
1
FEMP-05ROD-6 FINAL
December 15, 1995
As noted in our previous comments, Nevada and Ohio were major participants in
developing the United States nuclear deterrent option. The apparent success of this
endeavor offers the potential of a safer, more peaceful world. Since many states
and communities shared in the development of the nuclear deterrent. NTS CAB
members feel that it is also important that we all participate in providmg solutions
to the onerous waste problems that are present at many DOE sites. We applaud the
efforts at Fernald and other sites to consider, where feasible, on-site remediation
options. Given the significant amount of waste present at Fernald and other
locations throughout the nation, it is important that we remediate, wherever
possible, potential health and safety risks to the public. Minimizing the amounts of
waste that need to be transported is important in ameliorating some of these risks.
The NTS CAB is supportive of the recommendation for on-site remediation of the
waste from OU5. Protecting what we understand is an extremely important
regional aquifer by removing the waste to a safer controlled site at Fernald would
seem to offer many benefits. It is fortunate that an onsite solution is available.
Response:
Agree with commentor about shared responsibilities vis-a-vis providing solutions to the
waste disposal problems that are a result of the development of the nation's nuclear
deterrent. EPA and DOE believe that a combination of on- and off-site disposal
provides the best solution to the problem.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8. 1995 12:J4pm A.3-88
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ONoEIft
Sute of Ohio Environmental Protection Agency
HJthwest District Office
. East Fifth Street
Dayton. Ohio 45402-2911
(513) 285-S357
FAX (513) 285-6249
George V. Voinovich
Governor
June 15, 1995
RE: DOE FEMP
HAMILTON COUNTY
OU5 PROPOSED PLAN
PUBLIC COMMENTS
Mr. Gary Stegner
Director, Public Information
U.S. DOE Fernald Area Office
P.O. Box 538705
Cincinnati, OH 45253-8705
Dear Mr. Stegner:
The purpose of this letter is to provide Ohio EPA's official comments on the Operable Unit 5
Proposed Plan during the public comment period. Ohio EPA's comments are as follows:
1. .The OU5 Proposed Plan is the culmination of efforts by U. S. DOE, Ohio EPA, and U. S.
EPA to understand and develop a plan for mitigating releases to the environment from
OU5. Ohio EPA believes the alternative selected in the Proposed Plan is protective of
human health and the environment. Ohio EPA believes the preferred alternative is the
appropriate one, when considered in the context of overall site cleanup. Ohio EPA
supports the concept of a balanced approach where the low volume nigh concentration
wastes go off-site for disposal and high volume lower concentration wastes are disposed
of in an engineered facility on-site. We believe that this approach provides the most
implementable and protective strategy for remediation of the FEMP site.
2. The Operable Unit 5 Record of Decision (ROD) should clearly place restrictions on the
use of the engineered on-site disposal facility Ohio EPA understands the need to allow
flexibility for incorporation of other operable units but also feels the following restrictions
must be made in the ROD:
a) No disposal or long-term storage of off-site waste in the proposed engineered
disposal facility or any other facility on the FEMP site;
b) The disposal facility Waste Acceptance Criteria (WAC) for Uranium-238 should
be set at a maximum of 346 pCi/g or 1030 ppm for total uranium with the
flexibility to be lowered based upon other operable unit decisions and volumes.
The WAC must be an upper limit of concentration acceptable into the disposal
facility and may not be used as an average limit.;
c) No characteristic hazardous waste should be disposed of in the facility.
PPFINAL.CMT
I
2
i
PnneC 0" recyc»o caw
A.3-89a
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methods to reduce or eliminate discharges and releases from the excavation and disposal
activities should be considered during the design of the system.
Mr. Stegner
June 15, 1995
Page 2
3. Ohio EPA supports DOE's use of the proposed MCL for total uranium of 20 ug/1 as the
groundwater remediation level. Ohio EPA believes remediation to this standard will
ensure the Great Miami Aquifer is restored to its full beneficial use. Any proposed
changes to the 20 ug/1 total uranium remediation standard would necessitate a ROD
amendment including a formal public comment period.
4. DOE should commit to being open to consider new technologies which may reduce the j
volume, toxicity or mobility of wastes being disposed of on-site. Ohio EPA is simply 4
requesting that DOE remain open to the idea of additional technologies which may result !
in a safer waste form for on-site disposal. ~
5. During implementation of the preferred alternative, DOE must use excavation and waste |
management techniques which will prevent the dilution of waste concentrations to meet 5
the WACs. DOE must not use dilution to meet the WAC or remediation levels. j^
6. DOE should commit to including and/or developing real-time monitoring for discharges to T
the environment resulting from remedial actions. DOE should attempt to incorporate any j
new developments in real-time monitoring from the DOE Office of Technology 6
Development as well as the private sector. Data obtained from real-time monitors and any i
additional monitoring activities should be provided to the Ohio EPA and public in a timely j_
manner.
7. DOE should attempt to incorporate pollution prevention activities whenever possible i
during the design and operation of the OU5 remedial action systems. All available 7
i
8. DOE must ensure the public that their involvement will not be diminished during Remedial i
Design and Remedial Action (RD/RA). DOE should commit within the Record of °
Decision for OU5 to maintaining the exceptional on-going public involvement program j
during RD/RA. ""
9. DOE should make commitments within the OU5 ROD concerning perpetual government J"
ownership of properties associated with the OU5 ROD. DOE must provide commitments j
to ensure the land-use employed to develop the cleanup standards is maintained into the 9
future. DOE ownership is essential to maintaining institutional controls and limiting land- j
use to ensure protectiveness of the site. J-
10. With regard to the request for a USEPA waiver of the Ohio solid waste siting criteria, 10
PPFINAL.CMT
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Mr. Stegner
June 15, 1995
Page 3
Ohio EPA supports this waiver only in that it allows for a remedy more protective than
capping in place and more implementable than off-site shipment. Since the DOE FEMP is
a CERCLA site and its location would not allow issuance of an Ohio EPA exemption of -IQ
the criteria, Ohio EPA believes a waiver is the appropriate mechanism to support the
preferred alternative. Ohio EPA's support of the waiver is inherently tied to the
restrictions described in comment #2 above.
If you have any questions concerning these comments please contact me at (513) 285-6466.
Sincerely,
Thomas A. Schneider
Fernald Project Manager
Office of Federal Facilities Oversight
cc: Terry Finn, Ohio AG
Jim Saric, USEPA
Terry Hagen, FERMCO
Lisa August, Geotrans
Sharon McLellan, PRC
Manger TPSS, OEPA/DERR
JeffHurdley, OEPA/Legal
Ruth Vandegrift, ODH
PPFINAL.CMT
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA The Operable Unit 5 Proposed Plan is the culmination of efforts by U.S. DOE, Ohio
1 EPA, and U.S. EPA to understand and develop a plan for mitigating releases to the
environment from OU5. Ohio believes the preferred alternative is the appropriate
one, when considered in the context of overall site cleanup. OEPA supports the
concept of a balanced approach where the low volume high concentration wastes go
off-site for disposal and high volume lower concentration wastes are disposed of in
an engineered facility on-site. We believe that this approach provides the most
implementable and protective strategy for remediation of the FEMP site.
Response:
Comment acknowledged. The preferred remedial alternative as identified in the
Proposed Plan for Operable Unit 5, with modification to accommodate public comments,
is the selected remedy. The selected remedy is documented in Section 9.0 of this ROD.
OEPA The OU5 Record of Decision (ROD) should clearly place restrictions on the use of
2 the engineered on-site disposal facility. Ohio EPA understands the need to allow
flexibility for incorporation of other operable units but also feels the following
restrictions must be made in the ROD:
a) No disposal or long-term storage of off-site waste in the proposed engineered
disposal facility or any other facility on the FEMP site.
b) The disposal facility WAC for uranium-238 should be set at a maximum of
346 pCi/g or 1030 ppm for total uranium -with the flexibility to be lowered based
upon other operable unit decisions and volumes. The WAC must be an upper
limit of concentration acceptable into the disposal facility and may not be used
as an average limit.
c) No characteristic hazardous waste should be disposed of in the facility.
Response:
a) The DOE concurs with the comment and has no intention of using the disposal
facility associated with the Operable Unit 5 remedy to address wastes generated from
off-site locations. Additionally, the DOE has no intention of using existing or newly
constructed storage facilities located at the FEMP for the long-term storage of wastes
generated from off-site locations. Specifically excluded from this prohibition are
laboratory wastes generated at off-site facilities resulting directly from the chemical,
radiological or engineering analysis of FEMP waste materials or generated during
the conduct of treatability or demonstration type studies on FEMP waste materials.
Such analyses and studies are typically performed as an integral part of
implementing a selected remedy at a cleanup site.
Language has been added to Section 10 of this ROD to specifically identify that the
FEMP storage and future disposal facilities shall not be used for the long-term
storage or disposal of wastes generated from off-site locations.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:43pm A. 3-89
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA (Contd.)
2 (Contd.)
b) The waste acceptance criteria for the engineered disposal facility defined in the
Feasibility Study and Proposed Plan have been adopted as part of the selected
remedy for Operable Unit 5. These criteria, as defined in Section 9 of this ROD,
include the establishment of a concentration-based waste acceptance criteria for total
uranium of 1030 parts per million. This limit has been set as an upper permissible
concentration level for contaminated soil to be received into the on-property disposal
facility, and as such will not be used as an average limit.
The selected remedy provides that soil exceeding this waste acceptance criteria will
be shipped off site for .disposal at an appropriate facility. DOE is committed to
implementing this remedy as defined in this decision document. However, DOE must
also bring to the commentor's attention that the availability of off-site disposal
capacity cannot be assured over the 10- to 25- year cleanup program associated with
Operable Unit 5. In the event off-site disposal capacity becomes unavailable or cost
prohibitive at some point in the future, DOE considers it important that flexibility be
maintained and indicated in the ROD so as to permit the application of treatment
technologies to soil exceeding these acceptance criteria to convert them to a form
suitable for on-property disposal. The application of such technologies would only
occur following receipt of approval of EPA and input from OEPA.
Section 9 of the ROD adopts the 1030 pans per million waste acceptance criteria for
total uranium as a maximum concentration-based limit for contaminated soil to be
suitable for on-property disposal at the FEMP. Section 9 also adopts off-site
disposal as the selected remedy for soil found to exceed the waste acceptance criteria
for total uranium. Language was added to Section 9 to permit the DOE to solicit the
approval of EPA and input from OEPA to apply treatment technologies to soil
exceeding the waste acceptance criteria to convert these materials to a form suitable
for on-property disposal. Such a request would only be made in the event off-site
disposal capacity becomes unavailable or cost prohibitive.
CRU5\ROD\MCM\APP-A\KSC-K-R.ROD\De
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA OEPA 's comment concerning the disposal of characteristic waste relates to the
2 (Contd.) component of Operable Unit 5 soil that is potentially contaminated with RCRA-
regulated constituents at levels sufficient to classify the soil as RCRA characteristic
waste. OEPA's comment imposes a requirement to treat the RCRA characteristic soil
(in essence, to remove the characteristic property) before disposal in the on-property
disposal facility or, alternatively, to dispose of the RCRA characteristic soil off site.
In response to OEPA's concern, DOE acknowledges that EPA's corrective action
management unit rule is an applicable or relevant and appropriate requirement for
the Operable Unit 5 remedy that provides the regulatory framework for determining
treatment and on-property disposal requirements for RCRA-regulated constituents in
soil. DOE also acknowledges that the corrective action management unit rule
requires several decision steps to ensure that a protective remedy is identified and
can be reliably implemented. These decision steps — contained in Section 264.552 of
the corrective action management unit rule — can be summarized as follows: 1) the
remedy must be protective of human health and the environment - accomplished for
Operable Unit 5 through the establishment of health-protective final remediation
levels and numerical waste acceptance criteria for all constituents of concern,
including the RCRA-regulated constituents; 2) the remedy must minimize the
potential for future release - also accomplished through the setting of health-
protective final remediation levels and waste acceptance criteria that explicitly
consider the potential for cross-media impacts; and 3) the remedy must enhance
lone-term effectiveness through the application, as appropriate, of treatment
technologies that reduce toxicitv, mobility, or volume of wastes that will remain in
place after closure of the corrective action management unit; as cited in the
preamble for the corrective action management unit rule, this decision step is
analogous to the preference under CERCLA for treatment-based remedies.
Meetings were held on September 5 and October 26, 1995 with EPA and OEPA to
identify an implementation strategy to resolve OEPA's concern regarding the need to
restrict the on-property disposal of soil that is RCRA characteristic. Recognizing
that EPA and DOE have developed health-protective final remediation levels and
numerical waste acceptance criteria for all of the Operable Unit 5 constituents of
concern (including the RCRA-regulated constituents), OEPA indicated that the
decision to require further treatment of RCRA characteristic soil has its origin in the
need to satisfy, on a site-specific basis, the regulatory preference for treatment that
is contained in decision step 3 above. As stated in the preamble to the corrective
action management unit rule, the decision to apply cost-effective treatment at a site is
a case-by-case decision that must consider waste- and site-specific factors. Based on
a review of site characterization data from the Operable Unit 5 remedial
investigation as well as historical process knowledge, six geographic areas of the
FEMP have been identified where RCRA characteristic soil may be present in
quantities that offer reasonable opportunities for cost-effective treatment. These six
areas are:
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:43pm A.3-91
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA • Abandoned sump west of pilot plant
2 (Contd.) • Area between KC-2 warehouse and railroad tracks
• Trap range
• Fill material west of Operable Unit 4 silos along Paddys Run streambank
• Scrap metal pile area
• Area north of maintenance building.
The six areas were identified by reviewing a combination of existing analytical data
and process knowledge concerning the activities that took place in each area.
Conversely, other areas within Operable Unit 5 were eliminated from further
consideration using the same process. Specifically, DOE evaluated the Operable
Unit 5 remedial investigation database to identify instances where soil total
contaminant concentration levels for toxicity characteristic RCRA constituents were
numerically more than 20 times the associated toxicity characteristic leaching
procedure leachate standard. The "20 times rule" (as this effort is customarily
catted) is a conservative suggestion in EPA guidance to identify waste streams with
an increased potential to demonstrate a RCRA characteristic. In those instances
where multiple "20 times " exceedances were noted in a localized geographic area,
process knowledge information was r.eviewed to ascertain if any activities were
conducted at that location which could have been the source of elevated contaminant
concentrations. The locations of the analytical samples and the process knowledge
information were then used in combination to bound the suspect areas. Application
of this process led to identification of the six areas denoted above.
An identical process was used to screen out the remaining geographic areas within
Operable Unit 5. The remedial investigation database contains an extensive volume
of analytical data encompassing the entire anticipated remediation area. EPA
guidance regarding procedures for RCRA waste characterization (OSWER Directive
9938.4-03) states that waste sampling should "reflect the average properties of the
universe from which the samples were obtained. " The waste universe in question
here is the Operable Unit 5 soil. An examination of the remedial investigation
database in light of the "20 times rule" strongly demonstrates that the average
characteristics of Operable Unit 5 soil are not indicative of an enhanced potential for
characteristic waste. Except for specific areas noted above, where analytical data
and process knowledge indicate a potential for a volume of readily segregated soil
that could demonstrate a RCRA characteristic, this logic was used to screen out
Operable Unit 5 soil from further concern. In the very limited instances where a
single sample in an area exceeded the "20 times rule," the presence of other data
points in the immediate vicinity below the "20 times rule " and lack of process
knowledge were used to screen the area out, the logic being that the individual
exceedance was not representative of the soil volume in question.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:43pm A.3-92
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA In completing its review, DOE also evaluated information specific to the FEMP's
2 (Contd.) designated hazardous waste management units. Under the conditions of an
anticipated OEPA Director's Findings & Orders for RCRA/CERCLA integration,
hazardous waste management units at the FEMP will be closed either under the
jurisdiction ofRCRA or through the CERCLA process. For those units anticipated to
be clean closed under RCRA, applicable regulations require specific evaluation of
the presence of hazardous waste. Any such hazardous waste generated during clean
closures will be managed in full compliance with all applicable requirements of
RCRA (and DOE is not seeking to apply relief through the corrective action
management unit rule for any of these closures). For those hazardous waste
management units being closed under the CERCLA process, most of the units were
screened out based on two considerations. First, for most of the units, the RCRA
hazardous waste historically present was managed within containers, such as drums,
in addition to placement within structurally sound secondary containment that would
minimize the potential for significant releases to surrounding soil. For these units
there was no evidence of releases of hazardous constituents to the surrounding soil.
The second consideration was the completion of removal actions at several of the
units. These removal actions resulted in the removal of the majority of the affected
soil and thus there is no evidence that a significant quantity ofRCRA characteristic
soil remains "in place" at the respective locations. The soil volumes that were
removed as part of these actions, if still stored on site, will be evaluated for disposal
requirements (including an evaluation ofRCRA properties as needed) as pan of the
remedial design for Operable Unit 5.
The other general area of concern evaluated by DOE was the area under the process
area buildings. DOE used analytical data from remedial investigation borings
completed beneath building floors in areas where process knowledge indicated a
significant concern (sumps, processing areas, etc.,) as well as from randomly
selected areas, for evaluating the potential presence of quantities ofRCRA
characteristic soil that could provide additional opportunities for cost-effective
treatment. The data considered were principally total contaminant concentrations
evaluated in light of the "20 times rule. " In addition to these data, however, there
were a number of samples of investigation-derived waste (primarily drill cuttings)
generated from beneath buildings that had been subjected to the toxicity
characteristic leaching procedure. These data, reviewed as a group, strongly
suggest that the representative characteristics of soil beneath process area buildings
do not indicate an enhanced potential for characteristic waste beneath the buildings.
Further information which qualitatively supports this conclusion relates to the
probable sources of contamination beneath the buildings; i. e., contaminant migration
through cracks in floors or from leaks from process piping beneath the floors. These
contaminant migration pathways would serve to limit the overall area! impact to
Operable Unit 5 soil. This, in turn, supports the position that contamination
associated with these releases would not be representative of the average
characteristics of the soil beneath the buildings.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:43pm A.3-93
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA DOE, EPA, and OEPA all desire to satisfy the regulatory preference for treatment
2 (Contd.) within the context of the Operable Unit 5 remedy. At the October 26, 1995 meeting,
consensus was reached that the six geographic areas identified above define the
boundaries within which additional efforts will be made to identify and segregate for
treatment (if needed) the soil that is RCRA characteristic. Within these geographic
areas, as soil is excavated based on exceedances of final remediation levels, follow-
up analytical testing will be performed to determine if the soil demonstrates a RCRA
characteristic. If the soil does not demonstrate a RCRA characteristic and it meets
the on-property numerical waste acceptance criteria it will be placed in the disposal
facility. If the representative volume of the soil in question demonstrates a RCRA
characteristic it will be preferentially segregated for treatment before disposition
either on or off site.
As part of the consensus DOE, EPA, and OEPA have agreed that sufficient existing
data and historical process knowledge are available to identify the boundaries of the
six geographic areas as those that represent a reasonable opportunity for cost-
effective soil treatment. Outside of these geographic areas, DOE, EPA, and OEPA
concur that there is no reasonable basis to conclude that an increased potential for
RCRA characteristic soil exists that would provide additional opportunity for cost-
effective soil treatment. Therefore, outside the boundaries of the six geographic
areas, no additional analytical data will be required to screen for the presence of
characteristic waste before placement in the disposal facility.
To accommodate OEPA's concern initiated by this comment and discussed at the
October 26 meeting, the remedy description provided in Section 9.0 of the ROD
incorporates a commitment by DOE to address the potential RCRA characteristic
concern originating from within the six identified geographic areas. The revised
description identifies the overall approach, the treatment technique to be applied to
the segregated material, and the use of the uxdcity characteristic leaching procedure
to guide the identification of the material requiring preferential treatment. The
responses to comments from other members of the public (who voiced similar
concerns on this issue) will also acknowledge DOE's commitment and adoption of
the implementation strategy.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Deccmber 15, 1995 9:37tm A.3-94
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA OEPA supports DOE's use of the proposed maximum contaminant level for total
3 uranium of 20 ug/1 as the groundwater remediation level. OEPA believes
remediation to this standard will ensure the Great Miami Aquifer is restored to its
full beneficial use. Any proposed changes to the 20 ug/1 total uranium remediation
standard would necessitate a ROD amendment including a formal public comment
period.
Response:
Consistent with Section 300.430(e)(2)(i)(C)ofthe National Contingency Plan, the DOE
has adopted the maximum contaminant levels under the Safe Drinking Water Act as
relevant and appropriate requirements to the restoration of the Great Miami Aquifer.
Lacking a final promulgated maximum contaminant level for uranium, DOE adopted, as
pan of the selected remedy, the maximum contaminant level proposed by EPA in July
1991 under the Safe Drinking Water Act of 20 parts per billion as the final remediation
level for restoration of the aquifer. This proposed standard was adopted as a "To Be
Considered'1 requirement to the selected remedy.
The estimated costs for the restoration of the Great Miami Aquifer are, as would be
expected, very sensitive to the established final groundwater cleanup limits (final
remediation levels). While DOE is committed to fully restoring the aquifer to health-
protective levels, DOE must do so in full recognition of its role as a steward of public
funds. Within its stewardship role, the DOE must ensure that public funds are
committed only to remedial activities which yield a commensurate environmental or
human health-related benefit. As such, the DOE must evaluate the technical and
economic implications of pursuing adoption of the final maximum contaminant level for
uranium, once promulgated by EPA. Such a technical and economic evaluation will be
warranted regardless of whether the final maximum contaminant level for uranium
represents a higher or lower concentration-based limitation than the proposed 20 pans
per billion standard. In the event DOE considers it appropriate to pursue a change to
the final remediation level for uranium in groundwater identified in this decision
document, DOE will initiate such a change in a manner consistent with CERCLA, the
National Contingency Plan and the terms of the Amended Consent Agreement.
Section 9 of this ROD adopts the proposed maximum contaminant level of 20 parts per
billion for total uranium as the final remediation level for affected regions of the Great
Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:43pm A.3-95
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA DOE should commit to being open to consider new technologies which may reduce
4 the volume, toxicity or mobility of wastes being disposed of on-site. OEPA is simply
requesting that DOE remain open to the idea of additional technologies which may
result in a safer waste form for on-site disposal.
Response:
DOE concurs with the comment that the FEMP should continue to be open to new
technologies that may reduce the volume, toxicity or mobility of wastes being disposed of
onsite. Language expressing this commitment was provided in the Proposed Plan in the
description of the preferred alternative, and has been incorporated in Section 9 of this
ROD. Included within this language is a commitment by DOE to evaluate two such
technologies during remedial design, physical separation and a soil amendment process.
DOE will conduct engineering studies of these two technologies to assess the viability of
applying them as part of the Operable Unit 5 remedy.
OEPA During implementation of the preferred alternative, DOE must use excavation and
5 waste management techniques which will prevent the dilution of waste
concentrations to meet the WACs. DOE must not use dilution to meet the WAC or
remediation levels.
Response:
DOE agrees that an important consideration during the remedy implementation phase is
to ensure that proper excavation control and waste management practices are applied to
prevent the dilution of contaminated soil and increase the volume of soil requiring
disposal. DOE has no intention of using dilution as a mechanism to attain the waste
acceptance criteria for the disposal facility. DOE is compiling detailed procedures to
guide site-wide excavation operations for contaminated soil. These procedures, which
will be developed during the remedial design phase for Operable Unit 5, will clearly
define intended excavation methods which will ensure against such dilution from taking
place.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:43pm A.3-96
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FEMP-05ROD-6 FINAL
December 15, 1995
OEPA DOE should commit to including and/or developing real-time monitoring for
6 discharges to the environment resulting from remedial actions. DOE should
attempt to incorporate any new developments in real-time monitoring from the
DOE Office of Technology Development as well as the private sector. Data
obtained from real-time monitors and any additional monitoring activities should be
provided to the OEPA and public in a timely manner.
Response:
DOE is committed to executing a responsible and technically defensible environmental
monitoring program during the conduct of remedial actions at the FEMP. The specifics
of this program will be defined during the remedial design phase. DOE will take into
consideration commercially available and emerging monitoring techniques which could
provide real-time or near real-time data on environmental releases. As pan of this
planning, DOE will evaluate technologies under consideration by the DOE Office of
Technology Development.
The DOE currently has in place a program for reporting upon environmental monitoring
data collected at the FEMP including nonroutine releases (such as spills) and more
routine environmental discharges generated by site cleanup activities. As pan of the
Operable Unit 5 remedial design process, the existing site reporting system will be
evaluated and necessary changes effected to ensure the program is properly aligned with
proposed remedial activities. One goal of the reporting system will be to continue to
repon environmental discharges to the OEPA and the local community in a prompt and
responsible manner. The proposed mechanisms and frequency of reporting will be
defined in the remedial design documentation for Operable Unit 5 and be subject to EPA
approval, formal review by OEPA, and will be made available for public inspection.
OEPA DOE should attempt to incorporate pollution prevention activities whenever possible
7 during the design and operation of the OU5 remedial action systems. All available
methods to reduce or eliminate discharges and releases from the excavation and
disposal activities should be considered during the design of the system.
Response:
Pollution prevention will be a key consideration during remedial design for Operable
Unit 5. Considerations during remedial design will include minimizing discharges to the
Great Miami River to the extent practical, applying appropriate mitigative measures
during excavation and soil transport and staging operations to minimize fugitive dust
emissions, and ensuring the necessary controls to reduce the migration of contaminated
soil and surface water out of controlled areas during rain events. DOE's planned
actions will be documented during remedial design and subject to approval by EPA,
formal review by OEPA, and will be available for public inspection.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11. 1995 12:43pm A.3-97
-------
FEMP-05ROD-6 FINAL
December 15, 1995
OEPA DOE must ensure the public that their involvement will not be diminished during
8 RD/RA. DOE should commit within the ROD for OU5 to maintaining the
exceptional ongoing public involvement program during RD/RA.
Response:
DOE is committed to continuing the active community involvement program currently in
place at the FEMP throughout the duration of remedial activities at the site. This issue
has been discussed at public meetings and has been the subject of a more focused
roundtable held with interested members of the local community. Language has been
added to Section 9 of this ROD to formalize the commitment to continue the on-going
public involvement program during the remedial design/remedial action process.
OEPA DOE should make commitments within the OU5 ROD concerning perpetual
9 government ownership of properties associated with the OU5 ROD. DOE must
provide commitments to ensure the land-use employed to develop the cleanup
standards is maintained into the future. DOE ownership is essential to maintaining
institutional controls and limiting land-use to ensure protectiveness of the site.
Response:
The comment raises the need to properly align the necessary institutional control
provisions for the FEMP with the future land use for the facility to ensure the continued
protection of human health. DOE agrees with the need for this alignment. It is not the
intent of DOE to attempt to establish a final future land use for the FEMP through this
decision document. DOE does recognize that the final remediation levels identified in
Section 9.0 of this ROD do establish the permissible concentrations of contaminants
which could remain at the site following completion of remedial actions. These
remaining concentrations of contaminants will present a potential for exposure to future
users of the FEMP.
The Fernald Citizens Task Force issued recommendations regarding future use of the
Fernaid property in May of 1995. In these recommendations, the Task Force
recommended that the area of the FEMP containing the disposal facility and associated
buffer zone remain under the continued ownership of the federal government.
Additionally, the Task Force recommended that the remaining portions of the FEMP
property be made available for the uses that are the most beneficial to the surrounding
communities. While the Task Force recommended prohibiting any sort of agricultural or
residential uses of the remaining portions of the FEMP property (outside the disposal
facility area), the Task Force encouraged DOE to consult with local communities to
establish their preferences for future use and ownership of these areas of the site.
Consistent with this recommendation, DOE does not consider it prudent to insert .
enforceable provisions within this ROD to provide for the continued federal ownership of
the entire FEMP property.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:52pm A.3-98
-------
FEMP-05ROD-6 FINAL
December 15, 1995
OEPA Additionally, DOE considers that final, enforceable institutional control measures for
9 (Contd.) postremedial conditions at the FEMP should be established based upon an analysis of
the actual residual concentrations as measured in site soil and groundwater following
the completion of remedial actions; the measured concentrations and spatial distribution
may differ from FS projections. This difference in estimated versus measured
concentrations could have a significant impact on the required institutional controls
necessary to maintain continued protectiveness. In this ROD, DOE has elected to define
that institutional controls are a necessary component of the remedy to ensure continued
protectiveness, but that the specific institutional control provisions necessary to be
applied to postremedial site conditions will be defined during remedial design. The
institutional control provisions defined during remedial design may be modified during
the remedial action phase to accommodate the progressive findings of the field
certification efforts. As with all remedial design and remedial action documentation, the
plan for institutional controls at the FEMP, and any necessary modifications to it, will
be subject to approval by EPA and review by OEPA.
The need for institutional controls during the conduct of remedial actions and the
requirement for continued federal ownership of the disposal facility area on the FEMP
have been specifically identified in this ROD. More specific detail on the actual
implementation of these controls will be defined during remedial design.
Section 9 of this ROD provides a discussion on the role of institutional controls as a
necessary component of the Operable Unit 5 remedy. The language of the ROD
provides for the following institutional control provisions:
• Continuation of access controls at the FEMP during the period of remediation
• Provision of alternate water throughout the period of remediation to residences
and industrial users whose current wells are located within an area of the aquifer
which exhibit concentrations exceeding the final remediation levels for
groundwater • j
• Continued federal ownership of the area comprising the disposal facility and
associated buffer zones
• Implementation of deed restrictions or continued federal ownership of the
remaining areas of the FEMP, as necessary to ensure the continued protection of
human health. If ownership of portions of the FEMP is transferred in the future,
restrictions will be included in the deed, and proper notifications will be provided
as required by CERCLA.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 11, 1995 12:S2pm A.3-99
-------
FEMP-05ROD-6 FINAL
December 15, 1995
OEPA With regard to the request for a USEPA waiver of the Ohio solid waste siting
10 criteria, OEPA supports this waiver only in that it allows for a remedy more
protective than capping in place and more implementable than off-site shipment.
Since the DOE FEMP is a CERCLA site and its location would not allow issuance
of an OEPA exemption of the criteria, OEPA believes a waiver is the appropriate
mechanism to support the preferred alternative. Ohio EPA's support of the waiver
is inherently tied to the restrictions described in comment #2 above.
Response:
Comment acknowledged. This ROD provides a discussion in Section 10 on the required
waiver of State of Ohio siting requirements needed to implement the selected remedy.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\D«cember 11, 1995 12:52pm A.3-100
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
AfitJI ¥
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(Below information is optional)
Name: _
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-101a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, D. As a young adult I feel as if leaving this nuclear material here as being not the
1 answer. It will contaminate one of the worlds largest aquifers. My family and I
will be living here for many, many more years, do not leave this deadly material to
contaminante our water, and thousands of other peoples water.
Response:
DOE acknowledges that no one wants contamination near where they live but
contaminated material already exists at the FEMP. The cleanup plan proposed for the
FEMP will address this existing contamination and reduce the levels in the soil and
groundwater to concentrations deemed to be health-protective by federal environmental
regulation.
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has
adversely impacted an approximate 200-acre area of the aquifer system. DOE also
recognizes that if the FEMP is not cleaned up it poses continued contamination risk to
the public and to the aquifer. DOE intends to eliminate this unacceptable risk by
moving forward with a balanced remediation approach. This approach gets the most
contaminated materials away from the aquifer (by shipping them off site), restores the
aquifer, and limits the quantity and disposal configuration of the contaminated material
remaining at the site. Completion of the selected remedy will also provide for more
beneficial use of the FEMP property outside the disposal facility area.
Plans are to remove the materials that constitute about 97% of the radioactivity present
at the FEMP for disposal at an off-site disposal facility. This will be accomplished via
completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3% of the current quantity of radioactivity present at the site. This 3% is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy
for Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\IBC-K-R.ROD\December 8, 1995 12:34pm A.3-101
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, D. (Contd.)
1 (Contd.) The waste acceptance criteria considers the hydro-geologic environment of the site and
the protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium
outside the former production area of the FEMP and 20 parts per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal
facility, a tenfold safety factor. It should be noted that sophisticated computer model
simulations used to derive the waste acceptance criteria were completed assuming that
there was no active maintenance of the facility and that the synthetic barriers present in
the facility (e.g., high-density polyethylene membranes) were not functioning. These
simulations indicate that even under these extreme conditions, the facility would still be
protective of the aquifer over the full 200- to 1000-year performance period envisioned
by federal regulations.
Renck, D.
2
Renck, D.
3
This is a very quick and unsafe way of dealing with this huge problem.
Response:
The proposed cleanup approach was not thought of overnight, rather it has been
developed after several years of careful study of the site and the various options
available to address the contamination. The proposed cleanup plan will correct an
existing contamination problem and reduce the levels of contamination within the
environmental media at the site to levels deemed to be health-protective by federal
environmental regulation. It cleans up the FEMP by getting the material with higher
levels of contamination away from the site, and provides a strategy for permanently
protecting human health and the underlying Great Miami Aquifer by isolating the
remaining less contaminated material in an engineered disposal facility at the site.
Shipping the nuclear material to a safe place is the only answer.
Response:
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste
acceptance criteria for the less contaminated material were developed for the engineered
disposal facility to help ensure protection of the aquifer. Only material that falls below
the contamination level of the waste acceptance criteria will be disposed of in the
engineered disposal facility. Material that does not meet the criteria will have to be
either treated or shipped off site.
CRUS\ROD\MCM\APP-A\RSC-K-R.ROD\Deconbcr 8, 1995 12:34pm A.3-102
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
y
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(Below information is optional)
Name:
* £
City: _
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
y.
A.3-103a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, J. M. I am opposed to the waste storage dump proposed for the FEMP. The
1 contamination to the aquifer is my primary concern. The aquifer needs to be
protected as a source for drinking water for the thousands of people who use it.
This method of containment doe not convince me that not further contamination
will occur. If this method were safe. NO water should leak into the groundwater.
This is not a good enough solution. The second concern is the ground covering the
dump and the contaminants left in the area. The area will not be cleaned up to a
point that a good use can be made of it.
Response:
The proposed cleanup plan will correct an existing contamination problem and reduce
the levels of contamination within the environmental media at the site to levels deemed to
be health-protective by federal environmental regulation. It cleans up the FEMP by
getting the material with higher levels of contamination away from the site, and provides
a strategy for permanently protecting human health and the underlying Great Miami
Aquifer by isolating the remaining less contaminated material in an engineered disposal
facility at the site.
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has
adversely impacted an approximate 200-acre area of the aquifer system. DOE also
recognizes that if the FEMP is not cleaned up it poses continued contamination risk to
the public and to the aquifer. DOE intends to eliminate this unacceptable risk by
moving forward with a balanced remediation approach. This approach gets the most
contaminated materials away from the aquifer (by shipping them off site), restores the
aquifer, and limits the quantity and disposal configuration of the contaminated material
remaining at the site. Completion of the selected remedy will also provide for more
beneficial use of the FEMP property outside the disposal facility area.
DOE's plans for remediation of the site as a whole include a conservative approach
regarding on-site and off-site disposal of contaminated material. It is important to
distinguish that this approach includes off-site disposal of all of the more highly
contaminated material found at the FEMP in all operable units.
Plans are to remove the materials that constitute about 97% of the radioactivity present
at the FEMP for disposal at an off-site disposal facility. This will be accomplished via
completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:34pm A.3-103
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, J. M. (Contd.)
1 (Contd.)
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3% of the current quantity of radioactivity present at the site. This 3% is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, -and Operable Unit 4 construction rubble. While the remedy
for Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-site disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-site disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste
acceptance criteria for the less contaminated material were developed for the engineered
disposal facility to help ensure protection of the aquifer. Only material that falls below
the contamination level of the waste acceptance criteria will be disposed of in the
engineered disposal facility. Material that does not meet the criteria will have to be
either treated or shipped off site.
The waste acceptance criteria considers the hydrogeologic environment of the site and
the protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 8O parts per million total uranium
outside the former production area of the FEMP and 20 parts per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal
facility, a tenfold safety factor. It should be noted that sophisticated computer model
simulations used to derive the waste acceptance criteria were completed assuming that
there was no active maintenance of the facility and that the synthetic barriers present in
the facility (e.g., high-density polyethylene membranes) were not functioning. These
simulations indicate that even under these extreme conditions, the facility would still be
protective of the aquifer over the full 200- to 1000- year performance period envisioned
by federal regulations.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\D«cember 8, 1995 I2:34pm A.3-104
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, J. M. How can you say that only 9 inches of rain water per year will find it's way into the
2 aquifer.
Response:
The predicted infiltration rate through the proposed disposal facility and into the aquifer
is estimated to be 0.89 inch per year. This amount of infiltration is much lower than
estimated infiltration rates through the surrounding soil (which average about 6 inches
per year). The reason for the difference is that the impermeable cap on the disposal
facility is designed to carry precipitation away from the facility, not through it. Most of
the precipitation will travel horizontally away from the facility, and very little will be left
to travel vertically through the facility. This design infiltration rate for the disposal
facility does not take any credit for the use of synthetic layers because there is no
evidence that synthetic material will perform satisfactorily for 1000 years. The 0.89
inch per year estimate also assumes that the leachate collection system is not
functioning.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Deconber 8, 1995 12:34pm A.3-105
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
°lan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
joil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
(Below information is optional)
Name:
Address:
City:
Phone:
Mailing List Additions
'•;ase add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
rnald Environmental Management Project.
Yes
No
A.3-106a
-------
!-ernaid Comments - Operable Unit # 5 j
i
Don't trust DOE or EPA ' '
Poor past record - whatever they say I believe opposite. I
i
Those who ignore past mistakes are doomed to repeat them. ""
If the law can be changed to allow siteing of waste over the 2
aquifer it can be changed to allow outside waste into Ross. ^
i
3
If the west does not want the waste why do we want it? I
T
Cost estimates at +50 to -30% are more like wags than true cost 4
estimates. (Wild as guess) "
i
No one k_D_ows_ the storage pit will not leak. c
What about perche water under pit i
Tornados !
Earthquakes -p
6
DOE promised a clean up not a cover up. —
T
The citizens task force did not contain local citizen, only 1 (
so their concern about the local area is minimal.
T
o
If the site once it is cleaned up is safe why doesn't DOE put \
its new office building on site? They own the land.
Can the removal and cell be designed so that radioactive waste g
goes off site until all is gone or the west refuses to take it J-
any more?
When the dump leaks in the future what will be the cost to fix it -|Q
then? —
Once the most hazardous materials are gone the materials J..
remaining become the most hazardous. Clean it up don't pile it i
up and categorize it as clean and safe. "
i
12
Does the Citizen Task Force want this dump in their backyard? |
-------
The number of transport worker accidents involved in moving this I
is irrevelant to the decision. Any, all and no actions involve 13
risk. The question is "Is it a good long term idea to site '
nuclear waste over an aquifer?" The answer is NO . "
Now figure out the cost effective way to remove the material 14
safely . *L
Perch water areas may be under the proposed cell site which may 15
make the cell leak into the aquifer. . —
T
Why would Ohio EPA allow a nuclear dump to be established over on 16
aquifer? —
T
Creating the dump (cell) destroys more of the site than just 17
shipping it out. *—"
The current projections go 1000 years into the future but just J
20-30 years ago DOE thought nothing about working people without .L
protection. The more we know about nuclear/radioactive material i
the worse it appears to get. The more that is moved now the j^
better our community will be.
T
No one knows what the future land use will be. The Citizen Task j
Force did not recommend a use. Someone needs to decide a real 19
practical use, if any, before the dump (cell)/ clean up is i
f inalized . k~-
Why build one cell, why not turn this into a nuclear dump for all j
of the U.S.? If it is safe lets take it all if it is not - 20
Then lets get rid of it. Is a little cancer OK? JL
Is Fernald the only site in the US considering on site waste 21
disposal? Where else and why? —
i
22
Who is to txLarne. for this mess? j-
T
Who is held responsible when this cell leaks? What are the 23
guarantees? —
-------
This proposal on page 32 states NO Significent long term impact.
On Water Quality
Hydrology
Air Quality
Socioeconomic
Or culutral resources will be caused by the dump.
I want to know how thes conclusions were reached.
To state that a cuclear dump would have no_ significent impact
without detailed plans for future use seems unreasonable.
You seem to say different things to different groups.
It is safe to move nuclear material? We have never had a serious
accident when moving it.
25
Page 33 - Don't move it some one will have a train wreck..
What is it - should we all stay home from work because someone
might / will die in a traffic accident if we go to work? Lets
get on with the job.
Some dump somewhere out west will be glad to take our nuclear 26
crap. Quit using this as an excuse. J_
The dump grew from 1610 x 1610 x 40 feet 60 acres to
2400 x 1300 x 62 feet 71 acres
Why? Woops a math error. 27
Maybe thats only 10 years protection on the aquifer instead of
1000.
Damn those decimal points!
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
sn
28
(Below information is optional)
Name:
Address:
City:
Phone:
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
-------
49
1 spend hard earned taxpayer money to treat water for
2 drinking and then dump it to the river. This is
3 inconceivable in this time of shrinking budgets.
4 We all need to tighten our belts. Here we need to
5 simply abandon such an idea and treat only as
6 necessary to protect the river (fish, et cetera)
7 and recreational users of the river. Anybody using
8 the river for drinking (Note: I don't know of any)
9 would be required to treat the water anyway.
10 Those were submitted into the record
11 this evening.
12 Now I have a request by Tom Renck to
13 speak with Ross Area Merchants. Tom. You can use
14 this microphone here or that one there, either
15 one.
16 MR. RENCK: I'm Tom Renck, I'm
17 representing the Ross Area Merchants. I have seven
18 points to make, and I am going to start off I think j
19 with my conclusion, which I think this needs to be
20 taken as we're taking this whole thing, which is as j
29
21 citizens we trusted this group to clean it up and
22 did not become actively involved until March 17th.
23 We now at that point found out that there was a
24 cover-up, and we've wrote a letter and the
Spangler Reporting Services
PHONE (513) 381-3330 PAX (513) 381-3342
-------
50
1 merchants, which represents about 60 businesses in j
r\_
2 the local area, are opposed to this cell. We don't
3 feel it's a good long-term solution.
4 You folks have been studying this for
5 two years. We're given 30 days to comment on this,
6 we don't feel that's long enough. This is one of
7 our busiest times in the year in this farming
8 community. Everybody is out in the fields tonight,
9 that's why there aren't people here that should
10 have been here. So we would like to have another
11 30 days to comment on this process.
12 We feel that the Citizens Task Force
13 is not representative of the local citizens. We
14 don't know where these folks came from. We
31
15 understood that a lot of the people tried to get on
16 here locally. We didn't have a lot of involvement
17 because we thought it was going to be cleaned up,
18 so we feel that the Citizens Task Force does not
19 represent us fairly.
20 Seems to be an awful lot of jargon
21 used in this, Operable Unit Number 5, on-site
22 engineered disposal facility. We call this a dump,
23 and I think when all this information is being
24 given out to people, they're getting very, very
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
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51
1 confused. I've involved about two months, and this
2 is the amount of material that I've received to
3 study, read, revise, look at. I mean this is not
4 my job, and I'm overwhelmed. I have another
5 cardboard box at home that I throw all this Fernald
6 information in, and it's about two or three foot
7 high of stuff that I can glean at and get rid up,
8 but we're just overwhelmed, we're wore out, and I
9 think that's part of the process, we get worn down
10 trying to understand what's going on in our
11 community.
32
12 Last week I attended a meeting that I
13 thought was important, same notification. Operable
14 'Unit No. 5 deals with 9,800,000 cubic yards of
15 material. This thing dealt with 3,400 barrels of
16 material. It's just a drop in the bucket, but the j
!
17 same process goes on, and the average citizen that
18 gets involved just gets overwhelmed, and we've run
19 out of time, we've run out of energy.
20 I have .another document that has 30
21 comments about the document Operable Unit 5, so I'm
22 submitting the letter from the Ross Area Merchants
23 in opposition to this and my 30 comments in
24 writing, and I will hand this to Gary when I get
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T. E.
1
Renck, T. E.
2
Don't trust DOE or EPA
Poor past record - whatever they say I believe opposite.
Those who ignore past mistakes are doomed to repeat them.
Response:
Comments acknowledged.
If the law can be changed to allow siteing of waste over the aquifer it can be
changed to allow outside waste into Ross.
Response:
The granting of the waiver to the State of Ohio facility siting requirements does not
require a change to federal or state laws or regulations. CERCLA and the National
Contingency Plan both contain specific language regarding the issuance of a waiver to
federal or state environmental or siting requirements to facilitate the implementation of
response actions at cleanup sites.
