United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R08-92/064
April 1992
PB93-964404
SEPA Superfund
Record of Decision:
Rocky Flats Plant (USDOE)
-------
NOTICE
The appendices listed in the index that are not found in this document have been removed at the reQuest of
the issuing agency. They contain materiaJ which supptement. but adds no further applicable information to
the content of the document. All supplemental material is. however, contained in the administrative record
-------
, 50272-101
REPORT DOCUMENTATION '1,. REPORTNO.
PAGE I EPA/ROD/R08-92/064
I ~
3. Reclplenta AcC88810n No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Rocky Flats Plant (USDOE) (Operable
Third Remedial Action - Interim
7. Author(a)
5. Report Daw
04/06/92
Unit 4), CO
6.
8. Performing Orllaniza1l0n RefIt. No.
9. Performing Orllainiza1l0n Name and Addre..
10. Projec1lTa8klWorIc Unit No.
11. Con1l'8c1(C) or Grant(G) No.
(C)
(G)
.
1~ Sp-orinII OrIl8niza1ion Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ... Period Covered
Agency
800/000
14.
15. Supplement8ry Notea
PB93-964404
16. Abenct (Unlit: 20D worda)
The Rocky Flats Plant (USDOE) (OU4) site is part of the 6,SOO-acre nuclear weapons
research, development, production, and plutonium processing complex in Jefferson
County, Colorado. The plant is composed of the 4S0-acre Rocky Flats Plant (RFP)
security area and the remaining buffer area. Land use in the area is predominantly
rural, agricultural, commercial, and industrial, with several residential areas within
5 miles of the site. Since 1951, the Department of Energy (DOE) has used the site to
manufacture components of nuclear weapons; process plutonium; fabricate, machining, and
assemble components from metals. The central portion of RFP contains the Solar
Evaporation Pond (SEPs) Waste Management Unit, including Ponds 207-A, 207-8 North,
207-B Center, 207-8 South, 207-C, and the Interceptor Trench System (ITS). The SEPs
were formerly used to store and treat liquid process waste having less than
100,000 picocuries (pci/l) per liter of total long-lived alpha activity. These process
wastes also contained high concentrations of nitrates as well as treated acidic wastes
containing aluminum hydroxide. The ponds are known to have received other wastes,
including sanitary sewer sludge, lithium chloride, lithium metal, sodium nitrate,
ferric chloride, sulfuric acid, ammonium persulfates, hydrochloric acid, nitric acid,
(See Attached Page)
17. Doclllll8llt Analy.a L Deac:riptora
Record of Decision - Rocky Flats Plant (USDOE) (Operable Unit 4), CO
Third Remedial Action - Interim
Contaminated Medium: sw
Key Contaminants: VOCs (TCE) , metals (chromium), radioactive materials
b. Identi1ier8l0pen-Ended Terrna
c. COSA TI ReIdIGroup
18. AvailabiUty Statement
19. Security Cia.. (Thia Report)
None
21. No. of Pall"
114
I
20. Security Cia.. (Thia Page)
None
22.. Prlca
(See ANSl-Z3S.18)
See Inetruc/Jone on Rev.,..
4-77)
(Formerty NTlS.35)
-------
EPA/ROD/R08-92/064
Rocky Flats Plant (USDOE) (Operable
Third Remedial Action - Interim
Unit 4), CO
stract (Continued)
hexavalent chromium, tritium, and cyanide solutions. Sludge from the SEPs was removed
periodically to implement repair work on the pond liners and as part of routine waste
management activities. Removed sludge was mixed with Portland cement and solidified as
a mixture of sludge and concrete for shipment for offsite disposal. In 1986, placement
of process waste material into these ponds ceased. From 1971 to 1974, construction of
interceptor trenches was initiated to prevent natural seepage and pond leakage from
enterin~ North Walnut Creek. In 1981, the system was replaced by the current ITS,
which collects an estimated 4 million gallons per ¥ear for discharge to the 207-8
ponds. This interim ROD addresses management and treatment of liquids contained in
ponds 207-A, 207-8 North, 207-8 Center, 207-8 South, and the water collected by the ITS
as the OU4 at the site. Future RODs will address removal and solidification of the
sludge, and. will further investigate, and characterize the sit~. The primary
contaminants of concern affecting the surface water are VOCs, including TCE and carbon
tetrachloride; metals, including chromium; and radioactive materials.
The selected interim remedial action for this site includes constructing and utilizing
three temporary surge tanks and associated piping to contain and transfer water
collected by the ITS; evaporating approximately 3 million gallons of water from pond
207-A and 5 million gallons of water from the 207-8 ponds using onsite flash
evaporator~ and associated. tanks; transferring the distillate to a holding tank for
reinjection into the Raw Water System for plant cooling tower usage; collecting the
flash evaporator concentrate in holding tanks; and onsite solidification of the
residual; and conducting treatability studies using surrogate pond water to simulate
the proposed treatment system. The estimated total cost for this interim remedial
ction is $8,017,000, which includes an annual O&M cost of $1,170,000 for 3 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific surface
based on site-specific radionuclide standards and MCLGs or
relevant CWA water quality criteria.
water clean-up goals are
MCLs and attainment of
~
-------
,o~"
t)L", '.r:l~
. . ,'.'", ~"~'.. - ...1)
.., . . lot( Branch
_:co
4
, I; ~
~INAL
PROPOSED
INTERIM MEASURE/INTERIM REMEDIAL ACTION
DECISION DOCUMENT FOR
THE SOLAR EVAPQRATION PONDS
OPERABLE UNIT NO.4
u.s. DEPARTMENT OF ENERGY
,Rocky Flats Plant
Golden, Colorado
April 1992
-------
TABLE OF CONTENTS
" ".
PAGE
""'. .
LIST OF TABLES
. . . . . . . . . . . . . . . . . . . . . . ',' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. v
. LIST OF FIGURES. . . . . . . . . . . . '. . . . . . . . . . . . . . . . . . . '.' . . . . . . . . . ',' . ; . . . . . . . . .. vi
UST OF .APPBN'DICE,S . . . . . . . . . . . . . . . . . ", . . ~ . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . .. vi
EXECUTIVE SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ES-l
1.0 INTRODUC'I'ION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-1
1.1 SfI'E NAME AND LOCATION. . .. . . . . . .. . . . . . . . . ... . . . . . . . . . . . . . . .. 1-1
1.2 STATEMENT OF BASIS AND PURPOSE........ ........ ....... .. ..... 1-1
1.3 ASSESS~ OF TIlE SrrE . . . . . . . . . . . . . . . . . . .'. ~-. . . . . . . . . . . . . . . . .. 1-2
1.4 IM/IRA PROJEcrs ........................ '. . . . . . . . . . . . . . . . . . . . .. 1-2
1.5 DESCRIPTION OF THE SELECI'ED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . .. 1-2
1.6 DECl.ARATION ............................................. '. . .. 1-3
1.7 EPA AND CDH SUPPORT AND ACCEPI'ANCE OF THE SELECI'ED
~Y . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-3
. ,
2.0 SfI'E CHARACTERIZATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-1
2.1 SITE NAME, LOCATION AND DESCRIPTION. ............... .. . . .. . .. 2-1
2.1.1 Topography............................................ 2-6
2.1.2 Meteorology...... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-6
2.1.3 Nearby Populations, Uses of Adjacent Land and Nanual Resources. . . .. 2-8
2.1.4 Site and Local Surface Hydrology. . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-10
2.1.5 Site and Local Hydrogeology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-12
2.1.6 Ecology............... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-13
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . .. 2-15
2.3 SUMMARY OF CONTAMINANTS ASSOCIATED WITH THIS IMIIRA . . ..... 2-16
2.3.1 Ponds 207-B North. Center, and South. . . . . . . . . . . . . . . . . . . . . . .. 2-16
2.3;2 Pond 207-C ......................"..................:. 2-16
2.3.3 InterceptOr Trench System (ITS) . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-17
2.4 COMMUNITY PARTICIPATION........... ... . ...... . ....... .. ..,. 2-36
2.5 SCOPE AND ROLE OF THE IMIIRA .........'....................... 2-37
2.6 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-37
2.6.1 Pathway Exposure Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-38
2.6.2 Chemicals of Concern. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. '2-40
2.6.2.1 Radionuclides ................................,2-40
RFPaJlm.3.R
-------
TABLE OF CONTENTS
(Continued)
~
2.6.2.2 Metals...................................... 2-41
2.6.2.3 OrganicS...........................;.'....... 2-41'
2.6.3 Toxicity Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-41
2.6.3.1 Radionuclides ................................ 2-41
2.6.3.2 Metals.. . . . . ; . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-42
2.6.3.3 Volatile Organics. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-42
2.6.4 Risk O1aracterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-42
3.0 DESCRIPTION AND ANALYSIS OF SELEerED REMEDY. . . . . . . . . . . . . . . . . . . .. 3-1
3.1 DESCRIPI10N OF SELEerED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-1
3.1.1 Treatment System Components. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-1
3.1.1.1 Location and Equipment Description. . . . . . . . . . . . . . . .. 3-2
3.1.1.2 Process Description. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-6
3.1.1.3 Sampling and Analytical Requirement. . . . . . . . . . . . . . .. 3-9
3.1.1.4 Waste Analysis Plan (W AP) ....................... 3-9
.3.1.1.5 Facility Safety Features. . . . . . . . . . . . . . . . . . . . . . . . .. 3-9
3.1.2 Storage ComponentS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-11
3.1.2.1 Location of Tanks ............................. 3-11
3.1.2.2 Equipment Description. . . . . . . . . . . . . . . . . . . . . . . . .. 3-11
3.1.3 General Components. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-15
3.1.3.1 Quantity of Waste to be Treated. . . . . . . . . . . . . . . . . ., 3-15
3.1.3.2 Treatability Testing. . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-15
3.1.3.3 General Inspections. . . . . . . . . . . . . . . . . . . . . . . . . . ., 3-15
3.1.3.4 Management of Waste. . . . . . . . . . . . . . . . . . . . . ~ . . ., 3-16
3.1.3.5 Institutional Controls. . . . . . . . . . . . . . . . . . . . . . . . . .. 3-16
3.1.3.6 Assumptions. Uncenainties and Contingencies. . . . . . . . .. 3-17
3.1.3.7 Closure of IMJIRA Structural Components. . . . . . . . . . .. 3-17
3.1.4 Costs................................................. 3-17
. .
3.1.5 Remediation Goals and Perfonnance Standards. . . . . . . . . . . . . . . . .. 3-17
3.1.6 Proposed Schedule of Milestones. . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-19
3.2 ANALYSIS OF SELEerED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-19
3.2.1 Overall Protection of Human Health and the Environment. . . . . . . . . .. 3-21
RFPfJIIIII-J .R
ii
-------
. "
TABLE OF CONTENTS
(Continued)
PAGE
3.2.2 Co~p1iance with ARARs . . . . . . . . . . . '.' ... . . . . . . . . . . . . . . . . . .. 3-21
3.2.3 LOng-TeIDl Effectiveness and PeIDlanence . . . '..' . . . . . .. . . . . .'. . . .. 3-21
3.2.4 Reduction of Toxicity. Mobility or Volume through Treatment. . . . . .. 3-22
3.2.5 Shon-TeIDl impactS. . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . .. 3-22
3.2.6 Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . '.' . . . . . . . . .. 3-23
3.2.7 Cost................................................ 3-23
3.2.8 State Acceptance. . . . . . . . . . . . . . . . . . . . .'. ;-. . . . . . . . . . . . . . . ., 3-24
3.2.9 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-24
4.0 IDENTIFICATION AND ANALYSIS OF POTENTIAL ARARs ...... ...... .. ...... 4-1
4.1 STATEMENT AND BASIS OF PURPOSE OF POTENTIAL ARAR ANALYSIS. .. 4-1
4.2 SCOPE OF INTERIM MEASURES/INTERIM REMEpIAL ACTION. . . . . . . . . .. 4-1
4.3 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) AND PROTECfION OF HUMAN HEALTH AND
TIiE ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '.' 4-1
4.3.1 ARARs """""""""""""""""""""."'" 4-2
4.3.2 TBCs..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4-3
4.3.3 ARAR Categories. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4-3
4.4 AMBIENT OR CHEMICAL-SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . . .. 4-3
4.4.1 Safe Drinking Water Act MCLs ..... . . . . . . . . . . . . . . . . . . . . . . . .. 4-4
4.4.2 Colorado WQCC Standards for Surface Water. . . . . . . . . . . . . . . . . . .. 4-5
4.4.3 CW A Ambient Water Quality Criteria (A WQc) . . . . ~ . . . . . . . . . . . . .. 4-5
4.4.4 Protection of Human Health and the Environment. . . . . . . . . . . . . . . .. 4-6
4.5 LOCATION SPECIFIC REQUIREMENTS. .,. . ...... ........ .... .. ... .. 4-6
4.6 PERFORMANCE. DESIGN. OR OTHER ACTION SPECIFIC REQUIREMENTS.. 4-7
5.0 EXPLANATION OF SIGNIFICANT CHANGES TO THE IMIIRA ..... ...... ... . . .. 5-1
6.0 PUBLIC COMMENT AND RESPONSIVENESS SUMMARY..................... 6-1
6.1 CO~TYINVOL~.................. .'... '.""""""" 6-1
6.2 RESPONSES TO COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6-2
6.2.1 Verbal Comments Received During the Public Meeting. . . . . . . . . . . . .. 6-4
6.2.2 Wrinen Comments Received During the Public Comment Period. . . . . .. 6-8
"
RFPQJl1lJ.3.R
iii
-------
TABLE OF CONTENTS
(Continued)
PAGE
6.2.2.1 EP A Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6-8
6.2.2.2 PRC Environmental. Management, Inc. Comments
-------
TABLE
2.1
2.2
2.3
2.4 '
2.5
2.6
2.7
3.1
3.2
4.1
4.2
4.3
4.4
4.5
RFPQIIM.J.R
LIST OF TABLES
TITLE
SOLAREV APORATION POND 207-A, SUMMARY OF LIQUID SAMPLING
PAGE
RES'UL TS . e. . . . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-18
SOLAR EVAPORATION POND 207-B (NORTH), SUMMARY OF LIQUID
SAJdP~GRES'ULTS ................ ....... ..... ........ ... 2-21
SOLAR EVAPORATION POND 207-B (CENTER), SUMMARY OF LIQUID
SAJdP~O RES'ULTS ............ .'. . . . . . . . . . . . . . . . . . . . . . . . .. 2-25
SOLAR EVAPORATION POND 207-B (SOUTH), SUMMARY OF LIQUID
SAMPlJN'G RES'ULTS """""""""",' ..... . . . . . . . . . . . . . . .. 2-29
SOLAREV APORATIONPOND 207-C, SUMMARY OF LIQUID SAMP~G
RES'ULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-32
SUMMARY OF SELECT ANAL YTICAL DATA (SW-095), INTERCEPTOR
TREN'CH SYSTEM WA1'ER .......................;........... 2-35
CONCENTRATIONS OF SELEerED METALS ..................... 2-41
ESTIMATED COSTS OF SELECTED REMEDY................ ..... 3-18
MII..ESTONE SCHED'ULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-20,
POTENTIAL CHEMICAL SPECIFIC ARARstrBCs (STATE STAN-
DARDS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4-8
POTENTIAL CHEMICAL SPECIFIC ARARstrBCs (FEDERAL ST AN-
DARDS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4-11
PROPOSED CHEMICAL SPECIFIC ARARs/fBCs ................... 4-14'
ANALYSIS OF LOCATION SPECIFIC ARARs .. ................. ... 4-17
ANALYSIS OF ACTION SPECIFIC ARARs . . . . . . . . . . . . . . . . . . . . . . .. 4-20
v
-------
FIGURE
2-1
2-2
2-3
2-4
2-5
2-6
2-7
3-1
3-2
3,-3
3-4
3-5
APPENDIX
A
B
C
D
RFPaum-3.R
UST OF FIGURES
TITLE . fMm
ROCKY FLATS LOCATION MAP . . . ; . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-2
ROCKY FLATS PLANT AND VICINITY . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-3
soLAR EVAPORATION POND AREA ............................ 2-4
TOPOORAPWC MAP OF SOLAR EVAPORATION POND AREA . . . . . . . .. 2-7
1989 POPULATIONS AND HOUSEHOLDS. . .. . . .. . ... .. . . .. . .. . . .. 2-9
UPSTREAM AND ON-SITE SURFACE WATER FEATURES ........... 2-11
CONCEPI'UALEXPOSURE PATHWAYS......'-~................. 2-39 .
MAIN FLOOR BUILDING 910 .................................. 3-3
LOWER LEva BUILDING 910 .................. . . . . . . . . . . . . . .. 3-5
CONCEPI'UAL FLOW DIAGRAM PORTABLE EVAPORATORS......... 3-7
PROPOSED LOCATION FOR TEMPORARY SURGE TANKS .......... 3-12
TYPICAL TANK CONSTRUCTION..... ... ............... ....... 3-14 .
LIST OF APPENDICES
TITLE
ANALYTICAL DATA FOR INTERCEPTOR TRENCH SYSTEM WATER
WASTE ANALYSIS PLAN, PORTABLE EVAPORATOR, BUllJ)ING 910
ANALYTICAL DATA FOR WATER IN ALL SOLAR PONDS
ARARs AGREEMENT LETTERS
vi
-------
EXECUTIVE SUMMARY
.,
1bis document is the Proposed Interim Measure/lnterim Remedial Action. (IMIIRA) Decision Document
for Operable Unit No.4 (QU4),. the Solar Evaporation Ponds (SEPs). This document was prepared in
accordance with the Rocky Flats Interagency Agreement (lAG), dated January 22, i991, and applicable
regulatory guidance documents. 1bis IM/IRA document incorporates the United States Environmental
Protection Agency (EPA) and Colorado Deparunent of Health (CDH) comments on the draft IMIIRA
Decision Documents dated July 1~1 and August 1991..
Approximately 8 million gallons of excess liquids need to be removed fiDm the 2(J7-A and 2(J7-B SEPs
before the remaining sludges can be removed for solidification. Natural evaporation of pond liquids
accountS for only 2 million gallons per year. Funhennore, water collected by an Interceptor Trench System
(ITS), approximately 4 million gallons per year, is currently pumped into Pond 207-B North. Changes
to the CUITent operation of the SEPs are required to allow closure and remedial activities to proceed.
Specifically, the addition of water to the ponds through precipitation and collection from the ITS must cease, .
an alternate means of storing and treating collected water is needed, and an accelerated means of removing
excess pond liquids is required to allow removal of sludge and sediments from the SEPs. Additional
activities beyond the scope of this IM/IRA, such as removal and solidification of sludges into pondcrete,
further investigation, characterization. and remedial activities, will continue to occur at QU4.
The major components of the selected remedy include:
.
The constrUction and utilization of three temporary surge tanks and associated piping to
contain and transfer \Vater collected by the ITS
.
Three portable flash evaporators and associated tanks to treat excess liquids contained in
the 2(J7-A and 207-B SEps. and to treat future ITS collected waters.
The selected remedy is expected to pose a minimal risk to the health of woIkers. the general public, and
the environment The risk of the remedy is considered low because the proposed system operates as a
closed loop. The risk due to the surge tanks is low because of the low concentration of contaminants in
the ITS water. The risk to the public due to exposure to contaminated groWld water is also low because
there are no completed exposure pathways. Currently, this IM/IRA is anticipated to operate through 1995.
RFPtlIIJft-3.R
ES-l
-------
1.0 INTRODUCTION
This document is the Proposed Interim Measure/Interim Remedial Action (IM/IRA) Decision Document
. for Operable Unit N~. 4 (OU4), the So~ Evaporation Ponds (SEPs). This document was prepared in
accordance with the Rocky Flats Interagency Agreement (lAG), dated January 22, 1991, and applicable'
regulatory guidance documents. This IMIIRA document incolpOrates the United States Environmental
Protection Agency (EPA) and Colorado Department of Health (CDH) comments on the draft IMJIRA
Decision Documents, dated July 1991 and August 1991. This IMIIRA is expected to operate through 1995.
This IWIRA document for OU4, the SEPs, is intended to facilitate implementation of the SEPs' RCRA
partial closure actions. As such, the IM/IRA is being taken as an enabling activity to facilitate removal
and solidification of pond sludges and site closure. This IM/IRA document is not related to the IM/IRA
as referenced in the lAG. The lAG IMIIRA, scheduled in 1994, follows the PhaSe I RFIIRI report and
would be presented only after the RFIIRI was completed and approved. The distinction between this
IM/IRA and the lAG IM/IRA are the activities associated with pondcrete operations. Pondcrete operations
are, addressed in the Agreement In Principle (AlP), not the lAG, and thus this IM/IRA presents infonnation .
regarding actions necessary before pondcrete operations can continue to be implemented. Thus, the IMIIRA
actions presented in this decision document are focused only on operations relating to the flash evaporator
and surge tank systems. Also, this IM/IRA is a mechanism for pennitting the use of the proposed treatment
(Le., use of surge tanks and flash evaporators) as directed by EP A and CDH.
1.1 SITE NAME AND LOCATION
Rocky Flats Plant, United States Deparanent of Energy (DOE), Golden, Colorado.
1.2 STATEMENT OF BASIS AND PURPOSE
This IM/IRA is necessary to stabilize wastes in the SEPs, so that subsequent characterization and
remediation can be completed for this site. This decision document presents the selected interim remedial
action for OU4, the SEPs. which was chosen to pennit the required SEP closure activities to proceed, in
. accordance with the lAG, the Colorado Hazardous Waste Act (CHW A), the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA), the Resource Conservation and Recovery Act (RCRA), and the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the administrative
record for OU4, the SEPs, and is deemed a necessary component for continued closure activities of the
SEps.
RFPQJ.lm-3.R
1-1
-------
.~\
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this IM/IRA Decision Document, may present an imminent and substantial
endangeI1l1~ to public he~. welfare or the environment.
1.4 IMIIRA PROJECTS
The SEPs are RCRA interim status regulated units that are currently undergoing closure activities. The
removal of liquids and sludge is required to fulfill the intent of the AlP, which states in paIt "several past
disposal sites (i.e., solar ponds) on the plant pose a high risk for further spread of contaminants into surface
water, ground water and the soil The... site(s) require(s) special and atcelerated actions by the DOE"
(DOE, 1989b). A "no action" alternative to this IM/IRA is inconsistent with the AlP and the lAG, and
was not considered for these activities because the ponds must be dewatered in order to proceed with partial
closure activities and final remediation of the SEPs.
The objectives of this IM/IRA are to cease the addition of liquids (intercepted or trench water) to
Pond 207-B North, and to remove excess liquids from the SEPs (207-A and 207-B North, 207-B Center
and 207-B South) as expeditiously as possible in order to proceed with closUre activities for the ponds
consistent with state and federal laws, the lAG, the AIP and the protection of human health and the
environment.
1.5 DESCRIPTION OF THE SELEcrED RE!vIEDY
The SEPs were fonnerly used to store and treat liquid process waste. Emplacement of process waste
mate!ial into these ponds ceased in 1986. Present ongoing activities include evaporation of the liquids
currently held in the ponds, removal and solidification of pond sludge, and site monitoring and
characterization activities. The 207-B ponds (primarily the North impoundment) continue to be used for
storage of water collected by the ITS.