Specific language has been added to Section 9 of this ROD to identify that the on-
property disposal facility may only accept waste from on-site sources. Waste generated
from off-site facilities are specifically precluded from acceptance at the on-property
disposal facility. Changes to federal or state law or regulation and amendments to
Records of Decision are subjected to public reviews and comment before enactment.
CRUS\ROD\MCM\APP-A\RSC-K-R.ROD\Deconber 8, 1995 12:34pm A.3-106
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Renck, T. E. If the west does not want the waste why do we want it?
3
Response:
The selected alternative for Operable Unit 5 is one part of an overall site strategy which
applies a balanced approach to remediation of the FEMP site as a whole. This
approach includes off-site disposal of all of the more highly contaminated materials
found at the FEMP in all operable units.
Plans are to remove the materials that constitute about 97% of the radioactivity present
at the FEMP for disposal at an off-site disposal facility. This will be accomplished via
completion of the selected remedies for Operable Units 1, 2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3% of the current quantity of radioactivity present at the site. This 3% is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy
for Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste
acceptance criteria for the less contaminated material were developed for the engineered
disposal facility to help ensure protection of the aquifer. Only material that falls below
the contamination level of the waste acceptance criteria will be disposed of in the
engineered disposal facility. Material that does not meet the criteria will have to be
either treated or shipped off site.
Renck, T. E. Cost estimates at +50 to -30% are more like wags than true cost estimates. (Wild
4 as guess)
Response:
EPA guidance on the completion of cost estimates to support feasibility studies under
CERCLA defines that conceptual engineering estimates with a precision range of +50 %
to -30 % be used to support the remedy decision process. Of significance is that a
consistent precision range and consistent assumptions (to the extent practical) are
employed during the FS to ensure a fair comparison of alternatives. The selected
alternative is subjected to more detailed cost estimating during the remedial design
process.
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Renck, T. E. No one knows the storage pit will not leak. What about perche water under pit.
5 Tornados
Earthquakes
Response:
The multi-layered lining and capping systems associated with the engineered disposal
facility are designed to minimize the infiltration and vertical migration of surface water
through the stored waste and into the underlying soil and groundwater aquifer. It is
recognized that complete elimination of infiltration through the disposal facility is
unlikely. Approximately 6 inches of rainfall per year naturally infiltrate through the soil
and clay in the FEMP area into the underlying groundwater aquifer. The lining and
capping systems associated with the engineered disposal facility will significantly reduce
this infiltration rate. Engineering calculations indicate that the infiltration rate through
the cap, liner and underlying soil would be less than 0.1 inch per year. To help ensure
long-term protectiveness, the waste acceptance criteria for the on-property disposal
facility were derived assuming that the infiltration rate through the cap, lining system
and underlying soil would be approximately 0.9 inches per year.
Regarding the potential occurrence of perched water under the on-property disposal
facility, the on-going siting investigation is examining the hydrogeologic and geologic
conditions in the northeastern portion of the site. The investigation is designed to
identify the best available geology at the FEMP site for purposes of siting the on-
property disposal facility. A few of the considerations in establishing the best available
geology are the thickness and relative impermeability of the existing clays and the
characteristics of any perched water zones encountered within the clays. The perched
water zones found at the FEMP are typically silty clay formations with increased
permeability. The intent of the siting investigation is to locate the facility in an area
with the thickest layer of protective clays coupled with the fewest number of significant
perched water zones. The occurrence of perched water zones within the clays were
considered in the derivation of the waste acceptance criteria for the various
contaminants of concern within the Operable Unit 5 media.
The probability and potential implications of tornados and earthquakes will be
considerations within the remedial design process for the disposal facility. A cursory
analysis of the impacts of tornados on the completed disposal facility indicates that such
an event would have minimal or no impact on the integrity of the disposal facility. A
cursory analysis indicated that the probability of a significant earthquake in the FEMP
area was inconsequential. More detailed analyses will be conducted during remedial
design.
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Renck, T. E. DOE promised a cleanup not a cover up.
6
Response:
The FEMP held routine public meetings throughout the remedial investigation/feasibility
study process. At each of these meetings, discussions were held or information was
distributed that discussed the remedial investigation/feasibility study decision process,
and DOE's and EPA's role in this process. At a number of these meetings the range of
options under consideration within the feasibility study process were discussed.
Additionally, the Cleanup Updates and fact sheets issued throughout the process
similarly discussed the options under consideration and the remedy selection process
being followed at the FEMP.
DOE and EPA consider the selected remedy to be the best available option considering
the tradeoffs between the technical and economic criteria evaluated. The selected
remedy restores the groundwater and soil at the site to levels considered health-
protective by federal environmental regulation, and permanently isolates the removed
contamination. The selected remedy provides for thejull restoration and permanent
protection of the Great Miami Aquifer and returns over 900 acres of land at the site for
alternate future uses.
Renck, T. E. The citizens task force did not contain local citizen, only 1 so their concern about
7 the local area is minimal.
Response:
The Fernald Citizens Task Force contained eight of fourteen members who live and work
in the direct vicinity of the site. Additionally, each of the Task Force meetings were
announced in the local papers and were open to the public. At each meeting the Task
Force requested public input into their ongoing deliberations and resolutions. A formal
public meeting was held by the Task Force to discuss some of their final resolutions on
cleanup levels, on-property disposal and future land use.
Renck, T. E. If the site once it is clean up is safe why doesn't DOE put its new office building on
8 site? They own the land.
Response:
The decision process establishing the location of any new office building to house site
personnel is not relevant to the Operable Unit 5 remedy. It should be noted, however,
that FERMCO/DOE are currently soliciting interest from private businesses for the
construction of an office building or the use of an existing building. FERMCO/DOE are
currently exploring the relative economic benefits of securing a long-term lease
arrangement with the owner of such a facility. DOE is not presently considering the
construction of such a facility using federal funding, and as such no consideration is
being given to using federal land to site the privately owned structure.
CRU5\ROD\MCM\APP-A\KSC-K-R.ROD\December 8, 1995 12:34pm A.3-109
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Renck, T. E.
9
Renck, T. E.
10
FEMP-O5ROD-6 FINAL
December 15, 1995
Can the removal and cell be designed so that radioactive waste goes off site until all
is gone or the west refuses to take it any more?
Response:
The balanced approach allows 97% of the radioactivity at the FEMP to be disposed of
at an off-site facility. This relatively highly contaminated material is contained in a
relatively low volume of material. Approximately 3% of the radioactivity present at the
FEMP will remain on site. This 3% is distributed over 2.4 million cubic yards of soil
and rubble. Shipping contaminated soil and rubble to an off-site facility in an attempt to
remove as great a volume of material as possible before the off-site facility "shuts its
doors " would neither guarantee a protective remedy nor constitute responsible action on
the part of DOE. There is no guarantee the most highly contaminated materials would
make it off site before refusal of material by the off-site facility. In this instance a
considerably greater percentage of radioactivity could remain on site than under the
currently proposed alternative. Additionally, a remedy involving off-site shipment of
waste has been endorsed by several out-of-state stakeholders based on the balanced
approach. DOE cannot in good faith abandon this principle.
When the dump leaks in the future what will be the cost to fix it then?
Response:
The cost analyses presented in the Feasibility Study Report for Operable Unit 5 for
alternatives considering on-property disposal included projected long-term monitoring
and maintenance costs of the facility. These costs included projected routine
maintenance items such as grass cutting and groundwater monitoring, and repairs to the
capping system, as needed", to address concerns raised during inspections of the facility
or in response to monitoring results.
It should be recognized that the probable root cause of any future increase in aquifer
concentrations underlying the footprint of the disposal facility would be a localized
failure of the capping system. Repairs to/the capping system of the disposal facility
would be readily implementable and not cost prohibitive.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Deconber 8, 1995 12:34pm A.3-110
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Renck, T. E. Once the most hazardous material are gone the materials remaining become the
11 most hazardous. Clean it up don't pile it up and categorize it as clean and safe.
Response:
Comment Acknowledged. The selected remedy will excavate approximately 1.8 million
yards of contaminated soil to ensure the long-term protection of future human and
biological receptors and the underlying Great Miami Aquifer. Soil will be removed to
attain cleanup levels deemed health-protective by federal environmental regulation. The
exhumed soil will be permanently isolated in an on-property disposal facility. Following
completion of remedial actions and enactment of the necessary institutional provisions,
the site can be categorized as "clean and safe. "
DOE understands that a segment of the community near the FEMP wants the site
cleaned up and all contamination removed. DOE realizes that some of the public will
think that it is unfair to propose that some contaminated FEMP material remain in an
engineered on-property disposal facility. But it is equally unfair to expect other
communities located in other areas of the country to accept large quantities of
contaminated material from the FEMP site. The current site-wide remedial approach, of
which Operable Unit 5 is a component, involves balancing the off-site disposal of large
volumes of highly contaminated wastes with on-property disposal of less contaminated
soil and rubble.
Renck, T. E. Does the Citizen Task Force want this dump in their back yard?
12
Response:
The Fernald Citizens Task Force issued a recommendation regarding on-property
disposal at the FEMP. While the Task Force acknowledged that the FEMP was not the
ideal location for the disposal of radioactive materials, they endorsed a balanced
approach to site restoration and established that on-property disposal was the most
prudent and effective solution. The Task Force recommendation also contained a series
of considerations for the remedial design phase. These considerations will be
accommodated during the design phase of the on-property disposal facility.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:34pm A.3-111
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Renck, T. E. The number of transport worker accidents involved in moving this is irrevelant to
13 the decision. Any, all and no actions involve risk. The question is Is it a good long-
term idea to site nuclear waste over an aquifer? The answer is NO.
Response:
DOE and EPA concur with the commentor that all alternatives have some associated
risk. While the commentor considers the potential for transport accidents to be
irrelevant to the remedy decision, the National Contingency Plan requires that short-
term risks be evaluated as balancing criteria in the comparison of remedial alternatives.
This analysis of short-term risks is presented in Appendix G of the Operable Unit 5
Feasibility Study Report.
Regarding the long-term effectiveness of the selected remedy, clearly the FEMP is not
the optimal location for the construction of a disposal facility. The geologic conditions
present at the site were subjected to in-depth analysis as pan of the Operable Unit 5
remedial investigation/feasibility study process. The findings of this analysis contributed
to the conceptual design configuration of the projected on-property disposal facility and
to the derivation of the waste acceptance criteria. In all cases the analysis was
performed on the conservative side which would produce more restrictive design
requirements for the disposal facility and more limiting acceptance criteria. As a result
of this process over 97% of the radioactivity present at the FEMP site is being
dispositioned off site. The remaining 3% of the radioactivity is being considered for on-
property disposal. This material is being considered for on-property disposal as a result
of being dispersed in relatively low concentrations in approximately 2.4 million cubic
yards of soil and construction rubble.
As presented in the Operable Unit 5 Feasibility Study Report, Alternative 3A provides for
the long-term protection of human health and the environment, complies with all
applicable or relevant and appropriate requirements, and presents the best balance of
tradeoffs between the primary balancing criteria. Alternative 3A is considered to
provide for long-term protectiveness through the definition of stringent design
requirements for the on-property disposal facility, the adoption of strict waste acceptance
criteria, and the definition of concentration-based final remediation levels. While more
detail can be found in the Operable Unit 5 Feasibility Study Report, the applicable or
relevant and appropriate requirements identified in Appendix B of this Record of
Decision require that the on-property disposal facility be designed to attain a series of
federal and state environmental and facility siting requirements. These requirements
include federal and state hazardous waste regulations, federal regulations on the
disposal of uranium mill tailings and State of Ohio regulations for disposal of solid
wastes.
CRU5\ROD\MCMWPP-A\RSC-K-R.ROD\Decanber 8, 1995 12:34pm A.3-112
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December 15, 1995
Renck, T. E.
13
(Contd.)
Renck, T. E.
14
(Contd.)
The waste acceptance criteria were derived assuming that a performance requirement of
the disposal facility was the protection of the underlying aquifer for a period of 1000
years into the future. The 1000-year time frame was adopted from federal regulations
on the disposal of uranium mill tailings. The waste acceptance criteria were developed
assuming that the performance of the disposal facility should ensure that the facility did
not permit the concentrations of contaminants in the underlying aquifer to exceed
drinking water maximum contaminant levels for this 1000-year period. To accomplish
this derivation, conservative assumptions were made regarding the relative leachability
of the contaminants present in FEMP soil. These assumptions were based upon field
analysis performed during the remedial investigation and the feasibility study.
Additionally, conservative assumptions were employed in the waste acceptance criteria
derivation regarding the future infiltration rate through the disposal facility. While
modeling indicates that infiltration through the capping system of the disposal facility
will be less than 0.1 inch per year, the acceptance criteria were based upon
approximately 0.9 inch per year to accommodate a presumed failure of the synthetic
materials in the disposal facility lining and capping systems. These assumptions have
yielded a disposal system which will ensure long-term performance.
Lastly, the final remediation levels for soil for the FEMP have been derived to ensure
the long-term performance of the remedy. To derive the cleanup levels, cross-media
impacts were considered. Cross-media impacts refer to the potential for contaminants
present in the media to leach over the long-term into surface water and migrate
vertically to the underlying aquifer. Traditionally, this mode of contaminant transport is
not considered in the development of cleanup levels. Cross-media impacts were
considered at the FEMP to ensure that the remedy is protective over the long term. As
such, the modeling performed to develop the final remediation levels for soil were based
on the need to protect the underlying aquifer for the same period of 1000 years into the
future. To ensure that long-term protection is provided by the final remediation levels,
conservative input parameters were used in fate and transport models regarding the
chemical form of the uranium and other contaminants in the soil and the adsorptive and
desorptive properties of the soil column. These modeling results yielded soil cleanup
levels for the selected alternative which not only provide for the permanent protection of
future users of the land and soil at the site, but also present and future users of the
groundwater aquifer.
Now figure out the cost effective way to remove the material safely.
Response:
The selected alternative represents the best overall remedial alternative considered in the
feasibility study considering the threshold and primary balancing criteria as defined by
the National Contingency Plan. One of the balancing criteria used as a basis for
comparing remedial alternatives is cost. The detailed backup cost estimates for the
alternatives is presented in Appendix K of the Feasibility Study Report. A summary of
these estimates are presented in the Proposed Plan for Operable Unit 5.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Deconbcr 8, 1995 12:34pm A.3-113
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Renck, T. E.
16
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T. E. Perch water areas may be under the proposed cell site which may make the cell leak
15 into the aquifer.
Response:
As previously discussed above, the on-going siting investigation is examining the
hydrogeologic and geologic conditions in the northeastern portion of the site. The
investigation is designed to identify the best available geology at the FEMP site for
purposes of siting the on-property disposal facility. A few of the considerations in
establishing the best available geology are the thickness and relative impermeability of
the existing clays and the characteristics of any perched water zones encountered within
the clays. The perched water zones found at the FEMP are typically silty clay
formations with increased permeability. The intent of the siting investigation is to locate
the facility in an area with the thickest layer of protective clays coupled with the fewest
number of significant perched water zones. The occurrence of perched water zones
within the clays were considered in the derivation of the waste acceptance criteria for
the various contaminants of concern within the Operable Unit 5 media.
Why would Ohio EPA allow a nuclear dump to be established over on aquifer?
Response:
The siting of the on-property disposal facility at the FEMP requires the issuance of a
waiver to State of Ohio solid waste disposal facility siting requirements. The regulatory
basis for the issuance of waivers to facilitate the implementation of CERCLA response
actions is provided in the National Contingency Plan. Discussions on the technical basis
for the granting of the required waiver for the selected remedy is discussed in Section
5.6 of the Feasibility Study Report for Operable Unit 5 and in Section 10 of this Record
of Decision. OEPA has indicated that they support the issuance of the waiver as a
component of an overall balanced remedy for the site. OEPA endorsed the issuance of
the waiver under the stipulation that a series of technical and operational constraints be
factored into remedy implementation. These constraints are listed in the correspondence
from OEPA appearing in this Responsiveness Summary.
Creating the dump (cell) destroys more of the site than just shipping it out.
Response:
Alternative 3A requires the permanent dedication of approximately 131 acres of the
FEMP property to waste disposal (includes the disposal facility and associated buffer
zone). The remaining areas of the site would be available for alternate land uses.
Renck, T. E. The current projections go 1000 years into the future but just 20-30 year ago DOE
18 thought nothing about working people without protection. The more we know
about nuclear/radioactive material the worse it appears to get. The more that is
moved now the better our community will be.
Response:
Comment Acknowledged. See previous response to comment numbered as
T.E. Renck 11.
Renck, T. E.
17
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December 15, 1995
Renck, T. E. No one knows what the future land use will be. The Citizen Task Force did not
19 recommend a use. Someone needs to decide a real practical use, if any, before the
dump (cell)/clean up is finalized.
Response:
The comment raises the need to properly align the necessary institutional control
provisions for the FEMP with thefiuure land use for the facility to ensure the continued
protection of human health. DOE agrees with the need for this alignment. It is not the
intent of DOE to attempt to establish a final future land use for the FEMP through this
decision document. DOE does recognize that the final remediation levels identified in
Section 9.0 of this Record of Decision do establish the permissible concentrations of
contaminants which could remain at the site following completion of remedial actions.
These remaining concentrations of contaminants will present a potential for exposure to
future users of the FEMP.
The Fernald Citizens Task'Force issued recommendations regarding future use of the
Fernald property in May of 1995, recommending that the area of the FEMP containing
the disposal facility and associated buffer zone remain under the continued ownership of
the federal government. Additionally, the Task Force recommended that the remaining
portions of the FEMP property be made available for the uses that are the most
beneficial to the surrounding communities. While the Task Force recommended
prohibiting any son of agricultural or residential uses of the remaining portions of the
FEMP property (outside the disposal facility area), the Task Force encouraged DOE to
consult with the local communities to establish their preferences for future use and
ownership of these areas of the site. Consistent with this recommendation, DOE does
not consider it prudent to insert enforceable provisions within this Record of Decision to
provide for any specific final land use for the site including any language which would
require the continued federal ownership of the entire FEMP property.
Renck, T. E. Why build one cell, why not turn this is a nuclear dump for all of the U.S.? If it is
20 safe lets take it all if it is not - Then lets get rid of it. Is a little cancer OK?
(continued)
Response:
Comment Acknowledged. A general consensus of the public comments on the Operable
Unit 5 Proposed Plan was that specific language should be included in the Record of
Decision to preclude the acceptance of waste generated off-site into the on-property
disposal facility. Consistent with this position, language has been included in Section 9
of the Record of Decision to provide such a prohibition.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Decen>ber 8. 1995 12:34pm A.3-115
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December 15, 1995
Renck, T. E. Is Fernald the only site in the U.S. considering on site waste disposal? Where else
21 and why?
Response:
A number of sites across the United States have selected on-property disposal for
materials similar to those being addressed under Operable Unit 5; as examples, the
Weldon Spring site near St.Louis, the Maxey Flats site in eastern Kentucky, and the
former Vitro Rare Metals Plant at Canonsburg, Pennsylvania. Each of these facilities
adopted on-property disposal for the radioactive materials present at the sites. The
decision process for the Weldon Spring and Maxey Flats sites followed CERCLA and the
National Contingency Plan and therefore was based upon a weighting of the same
factors considered for Operable Unit 5. The decision process for Canonsburg used the
National Environmental Policy Act environmental impact statement process. This
process performs similar technical evaluations to the CERCLA decision process and has
been determined to be functionally equivalent to the remedial investigation/feasibility
study remedy selection process.
For sites contaminated with chemical constituents, on-property land disposal has been
widely applied since the inception of the Superfund program in the early 1980s. The
emplacement of caps over consolidated waste materials has been widely applied at
industrial sites across the United States.
Renck, T. E. Who is to blame for this 'mess?
22
Response:
The DOE has taken clear responsibility for contaminated media associated with the
FEMP. This responsibility is clearly outlined in the docket placing the FEMP (then the
FMPC) on the National Priorities List and within the Findings of Fact outlined in the
Amended Consent Agreement. DOE has similarly taken full responsibility for the prompt
implementation of a remedial action program, at the FEMP to ensure the long-term
protection of human health and the environment.
Renck, T. E. Who is held responsible when this cell leaks? What are the gurantees?
23
Response:
As indicated in Section 9 of this Record of Decision, the federal government has
committed to maintaining the land associated with the on-property disposal facility under
the continued ownership of the federal government. Any required maintenance of the
disposal facility would be the on-going responsibility of the federal government. The
CERCLA statute requires that remedies adopting on-property disposal as pan of the
remedy must perform reviews at least once every five years to assess the continued
protectiveness of the remedy. Section 9 of this Record of Decision contains language
regarding the commitment to perform these reviews. In the event these reviews indicate
that the remedy is no longer protective, additional response measures would be required
to be taken by the federal government to address the identified concern and ensure the
permanent protection of human health and the environment.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:34ptn A.3-116
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December 15, 1995
Renck, T. E. This proposal on page 32 states NO Signiflcent long-term impact. On Water
24 Quality, Hydrology, Air Quality Socioeconomic, Or culutral resources will be
caused by the dump. I want to know how thes conclusions were reached. To state
that a cuclear dump would have no significant impact without detailed plans for
future use seems unreasonable.
Response:
The statements in the Proposed Plan represent a summary of the analyses performed in
Section 5 (and associated appendices) of the Feasibility Study Report for Operable Unit
5. The commentor is referred to this section of the Report for the analysis of the long-
term impacts of the remedial alternatives subjected to detailed evaluation, including the
alternative selected for implementation (3A).
The final remediation levels and waste acceptance criteria for the selected remedy were
designed to achieve a consistent level of protectiveness to potential future human
receptors, identified under Land Use Objective 3 in the Feasibility Study Report and the
Proposed Plan as recreational and industrial users. These remediation levels for soil,
sediment and groundwater are defined in Section 9 of this ROD and are consistent with
the recommendations issued by the Fernald Citizens Task Force regarding future land
use. Following remedy implementation, no significant long-term exposure threat
associated with site-introduced contaminants would exist for future recreational or
industrial users of the site.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:34pm A.3-117
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December 15, 1995
Renck, T. E. You seem to say different things to different groups.
25
It is safe to move nuclear material? We have never had a serious accident when
moving it.
Page 33 - Don't move it some one will have a train wreck. What is it - should we
all stay home from work because someone might/will die in a traffic accident if we
go to work? Lets get on with the job.
Response:
DOE has attempted to provide consistent information to all parties regarding the
Operable Unit 5 remedy decision process. The commentor is correct in that there has
not been a serious accident involving the transportation of radioactive material in the
United States to date. This statement refers to the potential impacts associated with the
release of the radioactive material during a transportation accident, not to the potential
for injury or death as a result of accidents involving these vehicles unrelated to the
materials being conveyed.
The injury and death statistics summarized in the Proposed Plan and presented in detail
in Section 5 and Appendix G of the Operable Unit 5 Feasibility Study Report, refer to
accidents associated with the mode of transport unrelated to the materials being
transported. As clearly indicated in the Report, the potential impacts associated with the
loss of containment of the Operable Unit 5 materials during a transportation accident
are extremely low or negligible. These potential impacts are minimal because of the
relatively low concentrations of contaminants present in Operable Unit 5 materials.
These materials do not present an acute exposure threat to human receptors.
The impacts discussed on page 33 of the Proposed Plan refer to the potential accidents
associated with the bulk transport of large quantities of materials for those remedial
alternatives which rely upon off-site disposal as a principal component of the response.
Estimates of projected injuries and deaths associated with material transport were based
upon data obtained from the Department of Transportation and the railroad industry.
The data is based upon the mode of transport, the total miles transversed and the
number of highway-railroad crossings (for rail transport only). These statistics did not
consider the type of materials being conveyed or their potential impact to populations if
released during transportation-related accidents.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Decanber 8, 1995 12:34pm A.3-118
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T. E. Some dump somewhere out west will be glad to take our nuclear crap. Quit using
26 this as an excuse.
Response:
There currently are only two disposal facilities in the United States with the necessary
permits, licenses or authorities to receive the Operable Unit 5 materials. These facilities
are the Nevada Test Site and the Envirocare facility in Give, Utah. State authorities in
both locations have endorsed the selected remedies for Operable Units 1 through 5 at
the FEMP because they presents a balanced approach to site cleanup with a proper
distribution of responsibility for the long-term management of site contaminated
materials. While the operators of the disposal facilities may be open to the receipt of
the large quantity of Operable Unit 5 materials, the associated State authorities in each
location are not as receptive.
It should also be recognized that the Operable Unit 5 remedy is projected to take
between 10 and 25 years to implement, dependent on future funding levels. While
capacity may be available at a facility today to receive the material, the uninterrupted
and continued availability of this capacity over the long term is highly uncertain. This
high level of uncertainty for the continued availability of off-site disposal capacity was
one factor considered in the evaluation of available options for Operable Unit 5.
Renck, T. E. The dump grew from 1610 x 1610 x 40 feet 60 acres to 2400 x 1300 x 62 feet 71
27 acres. Why? Woops a math error. Maybe thats only 10 years protection on the
aquifer instead of 1000. Damn those decimal points!
Response:
The figures presented on page 36 in the Operable Unit 5 Proposed Plan are correct.
The 60-acre area refers to the projected footprint of the disposal facility to accommodate
the 1.8 million cubic yards of contaminated soil needing excavation to attain the final
remediation levels for Operable Unit 5. The 71-acre area referred to on page 42 of the
Proposed Plan refers to the projected footprint of the disposal facility that would be
. required to accommodate the materials identified for on-property disposition based upon
the integration of the anticipated final remedies for all five FEMP operable units. This
projection of the site-wide remedy, including the total quantities of materials estimated to
leave the site and those projected to remain following remedial actions, was provided to
properly frame for the reader the role of the Operable Unit 5 decision within the overall
site-wide remedial strategy. Therefore, the 71-acre disposal facility would include the
Operable Unit 5 materials, approximately 600,000 cubic yards of contaminated soil and
construction debris from Operable Units 1 through 4, and exhumed waste materials from
Operable Unit 2 facilities, including the fly ash piles and the lime sludge ponds.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Deconber 8, 1995 12:34pm A.3-119
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T. Who was notified of this? How? When? I thought all residents were to be notified.
28 Were they?
Response:
As part of the overall site program for community involvement at Fernald, Operable
Unit 5 provided the public with numerous opportunities during the past few years for
commenting on proposed cleanup alternatives relating to the remediation of
environmental media on and off site. The public involvement strategy consisted of a
combination of written information, support of the Fernald Citizens Task Force, meetings
with local trustees and activist groups, and public workshops to solicit public input.
Fernald management has consistently sought more effective ways to involve the public.
One example is the envoy program. DOE will continue to seek effective ways to involve
the public.
The specific Operable Unit 5 community involvement program included fact sheets,
monthly updates for FRESH meetings, reports, and new releases. Presentations were
regularly given at public workshops and ranged from discussions on the Operable Unit 5
Remedial Investigation/Feasibility Study Report to providing information on the latest
project designed to significantly reduce contamination. In addition, Operable Unit 5
supported the Fernald Citizens Task Force by fulfilling Task Force requests for
information.
To enable the public to become involved early in the decision-making process, Operable
Unit 5 held its first workshop on June 1, 1993. This workshop gave the public an
understanding of what alternatives were being considered to clean up Operable Unit 5.
The workshop focused on these issues:
What are the eight major steps in the Initial Screening of Alternatives screening
process?
What alternatives are being developed to clean up perched and regional
ground-water?
- What alternatives are being developed to clean up soil and stream sediment?
- How can the public become involved in the decision-making process?
As communications with Fernald stakeholders increased, Operable Unit 5 learned that
many did not understand complex groundwater issues. On November 23, 1993,
Operable Unit 5 conducted a second workshop to increase stakeholder understanding of
groundwater issues so they could make more informed comments on the preferred
cleanup alternative. This workshop focused on:
- What is the regional geologic setting of the FEMP and the Fernald area?
What is the occurrence and movement of groundwater?
What groundwater is contaminated at the FEMP and where can it spread?
As work moved beyond sampling and analysis and into preparing the very comprehensive
Remedial Investigation Report, Operable Unit 5 conducted its third workshop to explain
the nature and content of contamination at the site. The November 15, 1994, meeting
focused on:
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\Deceinber 8, 1995 12:34pm A.3-120
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T. (Contd.)
28 (Contd.)
- What are uranium concentrations in soil and the Great Miami Aquifer?
What are the other contaminants in soil and groundwater, and where are they going ?
What cleanup options are being considered?
- How can the public become more involved in the decision-making process?
A fourth workshop was held March 28, 1995, soon after submittal of the draft final
Feasibility Study and Proposed Plan for Operable Unit 5 to EPA and OEPA. This
workshop provided the public with a chance to ask questions and get information on the
Feasibility Study and Proposed Plan, before the formal public comment period. This
workshop focused on the following topics:
- How does DOE propose to clean up the soil, sediment, and groundwater and how
did DOE arrive at this recommendation?
- What are the risks of this proposed action?
- What does DOE plan to do with disposed soil?
- How can the public become involved in decision making?
Local governmental, business, and activist group meetings attended by FEMP managers
during the March-May 1995 time frame included:
March 22 — Ross Merchants Meeting
April 17 — Morgan Township Trustee Meeting
April 18 — Ross Township Trustee Meeting
April 24 — Crosby Township Trustee Meeting
April 25 — Ross Lions Club Meeting
May 17 — Cooperative Planning & Training Committee
Sections 3.0 and A.2.0 contain more information on public involvement and community
participation. DOE will continue to seek effective ways to involve the public.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8. 1995 12:34pm A.3-121
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T., ...this needs to be taken as we're [Mr. Renck said he represented the Ross Area
Transcript Merchants] taking this whole thing, which is as citizens we trusted this group to
29 dean it up and did not become actively involved until March 17th. We now at that
pouit found out that there was a cover-up, ...
Response:
The FEMP held routine public meetings throughout the remedial investigation/feasibility
study process. At each of these meetings discussions were held or information was
distributed that discussed the remedial investigation/feasibility study decision process,
and DOE's and EPA's role in this process. At a number of these meetings the range of
options under consideration within the feasibility study process were discussed.
Additionally, the Cleanup Updates and fact sheets issued throughout the process
similarly discussed the options under consideration and the remedy selection process
being followed at the FEMP.
DOE and EPA consider the selected remedy to be the best available option considering
the tradeoffs between the technical and economic criteria evaluated. The selected
remedy restores the groundwater and soil at the site to levels considered health-
protective by federal environmental regulations, and permanently isolates the removed
contamination. The selected remedy provides for the full restoration and permanent
protection of the Great Miami Aquifer and returns over 900 acres of land at the site for
alternate future uses.
CRUS\ROD\MCM\APP-A\RSC-K-R.ROD\December 8,1995 12:34pm A.3-122
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T., We ... are opposed to this cell. We don't feel it's a good long-term solution.
Transcript
30 Response:
DOE understands that a segment of the community near the FEMP site wants all
contamination removed from the site and shipped to an off-site location. DOE realizes
that some members of the public will think that it is unfair to propose that some
contaminated FEMP material remain in an engineered on-property disposal facility. But
it is equally unfair to expect other communities located in other areas of the country to
accept large quantities of contaminated material from the FEMP site. The current site-
wide remedial approach, of which Operable Unit 5 is a component, involves balancing
the off-site disposal of the FEMP's inventory of highly contaminated wastes with on-
property disposal of less contaminated soil and rubble.
Plans are to remove the materials that constitute about 97% of the radioactivity present
at the FEMP for disposal at an off-site disposal facility. This will be accomplished via
completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3% of the current quantity of radioactivity present at the site. This 3% is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy
for Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste
acceptance criteria for the less contaminated material were developed for the engineered
disposal facility to help ensure protection of the aquifer. Only material that falls below
the contamination level of the waste acceptance criteria will be disposed of in the
engineered disposal facility. Material that does not meet the criteria will have to be
either treated or shipped off site.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:34pm A.3-123
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FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T., We feel that the Citizens Task Force is not representative of the local citizens. We
Transcript don't know where these folks came from. We understood that a lot of the people
31 tried to get on here locally. We didn't have a lot of involvement because we
thought it was going to be cleaned up, so we feel that the Citizens Task Force does
not represent us fairly.
Response:
In early 1993, officials with the Department of Energy met with key stakeholder groups,
such as FRESH, to seek comments on the concept of creating a citizens advisory board.
The DOE initially decided that creating a citizens advisory board was the best way to
get public input on strategic issues related to cleaning up the Fernald site. Once the
decision was made to create an advisory board, the DOE decided to use a neutral,
third-party consultant — called a "convener" — to select people to serve on what would
become the Fernald Citizens Task Force. Only when stakeholders indicated their
acceptance did DOE proceed with finding a convener by writing a task order and
circulating it among Ohio colleges and universities.
DOE opted for the convener approach because it was perceived to be the most efficient
and fair way to seek members for the advisory group. The DOE considered other
approaches including:
- Empaneling a steering committee to select candidates
- Having DOE select members
- Asking a state agency to screen candidates
The convener for the Fernald Citizens Task Force was Dr. Eula Bingham, a professor of
environmental health in the College of Medicine and director of the Ohio Hazardous
Substances, Research, Education, and Management Institute at the University of
Cincinnati. She has extensive experience with citizen advisory groups, having served on
local, national, and international committees dealing with environmental and public
health issues. t
In addition to nominating candidates to serve on the Task Force, Dr. Bingham drafted a
charter, containing the group's mission statement and purpose. She began work in May
1993 and completed her task in August 1993.
Although Dr. Bingham operated independently, some steps she took during convening
included:
- Asking DOE for a list of key stakeholders' names and phone numbers. She used
this list for initial contacts; a letter of introduction was sent to key stakeholders
telling them that Dr. Bingham was convening an advisory group.
- Meeting with officials from DOE, EPA, and OEPA to discuss the mission of the
advisory group and how it would be convened. DOE agreed to appoint the slate
nominated by Dr. Bingham, rather than veto individuals.
- Calling and/or meeting with stakeholders and others recommended by key
stakeholders. The conversations focused on potential members and what should
be contained in the draft charter. Dr. Bingham sought candidates who ensured a
balanced and diverse representation of the parties affected by activities at the
Fernald site.
CRU5\ROD\MCM\APP-A\RSC-K-R.RODVDecember 8, 1995 12:34pm A.3-124
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Renck, T.,
Transcript
31 (Contd.)
Renck, T.,
Transcript
32
(Contd.)
- Holding a public work session in July 1993 to discuss how the Task Force should
operate and who should serve as members. Dr. Bingham asked for volunteers as
well. This meeting was advertised in area newspapers and through other
publicity channels, such as flyers and announcements to stakeholder groups.
DOE also continued, as pan of its public information program, providing updates on
the status of the convening process to stakeholders, either through meetings or other
face-to-face contact or with written materials.
When the draft charter and list of nominees were submitted to DOE, EPA, and
OEPA, that information was announced to the public via news releases and other
techniques.
The Task Force convened shortly after members received their appointment letters
from DOE. Its first meeting was held in October 1993. The group has publicized its
meetings in monthly mailings and advertisements in the Cincinnati Enquirer, the
Journal-News, and the Harrison Press.
...this Fernald information ... we're just overwhelmed, we're wore out, and I think
that's part of the process, we get worn down trying to understand what's going on
in our community. ... but the same process goes on, and the average citizen that
gets involved just gets overwhelmed, and we've run out of time, we've run out of
energy.
Response:
The DOE acknowledges that the volume of information supplied to the community can be
overwhelming. However, it would be inappropriate for the DOE to screen the
information presented to the public. For this reason the public is supplied with
information on all major issues at the FEMP through many forums including meetings,
reports and fact sheets. Members of the community are encouraged to select topics of
personal significance and to participate to the extent practical.
CRUS\ROD\MCM\APP-A\RSC-K-R.ROD\Deconber 8, 1995 12:34pm A.3-125
-------
Ross Area Merchants
March 17, 1995
Director Public Information
Mr. Gary Stigner
Fernald Area Office
US. Department of Energy
P.O Box 538705
Cincinnati, Ohio 45253-8705
Dear Mr. Stigner,
The Ross Area Merchants Association, a local business organization of 60
members, is very concerned and disappointed with the current proposal to store large
amounts of nuclear material on the Fernald site.
It was our understanding that the Fernald site would be cleaned up. Burying
nuclear waste over an aquifer is not an environmentally sound long term solution. The
original problems at Fernald were caused by this same short term thinking. This proposal
would nol clean up the problem, but be more like hiding the mess under a rug.
We, the business leaders of the Ross area, our families and employees totally reject
on site storage as a viable option Let's get serious about doing the job right for the long
term and bring to this community a real solution we can support and live with
Sincerely,
The Ross Area Merchants Association
IYJ
Ann M. Schulte, President
^n/vt-j
Cindy Queen, Treasurer
Eva Roudebush, Secretary
Joseph Conrad, Trustee
Thomas Renck, Trustee
P.O. Box 641 Ross, Ohio 45061-0641,
A.3-126a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Ross Area The Ross Area Merchants Assn. a local business organization of 60 members, is
Merchants very concerned and disappointed with the current proposal to store large amounts
Assn. of nuclear material on the Fernald site. It was our understanding that the Fernald
1 site would be cleaned up. Burying nuclear waste over an aquifer is not an
environmentally sound long-term solution. The original problems at Fernald were
caused by this same short term thinking. This proposal would not dean up the
problem, but be more like hiding the mess under a rug. We, the business leaders of
the Ross area, our families and employees totally reject on site storage as a viable
option. Let's get serious about doing the job right for the long term and bring to
this community a real solution we can support and live with.
Response:
DOE understands that a segment of the community near the FEMP site wants all
contamination removed from the site and shipped to an off-site location. DOE realizes
that some members of the public will think that it is unfair to propose that some
contaminated FEMP material remain in an engineered on-property disposal facility. But
it is equally unfair to expect other communities located in other areas of the country to
accept large quantities of contaminated material from the FEMP site. The current site-
wide remedial approach, of which Operable Unit 5 is a component, involves balancing
the off-site disposal of the FEMP's inventory of highly contaminated wastes with on-
property disposal of less contaminated soil and rubble.
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer: stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has
adversely impacted an approximate 200-acre area of the aquifer system. DOE also
recognizes that if the FEMP is not cleaned up it poses continued contamination risk to
the public and to the aquifer. DOE intends to eliminate this unacceptable risk by
moving forward with a balanced remediation approach. This approach gets the most
contaminated materials away from the aquifer (by shipping them off site), restores the
aquifer, and limits the quantity and disposal configuration of the contaminated material
remaining at the site. Completion of the selected remedy will also provide for more
beneficial use of the FEMP property outside the disposal facility area.
Plans are to remove the materials that constitute about 97% of the radioactivity present
at the FEMP for disposal at an off-site disposal facility. This will be accomplished via
completion of the selected remedies for Operable Units 1,2, 4, and 5 in conjunction
with the anticipated Operable Unit 3 remedy and the current plans to remove the site
legacy waste and uranium product.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:34pm A.3-126
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Ross Area
Merchants
Assn.
1 (Contd.)
(Contd.)
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3% of the current quantity of radioactivity present at the site. This 3% is
distributed over an estimated 2.4 million cubic yards of soil and rubble at the site. This
material will consist of lightly contaminated materials; specifically Operable Unit 5 soil,
Operable Unit 2 material, and Operable Unit 4 construction rubble. While the remedy
for Operable Unit 3 has not been finalized, rubble from this operable unit is also being
considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste
acceptance criteria for tine-less contaminated material were developed for the engineered
disposal facility to help ensure protection of the aquifer. Only material that falls below
the contamination level of the waste acceptance criteria will be disposed of in the
engineered disposal facility. Material that does not meet the criteria will have to be
either treated or shipped off site.
CRU5\ROD\MCM\APP-A\RSC-K-R.ROD\December 8, 1995 12:43pm A.3-127
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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Dvi-or health and
(Below information is optional)
Name: Ann M. Schulte
Address: 3825 Mew Hav<=»n
CltV" QV»ar»/^*"in flH '
Phone:
51 3-
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-128a
-------
53
1 or less.
2 We need real time monitoring.
3 Also continue to evaluate
4 technologies that would increase protection to
5 residents and community.
6 No dilution of waste to meet waste
7 acceptance criteria. Soils above 1030 to be
8 shipped off-site.
9 And I do support the US EPA's waiver
10 of siting criteria.
11 In conclusion, the Fernald site
12 beyond the disposal cell should become a wetland or
13 sanctuary, and I believe in the balance approach
14 for all DOE sites. Thank you.
15 MR. STEGNER: Thank you, Edwa.
16 Anyone else care to offer -- Ann.
17 MS. SCHULTE: I'm Ann Schulte, I'm a
18 member of Ross Area Merchants Association and I am
19 also a resident of --
20 UNIDENTIFIED SPEAKER: We can't hear
21 you.
22 MS. SCHULTE: I'm Ann Schulte and I
23 am also a resident of Morgan Township and I am also
24 a member of Ross Area Merchants Association. I'm
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
-------
54
1 opposed to the public storage unit for two reasons,
2 my main reason is because it's stored over an
3 aquifer. We're talking about drinking the water
4 for a vast number of people, and I feel this is a
5 risk that doesn't need to be taken. I think we
6 have looked at convenience over the health and
7 safety of the community.
8 Also the other concern I have is once
9 this cell has been approved, how do we have the
10 control of allowing outside storage or outside
11 contaminants to come into the storage unit?
12 There's a part of it- that will say it's been at
13 Fernald before, at some point it can come back here
14 again, and I don't want to be a dump site for the
15 rest of the community. Thank you.
16 MR. STEGNER: Thank you, Ann. Any
17 more comments tonight? Again be reminded that the
18 comment period is over on the 31st of May. Gary.
19 MR. STORER: I'm Gary Storer, Crosby
20 Township resident and trustee.
21 The northeast corner of the Fernald
22 site is a relatively uncontaminated zone, and my
23 idea is to locate the disposal cell --if there has
24 to be one, I've got some thoughts about that in a
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Schulte, A. I am opposed to the on-site disposal storage cell. My concern is that the radioactive
1 material will be stored over the Great Miami Aquifer.
Response:
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has adversely
impacted an approximate 200-acre area of the aquifer system. DOE also recognizes that
if the FEMP is not cleaned.up it poses continued contamination risk to the public and to
the aquifer. DOE intends to eliminate this unacceptable risk by moving forward with a
balanced remediation approach. This approach gets the most contaminated materials
away from the aquifer (by shipping them off-site), restores the aquifer, and limits the
quantity and disposal configuration of the contaminated material remaining at the site.
Completion of the selected remedy will also provide for more beneficial use of the FEMP
property outside the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1,2, 4, and 5
in conjunction with the anticipated Operable Unit 3 remedy and the current plans to
remove the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3 percent of the current quantity of radioactivity present at the site. This 3 percent
is distributed over an estimated 2.4 million cubic yards of soil and rubble at the site.
This material will consist of lightly contaminated materials; specifically Operable Unit 5.
soil, Operable Unit 2 material, and Operable Unit 4 construction rubble. While the
remedy for Operable Unit 3 has not been finalized, rubble from this operable unit is also
being considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste acceptance
criteria for the less contaminated material were developed for the engineered disposal
facility to help ensure protection of the aquifer. Only material that falls below the
contamination level of the waste acceptance criteria will be disposed of in the engineered
disposal facility. Material that does not meet the criteria will have to be either treated or
shipped off site.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-128
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FEMP-05ROD-6 FINAL
December 15, 1995
Schulte, A. (Contd.)
1
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium
outside the former production area of the FEMP and 20 pans per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal facility,
a tenfold safety factor. It should be noted that sophisticated computer model simulations
used to derive the waste acceptance criteria were completed assuming that there was no
active maintenance of the facility and that the synthetic barriers present in the facility
(e.g., high-density polyethylene membranes) were not functioning. These simulations
indicate that even under these extreme conditions, the facility would still be protective of
the aquifer over the full 200- to 1000-year performance period envisioned by federal
regulations.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\Dee«mber 8, 1995 12:4Jpm A.3-129
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Schulte, A. There is a law to protect this aquifer, but there is a waiver issued that will allow for the
la storage cell.
Response:
The DOE considers the restoration and protection of the sole-source Great Miami Aquifer
one of its highest priorities. The selected alternative for Operable Unit 5 includes an
expenditure in excess of $160 million on aggressive groundwater extraction and
treatment. In light of DOE's commitment to restore and protect the aquifer, the decision
to recommend an on-property facility was not made lightly. After detailed analysis of
several potential alternatives on the basis of implementability, risk and cost, an on-
property disposal facility was determined to be the only alternative that was
implementable and practical. Treatment alternatives were eliminated based on their
inability to attain the cleanup goals and off-site disposal was eliminated based on
uncertainties regarding the availability of disposal capacity throughout the duration of
the project and on cost.