Approximately 8 million gallons of excess liquids need to be removed from the 207-A and 207-B ponds
before the remaining sludges can be removed for solidification. Pond 207-C is not included in this IMIIRA
because the entire contents of the pond will be, solidified. Natural evaporation of pond liquids accounts
for only 2 million gallons per year. Furthennore, water collected by an ITS (approximately 4 milli~n
gallons per year) is currently pumped into Pond 207-B North. Changes to the current operation of the SEPs
are required to allow closure and remedial activities to proceed. Specifically, the addition of collected water
to the ponds must cease, an alternate means of storing and treating collected water is needed, and an
'. ..
RFPawn-3.R
1-2
-------
accelerated means of removing excess pond liquids is required to allow removal of sludge and sediments
from the SEPs. Additional activities beyond the scope of this IM/IRA, such as the removal and.
solidification of sludges into pondcrete, funher mvestigation, characterization, and remedial activities, will
continue to occur at OU4.
The major components of the selected remedy include:
.
The construction and utilization of three temporary surge tanks and associated piping to
contain and transfer water collected by the ITS
.
Three portable flash evaporators and associated tanks to gelt excess liquids contained in
the 207-A and 207-B SEPs and to treat collected waters.
1.6 DECLARATION
The interim action selected in this IM/JRA Decision Document is protective of human health and the
environment, complies with federal and state applicable or relevant and appropriate requirements (ARARs)
for this limited-scope action, and is cost-effective. Although this interim action is not intended to address
fully the statutory mandate for permanent solutions, to the maximum extent practicable, this interim action
does utilize tteatment and thus is in funherance of that statutory mandate. Because this action does not
constitute the final remedy for the solar ponds, the statutory preference for remedies that employ tteatment
that reduces toxicity, mobili~, or volume as the principal element. although partially addressed in this
remedy, will be addressed by the final response action. Subsequent actions are planned to address fully
the threats posed by the conditions at the solar ponds. Because this is an interim measurelinterim remedial
action, review of the solar ponds will be ongoing as EP A. CDH and DOE continue to develop final remedial
alternatives for the solar ponds under the lAG..
1.7 EPA AND CDH SUPPORT AND ACCEPTANCE OF THE SELECTED REMEDY
The IMIIRA Decision Document shall be final upon conclusion of the 60-day public comment period and
EP A and CDH approval.
RFPaJIm-3.R
1-3
-------
2.0 SITE CHARACTERIZATION
2.1 SITE NAME, LOCATION AND DESCRIPI'ION
The Rocky Flats Plant (RFP) is a govemment-own~ ~ contractor-o~rated facility. The facility is pan
of a nationwide nuclear weapons research. development, production and pluionium reprocessing complex
anminis(ered by the Rocky Flats Operations Office of the DOE. The operating contractor for the RFP is
EG&G Rocky Flats, Inc. The . facility manufactures components for nuclear weapons and conducts
plutonium reprocessing. It has been in operation since 1951. The RFP fabricates components from
plutOnium, uranium, beryllium, and stainless steel. Historically, productio_~ activities have included metal
fabrication, machining, and assembly. Both radioactive and nonradioactive wastes are generated in the
process. Current waste handling practices involve on-site and off-site recycling of hazardous materials
and off-site disposal of solid radioactive materials at another DOE facility.
-
The RFP is located in northern Jefferson County, Colorado approximately 16 miles northwest of Denver
and 9 to 12 miles from the neighboring communities of Boulder, Broomfield, Golden, and Arvada (see
Figure 2-1). The immediate area around the RFP is primarily. undeveloped and agricultural land. The RFP
is bounded on the north by State Highway 128, on the west by a parcel of land east of State Highway 93,
on the south by a parcel of land north of State Highway 72, and on the east by Jefferson County
Highway 17. Access to the plant is from ari east access "road exiting from Jefferson County Highway 17,
or a west access road exiting" from State Highway 93.
The facility is situated at an elevation of approximately 6,000 feet above mean sea level (ms!). It is on
the eastern edge of a geological bench known locally as Rocky Flats. The bench is approximately 5 miles
wide and flanks the" eastern edge of the foothills of the Rocky Mountains. The RFP consists of
approximately 6,500 acres of federally-owned land in Sections 1 through 4, and Sections 9 through 15 of
TIS, R70W, 6th Principal Meridian. Major buildings are located within the RFP Protected Area (PA) of
approximately 400 acres. The PA is surrounded by a buffer zone of approximately 6,150 acres. The PA
is within the controlled/security area (see Figure 2-2).
The SEPs are located in the central ponion of the RFP on the northeast side of the PA. The SEP Waste
Management Unit includes Ponds 207-A, 207-B .Nonh, 207-B Center, 207-B South, 207-C, and the ITS
(see Figure 2-3). The SEPs are RCRA interim status regulated units that are currently undergoing closure
activities. Activities associated with this IMIIRA would occur totally within the facility boundaries and
RFPaum-3.R
2-1
-------
. . .
lO
V
a::
Zw
~ID'
«::E
a::::>
02
~
~ID
CDO
Ow
w>
~O
Ua::
wa..
I a..
U«
'.
i i
I
,'--'--'-
i ~ BUFFER ZONE ~
I
I
I
I
I
i CONTROLLED
I AREA
I
I
I
I
~I -O~I:~AL/ ~ - ~-=-=~ i---.... . .1
I SITE I '.. '0" I
- BOUNDARY --- ~ -. I '--...> F-' I
: - .... ~~~:~~i~ :
I -,-- I / nllTU w~
I I ~ SOUTH WALNUT I
I . .,- CREEK I
I ..- I .
I ~=~~
I EAST ".
I ACCESS ROAD '-=1
RO~Q I
,t.I.O~~t'.._....... ---_.-.--.-t:~.,. I
II
11
I
I
I
IAPPROXIt.1~TE SCALEIL_.__.~. ROCKY FLATS BOUNDARY j
o 3300 FEET . - - . - - . - - . - - . - - .
WEST ACCESS
- . - - .ll--'-"~'
..-- ...' I
.~~' I
. I, )
. /'
II /'
/'
IL - - - - - - - - - - - .-/
~
-------- BUFFER ZONE ~
(
I
BROOMFIELD
ROCKY
FLATS
PLANT
FIGURE 2-1
ROCKY FLATS
LOCATION MAP
APPROXIMATE SCALE
I , I
o 40000 FEET
-------
I')
'It
->-
mm
00
WW
~>
uO
wcr
ICl.
uCl.
-------
would be controlled by standard facility procedures in compliance with the appropriate environmental
regulations.
The SEPs are currently confi~ as a series of five evaporation ponds (see Figure 2-3). Pond 2fJ7-A
. .
was placed into service in August i956: Ponds 2fJ7~B. North; Center. and South were placed into service
. .
in June 1960. Pond 2fJ7-C was constructed in 1970 to provide additional stOrage capacity and to allow
. .
the transfer and storage of liquids from the other ponds in order to perform pond repair work. These ponds
were formerly used to StOre and treat liquid process waste having less than 100.000 picocuries per liter
(pCi/l) of total long-lived alpha activity (DOE. 1980). These process wastes also contained high
concentrations of nitrates as well as treated acidic wastes containing aluminum hydroxide. The ponds are
also known to have received other wastes. including sanitary sewer sludge. lithium chloride. lithium metal.
sodium nitrate. ferric chloride. sulfuric acid. ammonium persulfates. hydrochloric acid. nitric acid. hexavalent
chromium. tritium. and cyanide solutions (Rockwell International. 1988).
Sludges from the SEPs have been removed from time to time to implement repair work on the pond liners
and as part of routine waste management activities. As the sludges were removed. they were mixed with
Ponland cement and solidified as a mixture of sludge and concrete (pond crete) for shipment to an off-site
low-level radioactive waste disposal site.
Emplacement of process waste material into these ponds ceased in 1986 because of changes in RFP waste
treatment operations. Present ongoing activities include evaporation of the liquids currently held in the
ponds. and site monitoring and characterization activities. The 2fJ7-B ponds (primarily the North
impoundment) continue to be used for storage uf intercepted seepage water collected by the ITS.
Construction of interceptOr trenches during the period from OctOber 1971 through April 1974 was initiated
to prevent natural seepage and pond leakage from entering North Walnut Creek. This system has been
replaced by the current ITS (see Figure 2-3).
The ITS (also known as the French Drain System) was installed in the hillside north of the SEPs. It became
active in April 1981 and is currently in use. The depths of the drain system. ranges from approximately
1 to 27 feet below the ground surface, with typical depths of 4 to 16 feet (Rockwell International, 1988).
Water collected in the ITS flows by gravity to the interceptOr trench pump house (see Figure 2-3). The
water from the pump house is currently pumped to Pond 207-B North. The current amount of intercepted
RFPaum-3.R
2-5
-------
seepage collected by the. ITS is estimated to be approximately 4 million gallons per year. The maximum
amount of water collected in anyone week was 700.000 gallons in June 1987 (Rockwell IntemationalI988).
2.1.1 TODOmDhv
The RFP is located along the eastern edge of the southern Rocky Mountain region immediately east of
the Colorado Front Range. The plant site is located on a broad. eastward sloping pediment that is capped
by alluvial depositS of Quaternary age (Rocky flatS Alluvium). The pediment surface has a fan-like form
with its apex near the mouth of Coal Creek Canyon and distal margins appro~ately 2 miles east of the
RFP. The tops of alluvial-covered pediments are nearly flat but Slope gently eastward at 100 to 50 feet
per mile (EG&G. 1991d). At the RFP the pediment surface is disseCteQ by a series of east-nonheast
trending stream-cut valleys. The valleys containing Rock Creek. North and South Walnut Creeks, and
Woman Creek lie 50 to 200 feet below the level of the older pediment surface. These valleys are incised
into the bedrock underlying alluvial deposits. but most bedrock is concealed beneath colluvial material
accumulated along the gentle valley slopes.
A topographic map of OU4 (see Figure 2-4) illustrates the area surrounding the SEPs and the proposed
location for the temporary surge tanks. The siting for the temporary surge tanks is explained in Section
3.1.2 of this document.
2.1.2 Meteorolosrv
The area surrounding the RFP has a semiarid climate characteristic of much of the central Rocky Mountain
region. Based on precipitation recorded between 1953 and 1976, the mean annual precipitation at the plant
is 15 inches. Approximately 40 percent of the precipitation falls during the spring season, much of it as
wet snow. Thunderstorms (June to August) account for an additional 30 percent of the annual precipitation.
Autumn and winter are drier seasons. accounting for 19 and 11 percent of the annual precipitation,
respectively. Snowfall averages 85 inches per year, falling from October through May (DOE. 1980).
Winds at the RFP, although variable, are predominantly from the west-nonhwesL Sttonger winds occur
during the winter, and the area occasionally experiences Chinook winds with gusts up to 100 miles per
hour. The canyons along the Front Range tend to channel the air flow during both upslope and downslope
conditions, especially when th~re is sttong atmospheric stability (DOE, 1980).
Rocky Flats meteOrology is strongly influenced by the diurnal cycle of mountain and valley breezes. Two
dominant flow patterns exist. one during daytime conditions and one at nighL During daytime hours. as
RFPtUl/n-3.R
2-6
-------
,.. .~.
the earth heats, the mountains receive more direct sunlight than the plain and valleys. The result is a general
trend for air flow to. travel toward the higher elevation (upslope). The general air flow pattern during.
upslope conditions for the Denver area is typically nOM to south, with flow moving up the South Pl~
River Valley and then entering the canyons into the Front Range. After sunset, the air against the mountain
. . ,
side is cooled and begins to flow toward the lower elevations (downslope). During downslope conditions,
air flows down the canyons of the Front Range onto the plain. This flow converges with the South Platte
River Valley flow moving toward the nOM-northeast.