As a result of this analysis, the DOE recommended an on-property disposal facility that
requires a waiver of the State of Ohio prohibition on siting a landfill over a sole-source
aquifer. There are two facts to be noted regarding the sole-source aquifer prohibition
and the waiver. First, the prohibition is intended to encourage the siting of new
commercial facilities in geologically appropriate areas by prohibiting their siting over an
aquifer. The prohibition is relevant to the FEMP and warrants a great deal of
consideration, although the situation here differs from that of a commercial enterprise
intent on profiting from a new disposal facility. The DOE's intent is to improve
conditions at an already contaminated facility. As discussed above, the on-property
facility is the only practical and implementable remedy.
Second, in order to waive a state requirement, the EPA must require that the DOE
demonstrate that the selected alternative will attain a standard of performance that is
equivalent to what would have been provided under the otherwise applicable requirement.
In this case, the DOE demonstrated to EPA's satisfaction that the siting of a disposal
facility at the FEMP would not result in concentrations of contaminants exceeding
drinking water standards in the aquifer throughout a performance period of 1000 years.
Use of the aquifer will in no way be impacted by the disposal facility. The DOE (or a
successor federal entity) will maintain a groundwater monitoring program to ensure
protection of the Great Miami Aquifer and take corrective action if unacceptable impacts
are detected.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\DecembCT 13, 1995 3:05pm A.3-130
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Schulte, A.
2
Schulte, A.
3
Transcript
I feel that cost and convenience has taken a preference over health and safety.
Response:
Public and worker health and safety were primary considerations, along with the ability
of the remedy to comply with identified applicable or relevant and appropriate
requirements, in the remedy decision process for Operable Unit 5. Cost was evaluated as
a balancing criteria consistent with the requirements of the National Contingency Plan.
The discussion on the detailed analysis of the remedial alternatives is presented in Section
5 of the Operable Unit 5 FS Report. Convenience is not an evaluation criteria defined
by federal regulation and was not considered in remedy selection. One parallel criteria
defined by regulation is implementability. Under this criterion the ability to implement
the remedial alternatives under consideration are evaluated in respect to existing or
projected future technology, institutional or administrative barriers which prevent prompt
or continuous implementation of a remedy. One consideration in the selection of the
Operable Unit 5 remedy was the high uncertainty in the availability of off-site disposal
capacity for the 1.8 million yards of contaminated soil within Operable Unit 5. Public
and worker health and safety will continue to be a primary concern to DOE, EPA and
OEPA as the selected remedy is implemented.
Also the other concern I have is once this cell has been approved, how do we have
the control of allowing outside storage or outside contaminants to come into the
storage unit? There's a part of it that will say it's been at Fernald before, at some
point it can come back here again, and I don't want to be a dump site for the rest of
the community.
Response:
DOE has no plans to bring contaminants to the FEMP site to be cleaned and then placed
in the on-property disposal facility. However, DOE is evaluating the potential cost
savings of treating some materials from other DOE sites at the FEMP and then shipping
them back to the originating facility for final disposal. There is much public concern
regarding placement of off-site waste in the site engineered disposal facility. The facility
is being designed to correct a problem that already exists at the FEMP. No
consideration is being given to placing waste from other sites in the FEMP engineered
disposal facility.
CRU5\ROD\MCM\APP-A\KSC-S-Y.ROD\December 8, 1995 12:43pm A.3-131
-------
Comment Sheet
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan for Operable Unit 5 at the FEMP site. The preferred alternative for soil includes the excavation of contaminated
soil and sediment that exceed proposed final remediation levels using conventional excavation equipment and
placement of the excavated materials in an on-property above-grade disposal facility. The preferred alternative for
groundwater is extraction and treatment of Great Miami Aquifer groundwater containing concentrations of
contaminants above established or proposed drinking water maximum contaminant levels (MCLs). Please use the
space provided below to write your comments, then fold, tape (no staples), and mail this form. We must receive
your comments on or before the close of the public comment period on May 31, 1995. If you have questions about
the comment period, please contact Gary Stegner in DOE's Public Information Office at (513) 648-3153.
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- --|--
(Below information is optional)
Name: _
Address:
City:
Phone:
Joseph U. Schuite^
3825 New Haven Road
Shandon, Ohio 45063
513 738 2946
Mailing List Additions
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project.
Yes
No
A.3-132a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Schulte, J. I am opposed to the on-site disposal storage cell. If this is approved, I feel the
1 aquifer will be at risk.
Response:
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has adversely
impacted an approximate 200-acre area of the aquifer system. DOE also recognizes that
if the FEMP is not cleaned up it poses a continued contamination risk to the public and
to the aquifer. DOE intends to eliminate this unacceptable risk by moving forward with a
balanced remediation approach. This approach gets the most contaminated materials
away from the aquifer (by shipping them off site), restores the aquifer, and limits the
quantity and disposal configuration of the contaminated material remaining at the site.
Completion of the selected remedy will also provide for more beneficial use of the FEMP
property outside the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1,2, 4, and 5.
in conjunction with the anticipated Operable Unit 3 remedy and the current plans to
remove the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3 percent of the current quantity of radioactivity present at the site. This 3 percent
is distributed over an estimated 2.4 million cubic yards of soil and rubble at the site.
This material will consist of lightly contaminated materials; specifically Operable Unit 5
soil, Operable Unit 2 material, and Operable Unit 4 construction rubble. While the
remedy for Operable Unit 3 has not been finalized, rubble from this operable unit is also
being considered for on-site disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-site disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste acceptance
criteria for the less contaminated material were developed for the engineered disposal
facility to help ensure protection of the aquifer. Only material that falls below the
contamination level of the waste acceptance criteria will be disposed of in the engineered
disposal facility. Material that does not meet the criteria will have to be either treated or
shipped off site.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-132
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Schulte, J
1
Schulte, J.
2
(Contd.)
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium
outside the former production area of the FEMP and 20 parts per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal facility,
a tenfold safety factor. It should be noted that sophisticated computer model simulations
used to derive the waste acceptance criteria were completed assuming that there was no
active maintenance of the facility and that the synthetic barriers present in the facility
(e.g., high-density polyethylene membranes) were not functioning. These simulations
indicate that even under these extreme conditions, the facility would still be protective of
the aquifer over the full 200- to 1000-year performance period envisioned by federal
regulations.
Also the potential exists for waste, not presently at the site, to be added to the
storage cell. I realize that this could be put in the proposal that no outside waste be
shipped and added to the storage cell. But if the funds to complete the project are
cut at some point, it would be very helpful to accept additional waste in order to
fund the completion of the project.
Response:
DOE has no plans to bring contaminants to the FEMP site to be cleaned and then placed
in the on-property disposal facility. However, DOE is evaluating the potential cost
savings of treating some materials from other DOE sites at the FEMP and then shipping
them back to the originating facility for final disposal. There is much public concern
regarding placement of off-site waste in the site engineered disposal facility. The facility
is being designed to correct a problem thai already exists at the FEMP. No
consideration is being given to placing waste from other sites in the FEMP engineered
disposal facility.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\Deconber 8, 1995 12:43pm A.3-133
-------
Formal Comment Card
Please write your formal comment(s) below for submittal during this meeting:
ALL
-fc
A.3-134a
-------
Formal Comment Card
Please write your formal comment(s) below for submittal during this meeting:
CcUL
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>/vj
JA/T.U.CJ)
-------
Formal Comment Card
Please write your formal comment (s) below for submittal during this meeting:
A/
i
M
-------
54
1 opposed to the public storage unit for two reasons,
2 my main reason is because it's stored over an
3 aquifer. We're talking about drinking the water
4 for a vast number of people, and I feel this is a
5 risk that doesn't need to be taken. I think we
6 have looked at convenience over the health and
7 safety of the community.
8 Also the other concern I have is once
9 this cell has been approved, how do we have the
10 control of allowing outside storage or outside.
11 contaminants to come into the storage unit?
12 There's a part of it that will say it's been at
13 Fernald before, at some point it can come back here
14 again, and I don't want to be a dump site for the
15 rest of the community. Thank you.
16 MR. STEGNER: Thank you, Ann. Any
17 more comments tonight? Again be reminded that the
18 comment period is over on the 31st of May. Gary.
19 MR. STORER: I'm Gary Storer, Crosby
20 Township resident and trustee.
21 The northeast corner of the Fernald
22 site is a relatively uncontaminated zone, and my
23 idea is to locate the disposal cell -- if there has
24 to be one, I've got some thoughts about that in a
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
-------
55
1 minute .-- if there has to be a disposal cell, it
2 should be located over the production area. Waiver
3 should be -- we should seek a waiver to allow for
4 this to happen. The main reason I feel this way is
5 that could be usable, a usable strip from that
6 northeast corner south to Wiley Road, future use,
7 land uses for township use or residents or
8 whatever.
9 Over the production area there's
10 already recovery measures in place to either clean
11 up contamination that might leak into the aquifer,
12 so those recovery measures are already in place.
13 Even though the northeast corner has a layer of
14 clay, I believe the layer of clay serves the same
15 purpose as the recovery measures that are already
16 in place over the production area.
17 I'm opposed to the on-site disposal
18 cell. I would be willing to take a risk of
19 shipping this stuff off-site until we're told we
20 cannot do so. There are sites willing to take the
21 contaminated materials. I also do not agree with
22 the transportation risk that I've been told is
23 associated with transporting this contaminated
24 material off-site.
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
-------
56
1 I also heard rumors, I haven't been
2 able to trace down the facts yet, about shifting
3 the disposal cell southward farther into Crosby
4 Township. I certainly would be opposed to this
5 also. I think if a disposal cell is also located
6 on-site, that security needs to be beefed up
7 on-site. I know the security officers no longer
8 carry arms, firearms. I think that would be a
9 necessity due to the recent hostilities that we've
10 all heard about in the news directed toward the
11 federal government.
12 Thank you for this opportunity to
13 express myself.
14 MR. STEGNER: Thank you, Gary. I
15 think it's important to note that Tom did ask for
16 an extension of the comment period, and it's
17 something that we can't unilaterally do, Tom. We
18 will take it under advisement, and I would say the
19 chances are extremely good you will get your wish
20 on this, but I can't state it right now, but we
21 will get you a response to that very soon.
22 MS. CRAWFORD: Will you let us know
23 if they are going to indeed do that? That means we
24 don't have to spend Memorial Day writing these
Spangler Reporting Services
PHONE (513) 381-3330 FAX (513) 381-3342
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Storer, G. All waste should be shipped offsite to Envirocare, NTS or other disposal sites. None
1 should be remain over the aquifer. The risk transportation and shipment are
minimal compare to leaving contaminants over the aquifer requiring monitoring,
security measures etc and placing the tri state at risk.
Response:
DOE acknowledges that no one wants contamination near where they live but
contaminated material already exists at the FEMP. The cleanup plan proposed for the
FEMP will address this existing contamination and reduce the levels in the soil and
ground-water to concentrations deemed to be health protective by federal environmental
regulation.
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has adversely
impacted an approximate 200-acre area of the aquifer system. DOE also recognizes that
if the FEMP is not cleaned up it poses continued contamination risk to the public and to
the aquifer. DOE intends to eliminate this unacceptable risk by moving forward with a
balanced remediation approach. This approach gets the most contaminated materials
away from the aquifer (by shipping them off site), restores the aquifer, and limits the
quantity and disposal configuration of the contaminated material remaining at the site.
Completion of the selected remedy will also provide for more beneficial use of the FEMP
property outside the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1, 2, 4, and 5
in conjunction with the anticipated Operable Unit 3 remedy and the current plans to
remove the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3 percent of the current quantity of radioactivity present at the site. This 3 percent
is distributed over an estimated 2.4 million cubic yards of soil and rubble at the site.'
This material will consist of lightly contaminated materials; specifically Operable Unit 5
soil, Operable Unit 2 material, and Operable Unit 4 construction rubble. While the
remedy for Operable Unit 3 has not been finalized, rubble from this operable unit is also
being considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\Deconber 8, 1995 12:43pm A.3-134
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Storer, G.
1
Storer, G.
2
(Contd.)
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on site was developed with input from the Fernald Citizens Task
Force and the public through numerous round tables and open forums. Waste acceptance
criteria for the less contaminated material were developed for the engineered disposal
facility to help ensure protection of the aquifer. Only material that falls below the
contamination level of the waste acceptance criteria will be disposed of in the engineered
disposal facility. Material that does not meet the criteria will have to be either treated or
shipped off site.
The waste acceptance criteria considers the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium
outside the former production area of the FEMP and 20 parts per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal facility,
a tenfold safety factor. It should be noted that sophisticated computer model simulations
used to derive the waste acceptance criteria were completed assuming that there was no
active maintenance of the facility and that the synthetic barriers present in the facility
(e.g., high-density polyethylene membranes) were not functioning. These simulations
indicate that even under these extreme conditions, the facility would still be protective of
the aquifer over the full 200- to 1000-year performance period envisioned by federal
regulations.
If the disposal cell is a reality, it should be located on the old production area.
Recovery measures are already hi place hi case of leakage, aquifer contamination,
acts of terrorism, etc. The northeast corner is really uncontaminated and it does not
make sense to introduce more contamination to this area. The clay base should not
be a determining factor in more than recovery measures under the old production
area. The land from the northeast corner running south to Willey Road still would
have potential productive land useage.
Response:
The justification for obtaining the EPA-CERCLA applicable or relevant and appropriate
requirement waiver of the Ohio solid waste siting criteria rests primarily with DOE
constructing the disposal facility over the most suitable geology available at the FEMP in
order to provide the greatest amount of natural protection for the aquifer. The existence
of media contamination before the construction of the disposal facility is not a significant
concern because remediation would have already occurred, thereby removing any
concerns associated with the effects of residual contamination in the soil or perched
groundwater. There are significant logistical concerns associated with constructing the
disposal facility over the former production area given the time required to remove the
buildings and remediate the soil and perched water, yet have the disposal facility
available to accept wastes in order to eliminate any double handling.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-135
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Storer, G. FERMCO security force needs to be reissued firearms. A disposal cell onsite will
3 require more security. Citizens throughout the US have demonstrated hostilities
toward the federal government. Armed security officer will provide added
protection to employees, contractors and ultimately the citizens and residents.
Response:
The on-property disposal facility would lead to the consolidation of contaminated
materials exceeding cleanup levels into a 131-acre area; 72 acres would constitute the
disposal facility plus the required 300-foot buffer area. The 131 acres will remain under
the continued ownership of the federal government. The Operable Unit 5 remedy
involves the excavation and placement of contaminated soil which exceeds 80 parts per
million uranium and is less than the waste acceptance criterion of 1030 parts per million
for uranium into the on-property engineered disposal facility. The disposal facility is
designed to ensure the protection of the Great Miami Aquifer from contaminants leaching
from the buried waste materials over the 200- to 1000-year time frame required by EPA
regulations. Due to the nature and concentration of the contaminants within the soil and
groundwater media at the FEMP (essentially low concentrations of uranium), the
potential threat which is being managed by the on-property disposal facility is from
chronic exposures over the long term, not from potential acute releases or exposures to
the contaminants. The engineered disposal facility will not possess qualities that make it
a target for sabotage.
CRUS\ROD\MCM\APP-A\RSC-S-Y.ROD\Deceoiber 8, 1995 12:43pm A.3-136
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Storer, G. I'm opposed to the on-site disposal cell. I would be willing to take a risk of shipping
4 this stuff off-site until we're told we cannot do so. There are other sites willing to
take the contaminated materials. I also do not agree with the transportation risk
that I've been told is associated with transporting this contaminated material offsite.
Response:
The selected alternative for Operable Unit 5 is one part of an overall site strategy which
applies a balanced approach to remediation of the FEMP site as a whole. This is
approach includes off-site disposal of all of the more highly contaminated materials found
at the FEMP in all operable units.
Plans are to remove the materials that constitute about 97 percent of the radioactivity
present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1,2, 4, and 5
in conjunction with the anticipated Operable Unit 3 remedy and the current plans to
remove the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3 percent of the current quantity of radioactivity present at the site. This 3 percent
is distributed over an estimated 2.4 million cubic yards of soil and rubble at the site.
This material will consist of lightly contaminated materials; specifically Operable Unit 5
soil, Operable Unit 2 material, and Operable Unit 4 construction rubble. While the
remedy for Operable Unit 3 has not been finalized, rubble from this operable unit is also
being considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
Several different options for the less contaminated material were considered before an
option for the construction of an on-property disposal facility was selected. Use of caps,
in-place containment, off-site disposal, and soil washing were all considered but the risks
and costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on-property was developed with input by the Fernald Citizens Task
Force and the public through numerous public round tables and open forums. Waste
acceptance criteria for the less contaminated material were developed for the engineered
disposal facility to help ensure protection of the public and the aquifer. Only less
contaminated material that falls below the contamination level of the waste acceptance
criteria will be disposed of in the engineered disposal facility. Materials that do not meet
the criteria will have to be either treated or shipped offsite.
The detailed analysis of the short-term risks associated with each remedial alternative
under consideration, including the selected remedy, is provided in Appendix G to the
Operable Unit 5 FS Report. Included in these analyses'are the evaluations of the
transportation risks associated with the implementation of each alternative. The
evaluation of transportation risks employ Department of Transportation factors on the
incidence of injuries and fatalities associated with rail and truck transport in the United
States. These factors were employed to derive similar projections for injuries and
fatalities associated with each of the FEMP remedial alternatives. The detailed short-
term risk assessment results presented in Appendix G of the FS Report were subjected to
the review and approval of the EPA and the review ofOEPA.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\D«cember 8, 1995 12:43pm A.3-137
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Storer, G. I also heard rumors, I haven't been able to trace down the facts yet, about shifting
5 the disposal cell southward farther into Crosby Township. I certainly would be
opposed to this also.
Response:
The exact location of the on-property disposal facility has not been finalized. Various
locations and sizes of the facility footprint have been depicted as the Operable Unit 2 and
Operable Unit 5 remedies have been defined. The reasons for the various depictions of
size and location are due to refinements to the estimated volume of material to be placed
in the facility and to interpretation of additional geologic information collected this past
winter and spring.
DOE submitted a Site Selection Report to EPA in late July for their review and approval
This report depicts an 800 x 4300-foot proposed footprint of the facility along the eastern
boundary of the FEMP. The southern end of the proposed facility footprint would be
approximately at the same latitude as the southern end of the existing parking lot. The
Site Selection Report is available for public viewing at the PEIC on Route 128. After
EPA comments are received and addressed, the Site Selection Report and thus the
location of the disposal facility will be final. This is anticipated to occur later this
summer or early fall.
Storer, G. I think if a disposal cell is also located on-site, that security needs to be beefed up
6 on-site. I know the security officers no longer carry arms, firearms. I think that
would be a necessity due to the recent hostilities that we've all heard about in the
news directed toward the federal government.
Response:
Please refer to response to Storer Comment 3.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-138
-------
Ji-COBb L
Michael 0. Leavin
Gov*mar
Di«nnc R. Nielsoa Ph.D.
Exmiilv* Dinctor
Brent C. Bradford
Deputy Director
State of Utah
_ ; i' / V
v - >
DEPARTMENT OF ENVIRONMENTAL QUALITY
OFFICE OF THE EXECUTIVE DIRECTOR
168 North 1950 Wen
P.O. Box 1*4810
Salt Lake City. Utah 84114-4810
(801) 53M400 Voice
(801)536-4401 Fax
(801) 536-4414 T.D.D.
June 19, 1995
Mr. Gary Stegner, Director
Public Information
Fernald Area Office
U.S. Department of Energy
P.O. box 538705
Cincinnati, OH 45253-8705
Dear Mr. Stegner:
This ts a follow-up letter to the correspondence of January 20, 1995. As we have previously
stated we appreciate being kept aware of what is happening at the Fernald site in relation to the
use of Envirocare as a disposal facility for low-level radioactive waste. It is our understanding
that remediation options relating to Operable Unit #5 are now under consideration.
We continue to support a balanced process which includes shipment of wastes off-site to
Envirocare and the Nevada Test Site combined with some stabilization of wastes on-site. This
balanced approach continues to support the perception that objective, technical-based decision
making has been used in this process. This will allow the continued use of Envirocare for
disposal of out of state remediation waste.
Please continue to keep us on your mailing list for proposals that involve shipment of wastes to
Utah.
Best Regards,
Dianne R. Nielson, Ph.D.
Executive Director
UTAH
*^*
Printed on recycled oaoer
A.3-139a
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Utah Dept. of We continue to support a balanced process which includes shipment of wastes off-site
Environmental to Envirocare and the NTS combined with some stabilization of wastes on-site. This
Quality balanced approach continues to support the perception that objective, technical-
1 based decision making has been used in this process. This will allow the continues
use of Envirocare for disposal of out of state remediation waste.
Response:
Comment acknowledged. EPA and DOE have applied the best scientific knowledge
available to the decision to build an on-property disposal facility and will continue to do
so throughout the remedial design/remedial action process. There is agreement that the
combination of some on-site and some off-site disposal of wastes provides the best
solution to the problem, and helps ensure the ongoing availability of storage space.
CRUS\ROD\MCM\APP-A\RSC-S-Y.ROD\Decembcr 8, 1995 12:43pm A.3-139
-------
22 if 'S
3686 Cincinnati-Brookville Road
Hamilton, Ohio 45013
May 18,1995
Mr. Jame^A. Saric
Remedial Project Director
U. S. Environmental Protection Agency
Region V - 5HRF-8J
77W.JatksonBJvd. __
ChicagoL IlKnoii 60604-3590
Dear Mr. Saric: .,.„
SUBJECT: PUBLIC COMMENTS ON FERNALD ENVIRONMENTAL
MANAGEMENT PROTECT (FEMP) OPERABLE UNIT #5 PROPOSAL TO
STORE LOW LEVEL TOXIC WASTES ON SITE - DUE BY MAY 31,1995
Locating permanent storage of any type of toxic waste over or near the Great Miami j
Aquifer within several hundred feet of homes and a heavily traveled state road (#126) •«
indicates blatant deliberate disregard for public health, environmental concerns and
long term cost effectiveness. What plastic liner will not fail due to stress cracking? J_
Unbelievable that any scientifically knowledgeable honest person would want to be 2
even remotely associated with such an ill conceived short-sighted proposal! ' J
What a waste of time and money not to do the job correctly the first time around to j
ship all toxic material offsite to an adequately buffered safe area so that if something 3
does go wrong (as is sure to happen), public health and environmental damage due to j
toxic waste migration will be minimized. JL
Sincerely,
J. E. Walther
CQN/K. Morgan
A.3-140a
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FEMP-05ROD-6 FINAL
December 15, 1995
Walther, J. Locating permanent storage of any type of toxic waste over or near the Great Miami
1 Aquifer within several hundred feet of homes and a heavily traveled state road
(#126) indicates blatant deliberate disregard for public health, environmental
concerns, and long term cost effectiveness. What plastic liner will not fail due to
stress cracking?
Response:
DOE acknowledges that no one wants contamination near where they live, but
contaminated material already exists at the FEMP. The cleanup plan proposed for the
FEMP will address this existing contamination and reduce the levels in the soil and
groundwater to concentrations deemed to be health protective by federal environmental
regulation.
The selected cleanup remedy at the FEMP has three objectives related to the Great
Miami Aquifer; stop existing sources of contamination to the aquifer, restore the aquifer
to maximum beneficial use in a reasonable time frame, and protect the aquifer from
future contamination originating from the FEMP property. DOE recognizes that the
aquifer is an important national and local resource and that the FEMP site has adversely
impacted an approximate 200-acre area of the aquifer system. DOE also recognizes that
if the FEMP is not cleaned up it poses continued contamination risk to the public and to
the aquifer. DOE intends to eliminate this unacceptable risk by moving forward with a
balanced remediation approach. This approach gets the most contaminated materials
away from the aquifer (by shipping them off site), restores the aquifer, and limits the
quantity and disposal configuration of the contaminated material remaining at the site.
Completion of the selected remedy will also provide for more beneficial use of the FEMP
property outside the disposal facility area.
Plans are to remove the materials that constitute about 97 percent of the radioactivity .
present at the FEMP for disposal at an off-site disposal facility. This will be
accomplished via completion of the selected remedies for Operable Units 1,2, 4, and 5
in conjunction with the anticipated Operable Unit 3 remedy and the current plans to
remove the site legacy waste and uranium product.
What will remain for disposal at the FEMP in the engineered disposal facility will be
about 3 percent of the current quantity of radioactivity present at the site. This 3 percent
is distributed over an estimated 2.4 million cubic yards of soil and rubble at the site.
This material will consist of lightly contaminated materials; specifically Operable Unit 5
soil, Operable Unit 2 material, and Operable Unit 4 construction rubble. While the
remedy for Operable Unit 3 has not been finalized, rubble from this operable unit is also
being considered for on-property disposal. All material will have to pass stringent waste
acceptance criteria before being placed in the on-property disposal facility. These waste
acceptance criteria were conservatively developed for the long-term protection of the
public and the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-140
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FEMP-05ROD-6 FINAL
December 15, 1995
Walther, J.
1
Walther, J.
2
(Contd.)
Several different options were considered for the less contaminated material before the
excavation and on-property disposal option was selected. Use of caps, in-place
containment, off-site disposal, and soil washing were all considered but the risks and
costs were judged to be unacceptable. The decision as to what less contaminated
material would remain on property was developed with input from the Fernald Citizens
Task Force and the public through numerous round tables and open forums. Waste
acceptance criteria for the less contaminated material were developed for the engineered
disposal facility to help ensure protection of the aquifer. Only material that falls below
the contamination level of the waste acceptance criteria will be disposed of in the
engineered disposal facility'. Material that does not meet the criteria will have to be
either treated or shipped off site.
The waste acceptance criteria consider the hydrogeologic environment of the site and the
protective properties of the engineered disposal facility. Soil, for instance, would be
excavated down to the proposed cleanup level of 80 parts per million total uranium
outside the former production area of the FEMP and 20 parts per million within the
former production area. Current estimates indicate that placing all of the lightly
contaminated soil together in the disposal facility will produce an average concentration
of about 100 parts per million of uranium in the facility. This average concentration is
one-tenth of the waste acceptance criteria for disposal in the on-property disposal facility,
a tenfold safety factor. It should be noted that sophisticated computer model simulations
used to derive the waste acceptance criteria were completed assuming that there was no
active maintenance of the facility and that the synthetic barriers present in the facility
(e.g., high-density polyethylene membranes) were not functioning. These simulations
indicate that even under these extreme conditions, the facility would still be protective of
the aquifer over the full 200- to 1000-year performance period envisioned by federal
regulations.
The long-term cost effectiveness of the selected Operable Unit 5 remedy was evaluated
against other alternatives in the FS detailed evaluation of alternatives. Comprehensive
. cost estimating in this evaluation indicated that even with the inclusion of conservative
long-term monitoring and maintenance costs of the disposal facility, it was still much
more cost effective to dispose of some material on property rather than ship all the
material off site.
Unbelievable that any scientifically knowledgeable honest person would want to be
even remotely associated with such an ill conceived short-sighted proposal!
Response:
Statement acknowledged.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-141
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FEMP-05ROD-6 FINAL
December 15, 1995
Walther, J. What a waste of time and money not to do the job correctly the first time around to
3 ship all toxic material offsite to an adequately buffered safe area so that if something
does go wrong (as is sure to happen), public health and environmental damage due
to toxic waste migration will be minimized.
Response:
As noted above, the DOE, EPA, and OEPA believe that the current balanced approach to
on-property and off-site disposal is the best option. The on-property disposal facility is
being designed and will be built with the primary objectives of short-term and long-term
protection of public health and safety and the long-term protection of the Great Miami
Aquifer.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-142
-------
MIAMI UNIVERSITY
Institute of Environmental Sciences
102 Boyd Hall
Oxford. Ohio 45056
513 529-5811
513 529-5814 FAX
May 16, 1995
Gary Stegner
Public Information Officer
U.S. Department of Energy, Fernald Area Office
PO Box 538705
Cincinnati, OH 45253-9985
Dear Mr. Stegner:
In this letter, I am submitting formal comments on the Proposed Plan for Operable
Unit 5. Some of the critical comments are directed at all parties, the Department of
Energy and the regulatory agencies. I want to say at the outset that'll good faith effort
has been made by all parties. Having said that, I also must say that this project is
large enough and important enough to do ij.the way a unique project should be done;
it is not adequate or acceptable to apply rules that may conflict with each other and
have varying degrees of scientific foundation to conditions at Fernald. It is only
possible to get a high degree of remediation and protection of public health and the
environment if all factors are taken into account simultaneously, acknowledging that
tradeoffs are necessary in one area in order to increase protectiveness in another area.
This takes me to the heart of the argument. One way of thinking about OU5 is that is
what is left after the other operable units have been remediated. The material
remaining in OU5 is generally very low in uranium concentration. There are a few,
but only a few, exceptions to this statement. Moreover, the amount of material which
has higher concentrations is very small, in the order of a few hundred thousand cubic
yards rather than a couple million cubic yards. The areas that have the higher levels
of uranium--in OUl-4-also are the areas more likely to have the more soluble
compounds of uranium. The remaining parts of OU5, which have the lowest levels of
uranium, and account for the largest part of the material to be placed in the on-site
disposal cell, are more likely to have the less soluble compounds of uranium.
A major part of the proposed remedy is to excavate material that has uranium in
concentrations higher than those which would result in either unacceptable levels of
uranium at the surface for the intended uses, or that would contaminate the Great
Miami Aquifer. This material would then be placed in an on-site disposal cell. While I
certainly support the on-site disposal cell, I strongly oppose moving so much material
into it. The reasons for my opposition are several-fold.
Excellence is Our Tradition
A.3-143a
-------
Gary Stegner
Page 2
May 16, 1995
First, an inappropriate standard is being applied to the levels necessary to assure a
safe drinking water supply in the Great Miami Aquifer (the figure proposed in the
draft rule under the Safe Drinking Water Act). At a minimum, the higher figure in
the final rule issued under the Uranium Mill Tailings Radiation Control Act should
be applied. This change alone would result in significantly less material being moved
to the disposal cell. Because there is some reason to believe the final rule under the
Safe Drinking Water Act will have MCLs for uranium even higher than those under
UMTRCA, no decision should be made that locks in the unnecessarily low values for
which the current plan has been developed. __
Second, I think it is a mistake to assume that the uranium compounds which are now
soluble will remain soluble for an extended .period of time. They inevitably will be
transformed into less soluble compounds, with attendant smaller effects on the Great
Miami Aquifer.
Third, a balancing of risk needs to be done between protection of the aquifer and
airborne pollutants that would be generated under the current plan. A large
residential subdivision lies just off-site, downwind from the site, directly in the path
which would be taken by these airborne pollutants during construction. Even if there
were no uranium or other contaminants in the surface soils which are to be moved to
the disposal cell, the risks to human health are unacceptably high compared to the
almost negligible risk of slightly elevated levels in the aquifer. The human population
in this area should not be subjected to this burden and this risk. To date, the presence
of this subdivision has been barely acknowledged. For an activity that will take place
over several years, it is hard to imagine that any activity at the site would be more
detrimental than these airborne particles.
Fourth, it is difficult for me to see how we can, in good conscience, propose a solution T
that makes such a small contribution to risk reduction at such an enormous cost. The j
arguments I have made above would lead to moving a much smaller amount of soil 4
into the disposal cell than the recommended solution. The resulting savings have been j
estimated by DOE/FERMCO to be in the order of several hundred million dollars. —
I urge that, in the construction of the lining system, more attention be given to 5
preventing downward migration of water to the underlying aquifer. This can be done j
-------
Gary Stegner
Page3
May 16, 1995
^^
with a thicker layer of sand and gravel, sloped to the edges of the cell. It should not be !
done by relying on a synthetic liner. The synthetic liner is important in the early part
of the disposal cell's life, but there is no reason to consider that the synthetic liner i
should function more than a couple decades. j
Gene E. Willeke, Ph.D., P.E.
Director
I next wish to endorse several parts of the proposed plan. First is the on-site disposal g
cell. It would be very foolish to consider transporting this material to Utah or ±
Nevada. Second is the removal of uranium from the Great Miami Aquifer by j
pumping and treating. I feel it will be found desirable to re-inject the. treated water
into the aquifer, thereby reducing costs and.further flushing the aquifer. I regret this
step was not undertaken earlier when it would have been possible to prevent some of j
the migration of uranium down-aquifer. Th6 barrier wells are better than nothing, but j
the better results could have been obtained by pumping from locations farther up- j
aquifer, where contaminant levels are higher. Finally, I endorse the treatment of !
contaminated storm water runoff. JL
Sincerely,
//
-------
FEMP-05ROD-6 FINAL
December 15, 1995
Willeke, G. "First, an inappropriate standard is being applied to the levels necessary to assure a
1 safe drinking water supply in the Great Miami Aquifer (the figure proposed in the
draft rule under the Safe Drinking Water Act). At a minimum, the higher figure in
the final rule issued under the Uranium Mill Tailings Radiation Control Act should
be applied. This change..."
Response:
DOE disagrees with the reviewer's comment that an inappropriate standard has been
applied to the restoration of the Great Miami Aquifer; however, DOE agrees that the
quantity of contaminated soil and material ultimately placed in the disposal facility as
well as their associated costs and the costs for the restoration of the Great Miami Aquifer
are very sensitive to the established final groundwater cleanup limits. Therefore,
consistent with Section 300.430(e)(2)(i)(C)ofthe National Contingency Plan, the DOE
has adopted the maximum contaminant levels under the Safe Drinking Water Act as
relevant and appropriate requirements for the restoration of the Great Miami Aquifer.
Lacking a final promulgated maximum contaminant level for uranium, DOE adopted, as
pan of the selected remedy; the maximum contaminant level proposed by EPA in July
1991 under the Safe Drinking Water Act for uranium of 20 parts per billion as the final
remediation level for restoration of the aquifer. This proposed standard was adopted as
a "To Be Considered" requirement to the selected remedy.
However, the DOE recognizes, in its role as the steward of public funds, that funds
should only be committed to remedial activities which yield a commensurate
environmental or human health-related benefit. As such, the DOE must evaluate the
technical and economic implications of pursuing adoption of the final maximum
contaminant level for uranium, once it is promulgated by EPA. Such a technical and
economic evaluation will be warranted regardless of whether the final maximum
contaminant level for uranium represents a higher or lower concentration-based level
than the proposed 20 parts per billion standard. In the event DOE considers it
appropriate to pursue a change to the final remediation level for uranium in groundwater
identified in this decision document, DOE will initiate such a change in a manner
consistent with CERCLA, the National Contingency Plan and the terms of the Amended
Consent Agreement.
Section 9 of this ROD adopts the proposed maximum contaminant level of 20 parts per
billion for total uranium as the final remediation level for affected regions of the Great
Miami Aquifer, with the caveat that once the final maximum contaminant level for
uranium is promulgated by EPA, a technical and economic evaluation of the final
maximum contaminant level, will be performed. Based on this evaluation, the DOE will
decide whether to initiate a change to the final remediation level for uranium in
groundwater.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 13, 1995 3:05pm A.3-143
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FEMP-05ROD-6 FINAL
December 15, 1995
Willeke, G. "Second, I think it is a mistake to assume that the uranium compounds which are
2 now soluble will remain soluble for an extended period of tune. They inevitably will
be transformed into less soluble compounds, with attendant smaller effects on the
Great Miami Aquifer."
Response:
Under static or nondynamic conditions, it is true that uranium compounds in soil would
gradually transform into less soluble uranium compounds, although the physical/chemical
process would probably take decades before an observable decrease in the uranium
solubility could be seen. However, certain physical processes such as surface water
runoff-induced conduits, occur in much shorter time periods, on the order of weeks,
resulting in the uranium compounds reaching the Great Miami Aquifer and potential
receptors before any solubility changes can occur. An example of this occurs with the
surface water runoff from the eastern portion of the FEMP, the area east of the north
access road, which drains to the storm sewer outfall ditch and ultimately to Paddys Run,
both of which provide direct conduits for the uranium compounds to the Great Miami
Aquifer. Additionally, it is important to point out that the disposal facility will isolate
this uranium-contaminated soil and material thereby providing the optimal conditions by
which the uranium compounds can become less soluble before they have any chance of
impacting the Great Miami Aquifer.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8. 1995 12:43pm A.3-144
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FEMP-05ROD-6 FINAL
December 15, 1995
Willeke, G. "Third, a balancing of risk needs to be done between protection of the aquifer and
3 airborne pollutants that would be generated under the current plan. A large
residential subdivision lies just off-site, downwind from the site..,."
Response:
Appendix G to the Operable Unit 5 FS Report presents the results of an assessment of the
short-term risks associated with the implementation of each of the remedial alternatives
considered. This short-term risk assessment evaluated the potential carcinogenic,
noncarcinogenic and mechanical risks to a series of hypothetical receptors including
remediation workers, near-property residents, and the public along the transportation
route. In the evaluation of near-property residents, the assessment evaluated the
potential carcinogenic and noncarcinogenic risks associated with potential inhalation of
dust resuspended during site excavation, on-property transport, soil staging and disposal
activities. The short-term risk assessment was performed consistent with the EPA Risk
Assessment Guidance for Superfund, Parts A and C.
The findings of the short-term risk assessment for the selected alternative (3A) indicated
that the projected carcinogenic risk to the reasonably maximally exposed near-property
resident due to the potential inhalation of dust particles generated during Operable
Unit 5 cleanup activities is 3.4 x Iff7. This carcinogenic risk represents the sum of the
projected risk from both the radiological and chemical carcinogens potentially present in
the resuspended dust particles. The short-term risk assessment estimated that the
projected noncarcinogenic risk to the same receptor from the implementation of the
selected remedy was less than a hazard index of 0.01. These projected risks are based
upon a maximally exposed hypothetical receptor located immediately adjacent to the
FEMP property boundary for the entire duration of the FEMP cleanup process. The
projected risk to a near-property receptor located at any other position would be expected
to be less than these projections. Additionally, the application ofmitigative measures
during soil excavation, transport and disposal activities to reduce fugitive dust emissions
would reduce these projected risks. These risk estimates are almost one order of
magnitude less than the permissible risk range defined by the National Contingency Plan
of 1 x 10* to 1 x IQ* and less than a hazard index of 1. These projected short-term risks
are over 3 orders of magnitude less than the projected carcinogenic risks to a potential
future off-property user of groundwater under an alternative which does not remove soil
presenting a cross-media impact to the Great Miami Aquifer.
DOE considers it a prudent measure to remove the soil that presents a long-term threat to
the underlying aquifer. DOE considers that the selected remedy provides the proper
balance of minimizing short-term impacts to the public and workers with the need to
ensure the long-term performance of the remedy.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\Deconber 8, 1995 12:43pm A.3-145
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FEMP-05ROD-6 FINAL
December 15, 1995
Willeke, G. Fourth, it is difficult for me to see how we can, in good conscience, propose a
4 solution that makes such a small contribution to risk reduction at such an enormous
cost...
Response:
A reduction in the volume of soil that is placed in the disposal facility will reduce costs.
However, on the basis of the responses to the preceding comments, the suggestions made
cannot be used to reduce the volume of soil to be placed in the facility beyond what is
currently projected. First, the Uranium Mill Tailings Radiation Control Act standard
cannot be used as the basis for the final remediation level for the Great Miami Aquifer
because such a remediation level is not acceptable to EPA and OEPA. As noted above,
DOE will consider adoption of the final maximum contaminant level for uranium, when
promulgated, as the final remediation level for uranium. Second, as explained above, it
is necessary to assume that some uranium will be in a soluble form, because of the
potential for uranium to reach groundwater relatively quickly by way of Paddys Run.
Finally, engineering controls and monitoring will be used to ensure that no significant
releases of contaminants and no significant impacts occur during remediation. The short-
term risks have been evaluated, including those to the off-property public during
remediation, and are considered to be acceptable.
The risk-based remedial alternative evaluations in the Operable Unit 5 FS Report show
that the greatest risk reduction afforded through the completion of the Operable Unit 5
remedial activities would be realized through the elimination of the cross-media impacts
associated with the leaching of uranium compounds from the surface soil to the Great
Miami Aquifer. Without the elimination of the cross-media impacts the projected
incremental lifetime cancer risk to a hypothetical groundwater user at the eastern fence
line has been estimated to be approximately 2 x Iff3 within the next 100 years; whereas,
the projected carcinogenic risk associated with the excavation and placement of
contaminated soil in the on-property engineered disposal facility has been estimated to be
approximately 3.4x 10~7.
Willeke, G. I urge that, in the construction of the lining system, more attention be given to
5 preventing downward migration of water to the underlying aquifer. This can be
done with a thicker layer of sand and gravel, sloped to the edges of the facility. It
should not be done by relying on a synthetic liner. The synthetic liner is important
in the early part of the disposal facility's life, but there is no reason to consider that
the synthetic liner should function more than a couple decades.
Response:
The design of the engineered disposal facility is being addressed by the remedial design
activities for Operable Unit 2. A major aspect of the design of the facility will be to
minimize the migration of water into the facility and ultimately into the underlying
aquifer.
Willeke, G. I next wish to endorse . . . the on-site disposal facility. It would be very foolish to
6 consider transporting this material to Utah or Nevada.
Response
Statement acknowledged. The selected remedy for Operable Unit 5 is consistent with the
"balanced approach " whereby more heavily contaminated materials will be shipped for
off-site disposal, while the large volume of materials exhibiting low concentrations of
contaminants will remain in the on-property engineered disposal facility.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-146
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FEMP-05ROD-6 FINAL
December 15, 1995
Willeke, G. I endorse . . . the removal of uranium from the Great Miami Aquifer by pumping
7 and treating. I feel it will be found desirable to re-inject the treated water into the
aquifer, thereby reducing costs and further flushing the aquifer. I regret this step
was not undertaken earlier when it would have been possible to prevent some of the
migration of uranium down-aquifer. The barrier wells are better than nothing, but
the better results could have been obtained by pumping from locations farther up-
aquifer, where contaminant levels are higher. Finally, I endorse the treatment of
contaminated storm water runoff.
Response:
Comment acknowledged. As identified in the Proposed Plan, the FEMP is presently
evaluating the potential application of reinfection techniques to the restoration of the
Great Miami Aquifer.
Regarding the need to pump from locations farther upgradient in the aquifer from the
present South Plume recovery wells, an analyses of more optimal well locations is
presently underway. The more optimal groundwater extraction well configuration for the
South Plume would be implemented as part of the remedial design and remedial action
phase.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-147
-------
soils above 1030 to be shipped off site.
- I do support the US EPA Waiver of siting criteria.
Thank you for this opportunity to make comments.
Edwa Yocum May 22, 1995
9860 Hamilton Cleves Pk.
Harrison, OH 45030
Gary Stegner
DOE Public Information
Fernald Area Office
US Dept. of Energy
P.O Box 538705
Cincinnati, OH 45253-9985
COMMENT ON OU5:
i
Alternative 3A is acceptable under certain conditions as listed. 1
i
- Place at least a three hundred foot Buffer Zone around 7-
the entire disposal cell. Add a ten ft. chain link fence n
skirting the Buffer Zone. This is to protect the " f
trespasser. «-. ^
i
- NO off -site waste for disposal at Fernald. ^
NO long term storage 'of off - site waste on J_
Fernald site.
- Future ownership of Fernald site should remain in the 4
hands of the Federal government. ~
i
- NO characteristic hazardous waste disposed in cell. i
( flammable, toxic, corrosive ).
- Ground water should be remediated to drinking water Q
standards of 20ppB or less, (^d &tnj~-\cA o^w33u^aA« . —
A.3-148a
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FEMP-05ROD-6 FINAL
December 15, 1995
Yocum, E.
1
Yocum, E.
2
Yocum, E.
3
Alternative 3A is acceptable under certain conditions as listed.
Response:
Comment acknowledged.
Place at least a three hundred foot Buffer Zone around the entire disposal cell. Add
a ten ft. chain link fence skirting the Buffer Zone. This is to protect the trespasser.
Response:
Current State of Ohio siting requirements for newly constructed solid waste disposal
facilities, which have been adopted as design requirements for the FEMP on-property
disposal facility, require a minimum 300-foot buffer from disposed waste to the nearest
property line. DOE will incorporate this requirement into the siting of the on-property
disposal facility.