I
-;
Temperatures at the RFP are moderate. Extremely warm or cold weather is usually of short duration. On
average, daily summer temperatures ranges from SS to 8S degrees Fahrenheit (OF), and winter temperatures
range from 20 to 4SOf'. Temperature extremes recorded at the plant range from 102°F on July 12, 1971~
to -26°F on January 12, 1963. The 24-year daily average maximum temperature for the period 19S2 to
1976 is 76°F, the daily minimum is 22°F, and the average mean is SO°F. Average relative humidity is
46 percem (DOE, 1980).
2.1.3 Nearbv Peoulations. Uses of Adiacent Land and Natural Resources
The population, economics, and land use of the areas surrounding the RFP are described in a 1989 Rocky
Rats vicinity demographics report by DOE (DOE, 1990b). This report divides general use of areas within
zero to 10 mi (zero to 16 km) of the RFP into residential, commercial, industrial, paries and open spaces,
agricultural and vacant, and institutional classification, and considers currem and furore land use near the
plant.
The majority of residential use within Smiles (8 km) of the RFP is located iJrmediately north and southwest
of Standley Lake (lHSS 201). Single family residents are also located immediately east and south of the
RFP. Figure 2-S shows the 1989 population distribution within areas up to S miles from the RFP.
Commercial development is concentrated near the residential developments north and southwest of Standley
Lake, and around the Jefferson County Airport approximately 3 miles (4.8 km) northeast of the RFP.
Industrial land use within 5 miles (8 Ian) of the plant is limited to quarrying and mining operations. Open
Space lands are located northeast of the RFP near the City of Broomfield, and in small parcels adjoining
major drainages and small neighbOIhood paries in the cities of Wesnninster and Arvada. Standley Lake
is surrounded b~ Standley Lake Park. Irrigated and non-irrigated croplands, producing primarily wheat
and barley, are located northeast of the RFP near the cities of Broomfield, Lafayette, and Louisville, north
of the RFP near Louisville and Boulder, and in scattered parcels adjacent to the eastern boundary of the
RFPawn.3.R
2-8
-------
t'--
.
4(
I
('I)
o
CD
.
o
('I)
o
~~
3m
«~
0::::1
02
>- >.
roro
0°
ulld
~>
uO
lJ..J CY.:
TI1..
i..)~
A
M
M11n
0-1
1-2
2-3
3-4
4-5
22
(7)
3671
(1141)
I
SOURCE: DOE. "1989 POPULATION. ECONOMIC AND
LAND USE DATA BASE FOR ROCKY FLATS PLANT".
AUGUST 1990.
'. ,
Sector Name
Sector 1
Sector 2
Sector 3
Sector 4
Sector 5
E
FIGURE 2-5
1 989 POPULATIONS AND
(HOUSEHOLDS),
-------
plant. Several horse operations and small hay fields are located south of the RFP. The demographics repon
characterizes much of the vacant land adjacent to the RFP and the reservoirs as rangeland (DOE, 1990b).
This proposed action would be within the existing RFP boundaries and would not adversely impact adjacent
agricultural areas or recreation areas. The action would tend to enhance the subsurface environment in
the vicinity of the SEPs and limit potentially adverse environmental effects from contaminant migration
off-site.
The land use immediately adjacent to OU4 consists of plant process areas and the buffer zone for the
facility.
2.1.4 Site and Local Surface Hvdrolo2V .
Several ephemeral streams flow through the RFP area. TQree of these ~ams (North Walnut Creek, South ..
Walnut Creek, and Woman Creek) originate within the ~ boundary and flow generally eastWard from
the plant site. The Walnut Creek and Woman Creek drainages within the boundary of the RFP are being
investigated under the lAG as OUS and OU6, respectively.. A foUrth ephemeral stream, Rock Creek,
originates in the Buffer Zone northwest of the main production facility and flows northwest from the RFP
(see Figure 2-6). Other surface water features in the vicinity of the plant included a complex netWork of
manmade diversions and impoundments. Flow into and within the swface water features results from direct
surface runoff, base flow from ground water, and diversions and wastewater from human-related activities.
Surface water drainage from the SEPs area is toward North Walnut ~ South Walnut Creeks. A series
of retention ponds known as the A-series ponds are located on North Walnut Creek. and a series of retention
ponds known as the B-series ponds are located on South Walnut Creek (see Figure 2-6). South Walnut
Creek joins North Creek and an unnamed tributary coming from the landfill area, approximately 0.7 mile
downstream of the eastern edge of the plant security area, within the buffer zone. The Walnut Creeks then
flow eastWard approxiIIiately 1 mile to Great Western Reservoir. North Walnut Creek is an eastward
flowing stream located north of the SEPs area. Surface runoff patterns indicate flow enters the drainage
from the SEPs area, the 700 Building Complex, the 300 Building Complex, and general surface runoff
from the north and west sides of the plant (Rockwell International, 1988).
The A-series ponds on North Walnut Creek are designated A-I, A-2, A-3, and A-4, from west to east.
Ponds A-I and A-2 are used only for spill control, and North Walnut Creek stream flow is diverted around
them through an underground pipe. Until. 1980, Ponds A-I and A-2 were used for storage and evaporation
RFPawn-3.R
2-10
-------
of laundry water. Pond A-3 receives the North Walnut Creek stteam flow and runoff from the noIthern
portion of the Plant.. Pond A-4 is designed for surface water conttol and for additional storage capacity
for overflow from Pond A-3.
The discharge from the ponds are regu1arly monitored to document compliance with National Pollutant .
Discharge Elimination SyStem (NPDES) pennit requirements. In addition to NPDES monitoring
requirementS, all discharges are monitored for plUtOnium, americium, uranium, and tritium concentrations.
2.1.5 Site and Local Hvdrogeolo2V
Two hydraulically-connected ground water systems exist in the RFP area: the shallow system which is
present is saturated surficial deposits (the upper hydrostratigraphic unit) in many areas of the RFP, and
the deeper system in claystones and sandstones of the underlying Arapahoe Formation (the lower
hydrostratigraphic unit). The. shallow unconfined system is recharged by infiltration from incident
precipitation and from surface and base flow water (such as drainages and reservoirs). Ground water flow
is generally to the east and toward drainages. Ground water locally discharges as seeps or springs in
drainages, especially where the surficial deposit/bedrock contact is exposed. Large water table fluctuations
may occur in the shallow system in response to seasonal variations in recharge and discharge, with the
highest water levels generally occulTing during the months of May and June and the lowest water levels
generally occurring in January and February. As a result of these fluctuations, the lateral and vertical extent
of saturated surficial deposits varies seasonally. Recent work has estimated hydraulic conductivities for
the RFP geologic units at lO-s cm/sec in the Rocky Flats Alluvium, lO-s cm/sec in subcroppings Arapahoe
Formation sandstones, 10" em/see in unweathered Arapahoe Formation sandstones, and 10-1 cm/sec in both
weathered and unweathered Arapahoe Fonnation claystones (DOE, 1991e; EG&G, 1991b).
Ground water in the lower hydrostratigraphic unit exists primarily in lenticular sandstone bodies within
claystone. Ground water flow in the upper hydro stratigraphic unit occurs in the unconsolidated Quaternary
surficial deposits and the shallow sandstone within the bedrock. Recharge to this unit consists of infiltration
from stteams and precipitation. The lower hydrostratigraphic unit is found in the deeper bedrock sandstones
which exhibit confined conditions. Recharge to this unit occur primarily from base flow and leakage from
the overlying claystone. Ground water in the lower hydrostratigraphic unit flows east ~owards a regional
di~charge area along the South Platte River some 20 miles (32 km) east of the RFP. Local seeps occur
along the sides of drainages where the bedrock crops out. Calculated horizontal linear flow velocities for
the bedrock system's average 0.1 ft/day (0.03 m/day) in the sandstone and approximately 9 x lO"" ft/day
(2.7 x 10"" m/day) in the claystone.
RFPawn-3.R
2-12
-------
Ground water generally flows toward the east in the SEPs area in the surficial materials and weathered
bedrock portions of the shallow ground water system. In the surficial materials, ground water flow diverges
somewhat in two directions: to the northeast toward North Walnut Creek and to the east-southeast toward
South Walnut Creek. In weathered bedrock. like surficial materials, ground water flows to the northeast
.' . .
and southeasL This ground water system is locally influenced by topography, the configuration of the top
ofbedrock. and the ITS north of the ponds. Consistent with regional recharging of the Arapahoe Fonnation
in this locality, it is assumed that ground water flows eastward within the subcropping sandstones.
Estimates of the vertical hydraulic gradient between surficial materials and weathered bedrock revealed
downward saturated flow between surficial materials and weathered bedrock. Water levels needed for the
calculations were obtained from ground water elevation data measured in 1990. Upward vertical flow has
been reported in preVious investigations.
The first and third quarters of 1990 represented the high and low flow regimes, respectively, for the vicinity.
Alluvial ground water enters the SEPs area from the west and flows east and then northeast or southeast.
Downgradient of the ponds to the north. most of the colluvial materials on the hill slope were removed
during construction of the ponds and the ITS. Alluvial ground water in this area seeps into weathered
bedrock where it is collected by the ITS or consumed by evapotranSpiration. North Walnut Creek and
the waste management area are separated by a region of unsaturated alluvium or the absence of surficial
materials above the water table. Although this region is extensive north of the ponds, flow tOward North
Walnut Creek is evident northeast of the ponds. Additionally, small regions of absent or unsaturated
alluvium are evident west, east, and south of the solar ponds. These regions do not appear to impede ground
water flow to the southeast. (DOE, 1991e; EG&G, 1991b).
2.1.6 EcoioEV
Ecosystems in the RFP buffer zone and surrounding areas are typical for the foothill ravine and High Plains
portions of Colorado. Aquatic ecosystems. include perrenial and intermittent streams, and several types
of man-made ditches, canals, ponds and reservoirs. Terresttial ecosystems include grasslands, shrublands
and woodlands, areas of reseeded and barren lands, and horticultural plantings. The Ecology Standard
Operating Procedures desribe 6 aquatic and 17 terrestrial habitat types. Many areas east and south of RFP
have been converted to uses like commercial and residential development. agricultural, and grazing land,
and water control and storage. Within the RFP Buffer Zone, there has been extensive grazing by both native
wildlife and domestic livestock. Domestic livestock have been excluded for more than 20 years from most
of the buffer zone. In the west side of the buffer zone is a relict stand of plants including big bluestem,
RFPQll11l-3.R
2-13
-------
little bluestem and other plants of the tallgrass prairie. Virgin stands of grass like this, located in areas
dominated by shortgrass steppe plants are rare. Because of the elevation. water regime and location between
the High Plain and Intermontane physiographic regions, many species of plants and animals usually found
in different habitats intermingle in the RFP buffer zone. The result is an extremely rich and diverse
population of native plants and animals.
A variety of vegetation is found within the buffer zone surrounding RFP. Included are species of flora
representative of tall-grass prairie, short-grass plains, lower montane, and foothill ravine regions. Riparian
. .
vegetation exists along the site's drainages and wetlands. None of these vegetative species present at RFP
have been reponed to be on the endangered species list (EG&G, 1991t). Since acquisition ofRFP property,
vegetative recovery has occurred, as evidenced by the preseD:ce of diStUIbance-sensitive grass species such
as big bluestem (Andropogon gerardiO and side oats grama (Bouteloua curtipendula) (DOE, 1980).
The fauna inhabiting the RFP and its buffer zone consists of species associated with western prairie regions.
The most common large mammal ~sthe mule deer (Odocoileus hemionus), with an estimated 100 to 125
permanent residents. There are anumber of small camivores, such as the coyote (Canis latrans), red fox
." ". .