Regarding the 10-foot chain link fence, the intent of this fence is to protect the trespasser
from the disposal facility. DOE will consider such a fence or other methods (i.e., natural
tree barriers, etc.), to provide the needed protection and demarcation of the disposal
facility area. Design drawings indicating the proposed siting and configuration of the
disposal facility will be provided to the public for review during the remedial design
process.
NO off-site waste for disposal at Fernald.
- NO long term storage of off-site waste on Fernald site.
Response:
The DOE concurs with the comment, and has no intention of using the disposal facility
associated with the Operable Unit 5 remedy to address wastes generated from off-site
locations. Additionally, the DOE has no intention of using existing or newly constructed
storage facilities located at the FEMPfor the long-term storage of wastes generated from
off-site locations. Specifically excluded from this prohibition are laboratory wastes
generated at off-site facilities resulting directly from the chemical, radiological or
engineering analysis of FEMP waste materials/contaminated media or generated during
the conduct of treatability or demonstration type studies on FEMP waste materials/
contaminated media. Such analyses and studies are typically performed as an integral
part of implementing a selected remedy at a cleanup site.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-148
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FEMP-05ROD-6 FINAL
December 15, 1995
Yocum, E. Future ownership of Fernald site should remain in the hands of the Federal
4 government.
Response:
The comment raises the need to properly align the necessary institutional control
provisions for the FEMP with the future land use for the facility to ensure the continued
protection of human health. DOE agrees with the need for this alignment. It is not the
intent of DOE to attempt to establish a final future land use for the FEMP through this
decision document. DOE does recognize that the final remediation levels identified in
Section 9.0 of this ROD do establish the permissible concentrations of contaminants
which could remain at the site following completion of remedial actions. These
remaining concentrations of contaminants will present a potential for exposure to future
users of the FEMP.
The Fernald Citizens Task Force issued recommendations regarding future use of the
Fernald property in May of 1995, recommending that the area of the FEMP containing
the disposal facility and associated buffer zone remain under the continued ownership of
the federal government. Additionally, the Task Force recommended that the remaining
portions of the FEMP property be made available for the uses that are the most beneficial
to the surrounding communities. While the Task Force recommended prohibiting any son
of agricultural or residential uses of the remaining portions of the FEMP property
(outside the disposal facility, area), the Task Force encouraged DOE to consult with local
communities to establish their preferences for future use and ownership of these areas of
the site. Consistent with this recommendation, DOE does not consider it prudent to
insert enforceable provisions within this ROD to provide for the continued federal
ownership of the entire FEMP property.
Additionally, DOE considers that final, enforceable institutional control measures for
postremedial conditions at the FEMP should be established based upon an analysis of the
actual residual concentrations as measured in site soil and groundwater following the
completion of remedial actions; the measured concentrations and spatial distribution may
differ from, FS projections. This differencf in estimated versus measured concentrations
could have a significant impact on the required institutional controls necessary to
maintain continued protectiveness. In this ROD, DOE has elected to define that
institutional controls are a necessary component of the remedy to ensure continued
protectiveness, but that the specific institutional control provisions necessary to be
applied to postremedial site conditions will be defined during remedial design. The
institutional control provisions defined during remedial design may be modified during
the remedial action phase to accommodate the progressive findings of the field
certification efforts. As with all remedial design and remedial action documentation, the
plan for institutional controls at the FEMP, and any necessary modifications to it, will be
subject to approval by EPA and review by OEPA.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-149
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FEMP-05ROD-6 FINAL
December 15, 1995
Yocum, E. (Contd.)
4
The need for institutional controls during the conduct of remedial actions and the
requirement for continued federal ownership of the disposal facility area on the FEMP
have been specifically identified in this ROD. More specific detail on the actual
implementation of these controls will be defined during remedial design.
Section 9 of this ROD provides a discussion on the role of institutional controls as a
necessary component of the Operable Unit 5 remedy. The language of the ROD provides
for the following institutional control provisions:
• Continuation of access controls at the FEMP during the period of remediation
• Provision of alternate water throughout the period of remediation to residences
and industrial users whose current wells are located within an area of the aquifer
which exhibit concentrations exceeding the final remediation levels for
groundwater
• Continued federal ownership of the area comprising the disposal facility and
associated buffer zones
• Implementation of deed restrictions or continued federal ownership of the
remaining areas of the FEMP, as necessary to ensure the continued protection of
human health. If ownership of portions of the FEMP is transferred in the future,
restrictions will be included in the deed, and proper notifications will be provided
as required by CERCLA.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 8, 1995 12:43pm A.3-150
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FEMP-05ROD-6 FINAL
December 15, 1995
Yocum, E. NO characteristic hazardous waste disposed in cell, (flammable, toxic, corrosive).
5
Response:
DOE agrees with the technical issues raised by this comment concerning the disposal of
RCRA hazardous waste (in particular, the disposal ofRCRA characteristic waste that was
raised by OEPA) in the on-property disposal facility. The Operable Unit 5 remedy
proposed by DOE is fully protective of human health and the environment for all
contaminants of concern that are present in the soil, including those contaminants that
qualify (and require management) as regulated hazardous waste under RCRA. Specific
waste acceptance criteria have been developed for the on-property disposal facility to
ensure that all of the materials placed in the facility will be consistent with the need for a
fully protective remedy. In particular, the waste acceptance criteria are intended to limit
the placement in the facility ofRCRA contaminants exhibiting toxicity to levels that are
protective of the Great Miami Aquifer. (Along with the waste acceptance criteria
developed for the materials exhibiting toxicity, DOE also proposes to prohibit the
placement of materials which qualify as ignitable, corrosive, or reactive characteristic
waste under RCRA). The approach used to develop limits for the placement of these
RCRA contaminants in the facility is the same as that used to establish limits on
radiological contaminants, such as uranium. The waste acceptance criteria developed for
the RCRA contaminants satisfy the regulatory requirements of EPA's RCRA corrective
action management unit rule, which has been adopted as an applicable or relevant and
appropriate requirement for Operable Unit 5.
In addition to the requirement that a health-protective remedy be adopted for a site
undergoing cleanup for RCRA-regulated substances (which is satisfied by the health-
protective waste acceptance criteria and final remediation levels adopted for the Operable
Unit 5 contaminated media), the corrective action management unit rule requires that the
remedy satisfy a regulatory preference for methods that enhance the long-term
effectiveness of the remedy through the application, as appropriate, of treatment
technologies that reduce toxicity, mobility, or volume of wastes that will remain in place
after site closure. In their comments on the Operable Unit 5 Proposed Plan, OEPA
raised a stipulation requiring treatment of the Operable Unit 5 soil materials that qualify
as RCRA characteristic hazardous waste ft. e., to remove the characteristic property
associated with the material) before placement in the disposal facility. Recognizing that
DOE has developed health-protective final remediation levels and waste acceptance
criteria for all of the Operable Unit 5 contaminants of concern, OEPA's additional
stipulation concerning the on-property disposal of characteristic waste has its origin in
the need to satisfy, on a site-specific basis, the regulatory preference for remedies that
employ treatment. As stated in the corrective action management unit rule, the decision
to apply cost-effective treatment is a case-by-case decision that must consider waste- and
site-specific factors. OEPA has designated the Operable Unit 5 soil that qualifies as
RCRA characteristic waste as a site-specific quantity of material that offers a reasonable
opportunity to apply additional treatment measures. Upon review of the site
characterization data from the Operable Unit 5 remedial investigation coupled with
historical process knowledge, six geographic areas of the FEMP have been identified
where a reasonable potential exists for the presence of soil that qualifies as containing
RCRA characteristic waste. DOE agrees that these six areas offer a reasonable, site-
specific, and cost-effective opportunity to treat additional materials before on-property
disposal, in the interest of enhancing the long-term effectiveness of the remedy through
treatment techniques. The remedy described in Section 9.0 of the ROD includes a
commitment by DOE to search for and employ treatment as necessary for characteristic
hazardous waste in soil that originates from within the six geographic areas.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 13, 1995 3:05pm A.3-151
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FEMP-05ROD-6 FINAL
December 15, 1995
Yocum, E.
5 (Contd.)
Yocum, E.
6
Yocum, E.
7
(Contd.)
RCRA characteristic waste. DOE agrees that these six areas offer a reasonable, site-
specific, and cost-effective opportunity to treat additional materials before on-property
disposal, in the interest of enhancing the long-term effectiveness of the remedy through
treatment techniques. The remedy described in Section 9.0 of the ROD includes a
commitment by DOE to search for and employ treatment as necessary for characteristic
hazardous waste in soil that originates from within the six geographic areas.
Ground water should be remediated to drinking water standards of 20 ppb or less.
(20 part per billion)
Response:
Consistent with Section 300.430(e)(2)(i)(C)ofthe National Contingency Plan, the DOE
has adopted the maximum contaminant levels under the Safe Drinking Water Act as
relevant and appropriate requirements to the restoration of the Great Miami Aquifer.
Lacking a final promulgated maximum contaminant level for uranium, DOE adopted, as
part of the selected remedy, the maximum contaminant level proposed by EPA in July
1991 under the Safe Drinking Water Act of 20 parts per billion as the final remediation
level for restoration of the aquifer. This proposed standard was adopted as a "To Be
Considered" requirement to the selected remedy.
The estimated costs for the restoration of the Great Miami Aquifer are, as would be
expected, very sensitive to the established final groundwater cleanup goals (final
remediation levels). While DOE is committed to fully restoring the aquifer to health-
protective levels, DOE must do so in full recognition of its role as a steward of public
funds. Within its stewardship role, the DOE must ensure that public funds are committed
only to remedial activities which yield a commensurate environmental or human health-
related benefit. As such, the DOE must evaluate the technical and economic implications
of pursuing adoption of the final maximum contaminant level for uranium, once
promulgated by EPA. Such a technical and economic evaluation will be warranted
regardless of whether the final maximum contaminant level for uranium represents a
higher or lower concentration-based limit than the proposed 20 parts per billion
standard. In the event DOE considers it appropriate to pursue a change to the final
remediation level for uranium in groundwater identified in this decision document, DOE
will initiate such a change in a manner consistent with CERCLA, the National
Contingency Plan and the terms of the Amended Consent Agreement. As done throughout
the remedial investigation/feasibility study decision making process, the DOE will involve
the public in any attempt to modify the final remedial goal for uranium in the Great
Miami Aquifer from the 20 parts per billion value identified in Section 9 of this ROD.
Real time monitoring.
Response:
DOE is committed to executing a responsible and technically defensible environmental
monitoring program during the conduct of remedial actions at the FEMP. The specifics
of this program will be defined during the remedial design phase. DOE will take into
consideration commercially available and emerging monitoring techniques that could
provide real-time or near real-time data on environmental releases.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\December 13, 1995 3:05pm A.3-152
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Yocum, E.
8
Yocum, E.
9
Yocum, E.
10
Yocum, E.
11
FEMP-05ROD-6 FINAL
December 15, 1995
Continued to evaluate technologies that would increase protection to Residents and
community.
Response:
DOE agrees that the FEMP. should continue to be open to new technologies that may
reduce the volume, toxicity or mobility of wastes being disposed of on site. Language
expressing this commitment was provided in the Proposed Plan in the description of the
preferred alternative, and has been incorporated in Section 9 of this ROD.
NO dilution of waste to meet waste acceptance criteria, soils above 1030 to be
shipped off site.
Response:
DOE agrees that an important consideration during the remedy implementation phase is
to ensure that proper excavation control and waste management practices are applied to
prevent the dilution of contaminated soil and increase the volume of soil requiring
disposal. DOE has no intention of using dilution as a mechanism to attain the waste
acceptance criteria for the disposal facility. DOE is compiling detailed procedures to
guide site-wide excavation operations for contaminated soil. These procedures, which
will be developed during the remedial design phase for Operable Unit 5, will clearly
define intended excavation methods which will ensure against such dilution taking place.
The selected remedy provides that soil exceeding this waste acceptance criteria will be
shipped for off-site disposal at an appropriate facility. DOE is committed to
implementing this remedy as defined in this decision document. However, DOE must also
bring to the commentor's attention that the availability of off-site disposal capacity cannot
be assured over the 10- to 25-year cleanup program associated with Operable Unit 5. In
the event off-site disposal capacity becomes unavailable or cost prohibitive at some point
in the future, DOE considers it important that flexibility be maintained and indicated in
the ROD so as to permit the application of treatment technologies to soil exceeding these
acceptance criteria to convert them to a form suitable for on-property disposal. The
application of such technologies would only occur following receipt of approval by EPA
and input from OEPA.
I do support the US EPA Waiver of siting criteria.
Response:
Comment acknowledged.
In conclusion the Fernald site beyond the disposal cell should become a wet land a
santuary.
Response:
Comment acknowledged. As discussed in the response to the comment listed as Yocum 4,
the DOE will be soliciting public input into the specific land use to be adopted for the
areas outside the disposal facility. Land uses currently under consideration include the
establishment of a wetland and/or a wildlife sanctuary.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\Deceniber 8, 1995 12:43pm A.3-153
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FEMP-05ROD-6 FINAL
December 15, 1995
Yocum, E. I believe in the balance approach for all DOE sites.
12
Response:
Comment acknowledged. The selected remedy is consistent with the "balanced approach"
whereby the smaller volume, more heavily contaminated process wastes are disposed of
off property, while the larger volume, low concentration contaminated materials are
placed into an on-property disposal facility.
CRU5\ROD\MCM\APP-A\RSC-S-Y.ROD\Decanber 8, 1995 12:43pm A.3-154
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FEMP-05ROD-6 FINAL
December 15, 1995
A.4.0 REMEDIAL DESIGN/REMEDIAL ACTION CONCERNS
EPA guidance requires that the Responsiveness Summary highlight specific issues raised during the
public comment period which pertain to the remedial design and remedial action process. The
following provides a summary of the concerns raised during the public comment period for Operable
Unit 5. Individual responses to these concerns are provided in Section 3 of this appendix.
• The FEMP should implement a responsible monitoring program during remedy
implementation to detect airborne discharges and/or releases to surface water. This
monitoring program should use real-time monitoring techniques to the extent possible.
Data from the program should be provided to the State of Ohio and the public in a timely
fashion. The DOE should continue to evaluate their monitoring program throughout
remedy implementation to possibly identify and apply, if practical, new or improved
methods of measurement.
• The FEMP should develop action levels for the monitoring program to establish thresholds
above which ongoing cleanup activities will be suspended until appropriate weather
conditions occur or work controls are implemented.
• Pollution prevention techniques should be implemented during remedial actions to minimize
or eliminate releases occurring during remedial actions.
• The principles of 'as low as reasonably achievable' should be considered during all
remedial design efforts.
• Groundwater pumping activities should not be completed until stakeholder input is
received.
• The FEMP should continue its excellent community involvement program throughout the
remedial design and remedial action process.
• The soil excavation techniques implemented at the FEMP should minimize the potential for
dilution of contaminated soil with clean material.
• The location of existing flood and perched water zones should be properly accommodated
within the design process for the on-property disposal facility.
• The on-property disposal facility design process should consider the possible implications
of the effects of tornados, earthquakes and acts of terrorism.
• The on-property disposal facility should consider the establishment of a minimum 300-foot
buffer zone surrounding the facility. Public access to this buffer zone and the disposal
facility should be limited through the construction of a perimeter fence or some other
formidable barrier.
CRU5\MCM\APX-A.ROD\December 11, 1995 ll:34tm A.4-1
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FEMP-05ROD-6 FINAL
December 15, 1995
• Long-term environmental monitoring should be provided to assess the continued
performance of the disposal facility. Clear responsibility should be established for the
long-term monitoring and upkeep of the facility.
• The FEMP should continue to evaluate and apply, if deemed practical, new and emerging
technologies which might provide improvements to the overall protectiveness or
performance of the remedy by reducing the volume, mobility or toxicity of the Operable
Unit 5 contaminated material.
• A consideration during the design process for the on-property disposal facility should be
the possible economical retrieval of the contents.
• Stringent and continuous oversight should be provided by an independent expert during the
design, construction and filling of on-property disposal facility.
• DOE should treat soil that contains RCRA characteristic properties to remove the
characteristic before on-property disposal.
CRU5\MCM\APX-A.ROD\Deconber 11, 1995 ll:34am A.4-2
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ATTACHMENT A.I
TRANSCRIPT OF THE OPERABLE UNIT 5 PUBLIC MEETING
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1
2
3
4
5 FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
6 OPERABLE UNIT 5
7 PUBLIC MEETING ON THE
8 FEASIBILITY STUDY & PROPOSED PLAN
9
10 May 23, 1995
11 The Plantation
12 - - -
13
14
15
16
17
18
19
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22
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24
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1 MR. STEGNER: Good evening and
2 welcome. Thank you all for coming. My name is
3 Gary Stegner, I work for Public Affairs for the
4 Department of Energy for Fernald. Soon I'll be
5 turning it over to Rob Jenke, our manager of
6 Operable Unit 5 at the Department of Energy at
7 Fernald.
8 If you haven't done so, I would urge
9 you, everybody that has shown up tonight, to
10 register at the door, at least before you leave
11 this evening, and if you want to speak during the
12 public comment period, the formal part of the
13 evening, if you would just indicate that on the
14 sign-in, that way we'll be sure to get you. It's
15 not required that you do so, but we'll have an open
16 mike, and that will give us a better idea of how to
17 allocate our time tonight. I would appreciate if
18 you do that, plus by signing in, you will be sure
19 to get on the mailing list and get all the
20 proceedings that happen tonight.
21 Also I want to tell you all there's a
22 lot of handouts here this evening there.in the back
23 of the room that gives you a better explanation of
*
24 Operable Unit 5 and our proposed plan for Operable
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1 Unit 5, and I would urge you to pick that stuff up
2 and take it home with you this evening also.
3 Let's talk a little bit about what
4 we're going to do tonight. We have two hours
5 scheduled. That should allow us plenty of time for
6 questions and comments. If it doesn't, we'll stay
7 here for as long as it takes. We know this is an
8 important issue in the community and we want to
9 make sure everybody gets their say. I want to make
10 sure everybody realizes that you do not have to
11 speak tonight to issue a formal comment on the
12 Operable Unit 5 proposed plan. You can do it in
13 writing, send it to me. The address and a response
14 card are included with the proposed plan document,
15 assembly document.
16 Again, this is a public hearing
17 tonight. We have a court reporter here with us to
18 transcribe the meeting. A copy of the transcript
19 will be placed in the Public Environmental
20 Information Center located on 128, very close to
21 the site. Probably be there within a couple of
22 weeks. Anyone who is interested in what's going on
23 here can review that transcript.
*
24 Rob will speak for about 20 to 30
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1 minutes tonight, give you kind of a review of
2 Operable Unit 5. For some of you, this may be your
3 first exposure to a Fernald meeting. Normally
4 we're very casual, you can shout questions out
5 pretty much at any time. Tonight I would ask that
6 everyone, just for the sake of getting through this
7 initial presentation, to hold their questions until
8 the question and answer period. Prior to going
9 into the official public comment section this
10 evening, we will take questions and answers.
11 Obviously this is a complicated
12 issue, we would urge you guys to ask a lot of
13 questions. We have people up here very, very
14 capable of responding to I think most of the
15 questions you folks would have tonight.
16 Fernald is a complicated place, a lot
17 of issues going on around there, but tonight I'm
18 going to try to keep the evening focused on
19 Operable Unit 5. Again, for the sake of conserving
20 time and since this is a formal public hearing
21 tonight, I want to keep it as focused as we
22 possibly can. So if you would, keep your questions
23 and comments, at least in the meeting part, focused
*
24 on Operable Unit 5. If you have questions outside
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1 the realm of this document, we'll be around during
2 the break, we'll be around after the meeting to
3 answer your questions. And again, we're only a
4 phone call away.
5 When is the formal comment period
6 over? 31st of May. So if you do not choose to
7 speak tonight, you do not choose to hand any
8 comments in tonight, you have until the 31st of May
9 to send your comments in to me to get them into the
10 formal record.
11 What I want to do now is turn the
12 next part of the evening over to Rob Jenke.
13 Following Rob we'll have some comments from our
14 regulators, Ohio and US EPA's. Then we'll have the
15 informal question and answer period. It shows it
16 on here being 35 minutes. We can go longer than
17 that if necessary, but again, we're here as long as
18 you want us to be, and following that we'll take a
19 10-minute break. Then we'll go formal into the
20 formal public hearing part of our evening. So,
21 Rob.
22 MR. JENKE: Okay. Thanks a lot,
23 Gary. I guess with that, 1^' 11 begin the
24 presentation. I appreciate you all coming
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1 tonight. As Gary said, this is the formal public
2 meeting on the Operable Unit 5 Proposed Plan and
3 Feasibility Study, and this presentation should
4 take about 30 minutes.
5 Before I get into the presentation,
6 I'd like to first start off with I guess a bit of
7 thanks to the team sitting here at the table. I'm
8 a relatively newcomer, as probably many of you
9 know, to Operable Unit 5. Most of my time at the
10 site with DOE has been spent in Operable Unit 3 . I
11 just came on board to Operable Unit 5 about nine
12 months ago, I guess August of '94, and it's been,
13 to be quite honest, a great learning experience. I
14 think I've learned a lot, and I think each of the
15 members of the team, both from FERMCO and the
16 people that were in DOE Operable Unit 5 at the
17 time, have been very helpful and I think supportive
18 of that transition, so I would like to thank them.
19 And I think a special thanks goes to Dennis and
20 Mark who put in long hours on this project, and I
21 think it's, this represents really a focal point to
22 all that hard work. I would just like to thank
23 them.
*
24 With that in mind, I would like to
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1 jump into -- Can everybody hear me okay without
2 this microphone because if you don't mind I'm going
3 to pull this away. I guess to start off with why
4 we're here tonight. We're here to share with you
5 how we came about the decision, the remedy, the
6 proposed remedy, that is, for Operable Unit 5.
7 'What we want to I guess convey is the options that
8 we looked at, the range of options, the factors
9 that went into coming up with those range of
10 options, and the tradeoffs that we encountered
11 along the way. Ultimately what you'll find at the
12 end, those of you who have already read the
13 proposed plan, certainly it represents in many ways
14 a compromise. The purpose of tonight's meeting is
15 to go over that in basically summary form.
16 What we'd like to have in terms of
i
17 feedback is feedback in terms of how we look at the
18 process. Are there things that we left out,
19 considerations, technical considerations that we
20 didn't include in our analysis, assumptions that
21 maybe are invalid. Basically do you see any flaws
22 in our logic. With that in mind, a brief overview
23 of tonight's presentation.
*
24 I'm going to start off with a little
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8
1 bit of a description of Operable Unit 5, sort of a
2 background description, more focused on the way it
3 fits in with the other operable units in terms of
4 volumes of waste, contaminated' soils in terms of
5 OU-5, that's what we're talking about, and in terms
6 of levels of contamination that exist in Operable
7 Unit 5. Then I'll move on to -- That will be the
8 overview, the contamination or the RI of Operable
9 Unit 5. Then we will move to how we determine
10 cleanup levels in the operable unit, and then
11 finally the path forward for using those cleanup
12 levels.
13 Operable Unit 5 represents the soil
14 and groundwater media at the site. It essentially
15 is the receiving end of all the past operations and
16 discharges. It's not a source operable unit,
17 meaning that we don't have a waste unit there we
18 have to remove and then treat and put back. We
19 basically have contaminated soil. So it's a little
20 different than Operable Unit 1, which is the pits,
21 or Operable Unit 4, which represents the silos.
22 Specifically Operable Unit 5
23 represents the soil, the groundwater, perched
*
24 water, surface water, sediment, flora and fauna. I
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1 think most of you are familiar with this. It's
2 been around the process for a while, but just to go
3 over it briefly.
4 In terms of FEMP waste volumes, what
5 does Operable Unit 5 mean to the site as a whole?
6 It represents about 60 percent of the FEMP waste in
7 terms of contaminated waste. Operable Unit 3,
8 which is roughly 6.6 percent of the waste by
9 volume, this slide is a little deceiving in that
10 Operable Unit 3, the pink area, is 6.6 percent, but
11 then we have uranium and thorium residues, which
12 are roughly 1.5 percent. Together we have about 8
13 percent at Operable Unit 3. In contrast, Operable
14 Unit 1 is approximately 20 percent by volume of
15 representing the waste at the site. This is
16 important because in terms of total radioactivity,
17 Operable Unit 5 represents the smallest
18 contribution, especially when we balance that off
19 the total volumes. Roughly about 2 -percent.
20 Operable Unit 2 isn't shown, basically because it
21 represents roughly .2 percent, so it would be
22 basically incremental to the Operable Unit 5 waste
23 volume, actually radioactivity increment.
24 As you can see, the Operable Unit 3
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10
1 materials in terms of uranium product, the legacy
2 waste and the thorium waste represents around 50
3 percent of the total radioactivity but only about
4 8 percent of the volume.
5 In terms of Records of Decisions and
6 remedies that we've basically established so far,
7 there's been four Records of Decisions that are
8 either in process, I'm not completely sure of
9 Operable Unit 2's status, but I believe we have
10 four signed Records of Decision.
11 We have a Record of Decision for
12 Operable Unit 1, which is the waste pits, to
13 excavate and ship to Envirocare in Utah.
14 For Operable Unit 2, that's the
15 soils, soils in the South Field area and connected
16 with the flyash piles and the sewage sanitary
17 landfill, that material will be/excavated and
18 disposed of on property.
19 Operable Unit 3, although disposition
20 decision hasn't been determined, the decision to
21 bring all the buildings down has, and we have an
22 Interim Record of Decision on that.
23 Operable Unit 4, which is the K-65
•
24 silos, the high radium bearing waste, that will be
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11
1 vitrified and shipped to the Nevada Test Site.
2 Again, the purpose of tonight's
3 discussion is Operable Unit 5. In terms of that
4 total radioactivity, where is that on the site or
5 around the site? This aerial isopleth basically
6 outlines the level of uranium contamination around
7 the site at a concentration of between 5 and 20
8 ppm, parts per million of uranium. As you can see,
9 at those levels it extends off property to some
10 degree, which resulted from the years of process
11 operations and discharges from the roughly I guess
12 two to three -- well, I guess nine process plants.
13 In terms of on property
14 contamination, uranium contamination, the levels
15 range between the southern portion of the property
16 5 to 10 parts per million on average, there's hot
17 areas -- I forgot my pointer, I apologize, but down
18 in the South Field areas there's concentrations
19 that are fairly high, but on average the
20 concentration is 5 to 10. The waste pit area,
21 those areas that are anywhere from a hundred to a
22 thousand, but on average around 10 to 20. The
23 production area is roughly a hundred to 10,000 in
24 places.
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12
1 Formerly we used to have some
2 contamination out near the incinerator that was
3 fairly high, in the order of 25,000 parts per
4 million. That soil has since been removed. So in
5 terms of peripheral area of the site, we're
6 basically down around the 5 to 10 or the 10 to 20
7 reading.
8 In terms of groundwater
9 contamination, depending on where you're at,
10 there's various plumes, we have the 3 to 20 plume
11 right here, represents the largest size, that's 3
12 parts per billion, less than 20 parts per billion.
13 In terms of 20 parts per billion plume, which is in
14 green, the largest section of that is in the South
15 Field area extending off-site. Within the
16 production area of Plant 6 we have a plume that is
17 greater than 20. I think in terms of maximum
18 concentrations in the South Field we're up around
19 300 I believe.
20 MR. CARR: Off-site'300, on-site
21 about a thousand.
22 MR. JENKE: On-site about a
23 thousand.
*
24 Given these levels of contamination
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13
1 in the soil and groundwater, the goal, the
2 objective of Operable Unit 5 was to determine or
3 develop cleanup levels for these media, essentially
4 surface soils and groundwater. The issue from the,
5 I guess from the start was given that we have large
6 quantities of soil that have concentrations of
7 uranium in it anywhere from 5 to 10,000 parts per
8 million on average across the site, we're probably
9 looking at a hundred parts per million, how do we
10 address that. We know background for uranium is
11 around 4 parts per million in soil, there aren't
12 any action levels in the regulations, EPA or state
13 regulations that we can adopt and say this is what
14 we're going to clean up the soils to at Fernald.
15 We're basically given the process we have to follow
16 under CERCLA and NCP and we have to develop cleanup
'17 levels. A guiding requirement under developing
18 those cleanup levels is to make sure we remediate
19 to health-protective levels for both the soil and
20 the groundwater.
21 In terms of the groundwater, we knew
22 from the beginning that our really only option is
23 to, one, restore it to its maximum beneficial use
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24 and, two, protect it in the future from the
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1 continued or possible continued migration of
2 contaminants from the surface soil, those that are
3 there now or those that we may leave in the future
4 after we determine the cleanup level to make sure
5 we don't recontaminate the groundwater. Those are
6 basically our guiding principles.
7 With that in mind, we have basically
8 two constraints or two needs to allow us to develop
9 a framework for developing these cleanup levels.
10 One is the need to address cross-media impacts,
11 which I just touched on, which is the process by
12 which contaminants, whether they be uranium,
13 radium, thorium, or other contaminants, migrate
14 through the surface soil and contaminate the
15 groundwater. It's a possible or potential exposure
16 pathway in the future and in the present, and
17 whatever cleanup level you achieve for or develop
18 for soils, that number has to be protected for the
19 groundwater in the future.
20 The other need or requirement that
21 allow us to set up this framework is a need to
22 develop receptor-specific exposure levels. Given
23 that we don't have a number that we can look up in
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24 the regulations, whether it be EPA regulations or
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1 state regulations or DOE orders, or NRC regulations
2 to say that we need to clean up uranium to this
3 concentration. Instead EPA has developed a process
4 for developing cleanup levels, so the site specific
5 process. The reason for that is, depending on the
6 level of use at the facility, ultimate use in the
7 future, the cleanup levels will vary. So the
8 process really calls for you to develop this
9 receptor-specific exposure scenario framework.
10 To do that we developed or postulated
11 four different receptors: A residential farming
12 receptor; an industrial/commercial worker receptor,
13 similar to the workers that exist who are working
14 on the site right now; a developed parkland
15 receptor, developed parkland would be a situation
16 where you had, you cleared the site off and you had
17 picnic tables, you had a park, restroom facilities,
18 you had possibly ball parks and swing sets and
19 things like that; or an undeveloped parkland, which
20 is basically green space with possibly hiking
21 trails or a bike trail, maybe an extension of the
22 Great Miami bike trail.
23 Given those receptors, we had to
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24 develop ultimately land uses to go along with
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1 them. Before we developed land uses, or I guess in
2 concert with developing land uses, we had a, we
3 have a rule book that we have to follow for
4 developing the cleanup levels, sort of a check
5 point on the cleanup levels. A framework for
6 determining whether levels are too high or too low,
7 really actually for the most part too high.
8 There's three parts to that rule book. The NCP is
9 certainly the overall guiding process which
10 establishes a risk range 10 to the minus 6 to 10 to
11 the minus 4, which is an incremental lifetime
12 cancer risk that someone could get from being
13 exposed to the contaminants at the site. That's
14 the risk range that we have to work within in
15 developing the cleanup levels.
16 Another criterion or rule book,
17 component of the rule book which represents a lot
18 of different standards and regulations and
19 guidelines is what's called ARARs, which are
20 applicable, relevant, and appropriate
21 requirements. The ARARs really, in some cases they
22 represent MCL's or specific cleanup levels, MCL's
23 or maximum contaminant levels for a specific
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24 contaminant. In some cases they are specific for a
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1 contaminant. For uranium they're not, at least at
2 the soils. And for other actions they represent
3 standards or processes that you have to follow to
4 implement the action. So there's a large number of
5 ARARs that have to be factored into the decision.
6 The last component of our rule book,
7 which is really in part included under the risk
8 range or the process for using the risk range as
9 well as ARARs, is to evaluate or consider
10 ecological effects. Ultimately the cleanup levels
11 that we choose for the soil and groundwater have to
12 be protective of ecological receptors that live in
13 and around the site and may ultimately be exposed
14 to contaminants.
15 Given that rule book, the question I
16 guess that certainly comes up in one's mind is how
17 do you go from that rule book and these exposure
18 scenarios and receptors to needing to know what the
19 future land use is. Quite simply, cleanup levels
20 vary with respect to future land use. As the level
21 of activity on the site, the future use of the site
22 goes up, cleanup levels go down. The reason for
23 that is as the level of activity, i.e., something
24 like farming occurs, you have a lot more exposure
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1 to the contaminant. The farmer is out plowing the
2 fields, he's planting crops, there's just a lot
3 more time outdoors in which to gain exposure. As
4 that exposure goes up, his corresponding risk to
5 contaminants goes up; therefore, cleanup levels,
6 acceptable cleanup levels go down.
7 On the opposite end is, would
8 probably be a trespasser receptor, where a
9 trespasser being an individual that maybe crosses
10 or transverses the site a few times a year and has
11 very minimal exposure. If you'take those two
12 receptors, it essentially establishes the range or
13 the magnitude, the difference between cleanup
14 levels within our land uses.
15 More specifically in terms of land
16 uses, we looked at four land use objectives, the
17 first one being unrestricted use, which would
.18 correspond to the residential farmer. That's
19 basically we clean the soil up to levels that would
20 permit an individual to come on and farm the land.
21 The fences are torn down, the buildings and
22 everything are taken away, and basically the site
23 is just released, no strings attached.
24 The next, how should I say, level of
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1 decreased activity would be land use objective
2 number two, where we released the outer peripheral
3 area of the site and maintain the center portion of
4 the site for a no access region. In that area we
5 evaluated a couple options. We evaluated on-site
6 disposal in a couple options or a couple ways or
7 manners in that area.
8 The third land use objective we
9 looked at was essentially a restricted use of the
10 outer portion of the site and then again no access
11 in the center. So the difference between two and
12 three is this would be a farmer and this would be
13 some type of restricted use, such as a developed or
14 undeveloped park or commercial/industrial scenario
15 or a trespasser, something along those lines.
16 Four would essentially be a fence
17 around the entire property, which would, of course,
18 correspond to the highest cleanup levels, the least
19 amount of remediation, at least of the soils.
20 In terms of, jumping back to
21 groundwater, in terms of the groundwater, I think
22 we knew right away that, I think even the community
23 and certainly EPA and Ohio, US EPA and Ohio EPA I
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24 think recognized right away there's not a lot of
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1 option in the groundwater. As you can see from the
2 earlier viewgraph on uranium contamination in the
3 aquifer, it's a very large plume. The Great Miami
4 Aquifer is rather large, as most of you, if not all
5 of you, realize or know. The options for restoring
6 or remediating the aquifer are somewhat limited.
7 You basically have to pump and treat it.
8 So up front we recognize that first
9 we had to restore the aquifer to maximum beneficial
10 use. Then we had to decide what level are we going
11 to remediate the aquifer, are we going to remediate
12 it to a risk space level of 1 times 10 to the minus
13 4 or one times 10 to the minus 5 or one times 10 to
14 the minus 6. As you I guess decrease or increase
15 your level of remediation to achieve levels such as
16 10 to the minus 6, the amount of pumping and
17 treatment that you have to do go up considerably.
18 In addition to looking at risk, we
19 looked at the use of maximum contaminant levels.
20 For uranium we only have proposed numbers. These
21 proposed numbers have been on the books for some
22 time. That's all we had and that's what we used.
23 Proposed MCL, maximum contaminant level for
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24 uranium. We decided based on the work that EPA had
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1 done on coming up with that proposed number, as
2 well as where that proposed MCL fell within our
3 risk assessment process, we did look at risk space
4 cleanup levels for the groundwater, we decided to
5 go with the MCL. That established --by coming up
6 with 20, that established the contour of our
7 plumes, which is why that graph earlier showed 20.
8 It also established to a great extent how much we
9 have to pump and where the wells would be located.
10 In any event, the really only option
11 for the groundwater is to pump and treat.
12 In terms of soil, at least
13 conceptually one would think there's a lot more
14 options. You could somehow put some type of cap on
15 it, in-place containment, that was examined. You
16 could maybe theoretically, one would think you
17 could maybe treat the soils in place, you could
18 treat VOC's, volatile organic compounds, in place
19 by stripping them, air stripping them or using some
20 type of biological agents to break them down.
21 Maybe something could be done with uranium.
22 Unfortunately, there are no more options there.
23 You can't eliminate radioactivity, you can't break
24 it down. You can only move it around. So that
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1 really didn't prove very feasible.
2 We looked into washing, and those of
3 you who have been involved in the process, there's
4 a lot of detail on it, just how hard we looked at
5 soil washing, basically in the form or the process
6 of removing the soil, running it through a process,
7 -multi-step process to wash uranium from it with
8 using strong or weak acids and water to basically
9 rinse it from the various fractions in which it
10 resides within the soil, the clays, the silts, the
11 sand. The problem with soil washing is we found
12 it's very expensive. I believe the numbers are
13 roughly a factor of three greater. It doesn't
14 achieve the lowest cleanup level within the area of
15 the production area, so it's not -- one could say
16 it's not protected in terms of achieving all our
17 cleanup levels for uranium, an4, three, we had
18 concerns with its implementability, given that we
19 have to start up this large process and we would
20 have to run approximately two million cubic yards
21 of soil through it. That raised a lot of concerns
22 with us in terms of the number of chemicals that we
23 would have to bring onto the site in order to run
24 the process, the length of time that it would take
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1 to do it. All of these point to soil washing as
2 not being very viable.
3 The only option left, if you look at
4 the top three in the feasibility study, the only
5 option left was to excavate and dispose. Once we
6 got to that point, we realized that with excavation
7 disposition or disposal, the issue is really
8 on-site or off-site. With that, we started looking
9 at considerations for on-site and off-site
10 ultimately, which became our remedy or our proposed
11 remedy for soil, is it on-site or off-site. Well,
12 we looked at, consulted with, and listened to the
13 Task Force recommendations for on-site disposal,
14 we've attended and conducted numerous public round
15 tables, open forums with many of the members of the
16 public on the issue of on and off-site disposal.
17 We've had a lot of, as you can imagine, many of you
18 realize, a lot of negative I guess feelings about
19 on-site disposals. It wasn't something we
20 certainly preferred, but, nevertheless, we have
21 considered numerous people's input on the issue.
22 We.also looked at the availability,
23 the uncertainty of off-site disposal. Given that
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24 the action associated with Operable Unit 5 is going
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1 to span probably 20 years, and the large part is
2 due to length of time it is going to take to get
3 the buildings down and out of the way in order to
4 get to the production area soils. That's a long
5 time frame in order to be sure or be, how shall I
6 say, enthusiastic that we have disposal capacity
7 there. There's concerns that have been expressed
8 to us from the states of Nevada and Utah to us
9 sending all of our stuff out there, as well as
10 people along the routes. The cost of off-site
11 disposal initially, given our cost numbers that we
12 have today, are approximately twice the on-site
13 disposal option, not quite twice. The cost over
14 the long term were very unpredictable, uncertain.
15 Given those considerations, we
16 basically came up with a proposed remedy which
17 you'll see in the proposed plan. There's a number
18 of components of the proposed remedy. This slide
19 tries to I guess provide a summary of the more
20 important ones. I believe the proposed remedy
21 that's in your handout is, the language is slightly
22 different than this one. This one was modified as
23 of later this afternoon so it didn't get in the
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24 slides. We tried to convey a few more of the
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. 1 factors. '
2 Ultimately, as I indicated earlier,
3 our primary goal is the restoration of the Great
4 Miami Aquifer, first and foremost. In terms of
5 soils, we're going to excavate all contaminated
6 soils down to our cleanup level. It's discussed
7 under alternative 3A in the proposed plan. Those
8 soils will be deposited in an on-property
9 engineered disposal facility, those that meet the
10 waste acceptance criteria for an on-property
11 disposal facility. Soils that don't will have to
12 be either treated or shipped off-site.
13 We'll continue to look at
14 technologies and innovations over the long haul to
15 make sure this was the right decision. That's a
16 tough, that will be a tough process. It will
17 always have to be balanced of with protectiveness
18 and its implementability and its practicality.
19 And I guess to sum up the proposed
20 remedy, we're going to try to maximize the release
21 of the largest portion of the site for reuse.
22 What's outlined in the proposed plan under
23 alternative 3A is an undeveloped, park scenario, but
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24 within that alternative there's a range of cleanup
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1 levels associated with other receptors.
2 Now, within the rule book once again,
3 the NCP allows us to go from 10 to the minus 6 to
4 10 to the minus 4, so essentially we, in terms of
5 the ultimate land use, we can move between those
6 receptors and still stay within the acceptable risk
7 range and modify the ultimate use it's agreed to or
8 desired I guess by the public down the road.
9 The proposed plan in our draft Record
10 of Decision when it's written up and sent into EPA
11 will not pick a particular land use. That wasn't
12 envisioned that that could be done at this time.
13 Back to on-site disposal, and this is
14 a slide that we put into our presentation just of
15 late because of the numerous, I guess all the
16 feedback we've gotten from the community on just
17 how unfavorable on-site disposal is. I guess I
18 wanted to touch on this a little bit because this
19 is real important. In terms of uranium, and I
20 mentioned this earlier, we take all the soils
21 across the site and we excavate them down to our
22 cleanup level, which under the proposed plan is 80
23 parts per million for uranium, and we take all
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24 those soils together, we're going to have an
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1 average concentration on a maximum end probably of
2 100 parts per million uranium. It's essentially 20
3 parts per million above our cleanup level. That is
4 approximately one-tenth of the waste acceptance
5 criteria for disposal in our on-property disposal
6 cell, so essentially we have a tenfold safety
7 factor there.
8 In terms of what's the purpose of the
9 on-site engineered disposal facility, we've had a
10 lot of comments on that in terms of how big the
11 buffer area is going to be, where the fence is
12 going to be located, how high the fence is going to
13 be, all very good questions. They're questions
14 that we're not answering in the proposed plan, we
15 haven't answered, nor will they be answered in the
16 ROD. It's a process we want to get as much
17 feedback as we can as we go through design.
18 They're issues that need to be worked out at that
19 time.
20 The important point that I want to
21 make is the purpose of the engineered disposal
22 facility isn't to keep one from being exposed to
23 the contamination in there from air pathway or
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24 direct radiation pathway, although it will do that
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1 certainly, it will make it off limits, it will be
2 monitored, there will be so many feet of cover on
3 top with a liner, there will be a fence around it.
4 The primary purpose for it is to protect the
5 aquifer, to protect the migration of the
6 contamination once you pile It all up in the soil
7 from migrating through the top of the soil and into
8 the aquifer and exceeding the MCL's.
9 With that in mind, what are the
10 concerns associated with off-site disposal. I
11 touched on some of these earlier when we were
12 talking about options of on and off-site disposal.
13 There were transportation risks and logistical
14 concerns associated with shipping this large a
15 quantity of soil across the country approximately
16 2,000 miles. There were uncertainties with the
17 availability of off-site capacity for this large a
18 quantity, given all the other things that are being
19 shipped from this site from the other operable
20 units. Once again, they represent by far the
21 magnitude of radioactivity at the site. There was
22 issues with the state acceptance on the receiving
23 end. And there are issues of cost. When we factor
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24 all those factors in, that's how we got to the
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1 proposed remedy of on-site disposal.
2 In terms of our path forward tonight,
3 as Gary indicated earlier, the public comment
4 period will end, it's scheduled to end May 31st
5 unless a member of the public, the community would
6 like to see it extended for some reason. If you
7 do, tonight would be a good time to talk about
8 that. We have received approval on the proposed
9 plan for Operable Unit 5, which is being handed out
10 and I guess was distributed at the beginning of the
11 comment period on May 1st from US and Ohio.
12 So where we're at in the process
13 right now is we're drafting up a Record of
14 Decision, and we're planning, as long as the public
15 comment period isn't extended, our plan is to
16 submit that to EPA, US and Ohio, on July 2nd. What
17 that will have in it is a more detailed description
18 of the proposed remedy. It will have a more
19 detailed description of the RI component, the
20 remedial investigation component. It will
21 basically be a formal document on the proposed plan
22 that will ultimately establish the decision for
23 Operable Unit 5.
24 Attached to that document will be a
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1 responsiveness summary, which will be formulated
2 from all the public comments that we have
3 received. There will be responses to those
4 comments, and they will be attached in draft form
5 and submitted to EPA for review and approval.
6 With that, I am done. I would like
7 to at this time turn it back over to you, Gary.
8 MR. STEGNER: Thanks, Rob.
9 You see on the agenda the next item
10 is comments by our regulators, so Jim Saric from
11 Region 5, US EPA, if you would please lead it off.
12 MR. SARIC: How is everybody doing
13 this evening, all right?