(Vulpesfulva), striped skunk (Mephitis mephitis), and long-tailed weasel (Mustelafrenata). S~all herbivores
can be found throughout the plant complex and buffer zone, including species such as the pocket gopher
(Thomomys ta~oides),.cottontail (Sylvilagus $p.), white-tailed jackrabbit (Lepus townsendiO, and the meadow
vole (Microtus pennsylvanicus) (DOE, 1980).
Commonly obsexved birds include western meadowlarks (Sturnella neglecta), homed larks (Eremophila
alpestris), mourning doves (Zenaidura macroura), and vesper sparrows (Pooecetes gramineus), western
kingbirds (Tyrannus vociferans), black-billed magpies (Pica pica), American robins (Turdus migratorius),
and yellow warblers (Dendroica magnolia). Killdeer (Charadrius vociferus), and red-winged black birds
(Agelaius phoeniceus) are seen in areas adjacent to ponds. Mallards (Anas plaryrhynochos) and other ducks
(Anas sp.) frequently nest and rear young on several of the ponds. Common birds of prey in the area
include marsh hawks (Circus cyaneus), red-tailed hawks (Buteo jamaicensis), ferruginous hawks (Buteo
regalis), rough-legged hawks (Buteo lagopus), and great homed owls (Bubo virginianus) (DOE, 1980).
Bull snakes (Pituophis melanoleucus) and rattlesnakes (Crotalus sp.) are the most frequently obsexved
reptiles. Eastern yellow-bellied racers (Coluber constrictor jlaviventris) have also been seen. The eastern
short-horned lizard (Phrynosoma douglassi brevirostre) has been reported on the site, but these and other
RFPaum-3.R
2-14
-------
lizards are not commonly observed. The western painted turtle (Chrysemys pieta) and thewestern plains
ganer snake (Thamnophis radix) are found in and around many of the ponds (DOE, 1980).
Two procedures which concern identification and management of threatened and endangered species at
RFP currently are being prepared by the EG&G National Environmental Policy Act (NEP A) Group. These
are the draft "Identification and Reporting of Threatened and Endangered and Special Concern Species, It
administtative procedure NEP A.12, Rev. 0, and the draft "Protection of Threatened and Endangered and .
. .
Special Concern Species," operations procedure F0.21, Rev. O.
2.2 SITE HISTORY AND ENFORCEMENT ACI'IVITIES
Past and CUITent waste handling practices at ~ Rocky Rats Plant dictate that environmental restoration
at the facility be conducted in accordance with two environmental laws: the Resource Conservation and
Recovery Act (RCRA) as amended by the Hazardous and Solid Waste Amendments Act; and the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
RCRA regulations apply to currently operating hazardous waste treattnent, storage and disposal facilities,
and the RCRA corrective action provisions are implemented to remediate releases of hazardous materials
. .
from these facilities. CERCLA regulations apply when hazardous substances have been released from
abandon~ or uncontrolled hazanious waste sites as well as releases at federal facilities. CERa..A
regulations also apply to releases from operating facilities that may pose a threat to human health and/or
the environment. DOE, EPA, and the State of Colorado signed a Federal Facilities Agreement (also known
as the lAG) under both RCRA and CERCLA which governs the environmental restOration activities at RFP,
including this IRA. The environmental restoration activities at the RFP fall under the jurisdiction of both
laws.
The SEPs are RCRA interim status regulated units that are currently undergoing partial closure activities.
Leakage from the ponds has contaminated soils and ground water with nitrates, heavy metals, and
radioactive material. A closure plan submitted to the regulatory agencies on July I, 1988, called for in-place
closure of contaminated liners and subsoils. A proposal was submitted to the regulatory agencies in
February 1989 to modify the closure plan for removal of contaminated liners and subsoils to achieve residual
contaminant concentrations protective of human health. Closure activities include: dewatering the
impoundments; removing, solidifying, and disposing the pond sludges and sediments at the Nevada Test
Site; capping the area with a RCRA cap; and collection and treatment of contaminated ground water
(Rockwell International, 1988).
RFPtJJJm-3.R
2-15
-------
This IM/IRA will facilitate the dewatering of the impoundmentS and allow closure activities to fulfill the
intent of the AlP.
2.3 SUMMARY OF CONTAMINANTS ASSOCIATED WITH THIS IMJIRA'
The scope of this IM/IRA is limited to the managing and treatment of liquids contained in ponds 207-A.
207-B North, 207-B Center.207-B South, and the water collected by the ITS. Pond 207-C is not included
in this IM/IRA because the pond does not require dewatering.
Detailed characterizations of the pond wastes were performed during 1986. 1987. 1988. and 1991. A
selected summary of these characterizations is included in Tables 2.1 thrOugh 2.5 of this document. The
tables are a compilation of the analytical results from 1986-1991. A complete listing of analytical data
is contained in Appendix C. .
At present, Pond 207-A is nearly empty and contains water tranSfeITed from the 207-B series ponds. and
water derived from incident precipitation (Rockwell International. 1988). Pond 207-A was completely
cleaned of sludge and water in 1988.
2.3.1 Ponds 207-B North. Center. and South
Ponds 207-B North. Center. and South contained process wastes until 1977 when the ponds were cleaned
and the linings replaced. Waste materials from these ponds were disposed of at an off-site low level
radioactive waste disposal site. Since 1977 these ponds have held treated sanitary effluent. treated water
from the reverse osmosis facility. backwash brine from the reverse osmosis facility. and ground water
pumped back from the SEPs' ITS. Ponds 207-B North and Center generally have low concentrations of
nitrates. metals. and radionuclides. Nitrate concentrations in the pond liquids were at or below drinking
water standards during the same time period (Rockwell International. 1988). A1l207-B ponds are CUITently
used to store intercepted water collected by the ITS north of the ponds.
2.3.2 Pond 207-C
Pond 207-C was constructed to provide additional storage capacity and to enable the transfer and storage
of liquids from the other ponds while the latter were .repaired. Pond 207-C is not included in this IMJIRA
because the entire contents of the pond will be solidified. The data in Table 2.5 is presented for
informational purposes only.
RFPQllm-3.R
2-16
-------
.".
2.3.3 InterceDtor Trench Svstem (ITS)
The ITS was constrocted on the hillside nonh of the SEPs to prevent natural ground water seepage and
. .
pond leakage from entering Nonh Walnut Creek. Water collected in the system flows by gravity to the
ITS pump house and currently is pumped to the 207-B ponds.
Sampling station SW -095 is located within the wet well of the ITS pump house and is representative of
the water quality which is currently pumped to the 207-B ponds. A summary of ITS water quality is
contained in RFEDs and the data is currently being validated. A summary of select analytical data of ITS
water quality (SW -095) is presented in Table 2.6. The complete data for SW -095 is included in
Appendix A. .
RFPawn-3.R
2-17
-------
TABLE 2.1
SOLAR EVAPORATION POND 207-A
SUMMARY OF UQUID SAMPLING RESULTS
':!;':::;::::i;,:::.::::;::::::':,:::::::::':::ll:ll::::l::::.::'::,:::::::::::::::::::::::i:i::::'::::;::j:::':j:::::::::::::::::':~91t~:.:Wqm~:,::::::::::,:t::::::j::':::::::::::'::::::::::::,:::::':::V::::
!111111111111111111111111111111111:111:llli:lil:llllll11!:IIII:III.II~~II'lllllililil:i:lill'iilliliiiii!.i'1Ii.illl::::ili/!lllil_!!I!I!j!i!iil:ll!ill!!!lil!!
ANIONS
Ammonia ppm NA 0.43
Bicarbonare ppm NA 35
Carbonare ppm NA.- 47
Chloride ppm NA 416
Cyanide, Total ppm ND - 1.7 0.478
Fluoride ppm NA ND
Nitrate. N ppm ND - 21,739 lQOO
Nittite ppm NA 39
Phosphate, Ortho ppm NA ND
Phosphate, Total ppm NA ND
Sulfa1e ppm NA 409
Sulfide ppm NA ND
TKN-N ppm NA ND
RADIONUCLIDES
Americium -241 pCi/l ND - 200 0.42
Plutonium -239 pCi/l ND - 660 0.71
Uranium -234 pCi/l 14()()().. 20000 310
Uranium -235 pCi/l NA 11
Uranium -238 pCi/l 21 ()()()..28000 340
Tritium pCi/l 240-3000 NA
Gross Alpha pCi/l 32-80000 300
Gross Beta pCi/l 2-40000 930
MISCEU.ANEOUS TESTS
Alkalinity, Total ppm NA 110
Conductivity @ 25C JlMHOs NA 8800
Total Dissolved Solids ppm 127000-127000 7600
Total Organic Carbon ppm NA 67.8
Total Suspended Solids % NA 23
pH ppm 8.3-11 9.9
METALS
Aluminum ppm 2.31-2.64 ND
Antimony ppm NA ND
-------
TABLE 2.1
. SOLAR EV APORA TION POND 207-A
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
- ... .........,." ..' :;::::~::'::::::::':;:::::::::::::;:::::::::::::j::::;:::::::::::@I?P~::iqm4::::::::::::::::::::::::::::.:::%:::::,:::::::'::::::::::':;.
......n,',,',,''''''''''''''''
........,',....."""'"''''''
[[[
.,.............................
- .... --.. --.. ....d.' ,.'.-,-.-,...., ,. 1111:IIIII:i:II:::I::IIII:: 111111 11::\:1;:::11::1111111 Iii
:lllil.lliilil:iili:llllil.III~[II'li::ii'ili:il!'I.1111111:::11
ArscJrlc ppm O. 15-0.15 ND
Barium ppm ND NA
Beryllium ppm ND-O. 1 NA
Bismuth ppm NA -- ND
Boron ppm NA 1.26
Cadmium ppm 0.070-0. 150 ND
Calcium ppm ND 60.4
Cobalt ppm 0.200-0.500 NA
Chromium. Total ppm 13.7- 16.7 ND
Copper ppm 1 .61- 1 .8 ND
Iron ppm 1 .5-8.0 ND
Lead ppm ND 0.004
Lithi'lm ppm NA 1 .42
Magnesium ppm ND 121
Manganese ppm 0.095-0. 1 15 ND
MereUI)' ppm ND-O.OOO2 ND
Molybdenum ppm NA ND
Nickel ppm 1 .9-2.0 ND
Potassium ppm 1 3200- 14300 376
Selenium ppm ND 0.015
Silicon ppm NA 0.846
Silver ppm NA ND
Sodium ppm 36300-42900 16 10
Saonlium ppm NA 2.35
Thallium ppm NA ND
Tin ppm 7- 13 ND
Vanadium ppm O. 10-0.20 NA
Zinc ppm 0.62-0.78 0.028
VOLATILE ORGANICS
Acetone ppb 100-260 ND
Methylene Chloride ppb ND ND
-------
TABLE 2.1
. SOLAR EVAPORATION POND 207-A
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
-,
SBMIVOLATn.E
AceDapbtbene
Bis(2-ethylhexyl) phthalate
4-Cbloro-3-methylphenol
2-Chlorophenol
1,4-Dichlorobenzene
2,4-Dinitrotoluene
Di-n-butyl phthalate
F1uoranthene
N-Niaoso-di-propy1amine
Phenol
Phenols. Total
Pyrene
1,2,4- Trichlorobenzene
PESTICIDES/pcBs
Auazine
Diazinon
Simazine
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
. ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
. .
:::::::::::::::::::::::::::~::::::::::::::::::::::::::::::::::::::::::::.F8::4qm~::::::::::::::::::::'::::::::::::}:::::::::::j::::::::::.:::::
iil:lli:lliill:I::I:lil::llill~[.1111Ij:II:::II!111111:ililllli:IIIII'I!II!:I:II::I:I:!:I:II~.:i!ll:jil:::I:\:::I::i\::;::\
NA NO
NA NO
NA NO
NA NO
NA NO
NA NO
NA NO
NA NO
NA NO
NA NO
13-35 NA
NA NO
NA NO
NA 3.5
NA NO
NA NO
References:
Rockwell International, 1988, Solar Evaporation Ponds Closure Plan.