14 This remedy that has been proposed by
15 DOE is one that's been a long time coming. We've
16 worked a lot directly with Ohio EPA, with DOE, with
17 the Fernald Citizens Task Force, and we worked
18 through a lot of these issues, as Rob talked about,
19 the soil washing and the different alternatives
20 that were there. We spent a lot of time looking at
21 earlier drafts, earlier revisions, the various
22 remedies trying to figure out what is the best
23 thing to do with this material, this large volume
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24 of material at this highly contaminated site that
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1 we have here at Fernald.
2 When all was said and done, when we
3 reviewed this document very critically and had lots
4 of comments and had lots of meetings over our
5 comments and what to do, we're very supportive of
6 this remedy as it stands.
7 This remedy is part of a large scale
8 strategy. It's a protective remedy that includes
9 both basically off-site disposal of the most
10 contaminated materials on-site and then on-site
11 disposal of the much larger volume of materials
12 that are lower level .contamination that's there.
13 And the thing about this remedy, it's
14 not limiting the land use I think here, but it
15 actually provides some type of future vision to
16 what the land use can be. As Rob said, it speaks
17 for the undeveloped park, but there's other land
18 uses that can come from this site if it so be it in
19 the future, and that's not why we're here to make
20 that decision on the ultimate land use, and I think
21 it's the people in the community who will make
22 those decisions ultimately what happens there.
23 And so I guess with that, you know, I
24 think that we really encourage your comments here
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1 tonight because they're a very important part of
2 this remedy selection process. It is not complete,
3 and we welcome all the comments that you have
4 here.
5 If you have any questions tonight,
6 I'll be glad to answer them, and I'll stick around
7 to answer those. But certainly this is part of a
8 large scale remedy of the site, and I sit back and
9 think about -- I was involved in the site, I became
10 involved in May of '91 was really when I got
11 heavily involved, and this site has come a long way
12 from the time which I think none of us really knew
13 exactly what direction we were ultimately headed
14 and we were studying the problem, studying the site
15 and how many samples to take here or there, what
16 are we going to do with this place. Ultimately I
17 think we've moved forward towards cleanup and we
18 have really tried to keep things rolling trying to
19 clean this place up. I think we're moving towards
20 that, we have direction, and certainly I'm very
21 interested in everyone's input.
22 With that, I'm done. Gary.
23 MR. STEGNER: Thank you, Jim. Next
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24 we have Tom Schneider from Ohio EPA.
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1 MR. SCHNEIDER: Good evening, glad
2 you all could make it out tonight. It's quite
3 evident that you're all committed to the public
4 participation process because you drove around the
5 barricades that say don't go this way. We all
6 drove through it too because we don't know any
7 other way to get here. We appreciate you being
8 out, it's a good time to be involved in the public
9 participation process at Fernald, and it is a time
10 of moving forward and making decisions. It's the
11 year of decisions; from about December of '94 and
12 through December of this year we'll have made
13 Records of Decisions for OU-4, OU-1, and OU-2 and
14 OU-5, so we'll have the site pretty much wrapped up
15 as far as decisions and how we move forward from
16 here from now to the end of the year. So now is
17 the time to be involved. If you're going to be
18 involved, this is when the most impact can be
19 made. So your comments now are most timely and
20 have a significant impact on how we move forward
21 with the site.
22 With regard to OU-5, Ohio EPA
23 supports the proposed or the preferred remedy. We
24 think it's both protective and implement able, with
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1 a lot of emphasis on implementable. Rob talked a
2 little bit about potential problems with off-site
3 disposal. We think it is important to take our
4 aggressive move forward and try to get this site
5 off the books so that we can choose the tough
6 decisions so we can move forward, and that's the
7 on-site alternative for the large volume lower
8 contamination materials. So the State of Ohio
9 supports the preferred alternative, we think it is
10 going to be protective. It takes into account
11 what's been referred to on a number of occasions as
12 the balanced approach, and that's what's really the
13 important thing here. We're looking at this as the
14 site-wide perspective, not just one operable unit
15 at a time. You really have to keep in mind the
16 whole size of the whole project, and as well on a
17 national perspective you have t/fc keep in mind that
18 there are other people out there who have back
19 yards just like we do.
20 So, anyway, I just wanted to let you
21 know that the State of Ohio supports it, and we
22 really want your public comments and this is the
23 document to do it on. Granted, this is the
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24 Reader's Digest version of the much larger FS that
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1 has all the details in it, but we want to make sure
2 you all have the opportunity, we put this nice
3 little page on here so you can write your comment
4 out, and we will pay for the postage to get it back
5 to us. Probably the easiest way that's ever been
6 developed for you to make your comments. You don't
7 even have to turn them in tonight or figure out how
8 to address it.
9 Anyway, I look forward to your
10 comments. Don't forget, the 31st is the last date
11 to do that, and if you have any questions, you can
12 chase me down after the meeting, my phone number is
13 in the book. Thanks.
14 MR. STEGNER: Thank you, Tom.
15 I think now we'll move directly into
16 the informal question and answer period. I think
17 probably most of you are very familiar with what
18 we're doing here at Operable Unit 5. If you still
19 have questions, details you want clarified, main
20 issues you want painted up more clearly, now is the
21 time to do that, and we will proceed as -- you can
22 use the microphone, you can holler them out, please
23 if you do, ask make sure that you're loud enough so
24 that the court reporter can get the questions. Now
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1 if you want to use the microphone, if you just want
2 to holler them out, I would suggest somebody could
3 start off with the first question.
4 MR. JENKE: Can I interject just one
5 thing before we get started, just so -- I don't
6 think I officially introduced all the panel. On my
7 left is Kathy Nickel, she's with the Department of
8 Energy at Fernald. We have Mark Jewett, who is
9 with FERMCO. Dennis Carr is with FERMCO, and Bill
10 Hertel is also with FERMCO. Between our panel here
11 and Gary, I think we can answer your questions.
12 MR. STEGNER: Between the panel
13 there, they can answer your questions I'm sure.
14 Pam.
15 MS. DUNN: I just have a couple
16 quick ones. We can fax comments in on Wednesday,
17 can't we?
18 MR. STEGNER: Yes, you can.
19 MS. DUNN: How much time do we have
20 after this before public meetings will start on the
21 RDRA; I mean is there going to be a little bit of
22 time where there won't be any meetings or are those
23 meetings going to get started right away?
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24 UNIDENTIFIED SPEAKER: Gary, aren't
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1 you planning to have a meeting on the 13th?
2 MR. STEGNER: My sense is that I
3 suspect we will start relatively soon, Pam. I
4 think this is something the public has a great deal
5 of interest in, the on-site disposal in
6 particular. This is something we want to keep them
7 apprised of exactly where we're headed. So I think
8 you can probably count on public involvement fairly
9 early and fairly often for the foreseeable future
10 on this.
11 MR. JENKE: Johnny had a comment.
12 MR. REISING: We had a meeting a
13 couple of months ago on the RD process. At that
14 point in time we tried to explain that 60 days
15 after finalization of the Record of Decision of
16 OU-5, that is the signature by the agencies, that
17 we're required to submit our work plan to the
18 agencies. That RD work plan will have a schedule
19 of subsequent deliverables as far as design
20 packages, and then, as you know, we have a
21 relatively well-defined process to inform you when
22 these design packages are going to be submitted and
23 an opportunity to comment on that. So again 60
*
24 days afterwards we will -- the RD will be
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1 submitted, the agencies will comment on it, we will
2 submit our work plan with the design packages, and
3 you will have an opportunity to comment on that.
4 MS. DUNN: We don't get a break.
5 MR. REISING: Right.
6 MR. STEGNER: Yes, sir.
7 UNIDENTIFIED SPEAKER: What is the
8 projected lifetime of the Miami aquifer? I didn't
9 see that anywhere reading in the book. You're
10 basing your proposal on 1,000 years, and I'd like
11 to know what's the proposal on or what's the
12 lifetime of that aquifer system to be around?
13 MR. JENKE: To be around?
14 UNIDENTIFIED SPEAKER: How long has
15 it been there?
16 MR. JENKE: It's been there since --
17 MR. HERTEL: It's been there for
18 about 150,000 years.
19 UNIDENTIFIED SPEAKER: You're only
20 basing your plan for a thousand years and you're
21 putting it on top of the aquifer.
22 MR. JEWETT: I think the key is the
23 thousand years is really a target time frame that
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24 we have to design against. It's kind of mankind's
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1 way of basically putting a number into an
2 indefinite performing engineering structure, and if
3 you can design for a thousand, that's kind of an
4 engineer's way of saying this thing can perform
5 indefinitely, it's a way of putting a time frame on
6 indefiniteness, and that's how the regulation is
7 developed. So it's not like we're planning at year
8 1,000 for everything to fail. That is probably the
9 key point.
10 MR. STEGNER: Any other questions
11 before we move into the break and then reconvene
12 for the public comment period?
13 MS. SCHULTE: The way I understand
14 there is a law that prohibits a storage unit over
15 the aquifer, and because of the fact that Fernald
16 existed before this law went on the books, there's
17 going to be a waiver for that, and my question is
18 if this is a new site coming into view and was not
19 a pre-existing unit, why does the EPA look at it in
20 the same light to grant a waiver for this storage
21 unit?
22 MS. NICKEL: As you know, I think
23 what you're referring to is the sole source
24 prohibition as part of Ohio's solid waste
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1 So with those reasons behind us, we
2 went to EPA and requested a waiver. To get that
3 waiver we had to demonstrate that our disposal
4 facility would be as protective as if we had fully
5 complied with that regulation, i.e., hadn't located
6 there. So what we had to do was to provide some
7 assurance that for that thousand year, i.e.,
8 indefinite period of time that the aquifer would
9 not be impacted, and the way we did that was by
10 eliminating the concentration of what could go into
11 the cell. As Rob talked, about we have waste
12 acceptance criteria of 1,030. What will go in
13 there is actually almost 10 times less than that.
14 If you have an opportunity to look in
15 the back, we have columns more or less that show
16 the liner and the cap design. It's a cap designed
17 to funnel water away from the facility and to
18 prevent infiltration into the facility, to prevent
19 contaminants from leaving the facility. With that
20 and also locating the facility on the site in the
21 best geological area, where the on-site clay is the
22 thickest, we were able to provide EPA with enough
23 assurance that we would protect the aquifer.
24 That's probably more of an explanation than you
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1 regulations. Originally the regulations were
2 targeted at limiting new sources of contamination
3 of the aquifer by encouraging sanitary landfills,
4 new commercial disposal facilities to locate
5 geologically appropriate places, not over an
6 aquifer. As you know, our situation is really
7 quite a bit different. We are already a source of
8 contamination to the Great Miami aquifer, but our
9 objective is to minimize or eliminate actually that
10 source. For that reason, we view that in a
11 different light. However, we did view that sole
12 source prohibition as an applicable regulation to
13 us. We took it really very seriously, but as Rob
14 mentioned, we have an aggressive groundwater
15 restoration component to our alternative that is
16 going to carry a price tag of $160 million with
17 it. Clearly we're not interested in a proposed
18 remedy that is going to put that aquifer at risk
19 and at going through that effort of getting it
20 cleaned up, but again, as Rob discussed, after we
21 went through an evaluation of the alternatives, the
22 on-site disposal facility really panned .out to be
23 the only option that we could insure its
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24 implementability as a practical alternative.
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1 wanted.
2 MR. JENKE: Can I add one thing to
3 that in terms of, I think maybe Jim or maybe Tom
4 would like to comment on it in terms of another
5 site that was clean and exists on top of an
6 aquifer, whether or not they would site it over an
7 aquifer, a disposal facility over an aquifer, I
8 believe they could answer the question or would
9 answer the question that, no, it probably wouldn't
10 be granted. I don't know if that was part of your
11 question.
12 MS. SCHDLTE: That's exactly what my
13 question is. If this was a different site, a new
14 site being looked at, this would not be considered
15 a good location for this because it's located over
16 an aquifer.
17 MR. JENKE: That's correct.
18 MS. NICKEL: The difference is we're
•19 taking already a bad situation, something that is
20 already at risk to the aquifer and trying to
21 improve it as opposed to trying to locate a new
22 commercial disposal facility.
23 MR. JENKE: Something that should be
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24 added to it is we could have provided the Ohio and
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1 I guess US, both Ohio and US could go along with
2 it, we could have proposed something such as a cap
3 that would not have required a waiver. What
4 requires a waiver is the fact we're digging it up,
5 putting it back down.
6 MS. SCHULTE: But that would not
7 have provided enough protection?
8 MR. JENKE: That would have been
9 less protective, certainly less protective than an
10 engineered disposal facility.
11 MS. NICKEL: And the big difference
12 is if you're a new commercial disposal facility,
13 you have options, you can go someplace else, you
14 don't have to locate over an aquifer. Because
15 we're already existing over the aquifer, we really
16 don't have a choice, we have to do something with
17 the facility we have at hand.
18 MR. STEGNER: Any more questions
19 before we break and reconvene for the formal part?
20 Let's take a 10-minute break now and
21 then we'll reconvene, we'll change the
22 configuration here.
23 (Brief recess.)
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24 MR. STEGNER: So far I only have two
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1 folks who have asked to enter comments into the
2 record tonight. Again, this is the formal part of
3 the evening where your comments will be entered
4 into the record. They will be responded to in the
5 responsiveness summary section of our document. We
6 would ask that for this part you use the microphone
7 if you want to speak, and state your name, and if
8 you have a written comment that you want to submit
9 also, please let me know and you can hand it to me
10 after your comments. • Also please remember that
11 this period lasts until the 31st of May, so if you
12 have comments you want to send me, fax to me
13 between now and then, please feel free to do so.
14 You do not have to speak tonight to have your
15 comments entered into the record.
16 So with that, Mr. Boudreau of the
17 Cincinnati Health Department has asked that I read
18 his comments, which I will do now. Mr. Boudreau
19 endorses land use objective one, full unrestrictive
20 use. This is the only means of insuring
21 environmental stability and protecting the Great
22 Miami Aquifer. The soil is contaminated with
23 uranium at 100 times background levels to a depth
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24 of 20 feet. The highest level, 8,000 parts per
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1 million, is 1600 times background level.
2 Contamination near processing facilities of acidic
3 uranium solutions is 400 parts per million, which
4 is 80 times background level. Another 11 square
5 miles which is approximately two times background
6 levels has all contributed to contamination of the
7 Great Miami Aquifer. The radioactive half life of
8 the uranium isotopes is 234 to 238 is 2.45 times 10
9 to the fifth to 4.46 times 10 to the ninth years
10 respectively (this is almost a million to many,
11 many millions of years). The contamination of
12 groundwater in the Great Miami Aquifer ranges from
13 50 parts per billion at the former production area
14 to 2100 parts per billion at South Field, a solid
15 waste disposal area. The highest projected
16 contamination levels in the aquifer will occur
17 within 1,000 years.
18 Consideration of Alternative 3A,
19 engineered disposal facility (on-site) will place
20 the Great Miami Aquifer at an unacceptable risk to
21 introduction of additional radioactive material
22 contamination over time.
23 I also have a comment, and the
4
24 gentleman had to leave, from Marvin W. Clawson.
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1 His comment: I agree with remedial action for
2 Operable Unit 5 is Alternative 3A. My concern is
3 the 300 foot area around disposal cell should be
4 planted in trees and fenced on outside of 300 foot
5 area so it would make it difficult for a trespasser
6 to enter the area. DOE should monitor area and be
7 responsible for upkeep of disposal cell forever.
8 I also have three other comments here
9 which I will now read into the record. I formally
10 submit the following comment --no name associated
11 with this. At a recent Fernald Citizens Task Force
12 meeting, Mr. Willeke brought up the issue that
13 Operable Unit 5 was using a proposed drinking water
14 standard for uranium. Mr. Willeke further noted
15 that the standard is expected to be finalized in
16 the next year and is anticipated to increase from
17 the current 20 parts per billio/i. I concur with
18 Mr. Willeke's position that the Operable Unit 5
19 decision should permit the adoption of the final
20 uranium drinking water standard when available.
21 This approach is consistent with the
22 recommendations of the task force and with the
23 spirit and intent of federal environmental
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24 regulations. Such an approach provides adequate
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1 protection to the aquifer and the public and would
2 save the government in excess of $150 million.
3 Such a savings must be taken seriously in these
4 times of financial crisis at the federal level.
5 Also attached, I formally submit the
6 following comment: During the Operable Unit 2
7 public meeting, a representative of Ohio EPA noted
8 that the disposal facility would not receive
9 hazardous waste. Of issue was soil containing lead
10 from a firing range.
11 At the October 15th Ohio EPA meeting,
12 representatives of the agency again recommended
13 that the public submit comments requesting a
14 prohibition of hazardous waste in the disposal
15 facility. For Operable Unit 5, again this appears
16 focused on.lead contaminated soil from a trap range
17 and possibly some other soils containing metals.
18 I question the sensibility of the
19 Ohio EPA position. It is inconceivable that a
20 disposal facility designed to contain uranium for
21 1000 years cannot be designed to address spent lead
22 bullets and other metals. The Ohio EPA position
23 presents an inconsistent message to the public. It
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24 cuts at the foundation of the disposal facility
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1 concept.; that of long-term performance.
2 At a recent Fernald Citizens Task
3 Force meeting, waste acceptance criteria for the
4 disposal facility were discussed. At this session
5 it was noted that criteria were being developed for
6 uranium and a series of other contaminants. It
7 would seem appropriate that these criteria address
8 lead and other metals.
9 In summary, I request that DOE
10 develop waste acceptance criteria for all
11 contaminants found in soil at the site. I further
12 request that soil received at the facility be
13 measured against these criteria, regardless of a
14 regulatory label (i.e., hazardous waste). This
15 will provide a consistent message to the public on
16 the disposal facility.
17 And, finally, I submit the following
18 comment: The Operable Unit 5 proposed plan notes
19 that treatment will be applied to wastewater and
20 groundwater streams such that the "blended"
21 concentration is less than the federal drinking
22 water standards. DOE needs to revise this
23 position.
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24 Why does DOE feel it necessary to
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1 spend hard earned taxpayer money to treat water for
2 drinking and then dump it to the river. This is
3 inconceivable in this time of shrinking budgets.
4 We all need to tighten our belts. Here we need to
5 simply abandon such an idea and treat only as
6 necessary to protect the river (fish, et cetera)
7 and recreational users of the river. Anybody using
8 the river for drinking (Note: I don't know of any)
9 would be required to treat the water anyway.
10 Those were submitted into the record
11 this evening.
12 Now I have a request by Tom Renck to
13 speak with Ross Area Merchants. Tom. You can use
14 this microphone here or that one there, either
15 one.
16 MR. RENCK: I'm Tom Renck, .I'm
17 representing the Ross Area Merchants. I have seven
18 points to make, and I am going to start off I think
19 with my conclusion, which I think this needs to be
20 taken as we're taking this whole thing, which is as
21 citizens we trusted this group to clean it up and
22 did not become actively involved until March 17th.
23 We now at that point found out that there was a
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24 cover-up, and we've wrote a letter and the
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1 merchants, which represents about 60 businesses in
2 the local area, are opposed to this cell. We don't
3 feel it's a good long-term solution.
4 You folks have been studying this for
5 two years. We're given 30 days to comment on this,
6 we don't feel that's long enough. This is one of
7 our busiest times in the year in this farming
8 community. Everybody is out in the fields tonight,
9 that's why there aren't people here that should
10 have been here. So we would like to have another
11 30 days to comment on this process.
12 We feel that the Citizens Task Force
13 is not representative of the local citizens. We
14 don't know where these folks came f±om. We
15 understood that a lot of the people tried to get on
16 here locally. We didn't have a lot of involvement
17 because we thought it was going to be cleaned up,
18 so we feel -that the Citizens Task Force does not
19 represent us fairly.
20 Seems to be an awful lot of jargon
21 used in this, Operable Unit Number 5, on-site
22 engineered disposal facility. We call this a dump,
23 and I think when all this information is being
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24 given out to people, they're getting very, very
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1 confused. I've involved about two months, and this
2 is the amount of material that I've received to
3 study, read, revise, look at. I mean this is not
4 my job, and I'm overwhelmed. I have another
5 cardboard box at home that I throw all this Fernald
6 information in, and it's about two or three foot
7 high of stuff that I can glean at and get rid up,
8 but we're just overwhelmed, we're wore out, and I
9 think that's part of the process, we get worn down
10 trying to understand what's going on in our
11 c ommuni ty.
12 Last week I attended a meeting that I
13 thought was important, same notification. Operable
14 Unit No. 5 deals with 9,800,000 cubic yards of
15 material. This thing dealt with 3,400 barrels of
16 material. It's just a drop in the bucket, but the
17 same process goes on, and the average citizen that
18 gets involved just gets overwhelmed, and we've run
19 out of time, we've run out of energy.
20 I have another document that has 30
21 comments about the document Operable Unit 5, so I'm
22 submitting the letter from the Ross Area Merchants
23 in opposition to this and my 30 comments in
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24 writing, and I will hand this to Gary when I get
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1 done.
2 MR. STEGNER: Thank you, Tom.
3 Do we have anyone else wanting to
4 speak. Edwa Yocum.
5 MS. YOCUM: Edwa Yocum, Crosby
6 Township resident, 9860 Hamilton Cleves Pike,
7 Harrison, Ohio. I live in Crosby Township, where
8 90 percent of the disposal cell will be in Hamilton
9 County. I support the alternative 3A. Also I have
10 other comments such as place at least a 300-foot
11 buffer zone around the entire disposal cell. Add a
12 10-foot chain link fence skirting the buffer zone,
13 so this would protect the trespassers.
14 No off-site waste for disposal at
15 Fernald. No long-term storage of off-site waste on
16 Fernald site.
17 Future ownership of Fernald site
18 should remain in the hands of the federal
19 government.
20 No characteristic hazardous waste
21 disposed in the cell, such as flammable, toxic, or
22 corrosive.
23 Groundwater should be remediated to
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24 the drinking water standard of 20 parts per billion
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1 or less.
2 We need real time monitoring.
3 Also continue to evaluate
4 technologies that would increase protection to
5 residents and community.
6 No dilution of waste to meet waste
7 acceptance criteria. Soils above 1030 to be
8 shipped off-site.
9 And I do support the US EPA's waiver
10 of siting criteria.
11 In conclusion, the Fernald site
12 beyond the disposal cell should become a wetland or
13 sanctuary, and I believe in the balance approach
14 for all DOE sites. Thank .you.
15 MR. STEGNER: Thank you, Edwa.
16 Anyone else care to offer -- Ann.
17 MS. SCHULTE: I'm Ann Schulte, I'm a
18 member of Ross Area Merchants Association and I am
19 also a resident of --
20 UNIDENTIFIED SPEAKER: We can't hear
21 you.
22 MS. SCHULTE: I'm Ann Schulte and I
23 am also a resident of Morgan Township and I am also
24 a member of Ross Area Merchants Association. I'm
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1 opposed to the public storage unit for two reasons,
2 my main reason is because it's stored over an
3 aquifer. We're talking about drinking the water
4 for a vast number of people, and I feel this is -a.
5 risk that doesn't need to be taken. I think we
6 have looked at convenience over the health and
7 safety of the community.
8 Also the other concern I have is once
9 this cell has been approved, how do we have the
10 control of allowing outside storage or outside
11 contaminants to come into the storage unit?
12 There's a part of it that will say it's been at
13 Fernald before, at some point it can come back here
14 again, and I don't want to be a dump site for the
15 rest of the community. Thank you.
16 MR. STEGNER: Thank you, Ann. Any
17 more comments tonight? Again be reminded that the
18 comment period is over on the 31st of May. Gary.
19 MR. STORER: I'm Gary Storer, Crosby
20 Township resident and trustee.
21 The northeast corner of the Fernald
22 site is a relatively uncontaminated zone, and my
23 idea is to locate the disposal cell --if there has
24 to be one, I've got some thoughts about that in a
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1 minute -- if there has to be a disposal cell, it
2 should be located over the production area. Waiver
3 should be -- we should seek a waiver to allow for
4 this to happen. The main reason I feel this way is
5 that could be usable, a usable strip from that
6 northeast corner south to Wiley Road, future use,
7 land uses for .township use or residents or
8 whatever.
9 Over the production area there's
10 already recovery measures in place to either clean
11 up contamination that might leak into the aquifer,
12 so those recovery measures are already in place.
13 Even though the northeast corner has a layer of
14 clay, I believe the layer of clay serves the same
15 purpose as the recovery measures that are already
16 in place over the production area.
17 I'm opposed to the on-site disposal
18 cell. I would be willing to take a risk of
19 shipping this stuff off-site until we're told we
20 cannot do so. There are sites willing to take the
21 contaminated materials. I also do not agree with
22 the transportation risk that I've been told is
23 associated with transporting this contaminated
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24 material off-site.
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1 I also heard rumors, I haven't been
2 able to trace down the facts yet, about shifting
3 the disposal cell southward farther into Crosby
4 Township. I certainly would be opposed to this
5 also. I think if a disposal cell is also located
6 on-site, that security needs to be beefed up
7 on-site. I know the security officers no longer
8 carry arms, firearms. I think that would be a
9 necessity due to the recent hostilities that we've
10 all heard about in the news directed toward the
11 federal government.
12 Thank you for this opportunity to
13 express myself.
14 MR. STEGNER: Thank you, Gary. I
15 think it's important to note that Tom did ask for
16 an extension of the comment period, and it's
17 something that we can't unilaterally do, Tom. We
18 will take it under advisement, and I would say the
19 chances are extremely good you will get your wish
20 on this, but I can't state it right now, but we
21 will get you a response to that very soon.
22 MS. CRAWFORD: Will you let us know
23 if they are going to indeed do that? That means we
•
24 don't have to spend Memorial Day writing these
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1 things.
2 MR. STEGNER: Absolutely, we will
3 let you know.
4 MR. REISING: We will make a
5 decision within a couple of days.
6 MR. STEGNER: By your meeting this
7 week you should know.
8 MR. SARIC: Yeah, you can go ahead
9 and take your 30 days.
10 MR. STEGNER: Thank you, Jim. That
11 was pretty simple. There's your approval authority
12 right there.
13 MS. CRAWFORD: So we have until June
14 30th now?
15 MR. SARIC: That's right, 30 plus
16 one.
17 MR. STEGNER: So enjoy your weekend
18 everyone. Do we have anymore individuals wanting
19 to comment? Yes, sir.
20 MR. KALLILE: My name is Jim
21 Kallile, I'm with the Ohio Department of Health. I
22 would like to say that based upon our point of
23 view, we also endorse the alternative for building
«
24 an on-site disposal cell, and we believe when you
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1 consider the risks and costs involved with
2 remediation of the entire site, we believe this is
3 the appropriate remedy.
4 MR. STEGNER: Thank you. Anyone
5 else right now?
6 Again, be reminded that now we have
7 until June 30th to get your comments in. And also
8 be reminded that the document, a form for comment
9 is included in the proposed plan summary which are
10 available in .the back of the room. I thank you all
11 for coming tonight. We appreciate your input. It
12 is very valuable to us and all your comments will
13 be responded to in the responsiveness summary.
14 Thank you all very, very much. Be
15 careful going home.
16 -
17 PUBLIC MEETING CONCLUDED
18 - - -
19
20
21
22
23
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24
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1 CERTIFICATE
2 I, LOIS A. ROELL, RPR, the undersigned, a
3 notary public-court reporter, do hereby certify
4 that at the time and place stated herein, I
5 recorded in stenotypy and thereafter had
6 transcribed with computer-aided transcription the
7 within (58) fifty-eight pages, and that the
8 foregoing transcript of proceedings is a complete
9 and accurate report of my said stenotypy notes.
10
11
12
13 MY COMMISSION EXPIRES: LOIS A. ROELL, RPR
14 AUGUST 12, 1997. NOTARY PUBLIC-STATE OF OHIO
15
16
17
18
19
20
21
22
23
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APPENDIX B
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS AND
TO BE CONSIDERED REQUIREMENTS FOR OPERABLE UNIT 5
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TABLE OF CONTENTS
List of Acronyms
Foreword
B-ii
B-iv
Table B.I Chemical-Specific Requirements for the Operable Unit 5 Selected Remedy B.l-1
Table B.2 Location-Specific Requirements for the Operable Unit 5 Selected Remedy B.2-1
Table B.3 Action-Specific Requirements for the Operable Unit 5 Selected Remedy B.3-1
Table B.4.A Method of Compliance with Chemical-Specific ARARs for the Operable
Unit 5 Selected Remedy B.4.A-1
Table B.4.B Method of Compliance with Location-Specific ARARs for the Operable
Unit 5 Selected Remedy B.4.B-1
Table B.4.C Method of Compliance with Action-Specific ARARs for the Operable
Unit 5 Selected Remedy B.4.C-1
FER\CRU5\MCM\ROD\APPX-B.ROD\December 11, 1995 2:SSpm
B-i
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LIST OF ACRONYMS
AEA Atomic Energy Act
ALARA as low as reasonably achievable
ARAR applicable or relevant and appropriate requirement
AWWT advanced wastewater treatment [facility]
BAT best available technology
BUSTR Bureau of Underground Storage Tank Regulations
CAA Clean Air Act
CAMU corrective action management unit
CEDE committed effective dose equivalent
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COC constituent of concern
CWA Clean Water Act
DCG derived concentration guide
DFO director's findings and orders
DOE U. S. Department of Energy
DOT U. S. Department of Transportation
EPA U. S. Environmental Protection Agency
FEMP Fernald Environmental Management Project
FHBM flood hazard boundary maps
FIRM flood insurance rate maps
GMA Great Miami Aquifer
HWMU hazardous waste management unit
LDR land disposal restriction
MCL maximum contaminant level [under SOW A]
MCL maximum concentration limit [under RCRA]
MCLG maximum contaminant level goal [under SDWA]
MTR minimum technology requirements
NAAQS National Ambient Air Quality Standards
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEPA National Environmental Policy Act
NESHAP National Emission Standards for Hazardous Air Pollutants
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
NRC Nuclear Regulatory Commission
NTS Nevada Test Site
NWP Nationwide Permit [Program]
FER\CRU5\MCM\ROD\APPX-B.ROD\December 11. 1995 2:55pm
B-ii
-------
LIST OF ACRONYMS (Continued)
OAC Ohio Administrative Code
OEPA Ohio Environmental Protection Agency
ORC Ohio Revised Code
OU5 Operable Unit 5
PAH polycyclic aromatic hydrocarbon
PCB polychlorinated biphenyl
pCi picocurie
ppb parts per billion
ppm parts per million
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SCS Soil Conservation Survey
SDWA Safe Drinking Water Act
SHPO State Historic Preservation Office
SOWC Southwestern Ohio Water Company
SSOD storm sewer outfall ditch
STP site treatment plan
SWMU solid waste management unit
TBC to be considered
TSCA Toxic Substances Control Act
TU temporary unit
UMTRCA Uranium Mill Tailings Radiation Control Act
UST underground storage tank
VOC volatile organic compound
WAC waste acceptance criteria
FER\CRU5\MCM\ROD\APPX-B.ROD\December 11. 1995 2:55p«n B-iii
-------
FEMP-05ROD-6 FINAL
December 15, 1995
FOREWORD
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED REQUIREMENTS FOR OPERABLE UNIT 5
The tables in this appendix identify the chemical-, location-, and action-specific applicable or relevant
and appropriate requirements (ARARs) for Operable Unit 5; two types of tables are provided for
each.
The first type (Tables B.I, B.2 and B.3) identifies the regulations that are ARARs or to be considered
(TBC) criteria for the anticipated Operable Unit 5 remedial activities at the FEMP, and includes: 1)
an explanation of what the requirement is about, 2) identification as an ARAR or TBC, and 3) why it
is an ARAR or TBC. Note that the requirements column in these tables provides only a summary;
the regulation, statute, or Federal Register citation listed in the tables should be consulted for a full
description of the requirement.
The second type (Tables B.4.A through B.4.C) summarizes the methods of compliance with the
requirements for the Operable Unit 5 selected remedy. TBCs (proposed requirements) are not
included hi these tables because they are not ARARs. Therefore, they are not used to determine if
the selected remedy will be in compliance with environmental regulations.
FmCRU5\MCM\ROD\APPX-B.ROD\December 11, 1995 4:35pm
-------
-------
FEMP-05ROD-3 FINAL
December 15, 1995
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
I
Groundnater Standard; (Uranium Mill Tailings Radiation Control Act)
Groundwater Standards for
Remedial Actions at
Inactive Uranium
Processing Sites
40CFR §192.02(a)(3)
The following are drinking water standards for processed and unprocessed uranium mill
tailings:
Uranium (234+238) , 30 pCi/L
Molybdenum 0.1 mg/L
Relevant and
Appropriate
These standards are relevant and appropriate
because uranium mill tailings were processed
at the FEMP. Compliance with standards set
for other constituents under this requirement
will be met through the Safe Drinking Water
Act as prescribed by the NCP.
MCLs and MCLGs for Volatile Organic Contaminants (Safe Drinking Water Act)
a
EPA National Primary
Drinking Water Standards
for MCLOs
40CFR §141. Hand
§141.50
EPA National Primary
Drinking Water Standards
for MCLs
40CFR §141.61
Ohio Drinking Water
Regulations for MCLs
OAC 3745-81-12
The following are the nonzero federal maximum contaminant level goals (MCLG) and State
of Ohio and federal maximum contaminant levels (MCL) for volatile organic contaminants
in mg/L:
Benzene
Carbon tetrachloride
Chloroform
Dibromochloropropane (DBCP)
Dichloroethane (1,2-)
Dichloroethylene (1,1-)
Dichloromethane
Dichloropropane (1,2-)
Ethylbenzene
Monochlorobenzene
Styrene
Toluene
Trichloroethane (1,1,1-)
Trichloroethane (1,1,2-)
Trichloroethylene
Vinyl chloride
Xylenes
Federal
MCLG
(mg/L)
0.007
0.7
0.1
0.1
1
0.2
0.003
10
Federal or
Ohio MCL
(mg/L)
0.005
0.005
0.1/0.08
0.0002
0.005
0.007
0.005
0.005
0.7
0.1
0.1
1
0.2
0.005
0.005
0.002
10
Relevant and
Appropriate
This requirement is not applicable to OU5
activities because there are no public drinking
water systems involved with this remediation.
The MCLs and nonzero MCLGs are
considered relevant and appropriate to the
GMA as it is a sole-source aquifer currently
used to supply drinking water to the regional
area.
Where the State of Ohio standard is more
stringent than the federal standard, the Ohio
standard is presented.
- = Represents a MCLG of zero.
Only nonzero MCLGs are pertinent per
CERCLA.
-------
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
MCLs and MCLGs for Semivolatife Organic Contaminant? (Safe Drinking Water Act)
EPA National Primary
Drinking Water
Regulations for MCLGs
and MCLs
40CFR 141.11
40CFR 141.51
40CFR 141.62
Ohio Drinking Water
Regulations
OAC 3745-81-11
OAC 3745-81-23
The following are the federal maximum contaminant
and federal maximum contaminant
mg/L.
Benzo(a)pyrene (PAH)
Dichlorobenzene o-
Dichlorobenzene m-
Dichlorobenzene p-
Hexachlorobenzene
Hexachlorocyclopentadiene
Pentachlorophenol
2,3,7,8-TCDD(Dioxin)
Trichlorobenzene (1,2,4)
levels (MCL) for
Federal
MCLG
(mg/L)
-
0.6
0.6
0.075
-
0.05
-
-
0.07
level goals (MCLG) and State of Ohio
semivolatile organic contaminants in
Federal or
Ohio MCL
(mg/L)
0.0002
0.6
0.6
0.075
0.001
0.05
0.001
3E-08
0.07
Relevant and
Appropriate
This requirement is not applicable to OU5
activities because there are no public drinking
systems involved with this remediation. The
MCLs and MCLGs are considered relevant
and appropriate to the GMA as it is a
sole-source aquifer currently used to supply
drinking water to the regional area.
- = Represents a MCLG of zero.
Only nonzero MCLGs are pertinent per
CERCLA.
CO
Proposed MCLs and MCLGs for Semlrolatile Organic Contaminants (Safe Drinking Water Act)
55 Federal Register 30370
(July 25,1990)
The following are proposed nonzero federal maximum contaminant level goals (MCLG) and
maximum contaminant levels for semivolatile organic contaminants in mg/L:
Federal
MCLG
(mg/L)
Benzo(a)anthracene (PAH)
Benzo(b)fluoranthene (PAH)
Benzo(k)fluoranthene (PAH)
Bromodichloromethane
Butyl benzyl phthalate (PAE)
Chloroform
Chrysene (PAH)
Dibenz(a,h)anthracene (PAH)
Hexachlprobutadiene
Indenol(l,2,3,-c,d)pyrene (PAH)
0.001
Federal or
Ohio MCL
(mg/L)
0.0001
0.0002
0.0002
0.1/0.08
0.1
0.1/0.08
0.0002
0.0003
NA
0.0004
TBC
These proposed MCLs are not ARARs
because they are not promulgated. The
proposed MCLs have been adopted as TBCs
because they represent health-based guidance
for application to the GMA to ensure
protectiveness of human health.
- = Represents a MCLG of zero.
Only nonzero MCLGs are pertinent per
CERCLA.
NA = Not Available
a- O
o a
-------
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
MCI* amf MCMJs for PesticMes/PCB Contaminants (Safe Drinking Water Act, continued.,.)
EPA National Primary
Drinking Water
Regulations for MCLGs
and MCLs
40CFR 141.11
40 CFR 141.51
40CFR 141.62
Ohio Drinking Water
Regulations
OAC 3745-81-11
OAC 3745-81-23
The following are the nonzero federal
maximum contaminant level goals (MCLG) and State
of Ohio and federal maximum contaminant levels (MCL)
in mg/L.
Adipate (diethylbexyl)
Aroclor
Atrazine
Chlordane
Endrin
Heptachlor
i Heptachlor epoxide
Lindane
Methoxychlor
Polychlorinated biphenyls (PCBs)
Toxaphene
Federal
MCLG
(me/L)
0.4
-
0.003
-
-
-
-
0.0002
0.04
-
™
for pesticides/PCB contaminants
Federal or
Ohio MCL
(me/L)
0.4
0.002
0.003
0.002
0.0002"
0.0004
0.0002
0.0002
0.04
0.0005
0.003
Relevant and
Appropriate
This requirement is not applicable to OU5
activities because there are no public drinking
systems involved with this remediation. The
MCLs and MCLGs are considered relevant
and appropriate to the GMA as it is a
sole-source aquifer currently used to supply
drinking water to the regional area.
tt= Ohio Drinking Water MCL
- = Represents a MCLG of zero.
Only nonzero MCLGs are pertinent per
CERCLA.
NA - Not Available
w
MCLs and MCLGs for Herbicide Contaminants (Safe Drinking Water Act)
EPA National Primary
Drinking Water
Regulations for MCLGs
and MCLs
40 CFR 141.11
40 CFR 141.51
40 CFR 141.62
Ohio Drinking Water
Regulations
OAC 3745-81-11
OAC 3745-81-23
The following are the nonzero
of Ohio and federal maximum
mg/L.
2,4-D
Dinoseb
2,4,5-TP
federal maximum contaminant
contaminant levels (MCL) for
Federal
MCLG
(mg/L)
0.07
0.007
0.05
level goals (MCLG) and State
herbicide contaminants in
Federal or
Ohio MCL
(mg/L)
0.07
0.007
0.01tt
Relevant and
Appropriate
This requirement is not applicable to OU5
activities because there are no public drinking
systems involved with this remediation. The
MCLs and MCLGs are considered relevant
and appropriate to the GMA as it is a
sole-source aquifer currently used to supply
drinking water to the regional area.
tt = Ohio Drinking Water MCL
-------
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
MCLs and MCLGs for Inorganic Contaminants (Safe Drinking Water Act, continued,,.)
EPA National Primary
Drinking Water
Regulations for MCLGs
and MCLs
40CFR141.il
40 CFR 141.51
40CFR 141.62
Ohio Drinking Water
Regulations
OAC 3745-81-11
OAC 3745-81-23
The following are the federal nonzero maximum contaminant
of Ohio and federal maximum
mg/L.
Antimony
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Thallium
contaminant levels (MCL) for
Federal
MCLO
(me/L)
0.006
2
0.004
0.005
0.1
1.3
-
0.002
0.1
0.05
0.0005
level goals (MCLG) and State
inorganic contaminants in
Federal or
Ohio MCL
(mg/L)
0.006
2
0.004
0.005
0.05"
TT
TT
0.002
0.1
0.01
0.002
Relevant and
Appropriate
This requirement is not applicable to OU5
activities because there are no public drinking
systems involved with this remediation. The
MCLs and MCLGs are considered relevant
and appropriate to the GMA as it is a
sole-source aquifer currently used to supply
drinking water to the regional area.
tt = Ohio Drinking Water MCL
TT = Copper - action level 1 .3 mg/L; Lead -
action level 0.0 15 mg/L.
- = Represents a MCLG of zero.
Only nonzero MCLGs are pertinent per
CERCLA.
i
Proposed MCLs and MCLGs for Inorganic Contaminants (Safe Drinking Water Act)
EPA National Primary
Drinking Water
Regulations for MCLGs
and MCLs
40 CFR 141.11
40 CFR 141.51
40 CFR 141. 62
Ohio Drinking Water
Regulations
OAC 3745-81-11
OAC 3745-81-23
The following are the proposed federal nonzero maximum contaminant level goals (MCLG)
and State of Ohio and federal maximum
contaminants in mg/L.
Arsenic
Cyanide
Silver
contaminant
Federal
MCLG
(mg/L)
NA
0.2
0.05
levels (MCL) for inorganic
Federal or
Ohio MCL
(mg/L)
0.05
0.2
0.05
Relevant and
Appropriate
This requirement is not applicable to OU5
activities because there are no public drinking
systems involved with this remediation. The
MCLs and MCLGs are considered relevant
and appropriate to the GMA as it is a
sole-source aquifer currently used to supply
drinking water to the regional area.
NA = Not Available
1
yo
8
-------
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
o
13
8
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AN
Citation Requirement ARAR/TBC Rationale
MCLs for Resource Conservation and Recovery Mt, Subtitle C and D
Chemicals in Drinking
Water (Solid Waste
Disposal Facility)
40 CFR 257.4
Ohio Solid Waste
Regulations
OAC 3745-27-1 0(D)
Chemicals in Drinking
Water (Hazardous Waste
Disposal Facility)
40 CFR 264.94
Ohio Hazardous Waste
Regulations
OAC 3745-54-94
A solid waste disposal facility shall not contaminate an underground drinking water source
beyond the solid waste boundary (outermost perimeter, of the waste). The concentration of
chemicals shall not exceed background levels or listed MCLs, whichever is higher.
A hazardous waste disposal facility must comply with the requirements specified in the
facility permit for the uppermost aquifer underlying the waste management area beyond the
point of compliance, which is a vertical surface located at the hydraulically downgradient
limit of waste management that extends down into the uppermost aquifer underlying the
regulated area. The concentration of chemicals in groundwater shall not exceed background
levels or the listed maximum concentration level (MCL) of the constituent for groundwater
protection, whichever is higher.
Solid Waste Hazardous Waste
RCRA MCL RCRA MCL
Inorganic Chemicals (mg/L) (mg/L)
Arsenic 0.05 0.05
Barium 1.00 1.00
Cadmium 0.01 ' 0.01
Chromium 0.05 0.05
Lead 0.05 0.05
Mercury 0.002 0.002
Selenium 0.01 0.01
Silver ' 0.05 0.05
Organic Chemicals
Benzene .005 NA
Carbon tetrachloride .005 NA
1,2-Dichloroethane .005 NA
1,1-Dichloroethene .007 NA
Trichloroethylene .005 NA
Radionuclides
Combined Ra-226 & Ra-228 5 pCi/L
Gross alpha particle activity 15 pCi/L
(excluding radon & uranium)
Relevant and
Appropriate
40 CFR 257.4and 40 CFR 264.94and their
Ohio equivalents are relevant and appropriate
because OU5 contains several of the
chemicals listed in the regulation.
Compliance with the MCLGs and MCLs
under the Safe Drinking Water Act (SDWA)
will assure compliance with these RCRA
MCLs as discussed in the NCP. The RCRA
MCLs reflect earlier versions of the SDWA
but the intent is to follow the updated
standards of the SDWA (Compliance With
Other Laws Manual).
NA = Not Available
1
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a
~2
-------
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
SURFACE WATER
Discharges of Liquid Waste to Surface Waters
Ohio Water Quality
Standards
OAC 3745-1-04
"Five Freedoms" for Surface Water are provided by the State of Ohio:
All surface waters of the State shall be free from:
• Objectionable suspended solids
• Floating debris, oil and scum
• Materials that create a nuisance
• Toxic, harmful or lethal substances
• Nutrients that create nuisance growth
Relevant and
Appropriate
OAC 3745-l-04pertains to both discharges to
surface waters of the State as a result of
remediation and any on-site surface waters
affected by site conditions.
Use Designation of Surface Water
Ohio Water Quality
Standards
OAC 3745-1-21
Paddys Run and the Great Miami River are designated as:
• Warm water aquatic life habitat
• Agricultural and industrial water supply
• Primary contact recreation
V*
Applicable
The Great Miami River between Ross Road
[River Mile (RM)95.7] to Taylorsville Dam
(RM 92.6) is a state resource water and RM
130 and 118 are public water supplies.
Discharges to the Great Miami River and
Paddys Run must not cause a violation of
applicable numeric or narrative water quality
standards for these designations.
-------
I
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
o
g Citation
O
§
&
g Ohio Water Quality
j> Standards
w
? OAC 3745-1-07
i
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W
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Surface waters in the State
Requirement ARAR/TBC Rationale
Warm Water HaWtat Water Quality Criteria
of Ohio must comply with the maximum concentrations of each
contaminant listed below for inside and outside the mixing zones of the receiving water to
protect warm water aquatic
habitats. "Outside Mixing Zone" shall be met after the effluent
and the receiving water have been determined to be reasonably well mixed based upon
information readily available to the Director. The criteria listed as "Inside Mixing Zone
Maximum" shall be applicable as end-of-pipe maximum effluent limits or as criteria to be
met within a short distance
of the effluent pipe if it can be demonstrated that discharge-
induced mixing occurs as per the definition of "area of initial mixing" in rule OAC 3745-1-02.
Parameter (ftg/L
or as marked)
Antimony (total)
Arsenic
Benzene
Beryllium (total)
Bis(2-ethylhexyl)
phthalate
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chromium
Chloroform
2-Chlorophenol
Copper (total)
Cyanide (free)
1 ,2-Dichloroethane
Dieldrin
Outside Mixing Inside Mixing
Zone Zone
Max. 30-Dav Ava. Max.
650 190 ' 1,300
360 190 720
1,100 560 2,100
520 23 1,000
1,100 8.4 2,200
5.6 1.4 11
1,800 280 3,500
NA 0.01 NA
590 26 1,200
1,800 210 3,600
1,800 79 3,600
200 8.8 400
18 12 35
46 12 92
12,000 3,500 24,000'
NA 0.005 NA
Applicable
OAC 3745-l-07is applicable because the site
is bordered by the Great Miami River and
Paddys Run.
NA = Not Available
Beryllium is based on a presumed water
hardness of lOOmg/L calcium carbonate
CaCOy
1
Copper is based on a presumed water Q T
hardness of lOOmg/L CaCOj. g Si
1- O
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P> 3
s >
-------
n
§
o
a
I
I
Citation
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Requirement
ARAR/TBC
Rationale
-
Parameter (fg/L
or as marked)
Lead (total)
Mercury (total)
Methylene chloride
Nickel (total)
Pentachlorophenol
PCBs
Selenium (total)
Silver (total)
Tetrachloroethylene
Trichloroethylene
Thallium (total)
Zinc (total)
Outside
Zone
Max.
130
1.1
9,700
1,600
5.3
NA
20
1.6
540
1,700
71
120
Mixing
30-Dav Ave.
6.9
0.2
430
170
3.2
0.001
5.0
1.3
73
75
16
110
Inside Mixing
Zone
Max.
260
2.2
19,000
3,100
11
NA
40
3.2
1,100
3,400
140
230
Lead is based on a presumed
of 100 mg/L CaCO y
water hardness
Nickel is based on a presumed water hardness
of 100 mg/L CaCO 3.
Silver is based on a presumed
of 100 mg/L CaCO j
Zinc is based on a presumed
of 100 mg/L CaCO y
.
water hardness
water hardness
a- O
12
-------
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
Human Health and Agricultural Water Snpply Criteria
Ohio Water Quality
Standards
OAC 3745-1-07
•
See previous requirement for
explanation of inside/outside
mixing zones. The maximum
(outside mixing zone) concentrations for contaminants listed below are based on the
designated use of the surface
Parameter (MS/L
or as marked)
Antimony (total)
Arsenic
Benzene
Beryllium (total)
beta-BHC
Bis(2-ethylhexyl) phthalate
Cadmium
Carbon tetrachloride
Chromium (total)
Copper (total)
1 ,2-Dichloroethane
Dieldrin
Fluoride (mg/L)
Lead (total)
Mercury (total)
Nickel (total)
N-Nitrosodi-n-propylamine
PCBs
PAHs
Selenium (total)
Thallium (total)
Vinyl chloride
Zinc Total
water body as Human Health
or Agricultural.
Outside Mixing Zone 30-Day Average
Human Health
4,300
NA
710
1.17
0.55
59
NA
44
3,433,000
NA
990 »*
0.00076
NA
NA
0.012
4,600
12.4
0.00079
0.31
NA
48
5,250
NA
Agricultural
NA
100
NA
100
NA
NA
50
NA
100
500
NA
NA
2.0
100
10
200
NA
NA
NA
50
NA
NA
25,000
Applicable
OAC 3745-l-07is applicable because the site
is bordered by the Great Miami River and
Paddys Run.
NA = Not Available
•
1
O *P
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8-
-------
n
S
TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
Human Health and Agricultural Water Supply Criteria (Continued.,.)
i
Management and Control
of Radioactive Materials in
Liquid Discharges
DOE Order 5400.5
Chapter II, (3)
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter H (3)(a)
10 CFR 834 (PROPOSED)
In addition to the requirements to limit dose to members of the public (on site and off site)
in accordance with the standards established in paragraphs n (l)(a) and II (l)(d), further
controls are imposed on liquid releases to protect resources such as surface water. Derived
concentration guides (DCGs) are not release limits, but rather are screening values for
considering best available technology (BAT) for these discharges and for making dose
estimates. These requirements apply at the point of discharge from the conduit to the
environment (see DCGs in DOE Order 5400.5 Chapter ffl (3) ).
The BAT is the prescribed level of treatment for liquid radioactive discharges to surface
water that would otherwise contain radioactive concentrations greater than the DCG values.
Implementation of the BAT process is not required for waste streams that contain
radionuclide concentrations of not more than the DCG values at the point of discharge to a
surface waterway.
Residual concentrations of radionuclides in water that may be ingested are listed in tabular
form in DOE Order 5400.5 Chapter ffl. The DCGs for the COCs are based on a committed
effective dose equivalent (CEDE) of 100 mrem/yr, assuming ingestion of 2 liters/day. Note
that these DCGs apply only if ingestion is the single pathway of exposure.
TBC
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential to result in
exposure to members of the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
DOE Order 5400.5 Chapter
II (3)(a)(5)
10 CFR 834 (PROPOSED)
The absorbed dose to native aquatic animal organisms shall not exceed 1 rad per day from
exposure to the radioactive material in liquid wastes discharged to natural waterways.
TBC
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential to result in
exposure to members of the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
I RADIATION LIMITS
1°
Dose Limits for Individual Members of the Public
Ohio General Radiation
Protection Standards
OAC 3701-38-15 (A)(1),(B)
DOE Order 5400.5 Chapter
II (l)(a)
10 CFR 834 (PROPOSED)
Operations causing air emissions shall be conducted such that:
• The total effective dose equivalent to individual members of the public from
the operation does not exceed 0.1 rem (100 mrem) in a year
• The dose in any unrestricted area from external sources does not exceed 0.002
rem (2mrem) in any one hour
Relevant and
Appropriate
This OAC standard is not applicable because
it applies to radiation sources which are not
regulated by the U.S. Atomic Energy Act
authority.
However, this standard is relevant and
appropriate because of the potential to result
in the exposure to members of the public.
NESHAP 40 CFR 61.91 will assure
compliance with the first bullet. The second
bullet is not found in NESHAP or in DOE
Orders.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
Radiation Dose Limit
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter II (1)
DOE Order 5400.5,
Chapter II (l)(a)
DOE Order 5400.5,
Chapter II (l)(a)(3)
10 CFR 834 (PROPOSED)
The public dose limits include consideration of all exposure modes from all DOE activities
(including remedial activities). The radiation dose limit is the sum of the effective dose
equivalent (weighted summation of doses to various organs of the body) from exposures to
radiation sources external to the body during the year plus the committed effective dose
equivalent from radionuclides taken into the body during the year. Medical sources,
consumer products, residual fallout from past nuclear accidents and weapons tests and
naturally occurring radiation sources are not included in this summation.
The exposure of members of the public to radiation sources as a consequence of all routine
DOE activities shall not cause, in a year, an effective dose equivalent of more than 100
mrem for all exposure pathways.
If unusual circumstances affect a DOE activity in such a manner that the potential public
dose could exceed an effective dose equivalent of 0.1 rem (100 mrem) in a year, DOE may
authorize a temporary increase of the dose limit up to 0.5 rem (500 mrem).
TBC
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential to result in
exposure to members of the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
a ?
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
Dose Limits for Individual Members «f the Public, Continued.,.
As Low As Reasonably
Achievable (ALARA)
DOE Order 5400.5
Chapter II, 2.
10 CFR 834 (PROPOSED)
Field elements shall develop a program and shall require contractors to implement an
ALARA process for DOE activities and facilities that have the potential to cause radiation
exposure to the public.
TBC
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential to result in
exposure to members of the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
STORAGE OF RADIOACTIVE MATERIAL
'_ Control of Residual
§ Radioactive Material
f DOE Order 5400.5
Chapter IV (6)(b)
CO
^ 10 CFR 834 (PROPOSED)
Interim storage must provide:
1) Control and stabilization features shall be designed to provide, to the extent
reasonably achievable, an effective life of 50 years with a minimum life of at least 25
years.
2) Controls shall be designed such that radon-222 concentrations in the atmosphere
above facility surfaces or openings in addition to background levels, will not exceed:
(a) 100 pCi/L at any given point;
(b) An annual average concentration of 30 pCi/L over the facility site; and
(c) An annual average concentration of 3 pCi/L at or above any location outside the
facility site.
(d) Flux rates from the storage of radon producing wastes shall not exceed 20
pCi/m ^sec, as required by 40 CFR Part 61.
3) Controls shall be designed such that concentrations of radionuclides in the
groundwater and quantities of residual radioactive material will not exceed applicable
federal or state standards.
4) Access to a property and use of on-site material contaminated by residual radioactive
material should be controlled through appropriate administrative and physical controls
such as those described in 40 CFR Part 192. These control features should be
designed to provide, to the extent reasonable, an effective life of at least 25 years.
TBC
The selected remedy will provide for the
interim storage of contaminated materials.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
STORAGE QF RADIOACTIVE MATERIAL (Continued)
Control of Residual
Radioactive Material
DOE Order 5400.5
Chapter IV (6)(d)
10 CFR 834 (PROPOSED)
1) Long-term management of uranium, thorium, and their decay products must provide:
(a) Control and stabilization features designed to provide, to the extent reasonably
achievable, an effective life of 1000 years with a minimum life of at least 200 years.
(b) Control and stabilization features designed to limit radon-222 emanation to the
atmosphere from the wastes to less than an annual average release rate of 20
pCi/m 7sec and prevent increases in the annual average radon-222 concentration
at or above any location outside the boundary of the contaminated area by more
than 0.5 pCi/L. Field verification of emanation rates shall be in accordance with
the requirements of 40 CFR Part 61.
(c) A long-term management facility for any potentially biodegradable contaminated
wastes properly conditioned so that the generation and escape of biogenic gases
will not cause the requirement in paragraph IV.6d(l)(b) to be exceeded and that
biodegradation within the facility will not result in premature structural failure in
violation of the requirements in paragraph IV.6d(a).
(d) Groundwater protection in accordance with legally applicable federal and state
standards.
(e) Access to a property and use of on-site material contaminated by residual
radioactive material controlled through appropriate administrative and physical
controls such as those described in 40 CFR Part 192 for uranium mill tailings
designed to be effective to the extent reasonable for at least 200 years.
2) In addition, long-term management of other radionuclides shall be in accordance with
Chapters 0, ffl, and IV of DOE 5820.2A,as applicable.
TBC
The long term management of radioactive
materials will be necessary under the selected
remedy. DOE orders are not ARARs
because they are not promulgated. This
DOE order is a TBC because the selected
remedy has the potential to result in exposure
to members of the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
I
1°
I
I
AIR
National Emissions Standards for Emissions of RadionucBdes Other than Radon From DOE Facilities
National Emission
Standards for Hazardous
Air Pollutants
40CFR §61.190,61.192
Subpatt Q
No source at a DOE facility shall emit more than 20 pCi/m ^sec of radon-222 as an average
for the entire source into the air.
Applicable
This requirement is applicable because the
FEMP presently and/or will continue to be a
storage and disposal facility for radium-
bearing material. This requirement explicitly
includes the FEMP in its designation of
facilities.
W
i
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National Emission
Standards for Hazardous
Air Pollutants
40CFR §61.90,61.9land
61.92- .97
Subpatt H
These requirements are applicable to DOE-owncd and operated facilities that emit any
radionuclides other than radon-222 and radon-220 into the air.
Emissions of radionuclides (except radon-220 and radon-222) to the ambient air from DOE.
facilities shall not exceed those amounts that would cause any member of the public to
receive in any year an effective dose equivalent of 10 mrem/yr.
To determine compliance with the standard, radionuclide emissions shall be determined and
effective dose equivalent values to members of the public calculated using EPA-approved
sampling procedures, computer models CAP-88 or AIRDOS-PC, or other procedures for
which EPA has granted prior approval.
Applicable
The selected remedy has the potential to
release radionuclides to the atmosphere
through fugitive dust and/or point source
emissions.
Control of Radon Emissions
Health and Environmental
Protection Standards for
Uranium and Thorium Mill
Tailings
40 CFR §192.06(b)
Subpart A
40 CFR §192.32(b)(l)(ii)
Subpart D
National Emission
Standards for Hazardous
Air Pollutants,
Radon-222 Emissions
40 CFR 61,
Subpart Q
The following standards apply to the:
• Control of residual radioactive materials from inactive uranium processing sites.
• Management of uranium byproduct materials after closure of a disposal area.
• Long-term management of uranium, thorium, and their decay products.
Controls shall be designed to provide reasonable assurance that releases of radon-222 from
the above materials to the atmosphere will not:
• Exceed an average release rate of 20 pCi/m 7sec (averaged over the entire surface
of the disposal site and over at least a one-year period).
Increase the annual average concentration of radon-222 in air or above any
location outside the disposal site by more than 0.5 pCi/L.
Relevant and
Appropriate
Radioactive materials in this operable unit
are a result of releases from uranium
processing. Contaminated soil and sediment
are similar in characteristic to materials
addressed by these regulations.
Requirements for design of controls for on-
property disposal should be consistent with
design for control of other residual
radioactive materials such as mill tailings.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
AIR EMISSION STANDARDS
Lead in Air
EPA Regulations on
National Primary and
Secondary Ambient Air
Quality Standards
40CFR 50.12
Ohio Ambient Air Quality
OAC 3745-17-08
Lead and its compounds measured as elemental lead should not exceed 1.5 micrograms per
cubic meter, maximum arithmetic mean averaged over a calendar quarter.
Relevant and
Appropriate
The federal regulation at 40CFR 50.12 is
relevant and appropriate because it sets a
standard for lead in air and lead has been
identified as a contaminant of concern at
OU5. The selected remedy has a potential
to release quantities of lead-bearing soil as
fugitives during excavation and disposal
operations. Additionally, lead could be a
contaminant in paniculate emissions from
point source discharges from sludge
dewatering and soil treatment/stabilization.
8
to
W
Definition of Derived
Concentration Guides for
Radionuclides
DOE Order 5400.5
Chapter in
10 CFR 834 (PROPOSED)
The derived concentration guides (DCGs) are provided as reference values for conducting
radiological environmental protection programs at operational DOE facilities and sites.
• Ingestion of water
• Inhalation of air
• Immersion in a gaseous cloud
The DCG values for internal exposure are based on a committed effective dose equivalent of
100 mrem for the radionuclide taken into the body by ingestion or inhalation during one
year.
The DCG values account for only three exposure pathways (ingested water or. inhaled air or.
air immersion) and do not include other potentially significant pathways. When more
complex environmental pathways are involved, a more complete pathway analysis is required
for calculating public radiation doses resulting from the operation of DOE facilities.
TBC
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential of remedial
actions to result in exposure to members of
the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
AIR EMISSION STAKfDAKDS (Cantawd)
Derived Concentration
Guides for Radionuclides
DOE Order 5400.5
Chapter HI, 3
10 CFR 834 (PROPOSED)
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter III
10 CFR 834 (PROPOSED)
The DCGs are given for different lung retention classes (noted as D,\V, or Y, where D
equals a removal half-time of 0.5 days, W equals a removal half-time of 50 days, and Y
equals a removal half-time of 500 days).
Derived Concentration Guide
ISOTOPE iCi/mL D W Y
Uranium-235 5 x 1012 2 x 1012
Uranium-236 5 x 1012 2 x 1012
Uranium-238 5 x 1012 2 x 1012
1 x 1013
1 x 1013
1 x 1013
Exposure conditions assume an inhalation rate of 8400m3 of air per year (based on an
exposure over 24 hours per day, 365 days per year).
Residual concentrations of radionuclides in air in an uncontrolled area are limited to the
following (for known mixtures of radionuclides, the sum of the ratios of the observed
concentration of each radionuclide to its corresponding limit must not exceed 1.0).
Derived Concentration Guide
ISOTOPE KCt/mL D W Y
Actinium-227 2 x 101S 7 x 1015
Lead 9 x 1013 —
Polonium-210 1 x 1012 1 x 1012
Protactinium-231 — 9xl015
Radium-224 — 4xl012
Radium-226 — 1 x 1012
Radium-228 — 3xl012
Technetium-99 1 x 108 2 x 109
Strontium-90 5 x 10 u —
Thorium-228 — SxlO14
Thorium-230 — 4xl014
Thorium-232 — 7 x 1015
Uranium-234 4 x 1012 2 x 1012
1 x 1014
1 x 1014
4xl014
SxlO14
IxlO14
TBC
TBC
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential for remedial
actions to result in exposure to members of
the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
DOE orders are not ARARs because they
are not promulgated. This DOE order is a
TBC because of the potential for remedial
actions to result in exposure to members of
the public.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
SOIL AND CONTAMINATED MATERIALS
Cleanup of Soil Contaminated with Residual Radioactive Materials
Health and Environmental
Protection Standards for
Uranium and Thorium Mill
Tailings
40CFR 192.02
Subpart A
40CFR 192.12(a)
Subpart B
40CFR 192.20
Subpart C
Remedial actions shall be conducted so as to provide reasonable assurance that, as a result
of residual radioactive materials, the concentration of radium-226 in land averaged over any
area of 100m2 shall not exceed the background level by more than:
5 pCi/g averaged over the first 15 cm of soil below the surface, and
IS pCi/g, averaged over 15-cm-thick layers of soil more than 15 cm below the
surface.
Compliance with this requirement should be shown through measurements performed within
the accuracy of currently available types of field and laboratory instruments in conjunction
with reasonable survey and sampling procedures.
Relevant and
Appropriate
The contaminated materials associated with
OU5 are similar in characteristics to uranium
mill tailings.
This regulation is not applicable as the FEMP
is not a designated uranium mill tailings
facility.
W
i
oo
Health and Environmental
Protection Standards for
Uranium and Thorium Mill
Tailings
40CFR 192.21(f) and
192.22(b)
Subpart C
Where radionuclides other than radium-226 and its decay product are present in sufficient
quantity and concentration to constitute a significant radiation hazard from residual
radioactive materials, remedial actions shall, in addition to satisfying the standards of 40
CFR 192.02,Subpart A and 192.12,Subpart B (both listed above), reduce other residual
radioactivity to levels that are as low as is reasonably achievable.
Relevant and
Appropriate
Contaminated material associated with OU5
are similar in characteristics to uranium mill
tailings.
Post Closure Standards for
Uranium and Thorium Mill
Tailings
40 CFR 192.32(b)(2)
Subpart D
The requirements for the management of uranium byproduct materials after closure of a
disposal area (40 CFR 192.32(b)(l)) shall not apply to any portion of a disposal site which
contains a concentration of radium-226 in land, averaged over areas of 100m2, which, as a
result of uranium byproduct material, does not exceed the background level by more than:
5 pCi/g averaged over the first 15 cm of soil below the surface, and
15 pCi/g, averaged over 15-cm-thick layers of soil more than 15 cm below the
surface.
Relevant and
Appropriate
Contaminated materials associated with OU5
are similar in characteristics to uranium mill
tailings.
Management of Thorium
Mill Tailings
40 CFR 192.40-192.42
Subpart E
The following are requirements for the management of thorium byproduct materials:
The provisions for the management of uranium byproduct material
(40 CFR §192.32)shall apply to thorium byproduct material and:
Provisions applicable to the element uranium shall also apply to the
element thorium
Provisions applicable to radon-222 shall also apply to radon-220
Provisions applicable to radium-226 shall also apply to radium-228
With the concurrence of EPA, alternative provisions may be substituted for any of the above
requirements provided the alternative provisions will provide at least an equivalent level of
protection for human health and environment.
Relevant and
Appropriate
Contaminated material associated with OU5
are similar in characteristics to uranium mill
tailings.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
Radiation Protection of the
Public and the
Environment - Soil
Contamination
DOE Order 5400.5
Chapter IV (4)(a)(l)
10 CFR 834 (PROPOSED)
If the average residual concentration of radionuclides in any surface soil or below surface
area less than or equal to 25 m2 exceeds the limit or guideline by a factor of(100/A) °'5
[where A is the area (in square meters) of the region in which the concentrations are
elevated], limits for "hot spots" shall also be developed and applied.
Procedures for calculating these hot spots limits, which depend on the extent of the elevated
local concentrations, are given in DOE/CH-8901. In addition, reasonable efforts shall be
made to remove any source of radionuclide that exceeds 30 times the appropriate limit in the
soil, irrespective of the average concentration in the soil.
TBC
The selected remedy involves the excavation
of contaminated soil and sediment. DOE
Orders provide guidance on addressing
contaminated soil and sediment at DOE
facilities. DOE orders are TBCs, rather than
ARARs because they are not promulgated.
10 CFR 834 is included as a TBC because it
is presently a proposed rule.
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter IV (4)(a)(2)(3)
10 CFR 834 (PROPOSED)
The generic guidelines for residual concentrations of radium-226, radium-228, thorium-230,
and thorium-232 are:
5 pCi/g, averaged over the first 15 cm of soil below the surface; and
15 pCi/g, averaged over 15-cm-thick layers of soil more than 15 cm below the
surface.
These guidelines take into account ingrowth of radium-226 from thorium-230 and of radium-
228 from thorium-232, and assume secular equilibrium. If both thorium-230 and radium-226,
or both thorium-232 and radium-228, are present and not in secular equilibrium, the
appropriate guideline is applied as a limit "fcti the radionuclide with the higher concentration.
If other mixtures of radionuclides occur, the concentrations of individual radionuclides shall
be reduced so that either the dose for the mixture will not exceed the basic dose limit or the
sum of the ratios of the soil concentration of each radionuclide to the allowable limit for
that radionuclide will not exceed 1. Explicit formulas for calculating residual concentrations
guidelines for mixtures are given in DOE/CH-8901.
TBC
Radionuclides are COCs for soil within the
scope of OU5. DOE orders are TBC rather
than ARARs because they are not
promulgated. This citation is included as a
TBC as it is more restrictive than the federal
standard in 40 § CFR 192, .02, .12(a), .20,
.21(0, -22(b), .32(b)(2), .40-.42. 10 CFR 834
is included as a TBC because it is presently a
proposed rule.
Guidelines for Residual
Radioactive Material-
Surface contamination
DOE Order 5400.5,
Chapter IV (4)(d)
10 CFR 834 (PROPOSED)
These generic surface contamination guidelines are applicable to existing structures and
equipment. These guidelines are generally consistent with standards of the NRC (1982) and
functionally equivalent to Section 4, "Decontamination for Release for Unrestricted Use," of
Regulatory Guide 1.86,but apply to nonreactor facilities. These limits apply to both interior
equipment and building components that are potentially salvageable or recoverable scrap. If
a building is demolished, the guidelines in paragraph IV (6)(a) are applicable to the resulting
contamination in the ground.
TBC
These criteria will be used for any process
facility building built and/or used for the
remedial action, including the AWWT, soil
washing, soil staging, etc., structures and
buildings. DOE orders are not ARARs
because they are not promulgated. This
DOE order is a TBC because of the
potential of remedial actions to result in
structures and equipment containing residual
radioactivity. 10 CFR 834 is included as a
TBC because it is presently a proposed rule.
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TABLE B.I (Continued)
CHEMICAL-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Resource Conservation and
Recovery Act
40 CFR 268.41
Revised Interim Soil Lead
Guidance for CERCLA
Sites and RCRA Corrective
Action Facilities
OSWER Directive #
9355.4-12
Requirement
Lead Soil Cleanup Standards
The maximum concentration of lead (5.0mg/L) may not be exceeded whether it is the
extract of a waste or waste treatment residual.
This lead soil guidance states the following:
Screening level of 400 ppm for lead in soil is proposed for residential land use;
Site-specific preliminary remediation goals (PRGs) at CERCLA sites and media
cleanup standards (MCLs) at RCRA corrective action facilities for residential land
use are described; and
A plan for soil lead cleanup at CERCLA sites and RCRA Corrective Action
facilities that have multiple sources of lead is described.
ARAR/TBC
Applicable
TBC
Rationale
Lead is a COC in soil and sediment in OU5.
This policy is not ARAR because it is not a
promulgated regulation.
This interim directive is a TBC because it
establishes an approach for determining
protective levels for lead in soil at CERCLA
sites and RCRA facilities that are subject to
corrective action under RCRA Section
3004(v) or 3008(h).
PCB Soil Cleanup Standards
PCB Spill Cleanup Policy .
40 CFR 761. 125
40 CFR 761.125(c)
PCBs at concentration of greater than 50 ppm are subject to TSCA decontamination
requirements in 40 CFR 761. 120(b).
Soil in nonrestricted access areas contaminated by a PCB spill will be decontaminated to
10 ppm PCBs by weight, provided that the soil is excavated to a minimum depth of 10
inches. The excavated soil will be replaced with clean soil, i.e., containing less than 1 ppm
PCBs, and the spill site will be restored (e.g. .replacement of turf) (761.125(c)(4)(v)]. For
soil in restricted access areas, decontamination will be to 25 ppm PCBs by weight
[761.125(c)(3)(v)].
TBC
PCBs are a COC in soil for OU5.
Concentrations of PCBs at OU5 are expected
to be less than 50 ppm. Although published
in the Code of Federal Regulations, this is a
policy, not a promulgated rule, and hence a
TBC. This TBC is pertinent to all Operable
Unit 5 final remediation levels for soil
containing PCBs as CERCLA wastes, per the
NCP.
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TABLE B.2
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
I
THREATENED & ENDANGERED SPECIES
HABITAT PROTECTION
w
to
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.302(h)
10 CFR 1021
Endangered Species Act
16 U.S.C. §1531, et seq.
Endangered and
Threatened Wildlife and
Plants
50 CFR §17.21, §17.31,
§17.61, §17.71, and
§17.94
Interagency Cooperation-
Endangered Species Act
50 CFR §402.01
All federal agencies must ensure that any action authorized,
funded, or carried out by them is not likely to jeopardize the
continued existence of any listed species or result in the
destruction or adverse modification of the constituent elements
essential to the conservation of a listed species within a
defined critical habitat. Additional requirements apply if it is
determined that a proposed activity could adversely affect
these species or their habitat.
Applicable
In 1993 and 1994 updated surveys at the FEMP
determined the presence of the state-listed Sloan's
crayfish (Orconectes sloanii) in Paddys Run.
Additionally, it was determined that good habitat exists
for the federally listed endangered Indiana bat (Myotis
sodalis) along Paddys Run and the storm sewer outfall
ditch. Moderate and marginal habitat exist in a very
limited area for the state-listed endangered cave
salamander (Eurycea lucifuga). Surveys did not locate
habitat or populations for the federally listed
endangered running buffalo clover (Trifolium
stoloniferum) or the state-listed endangered mountain
bindweed (Pofygonum cilinode) and slender fingergrass
(Digitariafiliformis). In addition, neither habitat nor
populations of the state-listed threatened spring
coralroot (Corallorhiza wisteriana) were found on
FEMP property.
Interagency Cooperation-
Endangered Species Act
50 CFR §402.12 (a),(b)
A biological assessment shall evaluate the potential effects of
the action on listed and proposed critical habitat and determine
whether any such species or habitat are likely to be adversely
affected by the action and is used in determining whether
formal consultation or a conference is necessary.
Applicable
These procedures are required for federal actions that
are "major construction activities."
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
SPECIES PROTECTION
Ohio Endangered Species
Regulations
ORC 1531.25
No person shall take or possess any native species of wild
animal, or any eggs or offspring thereof, that is endangered
with state-wide extinction.
Applicable
Updated surveys in 1993-94 found state-listed
threatened Sloan's crayfish (Orconectes sloanif)
populations in sections of Paddys Run. Moderate
habitat for the state-listed endangered cave salamander
(Eurycea lucifitga) was also determined during a 1993
survey of the FEMP.
Ohio Endangered Species
Regulations
ORC 1518.02
OAC 1501:18-1
No person shall root-up, injure, destroy, remove, or carry
away on or from public highways, public property, or waters
of the state, or on or from the property of another, without the
written permission of the owner, lessee, or other person
entitled to possession, any endangered plant listed in
OAC 1501:18-1.
Applicable
Surveys in 1994 did not locate the federally listed
endangered running buffalo clover (Trifoliiim
stoloniferum), the state-listed endangered mountain
bindweed (Pofygonum cilinode) or slender finger grass
(Digitariafiliformis), or state-listed threatened spring
coralroot (Corallorhiza wisteriana).
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Classification of Solid
Waste Disposal Facilities
and Practices
40 CFR §257.3-2
Solid waste disposal facilities or practices shall not cause or
contribute to the taking of any endangered or threatened
species of plants, fish, or wildlife.
Solid waste disposal facilities or practices shall not result in
the destruction or adverse modification of the critical habitat
of endangered or threatened species as identified in
50 CFR Part 17.
Applicable
This regulation is applicable to the use of engineered
cells.
HISTORIC AND CULTURAL RESOURCE PROTECTION
ANTIQUITY AND HISTORIC SITE PRESERVATION
Antiquities Act of 1906
16 U.S.C. §431-433 and
Historic Sites
Preservation Act
16 U.S.C. §461-467
No person may appropriate, excavate, injure,, or destroy any
historic or prehistoric ruin or monument, or any object of
antiquity situated or controlled by the Government of the
United States without an applicable permit. Identification and
preservation of cultural resources on federal lands is required,
including natural landmarks.
Applicable
Proposed areas of disturbance associated with Operable
Unit 5 remedial actions will be surveyed and the
Advisory Council on Historic Preservation and the State
Historic Preservation Office (SHPO) will be consulted
as agreed upon in a programmatic agreement with
DOE, SHPO, and the Advisory Council. This
regulation is applicable to soil excavation.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
ARCHAEOLOGICAL RESOURCE RECOVERY AND PRESERVATION
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.301 (c)
Archaeological
Resources Protection Act
(16 USC § 47099-47011)
Protection of
Archaeological
Resources
43 CFR §7.4(a)
No person may excavate, remove, damage, or otherwise alter
or deface or attempt to excavate, remove, damage, or
otherwise alter or deface any archaeological resource located
on public lands unless such activity is pursuant to a permit.
Applicable
Compliance will be coordinated through Section 106 of
the National Historic Preservation Act.
HISTORIC PRESERVATION
National Historic
Preservation Act
16 USC § 470C
Consideration of
Historic Properties
36 CFR Part 800
Archaeological and
Historic Preservation Act
16 U.S.C. §469, §470
DOE must take into account the effect of an undertaking on
historic properties and accord the Advisory Council on
Historic Preservation a reasonable opportunity to comment.
Historic properties are defined as any prehistoric or historic
district, building, site, structure, or object included in or
eligible for inclusion in the National Register of Historic
Places. This term includes artifacts, records, and persons
released to and located within such properties. Historic
properties that are to be substantially altered or demolished
must be recorded for future use and reference.
Upon discovery that a project may cause the irreparable loss,
destruction, significant scientific finding, prehistorical finding,
or loss of historical or archeological data, DOE must notify
the Dept. of the Interior in writing and provide appropriate
information concerning the project. DOE must, with possible
assistance from SHPO, undertake recovery, protection, and
preservation of the data.
Applicable
Applicable
Areas of disturbance associated with Operable Unit 5
remedial activities will be surveyed to determine
applicable requirements and the Advisory Council will
be consulted as agreed upon in a programmatic
agreement with DOE, SHPO, and the Advisory
Council.
See previous comment.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
o
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Citation
Requirement
ARAR/TBC
Rationale
HISTORIC PRESERVATION (Continued)
American Indian
Religious Freedom Act
42 U.S.C. §1996
Executive Order 11593,
Protection and
Enhancement of Cultural
Environment
3 CFR 54
Native American Graves
.Protection and
Repatriation Act
25 U.S.C. §3001
Provides for tribal access by native peoples to grave sites and
sites of cultural, symbolic, or religious significance.
An inventory of a site with potential historic places is required
for eligibility in the National Register of Historic Places.
Identification and preservation of cultural resources on federal
lands is required, including natural landmarks. DOE must
consult with appropriate Indian tribes prior to the intentional
excavation or removal after an inadvertent discovery of Native
American cultural items including human remains and objects
of cultural significance.
Applicable
Applicable
Applicable
See previous comment.
See previous comment.
See previous comment.
SENSITIVE ENVIRONMENTAL LOCATIONS
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.11 (a),
(b), (c)
Concurrent with its review of a proposed action to determine
appropriate NEPA requirements, DOE shall determine
applicability of the floodplain management and wetlands
protection requirements of this part.
In making a floodplain determination, DOE shall utilize the
Flood Insurance Rate Maps (FIRMs) or the Flood Hazard
Boundary Maps (FHBMs) prepared by the Federal Insurance
Administration of the Department of Housing and Urban
Development to determine if a proposed action is located in
the base or critical action floodplain, as appropriate. For a
proposed action in an area of predominately federal or state
land holdings where FIRM or FHBM maps are not available,
information shall be sought from the land administering
agency (e.g., Bureau of Land Management, Soil Conservation
Service, etc.) or from agencies with floodplain analysis
expertise.
Applicable
Review will be conducted concurrently with NEPA
determinations for proposed actions.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
FLOODI'LAIN/WETLANDS (Continued)
DOE Compliance with
Floodplain/Wetlands
Assessments
10 CFR §1022.12(a)
Prior to any proposed remedial action, DOE shall prepare a
floodplain/wetlands assessment.
Applicable
Floodplain/wetland assessments will be prepared as
required.
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.15(a)
If DOE finds that no practicable alternative to locating in the
floodplain/wetland is available, consistent with the policy set
forth in Executive Order 11988, DOE shall, prior to taking
action, design, or modify its action in order to minimize
potential harm to or within the floodplain or wetland.
Applicable
Floodplain/wetland impacts will be avoided and
minimized to the maximum extent practicable.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
, FLOODPLA1N/WETLANDS (Continued)
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.3(a),
VI
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DOE shall exercise leadership and take action to:
• Avoid to the extent possible the long- and short-term
adverse impacts associated with the destruction of
wetlands and the occupancy and modification of
fioodplains and wetlands,' and avoid direct and indirect
support of floodplain and wetland development
wherever there is a practicable alternative.
• Incorporate floodplain management goals and wetlands
protection considerations into its planning, regulatory,
and decision-making processes and shall to the extent
practicable:
- Reduce the hazard and risk of flood loss.
- Minimize the impact of floods on human safety,
health, and welfare.
- Restore and preserve natural and beneficial values
served by the floodplain.
- Minimize the destruction, loss, or degradation of
wetlands.
- Preserve and enhance the natural and beneficial
values of wetlands.
• Undertake a careful evaluation of the potential effects
of any DOE action taken in a floodplain and any new
construction undertaken by DOE in wetlands not
located in a floodplain.
• Identify, evaluate, and as appropriate, implement
alternative actions which may avoid or mitigate adverse
floodplain/wetlands impacts.
• Provide opportunity for early public review of any
plans or proposals for actions in fioodplains and new
construction in wetlands.
Applicable
Short and long term impacts associated with Operable
Unit 5 remedial activities will be avoided and
minimized to the maximum extent practicable.
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.5(b),(h)
This part shall apply to all proposed floodplain/wetlands
actions, including those sponsored jointly with other agencies,
where practicable alternatives to the proposed actions are still
available.
The policies and procedures of this part which are applicable
to floodplain actions shall apply to all proposed actions which
occur in a wetlands located in a floodplain.
Applicable
Short and long term impacts associated with Operable
Unit 5 remedial activities will be avoided and
minimized to the maximum extent practicable.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
§
Citation
Requirement
ARAR/TBC
Rationale
WETLANDS
Procedure for
Implementing the
National Environmental
Policy Act
40 CFR §6.302(a)
[Executive Order 11990]
Federal agencies conducting certain activities must avoid, to
the extent possible, the adverse impacts associated with the
destruction or loss of wetlands and to avoid support of new
construction in wetlands when a practicable alternative exists.
Applicable
Approximately 35.9 acres of jurisdictional wetlands and
8.9 acres of waters of the United States were identified
onsite as a result of the 1993 FEMP Wetland
Delineation. The U.S. Army Corps of Engineers
officially approved the delineation on August 19, 1993.
Wetland impacts associated with Operable Unit 5
remedial activities will be minimized and avoided to the
maximum extent practicable.
Executive Order 11990,
Protection of Wetlands
This order requires that federal agencies take action to avoid
adversely impacting wetlands wherever possible, to minimize
wetland destruction and to preserve the values of wetlands.
Applicable
Wetland impacts associated with Operable Unit 5
remedial activities will be avoided and minimized to the
maximum extent practicable.
W
Nationwide Permit
(NWP) Program
33 CFR §330
The U.S. Army Corps of Engineers has authorized certain
categories of activities involving the discharge of dredged and
fill material into wetlands and waters of the United States
under the NWP program. Impacts involving the discharge of
dredged and fill material will be conducted in accordance with
the substantive requirements of applicable NWPs as required.
Discharges not authorized by NWP will be conducted in
accordance with the substantive requirements of 33 CFR 323
and 40 CFR 230.
Applicable
Approximately 35.9 acres of jurisdictional wetlands and
8.9 acres of waters of the United States have been
identified on site. Impacts to these areas will be
avoided and minimized to the maximum extent
practicable. Discharges of dredged and fill material
authorized by NWPs will be conducted in accordance
with the substantive requirements of the respective
permits.
Permits for the
Discharge of Dredged
and Fill Material into
waters of the United
States
33 CFR §323
Remedial actions involving the discharge of dredge and fill
material into these areas shall meet the substantive
requirements of this section and 40 CFR §230.
Applicable
Discharges of dredged and fill material not authorized
by NWP will be conducted in accordance with the
substantive requirements of these regulations.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
w
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Citation
Requirement
ARAR/TBC
Rationale
WETLANDS (Continued)
Section 404(b)(l)
Guidelines for
Specification of Disposal
Sites for Dredged and
Fill Material
40 CFR §230
Section 401 State Water
Quality Certifications
OAC 3745-32
Protection of Wetlands
40 CFR §258.12
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07 (G)(15)
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
40 CFR 230 sets guidelines for evaluation of discharges of
dredged and fill material into wetlands and waters of the
United States. The requirements specify that no discharge of
dredged or fill material shall take place unless the permit
authorizing agency makes a determination of the short-term
effects of the discharge on the environment of the site, and if:
1. There is no practicable alternative to the action;
2. A state water quality standard will not be violated; and
3. It does not contribute to or causes the significant
degradation of waters of the United States.
Section 401 State Water Quality Certification is required to
conduct dredge and fill activities within wetlands or waters of
the United States. State Water Quality Certification is granted
provided:
1. The discharge does not prevent or interfere with the
attainment or maintenance of applicable water quality
standards; and
2. The discharge does not result in a violation of any
applicable provisions of the CWA.
New municipal solid waste landfill units must not be located in
wetlands unless Ohio approves otherwise.
A solid waste disposal facility may nof be located in a
floodway.
The limits of waste placement cannot be located within 200
feet of a stream, lake, or natural wetland, unless deemed
acceptable by the Director of the OEPA.
Applicable
Applicable
Applicable
Applicable
Applicable
Discharges of dredged and fill material associated with
Operable Unit 5 remedial actions will be evaluated and
conducted against the substantive requirements of these
regulations.
Discharges of dredged and fill material associated with
Operable Unit 5 remedial actions will meet the
substantive requirements of these regulations.
Wetland impacts associated with Operable Unit 5
remedial actions will be avoided and minimized to the
maximum extent practicable.
Floodway impacts associated with Operable Unit 5
remedial activities will be avoided and minimized to the
maximum extent practicable.
Wetland impacts associated with Operable Unit 5
remedial actions will be avoided and minimized to the
maximum extent practicable.
5
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
FLOODPLA1NS
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07 (G)(15)
The limits of solid waste placement and the leachate
management system cannot be located in a regulatory
floodplain, unless deemed acceptable by the Director of the
OEPA.
Applicable
This requirement is applicable to the siting of a solid
waste disposal facility.
Ohio Solid Waste
Disposal Regulations
OAC 3745-29-07 (G)(15)
The limits of solid waste placement and the leachate
management system cannot be located in a regulatory
floodplain, unless deemed acceptable by the Director of the
OEPA.
Applicable
This requirement is applicable to the siting of a solid
waste disposal facility.
js)
I
td
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.302(b)
Federal agencies must evaluate the potential effects of actions
they may take in a floodplain to avoid, to the extent possible,
adverse effects associated with direct and indirect development
of a floodplain.
Applicable
Floodplain impacts associated with Operable Unit 5
remedial activities will be avoided and minimized to the
maximum extent practicable.
Floodpiain Management
Executive Order 11988
This order requires federal agencies undertaking actions within
a floodplain to evaluate the potential for adverse impact on the
floodplain. If it is determined that adverse impacts could
occur, the effects of the action must be minimized to the
extent practical.
Applicable
Floodplain impacts associated with Operable Unit 5
remedial activities will be avoided and minimized to the
maximum extent practicable.
SOLID WASTE SITING CRITERIA
SOLE-SOURCE AQUIFERS
Siting Over a
Sole-Source Aquifer
Safe Drinking Water Act
42 U.S.C. §1424(e)
All federal financially assisted projects constructed in the area
of a sole-source aquifer and its principal recharge zone will be
subject to EPA's review to ensure that these projects are
designed and constructed so that they do not create a
significant hazard to public health.
Applicable
A notice in 53 FR 15876 (May 4, 1988) designated the
Buried Valley Aquifer System of the Great Miami/
Little Miami River Basins of southwestern Ohio as a
sole or principal source of drinking water. The FEMP
site is located above this aquifer.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
SOLE-SOURCE AQUIFERS (Continued)
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
A solid waste landfill facility cannot be located above an
aquifer declared by the federal government under the Safe
Drinking Water Act to be a sole-source aquifer.
Applicable
This requirement is applicable to the on-property
disposal of solid waste.
OEPA Guidance on Solid
Waste Siting Criteria:
GD202.101
Cd
NJ
The Director may grant an exemption to the prohibition of
siting a solid waste landfill facility over a sole-source aquifer
(OAC 3745-27-07(H)(2)(c)) under ORC 3743.02(G). In order
to grant an exemption, the Director needs to determine that no
adverse impact to human health or safety or the environment
will occur due to granting the exemption. The decision to
grant an exemption from this rule is made on a site-by-site
basis. Among the items that should be considered when*
determining if a waiver will be granted are whether a
significant thickness of low permeable material exists between
the landfill facility liner and the sole-source aquifer and
whether there is an interconnection between the sole-source
aquifer and any significant saturated zones which exist above
the sole-source aquifer.
TBC
This requirement is applicable to the on-property
disposal of solid waste.