EG&G. 1991e. Internal Repon. Sampling and Analysis of Solar Pond Water and Sludge.
July 1991. .
NA = Not Analyzed
ND = Not Detected
RFPawn-3.R
2-20
-------
TABLE 2.2
. SOLAR EVAPORATION POND 207-B. (NORTH)
SUMMARY OF UQUID SAMPUNG RESULTS
,",','.".'.',','.',",'.',..','.",.",'..'..'...','..',",', ;;:::;;:~:::::::;~;~):;:::::::::::::;:;::;:::::::::::;::::~7fl:::qj9#JI),~:::::'~::;::::;::::::~~:::':;:;;:U';::::;:::;;,:::'::;:;
"""'"'''''''','''''''..,'''''
......"""...".."...".......
,..,"',H""",."'",,"'''','
,,,,,,,,,,,,,,,"',''',,,,,,,,,,,
..........................,."...
.....,".........................
- :111!lllllliii!i~lilll!III!!:I!:III~t.II:I!I!I!lill!l!IIIII!IIIIIIIIII!II: " .... p......,. .' ...... ..... ......
1IIIii!!IIII!III!lllill!II!:!I~.I:I:I.!!::il!:;!!II!!1]111111
ANIONS
Ammonia ppm NA ND
BicmbolWe ppm NA ND
CarboD8le ppm NA ND
Chloride ppm NA 147
Cyanide, Tora! ppm NA 37.8
Fluoride ppm NA ND
Nitrate, N ppm 212 - 1367 39
Nibite ppm NA ND
Phosphate, Ortho ppm NA ND
Phosphate, Total ppm NA 0.04
Sulfare ppm NA 155
Sulfide ppm NA ND
TKN-N ppm NA ND
RADIONUCLIDES
Americium -241 pCjJl ND o. 14
Plutonium -239 pCjJl ND ND
Uranium -234 pCjJl 50 - S3 40
Uranium -235 pCjJl NA 1.7
Uranium -238 pCjJl 3 1 - 33 26
Tritium pCjJl 1200 - 1300 NA
Gross Alpha pCjJl 13 - 323 S9
Gross Beta pCjJl 5 . 200 1 10
MISCELLANEOUS TESTS
Alkalinity. Total ppm NA 7S
Conductivity @ 25C )!MHOs NA 3380
Tora! Dissolved Solids ppm NA 3200
Total Organic Carbon ppm NA 7.6
Total Suspended Solids % NA 18
pH ppm 7.S - 9.6 8.5
METALS
Aluminum ppm ND - 1 .00 ND
Antimony ppm ND ND
RFPawn-3.R
2-21
-------
TABLE 2.2
SOLAR EV APORA TION POND 207-B (NORTH)
SUMMARY OF LIQUID SAMPLING RES~TS
(continued) .
- . ::;:::::;::::::::;~::;:~:~::::~:~~;::~;:::::::;:::::::::;~:~:;:.~I:::tN~~~~~:~;::~;::::~:::::::::~::::.:::~::~:~:;:::::j::~'V::::
lili!lllliilillllilillllliliiiliill~I.lllil!iiiillilIllilllllllllllllll: :::~:::::V::::::::::::::::::::::::::::!~!:::::::::~:~::::::::::::;:::::::~::::~~:::
::::::::::::::::::::=::::::::~~~:::::::~::::::::::::;:::::::
Arsenic ppm ND ND
Barium ppm ND - 0.22 ND
Beryllium ppm ND - 0.06 NA
Bismuth ppm ND ND
Boron ppm 0.09 - 0.3 1 O. 173
Cadmium ppm ND - 0.01 ND
Calcium ppm 20 - 290 1 89
Cerium ppm ND NA
Cesium ppm ND NA
Cobalt ppm ND NA
Chromium. Total ppm ND ND
Copper ppm ND ND
Gennanium ppm ND NA
Iron ppm ND - 0.29 ND
Lead ppm ND - 0.004 ND
Lithium ppm 0.37 - 6 0.332
Magnesium ppm 66 - 120 79.3
Manganese ppm ND - 0.015 ND
Mercury ppm ND ND
Molybdenum ppm ND - 0.0069 ND
Nickel ppm ND - 0.05 ND
Niobium ppm ND NA
Phosphorous ppm ND NA
Potassium ppm 56 - 120 58.8
Rubidium ppm ND NA
Selenium ppm ND - 0.024 0.008
Silicon ppm ND - 5.6 1 .02
Silver ppm ND - 0.082 ND
Sodium ppm 363 - 820 403
Sttontium ppm O. 14 - 3.5 2.22
Tantalum ppm ND NA
Tellurium ppm ND NA
RFPaJII1&-3.R
2-22
-------
TABLE 2.2
. SOLAR EVAPORATION POND 207-B (NORTH)
SUMMARY OF UQum SAMPLING RESULTS.
(continued)
- ".....'"........................ [[[ti:::~~::~~4::::::::::::::::j:::j::::,::::::::'::ffi:::::::j::j:::::::
[[[
- '11!illlllllllllllli'lil:I:llllllllllrih1I,I:'II:lill11111111111.:111:11111 1IIIill!II!I~I://IIIIIJ.J!i..III::::IIIII:I!i:I!:I:i:i://1:
~:~:::::::::::~:::::::~::::::::::q~~@~~:~:::::~:::::::~
Tballium ppm ND ND
Thorium ppm ND NA
Tin ppm ND ND
, '0
Tiranium ppm ND NA
Tungsrm ppm ND NA
VStn~um ppm ND NA
Zirconium ppm ND NA
Zinc ppm ND - 0.022 0.048
VOLATILE ORGANICS
Acetone ppb ND ND
Methylene Chloride ppb 19-7 1 ND
Tetrachloroethene ppb ND ND
SEMIVOLATILE
Acenapbthene ppb NA ND
Bis(2-ethyl hexyl) phthalate ppb NA ND
4-Chloro-3-methylphenol ppb NA ND
2-chlorophenol ppb NA ND
1 ,4-Dichlombenzene ppb NA ND
2.4-Dinittotoluene ppb NA ND
Di-nbutyl phthalate ppb NA ND
Fluoranthene ppb NA ND
N-Niaroso-di-propylamine ppb NA ND
Phenol ppb NA ND
Pyrene ppb NA ND
1 ,2,4- Trichlorobenzene ppb NA ND
-------
TABLE 2.2
References:
SOLAR EVAPORATION POND 207-B (NORTH)
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
Rockwell International,. 1988, Solar Evaporation Ponds Closure Plan
00&0, 1991e, Internal Report, Sampung .and Analysis of Solar Pond Water and Sludge,
July 1991.
NA = Not Analyzed
ND = Not Detected
RFPawn-3.R
2-24
-------
TABLE 2.3
. SOLAR EVAPORATION POND 207-8 (CENTER)
SUMMARY OF UQUID SAMPLING RESULTS
."'... . -.. '... -""",,"'...'... ..... -.. "'.. """"""""""""""""""'."""'" ",",','.",'.",",",".",",".",",".",',',',",".",",",",",'''," ~~,~:,~~,;~,::,::~~:;:~~::;,:::~:~:,~:,::;:::~::::::::~~~~:
-------
\.
TABLE 2.3
SOLAR EVAPORATION POND 207-B (CENTER)
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
- . ," ,:::::':~~~~:~:':':'~:~~:~~::~:~:~::~':::::::::~:~:~:~:~:~":'17f~~::(q~&);~~i#.~::',,::::,::,'::";:'::'::::'"::~:::~:::::::~;~::::
..,.".......................
...,,,......,.................
'.',',',','.',',".'.'.',',',",','.',','.'.',",'.','.','.','
',',',','.'.',','.','.',',',',','.'.',",'.",',','.','.',',
[[[
- :llliliill:llll.illli:iiilil:IIII~f..'~III::III'II~11Ilillil~IIIIII:lllllill.!II!.:!.:IIIIIIIIIII:I~lli:j::1.1:1111::111\:111111111111
Barium ppm ND ND
Beryllium ppm ND ND
Bismuth ppm ND ND
Boron ppm 0.07 1 - 0.67 2.77
Cadmium ppm ND-O.Ol ND
Calcium ppm 2.9- 95 22.6
Cerium ppm ND NA
Cesium ppm ND - 0.35 NA
Cobalt ppm ND NA
Chromium. Total ppm ND 0.094
Copper ppm ND - 0.037 0.035
Germanium ppm ND NA
Iron ppm ND - 0.2 ND
Lead ppm ND - 0.002 ND
Lithium ppm 0.052 - 3.5 2.6
Magnesium ppm 3.9 - 9 1 18 1
Manganese ppm ND - 0.022 ND
Mercury ppm ND ND
Molybdenum ppm 0.004 - 0.037 ND
Nickel ppm ND - 0.016 ND
Niobium ppm ND NA
Phosphorous ppm ND - 0.2 NA
Potassium ppm 30 - I 10 729
Rubidium ppm ND NA
Selenium ppm ND - 0.019 ND
Silicon ppm 1.4 - 5.5 1.4 1
Silver ppm ND - 0.01 5 ND
Sodium ppm 67 - 800 2440
Sttontium ppm O. 14 - 0.52 2. 1 3
Tantalum ppm ND NA
-------
TABLE 2.3
SOLAR EVAPORATION POND 207.B (CENTER)
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
- :~:~~!~~:~:rt?~~?~r{j~{~~}~)~{ ~::::::::::::::::::~::~:::::::::~~::::::::::::~:~:::::~::::::~gtij1:~~).:~~#.!~::::::::::::::::::::~:~:~:::.:::::~:~:::~:::::::.::::.:
. :llillllllllll!IIIIIIIIIIIIIIII.~rll:III!:illlllllll1111111.1.111.1 :::::::::::::::::::::::::::i:::::::::::::::!~?J.:::::::I::::::::::::::::::::::::::::::::
~:::i~~:::~~:~:~~::~::::~:~:~::~~~~::::::::::~:::~::~:::::~::::~
Thorium ppm ND NA
Tin ppm ND o. 109
Titanium ppm ND NA
--
Tungsten ppm ND NA
Vanadiwn ppm ND - 0.0081 NA
Zirconiwn ppm ND - 0.004 NA
Zinc ppm ND - 0.04 1 ND
VOLATILE ORGANICS
Acetone ppb NA ND
Methylene Chloride ppb NA ND
Tettachloroethene ppb . NA ND
SEMIVOLATILE
Acenapbthene ppb NA ND
Bis(2-ethyl hexyl) phthalate ppb NA ND
4-Chloro-3-methylphenol ppb NA ND
2-Chlorophenol ppb NA ND
1 .4-Dichlorobenzene ppb NA ND
2.4-Diniaotoluene ppb NA ND
Di-n-butyl phthalate ppb NA ND
Fluoranthene ppb NA ND
N-Nittoso-di-propylamine ppb NA ND
Phenol ppb NA ND
Pyrene ppb NA ND
1 .2.4- Trichlorobenzene ppb NA ND
PESTICIDES/PCBs
Atrazine ppb NA 9
Diazinon ppb NA ND
Simazine ppb NA ND
RFPawn-3.R
2-27
-------
TABLE 2.3
. SOLAR EVAPORATION POND 207-B (CENTER)
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
References:
Rockwell International. 1988. Solar Evaporation Ponds Closure Plan
EG&G. 1991e. Intemal Report. Sampling and Analysis of Solar Pond Water and Sludge.
July 1991.