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
A solid waste landfill, facility cannot be located above an
unconsolidated aquifer capable of sustaining a yield of 100
gallons per minute for a 24-hour period to a water supply well
located within 1000 feet of the limits of solid waste placement,
unless deemed acceptable by the Director of the OEPA.
Applicable
This requirement is applicable to the on-property
disposal of solid waste.
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TABLE B.z (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
SOLE-SOURCE AQUIFERS (Continued)
to
OEPA Guidance on Solid
Waste Siting Criteria:
100 Gallon Per Minute
Aquifer
GD202.102
An exemption to the prohibition of siting a solid waste landfill
facility over an unconsolidated aquifer capable of sustaining a
yield of 100 gallons per minute for a 24-hour period (OAC
3745-27-07(H)(2)(d)) may be obtained by demonstrating that
the thickness and lack of permeability of the sediment that
exists between the bottom of the proposed landfill facility liner
and the top of the unconsolidated high-yield aquifer provide
adequate protection to the unconsolidated high-yield aquifer
from the effects of a release of leachate from the solid waste
landfill facility. The sediment should prevent leachate from
migrating from the bottom of the facility liner to the high-
yield aquifer in a time period equal to the active life of the
facility, including the postclosure care period.
TBC
This guidance is a TBC rather than a ARAR because it
is not promulgated. This guidance is a TBC for the use
of the on-property disposal facility.
OTHER SOJLID WASTE SITING LIMITATIONS
Distance from a Public
Water Supply, Ohio
Solid Waste Disposal
Regulations
OAC 3745-27-07
A solid waste landfill facility may not be located within the
surface and subsurface areas surrounding a public water
supply well through which contaminants may move toward
and may reach the public water supply well within a period of
five (5) years.
Applicable
This requirement is applicable to the on-property
disposal of solid waste.
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07 (G)(16)
The limits of solid waste placement and a leachate
management system may not be located within 200 feet of a
fault that has displacement in Holocene time.
Applicable
This requirement is applicable to the on-property
disposal of solid waste.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
td
io
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-07
Requirement
ARAR/TBC
Rationale
OTHER SOLID WASTE SITING LIMITATIONS (Continued)
The limits of solid waste placement cannot be located within
1000 feet of a water supply well or developed spring unless it
is deemed acceptable by the Director of the OEPA or it is:
• Controlled by the applicant, is needed as a source of
nonpotable water, no other reasonable alternate water
source is available, and the well is constructed to
prevent contamination of the groundwater; or
• Located at least 500 feet hydrogeologically upgradient
from the limits of solid waste placement; or
• Separated from the limits of solid waste placement by a
hydrogeologic barrier; or
• Constructed and used solely for monitoring
groundwater quality.
The limits of waste placement cannot be located within 300
feet of the solid waste landfill facility's property line, unless
deemed acceptable by the Director of the OEPA.
The limits of solid waste placement cannot be located within
1000 feet of a domicile whose owner has not consented in
writing to the location of the landfill facility.
The isolation distance between the uppermost aquifer system
and the bottom of the recompacted soil liner of a solid waste
landfill system cannot be less than 15 feet of in situ or added
geologic material deemed acceptable by the Director of the
OEPA.
Applicable
Applicable
Applicable
Applicable
This requirement is applicable to the on-property
disposal of solid waste.
This requirement is applicable to the on-property
disposal of solid waste.
This requirement is applicable to the on-property
disposal of solid waste.
This requirement is applicable to the on-property
disposal of solid waste.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
OTHER SOLID WASTE SITING LIMITATIONS (Continued)
OEPA Guidance on Solid
Waste Siting Criteria:
Minimum Distance From
a Public Water Supply
Well
GD202.105
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to
OEPA Guidance on Solid
Waste Siting Criteria:
Minimum Isolation
Distances to Wells and
Developed Springs
GD0202.103
The minimum distance to a public water supply well (OAC
3745-27-07 (H)(3)(c)) will be considered by the application of
this criteria:
- The five-year time of travel shall be calculated between
the boundary of the solid waste landfill facility and the
closest public water supply. A period of no less than
five years will be required before groundwater flowing
in a downgradient direction from the facility can
intersect with a public water supply well screen.
To be considered for an exemption from this rule, the
following will need to be demonstrated:
- That there is at least SO feet of separation between the
bottom of the solid waste landfill facility liner and the
aquifer system in which the public water supply well is
screened.
- That any release of leachate will be detected before
reaching the aquifer system in which the public water
supply well is screened.
- That once leachate is released below the liner, the
leachate will not reach the aquifer system in which the
public water supply well is screened within a time span
of 100 years plus the anticipated life of the solid waste
landfill facility, which shall include the 30-year
postclosure care period.
This guidance clarifies when exceptions to the required
1000-foot isolation distance from water supply wells and
developed springs (OAC 3745-27-07 (H)(3)(c)) apply and
when a situation contrary to the rule can be deemed acceptable
to the Director of the OEPA.
TBC
TBC
This guidance is a TBC rather than a ARAR because it
is not promulgated. This guidance is a TBC for the on-
property disposal of solid waste.
A public water supply exists outside of the five-year
time of travel from the FEMP property boundary.
This guidance is a TBC rather than a ARAR because it
is not promulgated.
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TABLE B.2 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
OTHER SOLID WASTE SITING LIMITATIONS (Continued)
to
£
OEPA Guidance on Solid
Waste Siting Criteria:
Material Acceptable to
the Director
GD202.104
For geologic material to be deemed acceptable to the Director
of the OEPA as added fill under OAC Rule 3745-27-07
(H)(2)(e), it must be able to meet the following criteria:
• The geologic material must be impermeable enough so
it will not store, transmit or yield a significant amount
of water to a well or spring
• The geologic material must be able to impede, both
physically and chemically, the flow of leachate
constituents through it.
In order to meet both criteria listed above, the added geologic
material should:
• Be classified as CL, SC, GC, CL-ML, or CH under
the Unified Soil Classification System
• Be composed of particles of which at least 25% by dry
weight will pass through a No. 200 (75 /im) sieve
v^
• Be composed of particles of which no more than 25%
by dry weight will not pass through a No. 4 sieve
• No particle should be greater than 8 inches in diameter
• Have a final permeability of no more than IxlO"5
cm/sec
• Be recompacted in a manner that when the landfill is
constructed on it, no damage to the landfill liner will
occur due to settling of the added material.
TBC
This guidance is a TBC rather than a ARAR because it
is not promulgated.
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TABLE B.4 (Continued)
LOCATION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Rationale
HAZARDOUS WASTE
LOCATION OF HAZARDOUS WASTE FACILITIES
Hazardous Waste Facility
Environmental Impact
OAC 3745.05(D)(6)(c)
A hazardous waste facility installation and operation permit
shall not be approved unless it is proven that the facility
represents the minimum adverse environmental impact,
considering the state of available technology, the nature and
economics of various alternatives and other pertinent
considerations
Applicable
This requirement is applicable for treatment, storage, or
disposal of hazardous wastes if HWMUs are to be
constructed during remediation. This requirement may
serve as a siting criteria.
Hazardous Waste Facility
Minimum Risk
OAC 3745.05(D)(6)(d)
w
A hazardous waste facility installation and operation permit
shall not be approved unless it is proven that the facility
represents the minimum risk of all the following:
1) contamination of groundwater and surface water;
2) fires or explosions from treatment, storage, or disposal
methods;
3) accidents during transportation;
4) impact to public health and safety;
5) air pollution; and
6) soil contamination.
Applicable
Use of any existing or potential HWMUs for
remediation where hazardous wastes may be stored,
treated, or disposed of must meet these substantive
requirements. This requirement may serve as a siting
criteria.
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n
§
TABLE B.3
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
HAZARDOUS WASTES
HAZARDOUS WASTE STORAGE
w
Empty Containers
OAC 3745-51-07 (A) and
(B)
RCRA
40 CFR 261.7
Subpart A
Any hazardous waste remaining in either an empty container or an inner liner removed
from an empty container is not subject to regulation under 40 CFR Parts 261 through
265 (RCRA requirements). A container is empty if:
1) All wastes have been removed that can be removed using the practices
commonly employed to remove materials from that type of container (e.g.,
pouring, pumping, and aspirating); and
2) No more than 2.5 cm (1 inch) of residue remains on bottom of the container
or inner liner; or
3) No more than 3% by weight, of the total capacity of the container remains in
the container or inner liner if the container is less than or equal to 110 gal. in
size, or no more than 0.3% by weight of the total capacity of the container
remains in the container or inner liner if the container is greater than 110 gal.
in size.
Relevant and
Appropriate
This requirement is relevant and
appropriate when containerizing soil
contaminated by RCRA waste. This
requirement would also be relevant
and appropriate for containerizing
any treatment residues exhibiting
RCRA characteristics including
advanced wastewater treatment
(AWWT) sludges and soil
decontamination residues. OEPA
has the overriding authority for on-
site management of RCRA wastes.
Condition of Containers
OAC 3745-66-71 through
74, 76 and 77
RCRA
40 CFR 265.171 through
.174, .176 and .177
Subpart I
If a container holding hazardous waste is not in good condition (e.g., severe rusting,
apparent structural defects) or begins to leak, the owner or operator must transfer the
hazardous waste from this container to a container that is in good condition or manage
the waste in some other way that complies with this requirement.
Relevant and
Appropriate
This requirement is relevant and
appropriate to handling containers
holding environmental media
contaminated with RCRA waste.
OEPA has the overriding authority
for on-site management of RCRA
wastes.
.
°6
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
o
8.
Citation
Requirement
ARAR/TBC
Remarks
HAZARDOUS WASTE STORAGE (Continued)
Waste Storage Piles
OAC 3745-56-51, (A)
through (F), 54 (A) and
(B), 56 (A) and (B), 57
(A)(B) and (C), 58 (A)(B)
and (C)
40 CFR 264.251 through
.259
to
A waste pile used to store or treat hazardous waste must have:
1) A liner that is designed, constructed, and installed to prevent any migration of
waste out of the pile into the adjacent subsurface soil or groundwater or
surface water at any time during the active life (including the closure period)
of the waste pile, and
2) A leachate collection and removal system immediately above the liner that is
designed, constructed, maintained, and operated to collect and remove leachate
from the pile.
The owner/operator must design, construct, operate, and maintain a run-on control
system capable of preventing flow onto the active portion of the pile during peak
discharge from at least a 25-yr storm and manage a runoff management system to
collect and control at least the water volume resulting from a 24-hr, 25-yr storm.
Collection and holding facilities associated with run-on and runoff control system must
be inspected weekly and be emptied or otherwise managed expeditiously after storms to
maintain design capacity of the system.
If the pile contains any particulate matter which may be subject to wind dispersal, the
owner or operator must cover or otherwise manage the pile to control wind dispersal.
Ignitable, reactive, or incompatible waste must not be added to a waste pile, unless
specified in OAC 3745-56-56 (A) and (B) or 57 (A)(B) and (C).
During construction or installation, liners and cover systems must be inspected for
uniformity, damage, and imperfections.
At closure, the owner/operator must remove or decontaminate all waste residues,
contaminated containment system components, contaminated subsoil, and structures and
equipment contaminated with waste and leachate, and manage them as hazardous waste
unless OAC 3745-51-03(D) applies.
If, after removing or decontaminating all residues and making all reasonable effort to
effect removal or decontamination of contaminated components, subsoil, structures and
equipment, the owner/operator finds that not all contaminated subsoil can be practically
removed or decontaminated, he must close the facility and perform postclosure care in
accordance with OAC 3745-57-10.
Relevant and
Appropriate
This requirement is relevant and
appropriate for on-site hazardous
waste piles used for longer than 90
days unless the CAMU Rule is
applied.
3 o
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. TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
HAZARDOUS WASTE STORAGE (Continued)
Containment
OAC 3745-55-75
RCRA
40CFR265.175(a)
through (c)
Subpart I
A containment system for RCRA containment storage areas must be designed and
operated to provide:
1) A sufficiently impervious base, which is sloped to collect any leaking liquids.
2) Sufficient capacity to contain liquids.
3) Prevention of run-on into the containment system.
4) A sump to prevent overflow of the collection system.
Storage areas for containers holding only wastes that do not contain free liquids need
not have a containment system, provided that:
1) The storage area is sloped or is otherwise designed and operated to drain and
remove liquid resulting from precipitation, or
2) The containers are elevated or are otherwise protected from contact with
accumulated liquid.
Relevant and
Appropriate
This requirement is relevant and
appropriate to handling soil
contaminated with listed or
characteristic RCRA waste. A
Part B Permit Application for
RCRA storage has been submitted to
the OEPA.
U)
Containment Building
RCRA
40 CFR 264.1100 through
.1102
Subpart DD
57 FR 37194
8/18/92
The owner or operator is not subject to the definition of land disposal in RCRA
Section 3004(k) provided that the unit:
1) Is a completely enclosed, self-supporting structure that is designed and
constructed of synthetic materials of sufficient strength and thickness to
support themselves, the waste contents, and any personnel and heavy
equipment that operate within the unit, and to prevent failure due to pressure
gradients, settlement, compression, or uplift, physical contact with the
hazardous wastes to which they are exposed, climatic conditions, and the
stresses of daily operation, including the movement of heavy equipment within
the unit and contact of such equipment with containment walls;
2 Has a primary barrier for management of solids, in addition to a liquid
collection system and secondary containment for management of liquids.
3) Has controls sufficient to prevent fugitive dust emissions to meet the no visible
emission standard in Sec. 264.1101(c)(l)(iv); and
4) Is designed and operated to ensure containment and prevent the tracking of
materials from the unit by personnel or equipment.
At closure, the owner or operator must remove or decontaminate all waste residues,
contaminated containment system components, contaminated subsoil, and structures and
equipment contaminated with waste and leachate, and handle them as a hazardous waste.
Relevant and
Appropriate
This requirement is not applicable
because the facility is currently in
interim status; 40 CFR 264
requirements only apply to facilities
with a Part B Permit. Excavated
RCRA soil and sediment may
require temporary storage during the
remedial action.
TJ
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O
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
I
?
u*
g
I
Ni
1
W
Citation Requirement ARAR/TBC Remarks
HAZARDOUS WASTE MANAGEMENT AND DISPOSAL
Preparing and
Transporting Hazardous
Waste Off-site
RCRA
40 CFR 262.20 through
.23, .30 and .33
Subparts B and C
OAC 3745-53-20 through
31
OAC 3745-52-30 and 33
Landfill Design
RCRA
40 CFR 265.301(a)
OAC 3745-68-01 1
Land Disposal Restrictions
RCRA
40 CFR 268.40 through
.44
Subpart D
OAC 3745-59
General requirements for transporting hazardous waste for off-site disposal require a
Manifest. Pretransporting requirements include appropriate packaging, labeling,
marking, and placarding.
• Construction of a landfill must include two (2) or more liners and a leachate collection
and removal system above and between such liners.
A restricted hazardous waste may be land disposed only if:
1) An extract of the waste or of the treatment residue of the waste does not exceed the
value shown in 40 CFR 268.41.
2) It is treated using a technology specified in 40 CFR 268.42(a) or an equivalent
treatment method.
3) The constituent concentrations in the waste or treatment residue of the waste do not
exceed the value shown in 40 CFR 268.43.
Applicable
Applicable
Applicable
Any residues determined to be
RCRA hazardous waste destined for
off-site disposal are subject to
manifest requirements. Remedial
actions involving off-site disposal of
RCRA wastes will be subject to this
requirement.
This requirement will be applicable
to on-property disposal.
This requirement is applicable to
those RCRA-listed hazardous wastes
that will be disposed of off-site.
Land disposal restrictions will not
apply to on-property disposal within
a CAMU under the CAMU Rule.
.a-
2
50
8 u
|8
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tn >r,
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o
s
o
a
TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
HAZARDOUS WASTE MANAGEMENT AND DISPOSAL (Continued)
W
Contaminated Debris
RCRA
40 CFR 268.2
Subpart A
40 CFR 268.45
Subpart D
40 CFR 261.3
Subpart A
Debris means solid material exceeding a 60-mm particle size that is intended for
disposal and that is a manufactured object, plant or animal matter, or natural geologic
material.
Hazardous debris means debris that contains a listed hazardous waste, or that exhibits a
characteristic of hazardous waste.
Hazardous debris must be treated prior to land disposal unless the EPA determines that
the debris is no longer contaminated with hazardous waste or the debris is treated to the
waste-specific treatment standard for the waste contaminating the debris.
Provided the debris does not exhibit a RCRA characteristic it is not subject to regulation
under 40 CFR parts 260, 261 to 266, 268, or 270 if:
1) The hazardous debris has been treated using one of the required extraction or
destruction technologies specified in 40 CFR 268.45; or
2) The debris, considering the extent of contamination, is determined to no longer be
contaminated with hazardous waste.
Applicable
This requirement is applicable to
hazardous debris that will be
disposed of off site. Land disposal
restrictions will not apply to on-
property disposal within a CAMU.
GENERAL FACILITY STANDARDS
Hazardous Waste
Determination
RCRA
40CFR262.il
Subpart A
OAC 3745-52-11 (A)
through (F)
A person who generates a solid waste must determine if that waste is a hazardous waste
using the following method:
1) First determine if the waste is not a solid waste (40 CFR 261.4).
2) Then determine if the waste is listed as a hazardous waste in Subpart D of 40 CFR
Part 261.
3) For purposes of compliance with 40 CFR Part 268 or if the waste is not listed in
Subpart D of 40 CFR part 261, the generator must then determine whether the
waste is identified in Subpart C [characteristic] of 40 CFR part 261.
Relevant and
Appropriate
This requirement is relevant and
appropriate for soil contaminated
with a RCRA listed waste or a
RCRA characteristic waste, and for
residues from treatment of soil
contaminated with RCRA listed
waste, if the waste is to be managed
or stored on-property within a
CAMU. This requirement would
further apply to waste sludges
generated by the AWWT or the soil
decontamination process where
RCRA constituents may be present.
A hazardous waste determination
will be applicable for any RCRA
regulated waste destined for off-site
disposal.
6
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. TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
GENERAL FACILITY STANDARDS (Continued)
*
10
W
u>
Treatment, Storage, and
Disposal General Facility
Standards
RCRA
40CFR265.13 through
.16 Subpart B
OAC 3745-65-13 through
16
General facility standards require that operators of a facility must obtain chemical and
physical analyses of a representative sample of each hazardous waste to be treated,
stored, or disposed of at the facility prior to treatment, storage, or disposal. The
analysis may include existing published or documented data on the hazardous waste or
on hazardous waste generated from similar processes.
The facility operator must also provide controlled access for the facility. In addition,
the operator must maintain and inspect all monitoring equipment, safety and emergency
equipment, security devices and operating and structural equipment that are important to
preventing human health hazards. Operators must train personnel for procedures
relevant to their emergency response training.
Relevant and
Appropriate
These standards are relevant and
appropriate where RCRA wastes are
managed on site.
Treatment, Storage, and
Disposal Facility
Preparedness and
Prevention
RCRA
40 CFR 265.31 through
.35, .37 Subpart C
OAC 3745-65-31 through
35,37
TSD facility operators must design, construct, maintain and operate facilities to
minimize the possibility of fire, explosion or any unplanned sudden or nonsudden
release of hazardous waste to air, soil, or surface water which might threaten human
health or the environment.
Relevant and
Appropriate
This requirement is relevant and
appropriate for the storage and
treatment of RCRA listed waste.
RCRA listed waste or characteristic
waste may be disposed of in an on-
property disposal facility.
Treatment, Storage, and
Disposal Facility
Contingency Plan and
Emergency Procedures
RCRA
40 CFR 265.51, .52, and
.55 through .56,
Subpart D
OAC 3745-65-51, 52, and
55 through 56
Each facility operator must have a contingency plan designed to minimize hazards to
human health and the environment due to fires, explosions, or any unplanned releases of
hazardous waste constituents to air, soil or surface/groundwater.
Relevant and
Appropriate
This requirement is relevant and
appropriate for the storage and
treatment of RCRA listed waste.
RCRA listed waste or characteristic
waste may be disposed of in an on-
property disposal facility.
)—i T3
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o O
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
GENERAL FACILITY STANDARDS (Continued)
pa
•ij
Treatment, Storage, and
Disposal of Hazardous
Waste in Miscellaneous
Units
OAC 3745-57-91 through
93
40 CFR 264.601 through
.603
Prevention of any release that may have adverse effects on human health or the
environment includes, but is not limited to:
A. Migration of waste constituents in the groundwater or subsurface environment.
B. Migration of waste constituents in surface water, or wetlands or on the soil surface.
C. Migration of waste constituents in the air.
Monitoring, tests, analytical data, inspections, response, and reporting procedures and
frequencies must ensure compliance with pertinent portions of the OAC.
A miscellaneous unit that is a disposal unit must be maintained in a manner that
complies with OAC 3745-57-91 during the postclosure care period.
If a treatment or storage unit has contaminated soil or groundwater that cannot be
completely removed or decontaminated during closure, the unit must also meet the
requirements of OAC 3745-57-91 during the postclosure care period. The postclosure
plan under OAC 3745-55-18 must specify the procedures that will be used to satisfy this
requirement.
Relevant and
Appropriate
These requirements are relevant and
appropriate to on-site facilities that
treat, store, or dispose of hazardous
waste in miscellaneous units unless
the CAMU Rule is applied.
GROUNDWATER MONITORING
Groundwater Monitoring
Program
RCRA
40 CFR 265.90
Subpart F
OAC 3745-65-90
The owner or operator of a surface impoundment, landfill, or land treatment facility
which is used to manage hazardous waste must implement a groundwater monitoring
program capable of determining the facility's impact on the quality of groundwater in
the uppermost aquifer underlying the facility.
Applicable
This requirement is applicable to all
interim-status RCRA land-based
units and to the disposal of soil
containing listed hazardous waste.
The Ohio EPA Director's Final
Findings and Orders (DFOs) signed
September 10, 1993, provides an
alternate groundwater monitoring
program from 40 CFR 265.92,
Subpart F, to integrate the RCRA
program with the CERCLA
response actions.
O ?
8 ^
3 5
Is
:.£
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§
TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
GROUNDWATER MONITORING (Continued)
"9
I
Groundwater Protection
Standard
RCRA
40 CFR 264.92 through
.100
Subpart F
OAC 3745-54-92 through
100
The owner or operator must ensure that hazardous constituents detected in the
groundwater from a regulated unit do not exceed the concentration limits for MCLs in
the uppermost aquifer underlying the waste management area beyond the point of
compliance during the compliance period.
The groundwater monitoring requirements include procedures for detection, compliance,
and corrective action monitoring programs.
Relevant and
Appropriate
This requirement is relevant and
appropriate to land-based units,
which would include any remedial
action using the on-site disposal
facility. However, the FEMP is
currently an interim status facility
with a Part B Permit application
pending.
CLOSURE UNDER RCRA
po
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(Jo
Closure Performance
Standard for HWMUs
RCRA
40 CFR 265.111
Subpart G
OAC 3745-66-11
The owner or operator must close a facility in a manner that:
1) Minimizes the need for further maintenance; and
2) Controls, minimizes or eliminates, to the extent necessary to protect human health
and the environment, postclosure escape of hazardous waste, hazardous
constituents, leachate, contaminated runoff, or hazardous waste decomposition
products to the ground or surface waters or to the atmosphere; and
3) Complies with these closure requirements.
Applicable
This requirement is applicable to
HWMU closures occurring during
the remedial action.
This requirement is relevant and
appropriate to disposal in an
on-property disposal facility.
Closure Performance
Standard
RCRA
40 CFR 265.114
Subpart G
OAC 3745-66-14
During the partial and final closure periods, all contaminated equipment, structures, and
soil must be clean closed, have risk-based closure, or be closed in place.
If the owner or operator demonstrates that not all contaminated soil can be practically
removed or decontaminated from a structure or land-based area, then the owner or
operator must close the structure or area and perform postclosure care in accordance
with the closure and postclosure care requirements that apply (40 CFR 264.310).
Applicable
This requirement is applicable to
actions involving removal, treatment
or storage of soil contaminated by
RCRA constituents from HWMUs.
Storage Area Closure
RCRA
40 CFR 264.178
Subpart I
OAC 3745-55-78
At closure, all hazardous waste and hazardous waste residues must be removed from the
containment system. Remaining containers, liners, bases, and soil containing, or
contaminated with hazardous waste, or hazardous waste residues must be
decontaminated or removed.
If the owner or operator demonstrates that not all contaminated soil can be practically
removed or decontaminated from a structure or land-based area, then the owner or
operator must close the structure or area and perform postclosure care in accordance
with the closure and postclosure care requirements that apply (40 CFR 264.310).
Relevant and
Appropriate
This requirement is relevant and
appropriate to Operable Unit 5 for
handling hazardous waste or
environmental media. This
requirement is not applicable
because the FEMP is currently in
interim status; 40 CFR 264
requirements only apply to facilities
with a Part B Permit.
1
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
o
CLOSURE UNDER RCRA (Continued)
Closure of Tank Systems
RCRA
40CFR265.197
Subpart J
OAC 3745-66-97
At closure of a tank system, the owner or operator must remove or decontaminate all
waste residues, contaminated containment system components (liners, etc.),
contaminated soil, and structures and equipment contaminated with waste, and manage
them as hazardous waste.
If the owner or operator demonstrates that not all contaminated soil can be practicably
removed or decontaminated then the owner or operator must close the tank system and
perform postclosure care in accordance with the closure and postclosure care
requirements that apply to landfills (40 CFR 264.310).
Relevant and
Appropriate
This requirement is relevant and
appropriate to RCRA wastes
contained in tanks that will be used
by Operable Unit 5 during remedial
actions.
I
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vb
Contained-In Policy
RCRA
58 FR 48092
9/14/93
Proposed rule.
58 FR 59976
11/12/93
Notice to extend
comment.
59 FR 10778
3/8/93
Clarification, partial
withdrawal.
Hazardous soil means soil that contains RCRA hazardous waste(s) listed in 40 CFR part
261, Subpart D, or that exhibits one or more of the characteristics of a hazardous waste
as defined in 40 CFR part 261, Subpart C.
This proposed rule recommends contained-in determinations for hazardous debris,
hazardous soil and other environmental media.
Any person may petition the Regional Administrator to exclude, under 261.(f)(2) or
261.3(g) of this chapter, hazardous debris and hazardous soil or other environmental
media, including but not limited to groundwater, surface water, and sediment, from
regulation as hazardous waste. The petition for a contained-in determination must
include information sufficient to demonstrate that specific constituent concentrations in
the hazardous debris, hazardous soil, or other environmental media to be excluded do
not pose a hazard to human health and the environment at that site. (Such a petition is
not necessary for remedial actions conducted pursuant to RCRA or CERCLA authorities
provided that a similar determination is made by the Regional Administrator based on
information substantially equivalent to the information listed below including public
notice and comment requirements).
TBC
Policies are not promulgated and
therefore cannot be ARARs. This
policy will be considered for
managing treated soil that is
contaminated with RCRA waste.
Risk-Based Remediation
Standards
Ohio EPA Closure Plan
Review Guidance for
RCRA Facilities.
Interim Final.
9/1/93
Federal regulations of May 2, 1986 (50 FR 16422) and March 19, 1987 (52 FR 8704)
modified the closure performance standard such that risk assessment, or what constitutes
"decontamination" of a site, may be considered by the EPA as a closure option. The
OEPA adopted the equivalent of the EPA's March 19, 1987, regulations on
December 8, 1988 (see OAC 3745-67-28), clarifying that risk assessment may be an
option. It is OEPA and Dept. of Hazardous Waste Management practice to consider
risk assessment as a possible third option for closure for all types of units.
TBC
The use of risk-based closures is to
be considered for closing HWMUs
with media contamination as
integrated with the CERCLA
remedial action.
18
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
LANDFILL CLOSURE AND CORRECTIVE ACTION
Corrective Action
Management Unit
RCRA
40 CFR 264.552
Subpart S
58 FR 865829 2/16/93
*
h>
Corrective action management unit or CAMU means an area within a facility that is
designated by the Regional Administrator under part 264 Subpart S, for the purpose of
implementing corrective action requirements under Sec. 264.101 and RCRA
Section 3008(h). A CAMU shall only be used for the management of remediation
wastes pursuant to implementing such corrective action requirements at the facility.
For the purpose of implementing remedies under Sec. 264.101 or RCRA
Section 3008(h), the Regional Administrator may designate an area at the facility
as a corrective action management unit, as defined above. One or more CAMUs may
be designated at a facility under the following conditions:
1) Emplacement of remediation wastes into or within a CAMU does not constitute
land disposal of hazardous wastes.
2) Consolidation or emplacement of remediation wastes into or within a CAMU does
not constitute creation of a unit subject to minimum technology requirements.
The owner/operator shall provide sufficient information to enable the Regional
Administrator to designate a CAMU in accordance with the criteria in Sec. 264.552.
Note: RCRA regulated units (HWMUs) within a CAMU are fully subject to RCRA
closure regulations.
Applicable
The CAMU concept is applicable to
the remedial action for RCRA
wastes. "Placement" as defined in
HSWA does not occur in a CAMU.
Therefore, land disposal restrictions
(LDRs) and minimum technology
requirements (MTRs) are not
"triggered" as ARARs during and
after the remedial activity within the
boundaries of the CAMU.
Postclosure Care
RCRA
40 CFR 265.117
Subpart G
OAC 3745-66-17
Postclosure care for each hazardous waste management unit must begin after completion
of closure of the unit and continue for 30 years after that date and must consist of at
least the following:
1) Monitoring and reporting in accordance with the requirements of Subparts
F,K,L,M,N, and X of this part; and
2) Maintenance and monitoring of waste containment systems in accordance with the
requirements of Subparts F,K,L,M,N, and X of this part.
Postclosure use of property on or in which hazardous wastes remain after partial or final
closure must never be allowed to disturb the integrity of the final cover, liner(s), or any
other component of the containment system, or the function of the facility's monitoring
systems. If clean closure is performed then postclosure care is not required.
Applicable
This requirement is applicable to the
closure of existing HWMUs.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
1
10
1.
w
LANDFILL CLOSURE AND CORRECTIVE ACTION Continued)
Minimum RCRA Landfill
Design Requirements for
Closure
RCRA
40 CFR 265.310
Subpart N
OAC 3745-68-10
At final closure of the landfill or upon closure of any cell, the owner or operator must
cover the landfill or cell with a final cover designed and constructed to:
1) Provide long-term minimization of migration of liquids through the closed landfill;
2) Function with minimum maintenance;
3) Promote drainage and minimize erosion or abrasion of the cover;
4) Accommodate settling and subsidence so that the cover's integrity is maintained;
and
5) Have a permeability less than or equal to the permeability of any bottom liner
system or natural subsoil present.
After final closure, the owner of operator must comply with all postclosure
requirements, including maintenance and monitoring throughout the postclosure care
period. The owner or operator must:
1) Maintain the integrity and effectiveness of the final cover, including making repairs
to the cap as necessary to correct the effects of settling, subsidence, erosion, or
other events;
2) Continue to operate the leachate collection and removal system until leachate is no
longer detected;
3) Maintain and monitor the leak detection system;
4) Maintain and monitor the groundwater monitoring system;
5) Prevent run-on and runoff from eroding or otherwise damaging the final cover; and
6) Protect and maintain surveyed benchmarks.
Relevant and
Appropriate
•
This requirement is relevant and
appropriate for on-property disposal
of material that may contain RCRA
waste. This requirement is not
applicable because the FEMP is
currently in interim status; 40 CFR
264 requirements only apply to
faculties with a Part B Permit.
RADIOACTIVE WASTES
MANAGEMENT AND DISPOSAL OF URANIUM MILL TAILINGS
Landfill Requirements
AEA/UMTRCA
40 CFR 192.02(a)
Subpart A
Control of residual radioactive material shall be designed to be effective for up to 1000
years, to the extent reasonably achievable, and in any case, for at least 200 years, and
provide protection of groundwater.
Relevant and
Appropriate
The requirement is relevant and
appropriate for residual radioactive
materials because they are
sufficiently similar to contaminated
soil and sediment being addressed
by Operable Unit 5. This
requirement will be met as a general
performance standard for on-
property or off-site disposal.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
o
I
Requirement
ARAR/TBC
Remarks
MANAGEMENT AND DISPOSAL OF URANIUM MILL TAILINGS (Continued)
Implementation of
Standards in 40 CFR 192,
Subparts A and B
AEA/UMTRCA
40 CFR 192.20
Subpart C
Implementing agencies shall establish methods and procedures to provide reasonable
assurance that the provisions of Subparts A (above) and B (Table B.I) are satisfied.
This should be done through use of analytical models and site-specific analyses for
Subpart A, and through measurements performed within the accuracy of currently
available types of field and laboratory instruments along with reasonable survey and
sampling procedures. This includes measuring the flow rate of uranium and
groundwater.
Relevant and
appropriate
This requirement is relevant and
appropriate for ensuring compliance
with 40 CFR 192 Subparts A and B.
Note that Subpart B is listed as an
ARAR in the chemical-specific
ARAR table, B.I.
pa
Lo
Management of Uranium
By-Product Materials
AEA/UMTRCA
40 CFR 192.30
through .34
Subpart D
This subpart applies to the management of uranium by-product materials under Section
84 of the Atomic Energy Act of 1954, as amended, during and following processing of
uranium ores, and to restoration of disposal sites following any use of such sites under
Section 83(b)(l)(B) of the Act.
Uraniunrby-product materials shall be managed to conform with groundwater •
protection, which includes detection monitoring. Subpart D(iv) allows for alternate
concentration limits of uranium to be established, as described in 264.95 and 264.94(b)
Relevant and
Appropriate
This requirement is for disposal
areas at active uranium mill tailing
sites, and is a relevant and
appropriate requirement for the
engineered disposal facility.
RADIOACTIVE WASTfc DISPOSAL
Performance Objectives
DOE Order 5820.2A,
Chapter III (3)(a)
Performance objectives must:
1) Protect public health and safety in accordance with standards specified in applicable
EH Orders and other DOE Orders.
2) Assure that external exposure to the waste and concentrations of radioactive
material which may be released into surface water, groundwater, soil, plants and
animals results in an effective dose equivalent that does not exceed 25 mrem/yr to
any member of the public. Releases to the atmosphere shall meet the requirements
of 40 CFR 61. Reasonable effort should be made to maintain releases of
radioactivity in effluents to the general environment ALARA.
3) Assure that the committed effective dose equivalents received by individuals who
inadvertently may intrude into the facility after the loss of active institutional
control (100 years) will not exceed 100 mrem/yr for continuous exposure or 500
mrem for a single acute exposure.
4) Protect groundwater resources consistent with federal, state, and local
requirements.
TBC
Residual radioactivity at the site
above background could result in
exposures to members of the public.
Disposal Methods
DOE Order 5820.2A,
Chapter HI, (3)(i)(l)-(6)
Low-level radioactive waste shall be disposed of by methods appropriate to achieve the
performance standard objectives in (3)(a) above, consistent with the radiation dose limits
in paragraph (3)(b)
TBC
This requirement is a TBC because
it is not promulgated. It will be
considered for on-site disposal.
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I
TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
LOW-LEVEL RADIOACTIVE WASTE DISPOSAL (Continued)
Disposal Facility and
Disposal Site Design
DOE Order 5820.2A,
Chapter III (3)(i)(8)
Design criteria shall be established prior to selection of new disposal facilities, new
disposal sites, or both. These design criteria shall be based on analyses of
physiographic, environmental, and hydrogeologic data to assure that the policy and
requirements of this Order can be met. The criteria shall also be based on assessments
of projected waste volumes, waste characterizations, and facility and disposal site
performance.
TBC
This requirement is a TBC because
it is not promulgated. It will be
considered for on-site disposal.
Disposal Facility
Operations
DOE Order 5820.2A,
Chapter III (3)(i)(9)
Operating procedures shall provide security, minimum long-term control,
closure/postclosure, markers for excavations, and training.
TBC
This requirement is a TBC because
it is not promulgated. It will be
considered for on-site disposal.
MANAGEMENT OP LOW-LEVEL RADIOACTIVE WASTE
a
Prohibits commingling of
Low-Level Radioactive
Wastes with Solid Waste
;£ ORC 3734.02.7 (A)(B)
Commingling of low-level radioactive waste with solid waste at a nonlicensed facility
under the Atomic Energy Act of 1954 is prohibited, even if the radioactive waste is
below regulatory concern.
Applicable,
Low-level radioactive waste to be
shipped for off-site disposal will
only be sent to facilities licensed
under the Atomic Energy Act
of 1954.
Low-level Radioactive
Waste Generation
DOE Order 5828.2A,
Chapter III (3)(c)
Technical and administrative controls shall be directed to reducing the gross volume of
waste generated and/or the amount of radioactivity requiring disposal. Waste reduction
efforts shall include consideration of process modification, process optimization,
materials substitution, and decontamination.
All DOE low-level waste generators shall establish auditable programs to assure that the
amount of low-level waste generated and/or shipped for disposal is minimized.
Each DOE low-level waste generator shall separate uncontaminated waste from low-
level waste to facilitate cost-effective treatment and disposal.
Each DOE low-level waste generator preparing a design for a new process or process
change shall incorporate principles into the design that will minimize the generation of
low-level waste.
TBC
This requirement is a TBC because
it is not promulgated. It will be
considered for on-site disposal.
D
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
MANAGEMENT OP LOW-LEVEL RADIOACTIVE WASTE (Continued)
Waste Treatment
DOE Order 5820.2A,
Chapter HI (3)(f)
Waste shall be treated by appropriate methods so that the disposal site can meet the
performance objectives stated in DOE Order 5820.2A Chapter III (3)(a).
Waste treatment techniques such as incineration, shredding, and compaction to reduce
volume and provide more stable waste forms shall be implemented as necessary to meet
performance requirements. Use of waste treatment techniques to increase the life of the
disposal facility and improve the long-term facility performance, by improved site
stability and reduction of infiltrating water, is required to the extent it is cost effective.
The development of large scale waste treatment facilities shall be supported by the
appropriate National Environmental Policy Act documentation.
Operation of waste treatment facilities shall be supported by adequate documentation.
TBC
This requirement is a TBC because
it is not promulgated. It will be
considered for on-site disposal.
w
t
H-»
4^
Low-Level Radioactive
Waste Shipment
DOE Order 5820.2A,
Chapter III (3)(g)
The volume of waste and number of shipments of low-level waste shall be minimized
and the shipments conducted based on plans developed by field organizations.
Generators must receive advance approval from the receiving facility and shall certify
before shipment that waste meets the receiving facility waste acceptance criteria (WAC).
The certification program shall be auditable and able to withstand independent review.
TBC
This requirement is not an ARAR
because it is not promulgated.
Long-Term Storage
DOE Order 5820.2A,
Chapter III (3)(h)
Requires achieving performance objectives of DOE S820.2A HI (3)(a); requires records
and documentation be maintained for low-level waste in storage; permits storage of
Waste until disposal by approved methods.
TBC
This requirement is not an ARAR
because it is not promulgated.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
MANAGEMENT OP LOW-LEVEL RADIOACTIVE WASTE (Continued)
This requirement is not an ARAR
because it is not promulgated.
Disposal Site
Closure/Postclosure
DOE Order 5820.2A,
Chapter III (3)(j)
W
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
UNDERGROUND STORAGE TANKS (USTs)
UST CLOSURE
General Requirements
RCRA
40 CFR 280.61 through
.66
Subpart F
OAC 1301:7-7-36
Owners and operators of petroleum or hazardous substance UST systems must, in
response to a confirmed release from the UST system, comply with abatement
measures, site characterization, product removal, investigations for soil and groundwater
cleanup, and corrective action plans, except for USTs excluded under 280.10(b) and
UST systems subject to RCRA Subtitle C corrective action requirements under
Section 3004(u) of the RCRA, as amended.
Applicable
Petroleum USTs will be closed as
part of site-wide remedial actions.
Ohio Petroleum
Contaminated Soil Policy
OPEA Policy PP 01 03
200
PP.01-03-200
The basis of the "contained in" policy is that environmental media, such as soil or
groundwater, are not considered to be waste material. Because they are not a solid
waste, the mixture rule, as set forth in OAC 3745-51-03, does not apply when they
become contaminated with a listed hazardous waste but only contains the waste. The
result of this policy is that if the waste constituents can be removed, the soil is no
longer considered to contain a hazardous waste. Therefore, since soil is not a waste
material it does not have to be delisted in order for it to be used for its intended
purpose. However, as long as the soil contains the waste material, it must be managed
as a hazardous waste.
If this concept is applied to petroleum-contaminated soil, the soil containing a petroleum
hydrocarbon would not need to be managed as a solid waste if the contaminants was
removed.
TBC
This policy allows for
treated/cleaned soil to be backfilled
at the excavation site. Operable
Unit 5 will consider this policy for
all soil treated below final
remediation levels to be backfilled
as clean soil.
2
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§
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I
i
TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
BEST MANAGEMENT PRACTICES PROGRAM
a
Best Management
Practices (BMP) Programs
Clean Water Act
40CFR125.104
Subpart K
BMP programs shall be developed in accordance with good engineering practices and:
1) Be documented in narrative form and include any necessary plot plans, drawings
or maps;
2) Establish specific objectives for the control of toxic and hazardous pollutants:
(a) Each facility component or system shall be examined for its potential for
causing a release of significant amounts of toxic or hazardous pollutants to
waters of the United States due to equipment failure, improper operation,
natural phenomena such as rain or snowfall, etc.
(b) Where experience indicates a reasonable potential for equipment failure
(e.g., a tank overflow or leakage), natural condition (e.g., precipitation), or
other circumstances to result in significant amounts of toxic or hazardous
pollutants reaching surface waters, the program should include a prediction
of the direction, rate of flow and total quantity of toxic or hazardous
pollutants which could be discharged from the facility as a result of each
condition or circumstance;
3) Establish specific BMPs to meet the objectives identified in (2) above, addressing
each component or system capable of causing a release of significant amounts of
toxic or hazardous pollutants to the waters of the United States.
Applicable
Substantive requirements of this
regulation are applicable to any
release of contaminants to waters of
the United States if BMPs are not
implemented.
AIR
AIR EMISSION STANDARDS FROM A STATIONARY SOURCE
Air Emissions from
Hazardous Waste
Facilities
ORC 3734.02 (1)
Emissions from a hazardous waste facility will not cause, or allow, any particulate
matter, dust fumes, gas, mist, smoke, vapor, or odorous substance to interfere with the
comfortable enjoyment of life for those individuals living near, or working in the
vicinity of the facility, or that is injurious to public health.
Applicable
This requirement is applicable for
the use of a hazardous waste facility
which produces air emissions.
Air Emission Standards
for Process Vents
RCRA
40 CFR 264.1030, .1032
through .1034
Subpart AA
This subpart applies to process vents associated, with distillation, fractionation, thin-film
evaporation, solvent extraction, or air or steam stripping operations that manage
hazardous wastes with organic concentrations of at least 10 ppm.
Applicable
This requirement is applicable for
treating soil contaminated with
RCRA waste.
D6
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oo
TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
AIR EMISSION STANDARDS FROM A STATIONARY SOURCE (Continued)
Malfunction and
Maintenance of Air
Pollution Control
Equipment
OAC 3745-15-06
(A)(l) and (A)(2)
Stack Height
Requirements
OAC 3745-15-12 (B) and
(C)
Scheduled maintenance must be established for pollution control equipment, as well as
time periods when the pollution source must be shut down during maintenance.
Stack height for air contaminant sources must be based on good engineering practices.
Applicable
Applicable
This requirement is applicable for
any remedial action that will use air
pollution control equipment on site.
The use of low-temperature thermal
desorption must meet this
requirement.
STATIONARY SOURCE AIR EMISSIONS
General Provisions on Air
Pollution Control
OAC 3745-15-07
ORC 3704.01-.05
Installation and
Modification of Air
Contaminant Sources
OAC 3745-31-05(A)(3)
Control of Emissions of
Organic Materials from
Stationary Sources
OAC 3745-21-07(G)(2)
Measures shall be taken to adopt and maintain a program for the prevention, control,
and abatement of air pollution in order to protect and enhance the quality of the state's
air resource so as to promote the public health, welfare, and economic vitality of the
people of the state.
The emission or escape into open air from any source whatsoever of smoke, ashes, dust,
dirt, grime, acids, fumes, gases, vapors, odors and combinations of the above in such a
manner or in such amounts as to endanger the health, safety, and welfare of the public,
or to cause unreasonable injury or damage to property shall be declared to be a public
nuisance. It is unlawful for any person to cause, permit, or maintain any such public
nuisance.
New or modified air contaminant sources are required to employ best available
technology to control emissions
Discharges containing organic material must not exceed 40 pounds in any one day, nor
eight pounds in any one hour, unless the discharge has been reduced by at least 85%.
Applicable
Applicable
Applicable
During the remedial action, the
potential exists for emissions of
radionuclides and toxic chemicals to
air, which might endanger
individuals or damage property.
This requirement is applicable to the
construction or modification of air
contaminant sources.
This requirement is applicable to the
discharge of organic emissions.
cr
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
o
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w
Citation Requirement ARAR/TBC Remarks
FUGITIVE AIR EMISSION STANDARDS
Visible Particulates in Air
EPA Regulations on
National Primary and
Secondary Ambient Air
Quality Standards
40 CFR 50.6(a),(b),(c)
Ohio Ambient Air Quality
OAC 3745-17-07 (A)
Particulate Ambient Air
Quality Standards
OAC 3745-17-02 (C)(D)
Particulate Non-
Degradation Policy
OAC 3745-17-05
The level of the national primary and secondary 24-hour ambient air quality standards
for particulate matter is a 150 fig/m3, 24-hour average concentration.
Visible particulate emissions from any stack may exceed 20% opacity, as a six-minute
average, for not more than six consecutive minutes in any 60 minutes, but shall not
exceed 60% opacity, as a six-minute average, at any time.
The standards for national primary and secondary standards must be ^50 /tg/m3, annual
arithmetic average. Particulate matter shall be measured in the gradient air as PM10
(particles with an aerodynamic diameter less than or equal to a nominal 10 /*m).
The level of ambient air quality standards for total suspended particles is a 150 /xg/m3,
24-hour average concentration. The level of the primary and secondary annual
standards for total suspended particulates is 50 /ig/m3.
Degradation of air quality in any area where the air quality is better than required in
3745-27-02 (described above) is prohibited.
Applicable
Applicable
Applicable
The federal standard at 40 CFR
50.6 for particulate matter in air is
applicable to remedial actions at
Operable Unit 5 because remedial
activities may contribute, at least
temporarily, to particulate matter in
the air. Particulate emissions may
be generated through fugitive
emissions from excavations and
disposal activities and point source
discharges from wastewater sludge
dewatering or soil
treatment/stabilization .
The Ohio standard for particulates
in air is not an ARAR because it is
not more stringent than the federal
standard at 40 CFR 50.6
This requirement is applicable for
the escape of particulates. This
includes excavation, demolition,
cleaning and scrubbing.
See comment above.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
FUGITIVE AIR EMISSION STANDARDS (Continued)
Control of Visible
Particulate Emissions for
Fugitive Dust
OAC 3745-17-07
W
u>
There shall be no visible participate emissions from any paved roadway or parking area
except for a period of time not to exceed six minutes during any 60-minute observation
period. There shall be no visible particulate emissions from any unpaved roadway or
parking area except for a period of time not to exceed 13 minutes during any 60-minute
observation period.
There shall be no visible particulate emissions from any material storage piles except for
a period of time not to exceed 13 minutes during any 60-minute observation period.
Relevant and
Appropriate
Paved and unpaved roadways,
parking areas, and material storage
piles will be in use during the
remedial action.
This requirement is not applicable as
the FEMP is not located within a
city or township subject to the rule;
however, the requirement is relevant
and appropriate for site activities
during the remedial action.
Grading, loading, and construction
operations will occur during soil
excavation, soil backfilling and
during construction and capping of
the disposal facility.
Ambient Air Quality
Standards for Non-
methane Hydrocarbons
OAC 3745-21-02(C) and
OAC 3745-21-03(D)
The ambient air quality guidelines for nonmethane hydrocarbons is a maximum three
hour arithmetic mean concentration of 160 /tg/m3, not to be exceeded between the hours
of six and nine a.m.
Hourly and three-hour concentrations must be determined in accordance with prescribed
methods.
Applicable
These requirements are applicable to
hydrocarbon emissions.
Restriction of Emission of
Fugitive Dust
OAC 3745-17-08 (B)
No person shall cause or permit any fugitive dust source to be operated; or any
materials to be handled, transported, or stored; or a building (or its appurtenances) or a
road to be used, constructed, altered, repaired, or demolished without taking or
installing reasonably available control measures to prevent fugitive dust from becoming
airborne. Such reasonably available control measures shall include, but are not limited
to, one or more of the following which are appropriate to minimize or eliminate visible
particulate emissions of fugitive dust.
- The use of water or other suitable dust suppression chemicals for the control of
fugitive dust from the demolition of existing buildings or structures, construction
operations, the grading of roads, or the clearing of land; or
- The periodic application of asphalt, oil, water, onother suitable dust suppression
chemicals on dirt or gravel roads and parking lots, and any other surfaces that may
cause emissions of fugitive dust.
Relevant and
Appropriate
This requirement is not applicable as
the FEMP is not located within a
city or township subject to the rule;
however, the requirement is relevant
and appropriate for site activities
during the remedial action.
Grading, loading, and construction
operations will occur during soil
excavation, soil backfilling and
construction of the disposal facility.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
I
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SOLID WASTES
SOLID WASTE DISPOSAL
Facility Design Criteria
OAC 3745-27-08 (C)(l)
through (9); (D) through
(H)
40 CFR 258.40
Subpart D
Open dumping or burning
ORC 3734.03
OAC 3745-27-05
40 CFR Part 257.3-7
Prescriptive engineering design specifications must be followed for the solid waste
landfill facility, including requirements for liner specifications, leachate management
systems, leachate storage, surface water control, benchmark location, access road
grading, groundwater control, explosive gas monitoring systems and structures,
composite and alternate cap systems, and the final cover.
Open dumping or burning of solid waste or infectious wastes is prohibited.
Applicable
Applicable
These requirements are applicable to
the on-site disposal facility. . The
prescriptive requirements needed for
construction of a solid waste landfill
will be performed. The OAC
requirements are more stringent than
the federal requirements, and
therefore become the pertinent
ARAR. Certification is not required
as specified in OAC 3745-27-08 (A)
and (B) because the FEMP is a
CERCLA site. However, the
substantive requirements will be
met.
This requirement is applicable to
site remediation.
SOLID WASTE DISPOSAL FACILITY OPERATIONS
Facility Operations
OAC 3745-27-09 (C),
(D) through (F);
(K) through (Q)
Daily Facility Operations
OAC 3745-27-09
(C) through (E), (F)(2);
(J) through (R)
OAC 3745-27-19
Solid waste landfill facility operations requirements.
This requirement specifies procedures for daily landfill operations and maintenance and
the types of waste that are acceptable.
Applicable
Applicable
These requirements are applicable to
the on-site disposal facility.
These requirements are applicable to
the on-site disposal facility.
FEMP-05ROD-6 F
December 15
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
W
fe
SOLID WASTE DISPOSAL FACILITY OPERATIONS {Continued)
Required Technical
Information
OAC 3745-7-06
(A)(B) and (C)
Ohio Solid Waste Disposal
Regulations
OAC 3745-27-19(N)
The minimum technical information required for a solid waste permit to install.
Included are a hydrogeologic investigation report, leachate production and migration
information, surface water discharge information, design calculations, and plan
drawings.
Section 3745-27-19(N) states the permittee shall submit to the Director of the OEPA,
upon every 10th anniversary of the effective date of a permit to install that approved the
initial construction of the facility, an analysis demonstrating that the design, construction
and final closure plan of the solid waste landfill facility continue to constitute the best
available technology. If the director of the OEPA determines that the design is no
longer consistent with best available technology as being applied to the solid waste
landfill industry in the state of Ohio, the permittee may be required to submit a permit
to install application for necessary modifications to the landfill facilities. If a permit to
install is required, the director of the OEPA shall not apply the siting criteria outlined in
paragraph (H) of OAC 3745-27-07 when considering the permit to install application.
Applicable
Relevant and
Appropriate
This paragraph presents the
substantive requirements of a solid
waste permit to install. This
requirement is applicable for a new
solid waste landfill facility. This
rule establishes the minimum
information required during the
remedial design stage.
A permit-to-install is not required
for the siting of an on-property
landfill at the FEMP because it is a
CERCLA site. However, the
substantive requirements will be met
through the CERCLA 5-year review
process.
SOLID WASTE DISPOSAL FACILITY CLOSURE
Final Closure of Solid
Waste Landfill Facilities
OAC 3745-27-11
(A),(B); (G)(l) through
(3), (7)
It is the responsibility of the permittee to complete final closure of the solid waste
landfill facility in a manner that minimizes the need for further maintenance and
minimizes postclosure formation and release of leachate and explosive gases to air, soil,
groundwater, or surface water to the extent necessary to protect human health and the
environment. The adequacy of closure methods must be approved by OEPA for cap
design, soil barrier layer, granular drainage layer and vegetative cover.
Applicable
These requirements are applicable to
the on-site disposal facility.
53
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation Requirement . ARAR/TBC Remarks
SOLID WASTE DISPOSAL FACILITY CLOSURE (Continued)
Postclosure Care of Solid
Waste Landfill Facilities
OAC 3745-27-14
(A)(l),(2)
RCRA Subtitle D
Postclosure Care •
EPA Criteria for
Municipal Solid Waste
Landfills
40 CFR §258.61
Following completion of final closure activities in accordance with Rule 3745-27-1 1 of
the Administrative Code, the owner or operator shall conduct postclosure care activities
at the solid waste landfill facility for a minimum of 30 years. Postclosure care activities
for all solid waste landfill facilities shall include, but are not limited to:
(1) Continuing operation and maintenance of the leachate management system, the
surface water management system, any explosive gas extraction and/or control
system, any explosive gas monitoring system, and the groundwater monitoring
system; and
(2) Maintaining the integrity and effectiveness of the cap system, including
making repairs as necessary to correct the effects of settling, dead vegetation,
subsidence, erosion, or other events, and preventing run-on and runoff from
eroding or otherwise damaging the cap system.
This requirement allows the State Director to direct the owner or operator to stop
managing leachate if the owner or operator demonstrates that leachate no longer poses a
threat to human health and the environment.
Applicable
Applicable
These requirements are applicable to
the on-site disposal facility.
These requirements 'are applicable to
the on-site disposal facility
WATER
SURFACE WATER
Pollution to Waters of the
State
ORC6111.04
Pollution to waters of the state is prohibited.
Applicable
This requirement is applicable to
any discharge to waters of the state.
Compliance with Water
Pollution Control
Requirements
ORC6111.07 (A)(C)
Failure to comply with water pollution control requirements is prohibited.
Applicable
See comment above.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation
Requirement
ARAR/TBC
Remarks
I
SURFACE WATER (Continued)
Ohio NPDES Permits
CWA
OAC 3745-33-05
ORC6111.042
40 CFR 122.41
Subpart C
The point source must be equipped with instrumentation to monitor and record data and
other information about the operation of the point source.
The permittee shall maintain in good working order and operate at optimum levels in
accordance with good engineering practices any wastewater treatment facilities or
control systems regardless of the quality of the effluent.
The permittee shall provide adequately trained and qualified personnel to operate the
wastewater treatment facility.
Applicable
The Ohio NPDES permit is
applicable because these
requirements are more stringent than
the federal regulations under the
Clean Water Act. These
requirements are applicable for point
source discharges to the Great
Miami River.
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•*>.
Storm Water Discharges
Associated with Industrial
Activity
40 CFR 122.26(a)(l)(ii)
40 CFR 122.26(b)(4)
and
OAC 3745-38
A discharge composed entirely of storm water associated with industrial activity must
obtain a NPDES permit.
These categories of facilities are considered to be engaging in'"industrial activity":
• Landfills, land application sites, and open dumps that receive or have received any
industrial wastes (waste that is received from any of the facilities described under
this subsection), including those that are subject to regulation under Subtitle D of
RCRA; and *»
• Construction activities including clearing, grading, and excavation that disturbs five
acres or more of total land area.
Applicable
The Ohio NPDES permit is
applicable because these
requirements are more stringent than
the federal regulations Under the
Clean Water Act. These
requirements are applicable for point
source discharges to the Great
Miami River.
Antidegradation Policy
OAC 3745-1-05
CWA
40 CFR 131.12
Existing instream water uses as defined in Rule 3745-1-07 of the Administrative Code
and designated in Rules 3745-1-08 to 3745-1-32 of the Administrative Code, shall be
maintained and protected. No further water quality degradation which would interfere
with or become injurious to existing designated uses is allowable.
Applicable
This requirement is applicable for
wastewater discharges to the Great
Miami River. Under CERCLA, the
State of Ohio has the overriding
authority for the antidegradation of
surface waters.
Analytical and Collection
Procedures
OAC 3745-01-03
Analytical methods and collection procedures for surface water discharge sampling are
specified.
Applicable
This requirement is applicable to
both discharges to surface waters as
a result of remediation and any on-
site surface waters affected by site
conditions.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
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Citation Requirement ' ARAR/TBC Remarks
SURFACE WATER (Continued)
National Pollutant
Discharge Elimination
System; Wastewater
Discharges Resulting
From Clean-up of
Response Action Sites
Contaminated with
Volatile Organic
Compounds
OEPA Policy #DSW-
DERR 0100.027
Establishes response action guidelines for treatment technologies and discharge criteria
for VOCs to be discharged to surface water.
TBC
This OEPA policy provides
guidance for wastewater discharges
which contain VOCs.
GROUNDWATER MONITORING
Monitoring Well System
OAC 3745-27-10
(A) and (B)
Groundwater Monitoring
Program
OAC 3745-27-10 (C) and
(D)
Groundwater Quality
Assessment Program
OAC 3745-27-10 (E) and
(P)
Corrective Measures
Study
3745-24- 19(F)
Groundwater monitoring program requirements of new landfill facilities include
background monitoring, detection monitoring and postclosure monitoring. The
groundwater monitoring system will consist of a sufficient number of wells installed at
appropriate locations and depths to yield groundwater samples from both the uppermost
aquifer system and any significant zones of saturation.
Sampling and analyses procedures must be designed to provide accurate representation
of groundwater quality at the background and downgradient wells. Sampling and
analysis procedures must be documented in a written plan. If the landfill facility owner
deviates from the monitoring parameters listed in OAC 3745-27-10 (D)(3) to (D)(6),
then an alternate list may be proposed to the Director. In addition, a written quality
assessment program must be prepared.
If a statistically significant change from background levels is identified for each
parameter or constituent being monitored, then the landfill owner must submit a quality
assessment program within 15 days. The plan must determine:
(1) If leachate or leachate-derived constituents have entered the groundwater
(2) The rate and extent of migration of leachate or leachate-derived waste in the
groundwater
(3) The concentrations of leachate or leachate-derived waste in groundwater.
After 180 days of determining that contaminants have leached from the landfill, a
corrective measures study must be submitted to OEPA. Remediation must include
meeting MCLs in groundwater for a risk-level of 1 x 10"6 for a cumulative lifetime risk
to an individual.
Applicable
Applicable
Applicable
Applicable
These requirements are applicable to
the on-site disposal facility.
These requirements are applicable to
the on-site disposal cell. An
alternate list of monitoring
parameters will be required
from those specified in
OAC 3745-27-10(D)(3) to (D)(6).
These requirements are applicable to
the on-site disposal facility.
These requirements are applicable to
the on-site disposal facility.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
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a
Citation Requirement . ARAR/TBC Remarks
GROUNDWATER WELLS
INJECTION
Unauthorized Injection
into Groundwater
OAC 3745-34-07
Injection of Class IV
Wells
OAC 3745-34-08
Underground Injection
Control Program
OAC 3745-34-01
OAC 3745-34-13
Injection of Wastes into
Wells
ORC6111.043
ORC6111.044toORC
611.049
OEPA Policy 5X26
Aquifer Remediation
Projects
Movement of fluid into underground sources of drinking water that contains a
contaminant which may cause a violation of any primary drinking water regulation
under OAC 3745-8 is prohibited.
Injection of hazardous or radioactive waste in Class IV wells is prohibited unless
approved by the Director pursuant to provisions for cleanup of releases under
Chapter 3734 of the Revised Code, CERCLA (42 U.S.C. 9601-9657), or RCRA
(42 U.S.C. 6901-6987).
Injection into existing and new Class V wells is authorized by rule pursuant to Section
6111.043 of the Ohio Revised Code until further requirements under future rules
become applicable, unless injection is of sewage, industrial wastes or other wastes, as
defined in Section 6111.01 of the Ohid Revised Code, into or above an underground
source of drinking water.
These sections of the Ohio Revised Code establish a program for regulations of the
injection of sewage, industrial waste, hazardous waste, and other wastes into wells in
order to control pollution of the waters of the state, to prevent contamination of
underground sources of drinking water, and to satisfy all requirements of the Safe
Drinking Water Act regarding injection wells as defined in regulations adopted under
that act.
This OEPA policy outlines requirements for groundwater remediation via subsurface
injection of fluids.
Applicable
Applicable
Applicable
Applicable
TBC
This requirement is applicable to
injection of groundwater.
This requirement is applicable to
injection of groundwater.
This requirement is applicable to the
reinjection of treated groundwater
into the GMA rather than
'discharging it to the Great Miami
River.
This requirement is applicable to the
reinjection of treated groundwater
into the GMA rather than
discharging it to the Great Miami
River.
This OEPA policy will provide
guidance for the reinjection of
treated groundwater into the GMA.
WELL CONSTRUCTION
Water Pollution from a
Solid Waste Disposal
Facility
40 CFR 257.33
Siting Monitoring Wells
OAC 3745-9-04 (A)
Water pollution from a solid waste disposal facility is prohibited.
New wells should be located where they can be maintained, and where protection of
groundwater, human health and the environment is maintained.
Applicable
Applicable
This requirement is applicable for
the on-property disposal facility.
This requirement is applicable for
the installation of new wells.
FEMP-O5ROD-6 FINAL
December 15, 1995
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
Citation Requirement ARAR/TBC Remarks
WELL CONSTRUCTION (Continued)
Monitoring Well
Construction
OAC 3745-9-05 (A)(l)
and (B) through (H); 06
(A)(B)(D) and (E); 07
(A), (B), (C), (E), and (F)
Pumping Wells
OAC 3745-9-08
Paragraph (C)
Monitoring Well
Maintenance and
Modification
OAC 3745-9-09 (A)
through (C), and (E)
through (G)
New wells must be constructed with the specified criteria of this requirement to avoid
contamination of groundwater.
Pumps may only be primed with potable water.
Monitoring wells must be maintained or modified to avoid cross-contamination of
groundwater.
Applicable
Applicable
Applicable
See comment above.
This requirement is applicable for
all well pumps that require priming.
This requirement is applicable for
all groundwater wells.
WELL ABANDONMENT
Abandonment of Test
Holes and Wells
OAC 3745-09-10
Upon completion of testing, a test hole shall be either completely filled with grout or
such other material as will prevent contaminants from entering groundwater.
Applicable
This requirement is applicable to all
groundwater wells on the site that
either will be installed or have been
installed since February 15, 1975.
POLYCHLORINATED BIPHENYLS (PCBs)
PCB DISPOSAL
Disposal Requirements
TSCA
40CFR761.60(a)(4)
Subpatt D
Any nonliquid PCBs at concentrations 50 ppm or greater in the form of contaminated
soil, rags, or other debris shall be disposed of in an incinerator or in a chemical waste
landfill.
Applicable
In the event soil containing PCBs
above 50 ppm is excavated, this
requirement is applicable. PCBs
were detected in soil beneath the
fire training facility.
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TABLE B.3 (Continued)
ACTION-SPECIFIC REQUIREMENTS FOR THE OPERABLE UNIT 5 SELECTED REMEDY
o
I
Citation
Requirement
ARAR/TBC
Remarks
PCB TREATMENT
TSCA
40CFR761.60(e)
Subpart D
Any person who is required to incinerate PCBs or PCB items under this subpart and
who can demonstrate that an alternate method of destroying PCBs or PCB items can
achieve a level of performance equivalent to the requirements under 40 CFR 761.70
may submit a written request to either the Regional Administrator or the Director,
Exposure Evaluation Division, for an exemption from the incineration requirements of
761.70 or 761.60. The applicant must show that the alternate method of destroying
PCBs will not present an unreasonable risk of injury to health or the environment.
Applicable
This requirement is applicable only
if PCB contaminated soil is greater
than SO ppm and is treated
on-property using a method besides
incineration.
PCB STORAGE
Storage for Disposal
TSCA
40 CFR 761.65
Subpart D
This section applies to the design of storage areas to be used for later disposal of PCBs
at concentrations of SO ppm or greater.
Applicable
This requirement is applicable for
storage of PCB-contaminated soil at
50 ppm or greater.
w
oo
OTHER REGULATIONS
NOISE CONTROL
Noise Control Act, as
amended
42USC4901,etseq.
Noise Pollution and
Abatement Act
42 USC 7641
The public must be protected from noises that jeopardize health and welfare.
Applicable
Because equipment and vehicles
would be involved in certain aspects
of the proposed action, all
substantive requirements of the act
are applicable. However,
appropriate engineering controls and
best management practices will be
implemented to reduce nuisance
noise to the maximum practicable
extent during conduct of the
proposed actions.
HAMILTON COUNTY EARTHWORK REGULATIONS
Erosion Control
Specifications
Hamilton County
Earthwork Regulations
Department of Public Works — temporary and/or permanent erosion and sediment
control features and devices shall be designed and constructed in accordance with the
State of Ohio Temporary Erosion Control Specifications.
TBC
This requirement is not an ARAR
because it is not promulgated. This
requirement will be considered for
activities that involve excavation,
erosion, and sediment control
features.
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TABLE B.4.A
METHOD OF COMPLIANCE WITH CHEMICAL-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Chemical ARAR
Method of Compliance
Applicable Chemical-Specific Federal ARARs
EPA Regulations on National Emission Standards for Hazardous Air
Pollutants
40 CFR 61
National Emission Standards for Emissions of Radionuclides other
than Radon from DOE Facilities
Subpart H
Existing site conditions currently attain compliance with this regulation through the application of
appropriate waste management and maintenance activities.
Dust suppression techniques will be implemented during all phases of remedial action involving the
handling of contaminated materials. Additionally, all soil treatment and wastewater treatment operations
with a potential to emit radionuclides to the environment will be equipped with emission control devices
(i.e., HEPA filters, etc.).
National Emission Standard for Radon Emissions from DOE Facilities
40 CFR 61 Subpart Q
Lead in Air
40 CFR 50. 12
The existing distribution of contaminants within the affected
environmental media in Operable Unit 5 attains compliance with this requirement.
The disposal facility design would accommodate sufficient barriers to ensure continued
compliance.
Compliance will be met.
Relevant and Appropriate Chemical-Specific Federal ARARs
National Primary Drinking Water Standards, Maximum Contaminant
Levels and Proposed Maximum Contaminant Levels
40 CFR 141.11,
40 CFR 141. IS and
40 CFR 141.16
The existing conditions exhibit concentrations of contaminants in the aquifer exceeding MCL or proposed
MCL concentrations.
Affected groundwater in the glacial till (1 gpm sustained yield) and GMA exhibiting greater than MCL or
proposed MCL concentrations will be extracted with recovery wells. The pumping/excavation operation
is anticipated to reduce contaminant concentrations to less than the MCLs or proposed MCLs at all points
in the aquifer system at and beyond the point of compliance.
Federal Nonzero Maximum Contaminant Level Goals for Organic and
Inorganic Chemicals
40 CFR 141.12,
40 CFR 141.50 and
40 CFR 141.51
See comment above
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TABLE B.4.A (Continued)
METHOD OF COMPLIANCE WITH CHEMICAL-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Chemical ARAR
Method of Compliance
Relevant and Appropriate Chemical-Specific Federal ARARs (Continued)
The National Primary Drinking Water Standards, Maximum
Contaminant Levels for Organic and Inorganic Chemicals
40 CFR 141.61 and
40 CFR 141.62
See comment above
Health and Environmental Protection Standards for Uranium and
Thorium Mill Tailings
40 CFR 192.02, Subpart A; 192.12(a), Subpart B; 192.20, Subpart
C; 192.21(f) and 192.22(b), Subpart C; 192.32(b)(2), Subpart D;
192.40-192.42, Subpart E
Select portions of the site exhibit existing concentrations exceeding these requirements.
Soil excavation efforts for radioactive environmental media will reduce the concentration of
radium-226/radium-228/thorium-230 to required levels, in addition to reducing other residual radioactivity
levels to attain final remediation levels.
Chemicals in Drinking Water for a Solid Waste Disposal Facility
40 CFR 257.4
Chemicals in Drinking Water for a Hazardous Waste Disposal
Facility
40 CFR 264.94
Lead Soil Cleanup Standards (Resource Conservation and Recovery
Act)
40 CFR 268.41
Waste generated from remedial activities may be
disposal facility would be designed and the WAC
underlying regional aquifer system. Through the
standard would be attained.
disposed of in an on-property disposal facility. The
established to ensure the continued protection of the
engineering design, complemented by the WAC, this
See comment above
Soil exceeding these standards would be excavated and placed in the on-property disposal facility.
Applicable Chemical-Specific Ohio ARARs '
Ohio Water Quality Standards for Surface Water
OAC 3745-1-04 and
OAC 3745-1-07
All surface water discharges will be controlled to the Great Miami River (permitted under NPDES) and
to Paddys Run during the period of active remediation. Storm water, process wastewaters, sanitary
sewage, and recovered groundwater will be managed to ensure the water quality standards are attained.
The AWWT system and an expansion of this facility will be employed to treat wastewater, storm water,
and recovered groundwater, as required, to ensure compliance with the standards.
Relevant and Appropriate: Chemical-Specific Ohio ARARs
General Radiation Protection Standards
OAC 3701-38-15(A)(l),(B)
Compliance will be met.
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TABLE B.4.B
METHOD OF COMPLIANCE WITH LOCATION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Location ARAR
16 U.S.C. 470, National Historic Preservation Act
and 36 CFR 60, 60.4, 63, 800
16 U.S.C. 1531, et seq., Endangered Species Act
50 CFR 402.01, 402.12,
Interagency Cooperation- Endangered Species Act
Archaeological Resources Protection Act
(16 USC §47099-47011)
43 CFR 7.4 (a), Protection of Archaeological
Resources
16 U.S.C. 431-433, Antiquities Act of 1906
16 U.S.C. 461-467, 469, and 470 Historic Sites
Preservation Act
25 U.S.C. 3001, Native American Graves
Protection and Repatriation Act
42 U.S.C. 1996, American Indian Religious
Freedom Act
42 U.S.C. 1424(e), Safe Drinking Water Act
Method of Compliance
Applicable Location-Specific Federal ARARs
Prior to remedial activities, surveys will be conducted to determine the presence of any cultural resources.
Cultural resources identified will be either avoided or managed in consistence with this requirement as agreed upon
with DOE, SHPO, and the Advisory Council in a signed programmatic agreement. Compliance will be met.
Studies are being conducted to determine the presence of individuals and potential habitat of federally and state-
listed animal and plant species. If habitat or individuals are found, appropriate mitigative measures would be
implemented. Compliance will be met.
Compliance will be coordinated through Section 106 of the National Historic Preservation Act.
Compliance will be coordinated through Section 106 of the National Historic Preservation Act.
Compliance will be coordinated through Section 106 of the National Historic Preservation Act.
Compliance will be coordinated through Section 106 of the National Historic Preservation Act.
Prior to remedial activities, surveys will be conducted to determine the presence of these cultural resources.
Cultural resources identified will be either avoided or managed in consistence with this requirement. Compliance
will be met.
Operable Unit 5 overlies a sole source aquifer (Great Miami Aquifer), which has been contaminated by site
process activities. Contaminants will be removed to health-protective levels during remedial activities.
Compliance will be met.
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TABLE B.4.B (Continued)
METHOD OF COMPLIANCE WITH LOCATION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
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Location ARAR
Method of Compliance
Applicable Location-Specific Ohio ARARs (Continued)
DOE Compliance with Flood Plain/Wetlands
Review Requirements
10 CFR 1022.3(a), (b)(l), (2), (3), (5), (6), (c),
(d), (e): .5(b), (h), ll(a), (b), (c), .12(a), .15(a)
Dredge and Fill
33 CFR 323, 330,
40 CFR 230
Procedure for Implementing the National
Environmental Policy Act
40 CFR 6.301(c)
Executive Order 11990, Protection of Wetlands
40 CFR 6.302(a)
Executive Order 11988, Protection of Floodplains
Procedure for Implementing the National
Environmental Policy Act
40 CFR 6.302(h)
Location of Solid Waste Disposal Facilities
40 CFR 257.3-2
40 CFR 258.12
A wetland delineation has identified freshwater wetlands within the 1050 acre FEMP property boundary. Remedial
activities relative to wetland impacts will be handled through the U.S. Army Corps of Engineers Nationwide
Permit (NWP) Program where possible. When not covered by a NWP, the action will meet requirements
mandated by individual permits per 33 CFR 323. Compliance will be met.
See above comment.
Substantive requirements will be met through the revised secretarial policy on NEPA. Compliance will be met.
Remedial design will minimize impacts to wetlands. Any unavoidable impacts will be undertaken in accordance
with 33 CFR 323 or 330. Any potentially impacted wetlands will be mitigated. Compliance will be met.
Remedial activities will minimize impacts to Floodplains. Impacted Floodplain areas would be backfilled with
clean soil and regraded to avoid alteration of flow patterns or uses of the Floodplain.
Substantive requirements will be met through the revised secretarial policy on NEPA. Compliance will be met.
Any planned disposal facility will be located so at to attain these statutory requirements.
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TABLE B.4.B (Continued)
METHOD OF COMPLIANCE WITH LOCATION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
CO
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Location ARAR
Method of Compliance
Applicable Location-Specific Ohio ARARs (Continued)
Protection of Endangered and Threatened Wildlife
and Plants
50 CFR 17.21, 17.31, 17.61, 17.71, and 17.94
Protection and Enhancement of Cultural
Environment
Executive Order 11593
3 CFR 154
All Federal agencies must ensure that any action authorized, funded, or carried out by them is not likely to
jeopardize the continued existence of any listed species or result in the destruction or adverse modification of the
constituent elements essential to the conservation of a listed species within a defined critical habitat. Additional
requirements apply if it is determined that a proposed activity could adversely affect these species or their habitat.
Compliance will be met.
Compliance will be met for identification and preservation of cultural resources on Federal land, including
landmarks.
natural
Relevant and Appropriate Location-Specific Federal ARARs
None Identified
v>
Applicable Location-Specific Ohio ARAR$
Ohio Endangered Species Regulations
OAC 1501: 18-1
ORC 1518.02 and
ORC 1531.25
Hazardous Waste Facility Environmental Impact
OAC 3734.05 (D)(6)(c)
Hazardous Waste Facility Minimum Risk
OAC 3734.05 (D)(6)(d)
Compliance will be met.
Compliance will be met.
Compliance will be met.
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TABLE B.4.B (Continued)
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METHOD OF COMPLIANCE WITH LOCATION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Location ARAR
Method of Compliance
Applicable Location-Specific Ohio ARARs (Continued)
Water use for Southwestern Ohio Tributaries
OAC 3745-01-17 and
OAC 3745-01-21
Ohio Solid Waste Regulations
OAC 3745-27-07(A) and (B) and
OAC 3745-27-09(Y)
State Water Quality Certifications
OAC 3745-32-02
Compliance will be met.
Any proposed disposal facility will be sited such that the facility and any associated leachate collection system will
be located out of a floodway or floodplain.
Required certifications would be attained prior to completing excavation or backfill operations within wetlands or
waters of the United States. Compliance will be attained.
Relevant and Appropriate Location-Specific Ohio ARARs
None Identified
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TABLE B.4.C
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Action-Specific ARAR
Method of Compliance
Applicable Action-Specific Federal ARAR$
Preparing and Transporting Hazardous Waste Off-Site
40 CFR 262.20 through 262.23, .30 and .33
Subparts B and C
OAC 3745-53-20 through 31
OAC 3745-52-30 and 33
Groundwater Monitoring Program
40 CFR 265.90(d)
Subpart F
OAC 3745-65-90(d)
Corrective Action Management Unit
40 CFR 264.552
Subpart S
Air Emission Standards for Process Vents
40 CFR 264.1030, 264.1032 through 264.1034
Subpart AA
Land Disposal Restrictions and Contaminated Debris
40 CFR 268.40 through 268.44, 268.45
Subpart D
OAC 3745-59
Water Pollution from a Solid Waste Disposal Facility
40 CFR 257.3-3
Hazardous waste that will be disposed of off site will comply with all substantive
and administrative requirements.
This requirement is being met via the September 10, 1993, Ohio EPA Director's
Final Findings and 'Orders (DFOs). These requirements will be considered during
the development of a long-term monitoring program during RD/RA.
A CAMU is designated at the FEMP to include the area within the FEMP property
boundaries for remedial action. Releases of contaminants that originated from the
FEMP and have reached off-property areas will also be managed within the
CAMU. The CAMU also includes the on-property disposal facility.
Units that treat soil and waste contaminated with organic compounds will comply
with air emission standards by employing control devices and monitoring.
Hazardous waste and associated debris will be treated to treatment standards for
off-site disposal. On-property disposal will not require land-disposal treatment
standards because of management under the CAMU Rule.
The on-property disposal facility design will aid in compliance with this
requirement.
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Action-Specific ARAR
Method of Compliance
Applicable Action-Specific Federal ARARs (Continued)
Postclosure Care
40CFR265.117
Subpart G
OAC 3745-66-17
Underground Storage Tank (UST) Closure
40 CFR 280.60 through 280.66
Subpart F
OAC 1301:7-7-36
Best Management Practices (BMP) Programs
40 CFR 125.104
Subpart K
PCB Disposal, Treatment, and Storage
40 CFR 761.60(a)(4), (e), and 761.65
Subpart D
Noise Control
42 USC 4901
42 USC 7641
Particulate Air Emissions
40 CFR 50.6 (a), (b), (c)
Empty Containers of Hazardous Waste
40 CFR 261.7
Subpart A
OAC 3745-51-07
Postclosure care requirements will be met for residual contaminants at the site
which exceed risk-based cleanup values (i.e., the on-property disposal facility).
The requirement will be satisfied by including such monitoring and maintenance
requirements into the operations & maintenance phase and long-term monitoring
program of the CERCLA response action.
All USTs and related petroleum-contaminated soil will undergo full closure per the
requirements during the CERCLA remedial action.
The BMP requirements will be met via conducting the FEMP's BMP Plan. The
BMP Plan will be progressively updated to accommodate changing site activities
during the conduct of CERCLA remedial actions.
Soil containing PCBs will be excavated to attain the final remediation levels.
Excavated soil will be dispositioned consistent with the WAC.
Engineering controls and best management practices will be implemented to reduce
noise to the maximum extent practicable during the remedial action.
Compliance will be met.
Containers that have held hazardous wastes will be considered empty if the
requirements in the rule are met.
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Action-Specific ARAR
Method of Compliance
Relevant and Appropriate Action-Specific Federal ARARs
Hazardous Waste Determination
40CFR262.il
Subpart A
OAC 3745-52-11
Soil exceeding the WAC will be treated for on-property disposal or dispositioned
off site. Materials destined to off-site disposal will be properly characterized to
complete the necessary hazardous waste determination.
Groundwater Protection Standard
40 CFR 264.92 through 246.100
Subpart F
OAC 3745-54-92 through 100
Groundwater monitoring for the on-property disposal facility will comply with the
substantive requirements.
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Storage Area Closure
40 CFR 264.178
SubpartI
OAC 3745-55-78
Substantive closure requirements for container storage areas involving hazardous
wastes will be met after the storage area is no longer needed for the CERCLA
remedial action.
Minimum RCRA Landfill Design Requirements for Closure
40 CFR 264.310
Subpart N
OAC 3745-68-10
The final closure substantive requirements will be met in the on-property disposal
facility design.
Containment Building
40 CFR 264.1100 through .1102
Subpart DP
Design and operation of the containment building(s) will comply with the design,
operation, and closure and postclosure care substantive requirements unless
provisions of the CAMU rule are applied.
§ 70
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
Action-Specific ARAR
Method of Compliance
Relevant and Appropriate Action-Specific Federal ARARs (Continued)
O
Treatment, Storage, and Disposal
General Facility Standards
40 CFR 265.13 through 265.16
Subpart B
OAC 3745-65-13 through 16
Treatment, Storage, and Disposal Facility
Preparedness and Prevention
40 CFR 265.31 through 265.35, 265.37
Subpart C
OAC 3745-65-31 through 35, 37
Treatment, Storage, and Disposal Facility
Contingency Plan and Emergency Procedures
40 CFR 265.51 and 265.52, 265.55 and 265.56
Subpart D
OAC 3745-65-51 and 52, 55 and 56
All general RCRA facility standards will be met during the CERCLA remedial
action as necessary for activities involving the management of hazardous waste.
Closure Performance Standard for HWMUs
40 CFR 265.111,265.114
Subpart G
OAC 3745-66-11 and 14
All HWMUs will be closed clean or closed with the CERCLA process. The
HWMU structures and contaminated soil will be fully addressed by
decontamination and dismantlement under OU3, and excavation, treatment, and on-
or off-site disposal of soil under OU5.
Condition of Containers
40 CFR 265.171 through 265.174, 265.175(a)-(c), 265.176, and 265.177
Subpart I
OAC 3745-66-71 through 74, 76, 77
OAC 3745-55-75
Container storage requirements for hazardous wastes will be complied with by
following the FEMP drum management plan as required by the SACD. Container
storage areas for hazardous waste will meet the requirements for containment
systems.
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
I
I
s
pd
4*
O
6,
Action-Specific ARAR
Method of Compliance
Relevant and Appropriate Action-Specific Federal ARARs (Continued)
Closure of Tank Systems
40 CFR 265.197
Subpart J
OAC 3745-66-97
Control of Residual Radioactive Materials
40 CFR 192.02(a)
Subpart A
Implementation
40 CFR 192.20
Subpart C
Management of Uranium Byproduct Materials
40 CFR 192.30 through 34
Subpart D
Solid Waste Disposal Facility Design Criteria
40 CFR 258.40
Subpart D
PCB Cleanup Policy
40 CFR 761. 120, .125, .130
Subpart G
Existing tank and container storage HWMUs are proposed to be closed through an
integrated RCRA/CERCLA process. The affected soil associated with these
HWMUs will be removed to attain final remediation levels for each COC to fulfill
RCRA closure requirements. Any new tank system or container storage facilities
installed to facilitate CERCLA remedial actions will be "closed" consistent with
these substantive requirements.
The control standards will be met in the design and operation of the cm-property
disposal facility multilayered capping system.
Compliance with the implementation requirements is met through the use of a
verification and certification sampling program and the use of groundwater models
for evaluating the long-term effectiveness.
The design of the on-property disposal facility capping system will attain these
standards.
The on-property disposal facility design will, at a minimum, comply with the
federal design standards for municipal solid waste landfills.
Soil containing PCBs will be excavated as necessary to attain final remediation
levels. Removed soil will be dispositioned consistent with the WAC.
2
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
o
1
x
H
1
(O
I
W
h
Action-Specific ARAR
Method of Compliance
Applicable Action-Specific Ohio ARARs
Analytical and Collection Procedures
OAC 3745-01-03
Antidegradation Policy
OAC 3745-01-05
40CFR131.12
Abandonment of Test Holes and Wells
OAC 3745-09-10
Malfunction and Maintenance of Air Pollution Control Equipment
OAC 3745-15-06
(A)(l) and (A)(2)
General Provisions on Air Pollution Control
OAC 3745-15-07
ORC 3734.02 (I)
Stack Height Requirements
OAC 3745-15-12
(B) and (C)
Restriction on Paniculate Emissions from Industrial Processes
OAC 3745-17-11
Prohibits Commingling of Low-level Radioactive Waste with Solid Waste
ORC 3734.02.7 (A)(B)
Open Dumping or Burning
OAC 3734.03
The analytical methods and collection procedures specified in this requirement will
be utilized to the extent necessary for surface water discharges.
The remedial action will ensure that water quality for Paddys Run and the Great
Miami River will not be degraded.
Existing FEMP water supply wells and all wells used in support of the RI/FS,
removal actions, remedial actions, and RCRA groundwater monitoring will be
properly plugged and abandoned in accordance with abandonment requirements
after they are no longer needed.
Scheduled maintenance will be established for pollution control equipment, as well
as times when the pollution source will be shut down during maintenance.
Air pollution nuisance prohibitions will be met by employing best management
practices such as dust control and air monitoring during the CERCLA remedial
action.
The stack height requirements will be met for alternatives using low-temperature
thermal desorption units.
Emission restrictions will be met during stabilization and any treatment by using
proper operations, maintenance, management, and monitoring.
Material to be disposed off site will only be sent to facilities licensed under the
Atomic Energy Act of 1954.
No open dumping or burning of solid waste will be performed during remedial
action.
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
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w
o
Action-Specific ARAR
Method of Compliance
Applkable Actk>n-Sp€cifk Ohto ARARs (Continued)
Particulate Ambient Air Quality Standards
OAC 3745-17-02 (C)(D)
Particulate Ambient Air Quality Standards
OAC 3745-17-05
Solid Waste Disposal Facility Construction Requirements
OAC 3745-27-08(C)(l) through (9), (D) through (H)
Solid Waste Disposal Facility Operations
OAC 3745-27-09(D) through (F), (K) through (Q)
OAC 3745-27-19
Groundwater Monitoring
OAC 3745-27-10
Solid Waste Disposal Facility Closure
OAC 3745-27-1 1(B);(G)(1) through (3), (7)
Solid Waste Disposal Facility Post Closure
OAC 3745-27-14
Underground Injection Control Program
OAC 3745-34-01
OAC 3745-34-07
OAC 3745-34-08
OAC 3745-34-13
Pollution to Waters of the State
ORC 6111.04
ORC 6111.07 (A)(C)
Compliance will be met.
Compliance will be met.
The on-property disposal facility construction design will meet the solid waste
landfill substantive design requirements.
The on-property disposal facility operations will meet these requirements.
Groundwater monitoring for the on-property disposal facility will fulfill these
requirements.
Final "closure" of the on-property disposal facility will meet these requirements.
Substantive requirements for postclosure care of the on-property disposal facility
will be included in the operations and maintenance phase of the CERCLA response
action.
The reinjection of treated groundwater into the GMA will comply with substantive
requirements.
Compliance with water pollution control requirements will be met.
FEMP-5ROD-6 FINAL
December 15, 1995
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TABLE B.4.C. (Continued)
METHOD OF COMPLIANCE WITH ACTION-SPECIFIC ARARs FOR OPERABLE UNIT 5 SELECTED REMEDY
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X
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I
CO
4k
o
oo
Action-Specific ARAR
Method of Compliance
ApplfcaWe Action-Specific Ohio ARAKs (Continued)
Injection of Wastes into Wells
ORC6111.043
ORC 6111.044 to ORC 6111.049
The reinjection of treated groundwater into the GMA will comply with substantive
requirements.
Relevant and Appropriate Action-Specific Ohio ARARs
Abandonment of Test Holes and Wells
OAC 3745-09-10
Quality Standards, Particulate in Air
OAC 3745-17-07, (B)(4), (5), (6)
Restriction of Emission of Fugitive Dust
OAC 3745-17-08
Ohio NPDES Permits
OAC 3745-33-05
40 CFR 122.41
Subpart C
All monitoring wells, piezometers and lysimeters will be plugged and abandoned
per these requirements after they are no longer needed.
Appropriate mitigative measures will be applied to all excavations and material
movement activities to reduce fugitive emissions. All point sources associated with
a' remedial alternative (i.e., sludge dewatering, etc.) will employ best available
emissions control technologies to mitigate particulates emissions.
Fugitive dust control will be achieved by employing control measures during
grading, loading, and construction operations while soil is handled.
Compliance with general permit conditions for wastewater discharges will be met
by employing proper operation and maintenance and monitoring during the
operations and maintenance phase of the CERCLA response action.
Hazardous Waste Storage Piles
OAC 3745-56-51 (A) through (F), 54 (A) and (B), 56 (A) and (B),
57 (A)(B) and (C), 58 (A)(B) and (C).
40 CFR 264.551 through .259
All general RCRA waste pile standards will be met during the CERCLA remedial
action as necessary for activities involving the management of hazardous waste.
Monitoring Well Requirements
OAC 3745-9-04 (A) and (B)
OAC 3745-9-05 (A)(l) and (B) through (H); 06 (A)(B)(D) and (E);
07 (A), (B), (C), (E), and (F)
OAC 3745-9-09 (A) through (C), and (E) through (G)
OAC 3745-9-08 Paragraph (C)
Monitoring well requirements will be met to ensure protection of human health and
the environment.
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