NA = Not Analyzed
ND = Not Detected
RFPaum-3.R
2-28
-------
TABLE 2.4
,.'
,..
. SOLAR EVAPORATION POND 207-B (SOUTH)
SUMMARY OF UQUID SAMPLING RESULTS'
.............. ......,..,.." ~:~i;::~::::;~;::~:,:::~~::';::::~:;:':,i~~:::;~:::::::~:~:'=,:::gtl:::($~"i~~gii.f:::::::::::~::i:::~::i::i::::j:..::~i'~;;:.ii::::::::
..............................
[[[
,,,,,,,,,,,,,,,,"',.....,'"
..............................
.............................
.........................,.,.
[[[
1111:11111111111111111111111111111111: 11111:lillll:llli:ilililillilli:ii!li'~~.liiiilillli!!111.liil.I.!ii!II!!I'lli !llllillliil:!!liloilllllii:IIII~~I~III:!III:lii:i!:;::::iiii!li\
ANIONS
Ammonia ppm NA 0.97
Bicarbonate ppm NA ND
Carbonate ppm NA 190
.-
Chloride ppm NA 745
Cyanide. Total ppm NA 0.509
Fluoride ppm NA 72.5
Nittate, N ppm NA 1800
Nittite ppm NA 100
PhospbaIe, Ortho ppm NA ND
PhospbaIe, Total ppm NA 2.6
Sulfate ppm NA 784
Sulfide ppm NA 1 .0
TKN-N ppm NA ND
RADIONUCLIDES
Americium -241 pCi/l NA 0.1
Plutonium -239 pCi/l NA 0.1
Uranium -234 pCi/l NA 760
Uranium -235 pCi/l NA 3 1
Uranium -238 pCi/l NA 870
Gross Alpha pCi/l NA 1600
Gross Beta pCi/l NA 2300
MISCEU.ANEOUS TESTS
Alkalinity. Total ppm NA 860
Conductivity @ 2SC pMHOs NA 23000
Total Dissolved Solids ppm NA 16000
Total Organic Carbon ppm NA 297
Total Suspended Solids % NA 6.0
pH unitS NA 9.2
-------
TABLE 2.4
SOLAR EVAPORATION POND 207.B (SOUTH)
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
-- . .- ..,.' , .." :i:~:i~:::~i:::'::~:::::::i::i::::::::::::~-:::::::::::~~::':::::~:::mf.~:':(~~).::R4ij1~:::::::::::~::::::::::::::::'::::::::f:~:i:~~::::::J,~::::::~::
.:.:.;.:.;.:.:.:.:.:.:.:.:.:.:-:.:.:.:.:.:.:.;;;.:;:;:.:.:.
..,..........................
....,........................
. 1IIIiiilillii!liiilillliiiliillilliJiI18\lili!iliiii1IIIIIIi-iiillliil!i-II!-i illiiiiiiiii:liiiiiiliii!ill!~I~.!!I\\\\\\il\iil:il\\i!111!!!i!:!
Barium ppm NA ND
Bismudl ppm NA ND
Boron ppm NA 2.77
--
Cadmium ppm NA ND
CaJcium ppm NA 18.9
Chromium, Total ppm NA 0.0228
Copper ppm NA 0.037
Iron ppm NA ND
Lead ppm NA ND
Lithium ppm NA 2.670
Magnesium ppm NA 1 80
Manganese ppm NA 0.0 1 82
Mercury ppm NA 0.00 1
Molybdenum ppm NA o. 122
Nickel ppm NA 0.040
Potassium ppm NA 79 1
Selenium ppm NA ND
Silicon ppm NA 0.952
Silver ppm NA ND
Sodium ppm NA 2940
SU'OnDum ppm NA 2.37
Thallium ppm NA ND
Tin ' NA ND
ppm
Zinc ppm NA 0.037
VOLATn.E ORGANICS
AcetOne ppb NA ND
Methylene Chloride ppb NA ND
T etrachloroethene ppb NA ND
SEMIVOLATn.E
Acenaphthene ppb NA ND
Bis(2-ethyl hexyl)phthalate ppb NA ND
4-Chloro- 3-methylphenol ppb NA ND
RFPaJlm.3.R
2-30
-------
TABLE 2.4
SOLAR EV APORA TION POND 207-B (SOUTH)
SUMMARY OF LIQUID SAMPLING RESULTS
(continued)
-- . :~:::::::::::::~:;:;:;~~::~~~~:::::::::;~::~;:::::::::~::::~;:::~::~gii~~:(~P#.~):~~~:~:~:~:~:~:~::::~~':'::::~:::':::::::::::;:~~:~~~::i,::::'~'::'
111111111!111!111\:I.I:I\\I\\I:!:I:!I:~~.II:!I:III!I!1:::II:I:IIIIIIIIIIII\II!: 1111111!!I!IIII!!!I!!:!!!!!III!I.':I!III!:I\::!\\!!\.:1:\:1:1:1\11
2-Cblorophenol ppb NA ND
1 .4-Dicblorobenzene ppb NA ND
2.~Dinitrotolucnc ppb NA ND
.-
Di-n-butyl pbtbaJarc ppb NA ND
F1uorantbene ppb NA ND
N-NitrosO-di-propylamine ppb NA ND
Phenol ppb NA ND
Pyrene ppb NA ND
1 .2.4- Trichlorobenzene ppb NA ND
PESTICIDES/PCBs
Atrazine ppb. NA 13
Diazinon ppb NA ND
Simazine ppb NA ND
References:
Rockwell International. 1988a. Solar Evaporation Ponds Closure Plan
EG&G. 1991e.lnIemal Repon. Sampling and Analysis of Solar Pond Water and Sludge.
July 1991. .
. NA = Not Analyzed
ND = Not Detected
RFPQM/1l-J.R
2-31
-------
TABLE 2.5
SOLAR EVAPORATION POND 207-C
SUMMARY OF LIQUID SAMPLING RESULTS
Compound
Units 1
207-C Liquid
1986-1988
Range
1991
Composite
ANIONS
Ammonia
Bicarbonate
Carbonate
Chloride
Cyanide, Total
Fluoride
Nitrate, N
Nitrite
Phosphate, Ortho
Phosphate, Total
Sulfate
Sulfide
TKN-N
ppm
ppra
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
NA
NA
NA . ._
NA
ND-1.9
NA
0.4-21400
NA
NA
NA
NA
NA
NA
ND
4000
25000
18300
9650
ND
2600
2500
390
431
12200
10
ND
RADIONUCLIDES
Americium -241
Plutonium -239
Uranium -234
Uranium -23S
Uranium -238
Tritium
Gross Alpha
Gross Beta
pCi/1
pCi/1
pCi/1
pCi/1
pCi/1
pCi/1
pCi/1
pCi/1
ND-13000
210-2100
NA
NA
NA
ND-6400
10000-46000
405-44000
8.6
670
2600
120
3900
NA
72000
170000
MISCELLANEOUS TESTS
Alkalinity, Total
Conductivity @ 2SC
Total Dissolved Solids
Total Organic Carbon
Total Suspended Solids
PH
ppm
uMHOs
ppm
ppm
%
ppm
NA
NA
93900-175800
NA
NA
7.7-12.5
45000
610000
400000
54.9
76
10.2
METALS
Aluminum
Antimony
ppm
ppm
NA
NA
ND
ND
RFPaum-3Jt
2-32
-------
TABLE 2.5
SOLAR EVAPORATION POND 207-C
SUMMARY OF UQUID SAMPLING RESULTS
(continued)
- . ::":::~::::::~::~:::":::;':~:::::~:~::::~:::::::~~::::::::;::~:~::":::::::::~::::::~.I~:~~:::~::::::::::::::::::"~:~:::::::::::::":~::~::::~~:~:::::::::~::::::::~::
!I!iii:iii:iliililil:I:!li~il:lllilll~[.lllillii!iililiiliilllllllllllil"li1i [li::I:lili!iiililii:!:!iliil":..:!i!ii!i!!i\!!!I!ill!li:1\::\:\i
Arsenic ppm NA ND
Banum ppm NA ND
Beryllium ppm ND-O.6 ND
Bismuth NA -- ND
ppm
Boron ppm NA 360
Cadmium ppm NA 0.3 12
Calcium ppm NA ND
Chromium. Tow ppm NA 2.36
Copper ppm NA 6.79
Iron ppm NA ND
Lead ppm . NA ND
Lithium ppm NA ND
Manganese ppm NA ND
Mercury ppm NA ND
Molybdenum ppm NA ND
Nickel ppm NA 5.09
PotaSsium ppm NA 78700
Selenium ppm NA ND
Silicon ppm NA 30. 1
Silver ppm NA ND
Sodium ppm NA 102000
Strontium ppm NA ND
Thallium ppm NA ND
Tin ppm NA ND
Zinc ppm NA ND
VOLATn.E ORGANICS
Acetone ppb NA 43
Methylene Chloride ppb NA ND
TettaChloroethene ppb NA ND
SEMIVOLA Tn.E
Acenaphthene ppb NA ND
Bis(2~thyl hexyl)phthalate ppb NA ND
RFPaum-3.R
2-33
-------
TABLE 2.5
SOLAR EVAPORATION POND 207-C
SUMMARY OF UQUID SAMPLING RESULTS
. (continued) .
- . ::,::,::::;:::::::,::::::::::!::::::::::'!:'::::::!:!',::::,,!::::::::::::::::~t;;g::~4~oo~:::::::@:::::':!::::::::!.::::::,::::::::.:::::::",::::!::!!::::U:
111111!1!1111:111\11:1111\1111:1::IIIIIII:I:III:illll.111111111'111\.11111111 ............,....... . .......-,....... ...
1:1:lli.III.IIIIII:.III':III:II_.,I:\\I:\\:'I;I::I\::\:11![\I:\
4-Ch1oro-3-meihylphenol ppb NA ND
2-Cbloropbenol ppb NA ND
1 .4-Dicblorobcnzenc ppb NA ND
2.4-DinittotOlucne NA .- ND
ppb
Di-n-butyl phtbaJate ppb NA ND
Fluoranthene ppb NA ND
N-Niuoso-di-propyJamine ppb NA ND
Phenol ppb NA ND
Phenols. Total ppb 13-35 NA
Pyrene ppb NA ND
1 .2.4- Tricblorobenzene ppb NA ND
PESTICIDESIPCBs
Atrazine ppb NA ND
Diazinon ppb NA 2.8
Simazine ppb NA 7.5
References:
Rockwell International. 1988. Solar Evaporation PoIids Closure Plan
EG&G. 1991e. Internal Repon. Sampling and Analysis of Solar Pond Water and Sludge.
July 1991.
NA = Not Analyzed
ND = Not Detected
RFPawn-3.R
2-34
-------
TABLE 2.6
SUMMARY OF SELECT ANALYTICAL DATA (SW-095)
INTERCEPTOR TRENCH SYSTEM WATER- .
AnalYte Units Range
Americium -241 pCjJl ND-2.2
GrossAlpba pCjJl 40-340
Gross Bela pCjJl 100-250
Pluronium -239 pCjJl ND-I0
Radium -226 pCjJ1 ND-4.4
Radium -228 ' -- 1.6-53
pCjJ1
Tritium pCjJl 1600-3200
Uranium -233. 234 pCi/l 43-122
Unmium -235. 236 pCjJl 2.093
UIanium '-238 pCjJl 25-84.8
Nitrate m&'1 1859-3205
Niuate/Nittite mgll 190-724
pH standard units 6.99-7.8
Tolal dissolved solids. mgll 1500-4560
Acetone pgll ND-80
Bis(2~thylhexyl)phtha1ate pgll ND-24 (B)
Carbon teuachloride P&'1 ND-ll
Chlorofonn pgIl ND-2 (J)
Diethyl phthalate pgIl ND-4 (J)
Di-n-butyl phthalate pgll ND-4(BJ)
Methylene chloride pg/l ND-5 (B)
PentaChlorophenol pg/l . ND-20 (J)
Tricbloroethene pgll ND-5
. From Appendix A.
NOTE:
These data have not been 100 percent verified. Validation and QNQC are currently underway.
pCi/l = picocuries per liter
mg/l = milligrams per liter
pg/l = micrograms per liter
ND = compound was analyzed but not detected.
B = compound was found in the blank and in the sample.
J = indicates an estimated value for an analyte that meets the identification criteria but had a
result less than the specified detection limit.
RFPfJllm.J.R
2-35
-------
Water quality analyses of ITS water indicate the presence of inorganic constituents (particularly nitrate).
radionuclides. and sporadic detections of low-level volatile organic compounds (VOC~). Inorganic
constituents and radionuclides are typically present in the general solar pond area and are present in both
" "
ground water and s~page flows. Sporadic VOCs detections are thought to be predominately contributed
by the flow from the West Collector of the ITS. The West Collector intercepts ground water flow. surface
nmoff, and flow from the Building 774n71 drain area (ASI. 1991).
2.4 COMMUNITY PARTICIPATION
In accordance with the Interagency Agreement (lAG), DOE has prepared this IMIIRA Decision Document
" "
to allow the public an oppoltUnity to review and comment on the seleCted remedy.
" " "
DOE will open a ~day comment period. DOE will hold a public hearing on this Proposed IMIIRA
. Decision ~ent. if requested to do so by the public. EP A or the State. The PropOsed IM/IRA Decision:
".DOcumem.isa concise document that (a) indicates the objective of the IM/IRA; (b) "discusses the selected.."
" "
remedy; (c) provides the rationale for the selected remedy; (d) presents an ARAR analyses. and; (e):
discusses how the interim remedy selected will be consistent with the final remedy for the OU4.
After receipt ofEP A, State and/or public comments concerning the Proposed IM/IRA Decision Document.
DOE will prepare a FmallM/lRA Decision Document for EP A and Stpe review and approval in accordance
with paragraph 150 of the lAG, which will include a response to comments received. As stated in the lAG.
"DOE will not commence any remedial/corrective activities associated with an IMJ]RA until EP A and the
State have approved the FmallM/lRA Decision Document and Responsiveness Summary." DOE will make
the EPA and State approved FinallM/lRA Decision Document and Responsiveness Summary available
to all interested parties 10 days prior to commencing the operation of remedial/corrective activities associated
with the IM/IRA.
The Fmal Decision Document for this IM/IRA will include deadlines for implementation of the IM/IRA
and shall be supponed by the Administrative Record. The supponing Administrative Record shall be
consistent with CERCLA and shall include. but not be limited to. significant facts and studies suppOnin~
the initial decision to conduct this IMIIRA. all comments received concerning the fin!il decision on the
action. EP A and State comments concerning the IM/IRA. and the DOE response to those comments.
RFPawn-3.R
2-36
-------
,.., '.
2.5 SCOPE AND ROLE OF THE IMJIRA
The Solar Evaporation ;Ponds are currently undergoing partial closure activities. Water collected by the
ITS is currently discharged into the 207-B ponds. The ponds (except for 207-C) must be dewatered to
a state which will allow the removal of the sludges for solidification into pondcrete. In order to facilitate
the dewatering of the ponds in an expedited f~on the addition of ITS water must cease. Therefore,
storage and treattnent of the intercepted water and treatment of excess pond liquids must occur in an
alternate fashion. The most effective means of storage of the intercepted water is storage in temporary
tanks. The most effective means of treatment of the excess pond liquids and the intercepted water is through
the use of three portable flash evaporators. A complete description of the process is included in Section
3.0 of this document.
This 1M/IRA is intended to be consistent with the final remedy for the Solar Evaporation Ponds. In fact.
. if the three ponahle flash evaporators and temporary surge tanks are not installed and operated. the removal
and solidification of the sludges into pondcrete cannot occur. The removal of liquids and sludge is required
to fulfill the intent of the AlP, which states, "several past disposal sites (Le.. solar ponds) on the plant pose
a high risk for further spread of contaminants into surface water, ground water and the soil. The . . . site(s)
require(s) special and accelerated actions by the DOE." Such actions will be performed in full compliance
with state and federal environmental laws (DOE. 1989b).
2.6 SUMMARY OF SITE RISKS
The OU4 IMJIRA is intended to facilitate implementation oithe SEPs' partial closure actions and to stabilize
. the operable unit by removing ~e source materials. As such. the IMJIRA is being taken as an enabling
activity to facU'tate pondcrete operations. site closure. and remedial action. The proposed actions are not
being taken in response to Agency guidance which directs interim actions to be taken in response to an
immediate site threat to or to take advantage of an opportunity to reduce Site risk quickly (EPA, 1991a).
"..~
The implications of this determination affect the summary of site risk to be performed below. . In a July
12, 1991 letter. CDH and EPA provided guidance to DOE for issuing the Proposed Decision Document
.
for this IM/IRA. This guidance instructed the Summary of Site Risks to "focus on the risks that the interima
action is intended to address and should provide rationale for the limited scope of the action." As indicated
above, the IMJIRA is not being proposed in response to site hazards. The action is being proposed as an
enabling activity to facilitate pondcrete operations. site closure, and remedial action. The'Summary of S~te
1tisb_wiJ,t.~ ~tbe potential publiC-health and environmental health impacts associated with operation
~.:~f the t1ash evaporator system. ;'
RFPaum.3.R
2-37
-------
,-
A key assumption of this pathway-based qualitative risk assessment is that the ground water pathway is
not CQmplete. This is a matter of fact that should be taken into consideration regardless of the presumed
efficiency of the collection system (ITS). Specifically, there currently is no human receptor exposed to
ground water containing COI'taminartts rele~ from the SEPs. This is because the plume is contained
. on the RFP. As a result. there are no domestic users of ground water in the vicinity of the SEPs
contaminant plume. Additionally. the distance from the SEPs to the nearest potential receptor is very
significant which suggests a low probability that contaminated ground water from the SEPs would be
available for a human to access in any reasonable foreseeable time. Municipally supplied domestic water
is readily available in the vicinity of RFP. Since no drinking water is available, the assessment that
exposure to contaminants emanating from the SEPs via a ground water pathway is improbable.
The information provided in this section is included for the general understanding of the site risks, and
are not quantifiable statements. It is not the intent of this paragraph to imply - that the IM/IRA will
characterize and remediate all ground water contamination which originated from the SEPs. As stated
previously, characterization of the ground water/surface water interrelations shall be perfonned during the
RFIIRI activities.
Whatever the ITS efficiency, implementation of the proposed IM/IRA will not significantly alter the ground
water pathway relative to potential human exposure. Assuming 100 percent efficiency of the ITS is less
imponant than the suggestion that the ground water pathway is incomplete. Additionally, futUre and more
detailed risk assessment evaluations both qualitative and quantitative will be performed in the continuing
Phase I and Phase n evaluationfmvestigations of the SEPs (QU4).
2.6.1 Pathwav Exoosure Assessment
The conceptual environmental exposure pathway resulting from the proposed IM/IRA is provided in
Figure 2-7. Pertinent features of the exposure pathway include:
.
Case A: This block model illustrates the primary exposure pathway associated with
conditions as they cu~ntly exist This includes two principal exposure pathways. Pathway'
Al is the ground water contamination exposure route. As indicated on Figure 2-7, there
is no contaminant receptor; rather, ground water is intercepted in the interceptor ditch and
returned to the SEPs (pond 207-B). Case A also includes an air pathway (A2) by which
compounds can be released from the SEPs and distributed by airborne transpon to off-site
receptors, workers, or ecological receptors. Pathway A2 is considet:ed to be a negligible
exposure mechanism because of the (1) very low contaminant concentrations in the pond
waters, (2) the small flux of contaminants released from the pond waters, and (3) the large
dispersion and dilution factors associated with airborne transport
~ -,.'
RFPflllm.3.R
2-38
-------
N
'It
4:
I
I'}
o
en
'It
o
I'}
<..'>0::
~w
3m
<{~
O::::J
02
>-->--
mm
00
WW
y:>
uO
wO::
IQ
uQ
4:
CASE A PRIMARY PA1HWAY
SOURCE, RELEASE PATHWAYS RECEPTOR
SOLAR INFIL TRA TlON ADVECTION & DISPERSION NONE.
(A1) EVAPORATION LEACHING IN GROUNDWA l£R
PONDS
SOLAR VOUTlUZATION AIR OFFSll£ PUBUC
(A2) EVAPORATION DROPLET DISPERSION WORKERS
~ ** PONDS RESUSPENSION
--
L
CASE B SECONDARY PA1HWAY
SOURCE . RELEASE PATHWAYS RECEPTOR
(B1 )
VOUTlLlZA TlON
(FLASHING)
AIR
DISPERSION
OFFSITE PUBLIC
WORKERS
FLASH TANK
FIGURE 2-7
CONCEPTUAL EXPOSURE
PATHWAYS
* GROUNOWA TER IS COLLECTED IN THE INTERCEPTOR 01 TCH
AND RECIRCULA TED BACK TO IHE SOLAR EVAPORA nON PONDS (POND 2078).
~ROUNOWATER 15 COLLECTED IN THE INI[R([PTOR DITCH'
-------
.
Case B: Case B conceptually illustrates how the proposed IMJIRA will modify the primary
pathway (Case A) through inttoduction of a secondary pathway. The secondary pathway
truneaies the recirculation loop and shunts the contaminated ground water from the
interceptOr ditch to the flash evaporatOr system. The secondary pathway introduces a new
exposure pathway (B 1) which originates at the flash tank. Volatile and possibly nonvolatile
compounds may be "flashed" (vaporization or particulate aerosolization) as they encounter
. the pressure differential of the flash wik. Once released. aerosolized compounds can enter
the atmosphere by passing through the system vent apparatuS. Once in the atmosphere.
aerosolized compounds could be tranSported to off-site receptOrs. nearby worlters. or
ecological receptOrs in the immediate vicinity by dispersion in the atmosphere.
A very important physical system that is included as a design feature of the IMIIRA that interrupts the
secondary pathway is not featured on Figure 2-7. This is a high efficiency particulate air (HEPA) filter
on the system vent to remove any aerosolized particulate matter before discharge to the atmosphere.
A review of Figure 2-7 indicates that only pathways A2 and Blare potentially cOmplete. ~ discussed
above. neither potentially complete pathway is expected to present an appreciable exposure source to the
off-site public. worlters. or ecological receptors.
2.6.2 Chemicals of Concern
The SEps. as indicated on Figure 2-7. are the source of chemical compounds that may enter any of the
exposure pathways. Chemicals of concern (COCs) (from Tables 2.1" through 2.5) are the compounds that
would most likely present significant human health hazards in the event that sufficient exposure conditions
and concentrations were met A review of available analytical data suggests that very few compounds,
characteristic of the SEPs, are notably toxic to humans. Additionally, those compounds that could
potentially pose a human health threat are generally at very low concentrations. A brief discussion of
potential COCs follows.
The potential contaminants of concern for this qualitative assessment can be summarized as: (1) cenain
radionuclides such as Pu~zs' and Am-34!, (2) certain heavy metals such as beryllium. cadmium and chromium,
and (3) a limited number of VOCs such as carbon tetrachloride and trichloroethylene.
2.6.2.1 Radionuclides
Pu'zs, and Am-341 have been detected in the SEP waters. Aqueous concentrations of Pu-zs, of 0 to 660 pCiIl
have been reported. Am-2Al has been deteCted at 200 pCi/l. Additionally, tritium and uranium have been
detected in waters from the SEPs..
RFPQ1lm-3.R
2-40
-------
. .,
2.6.2.2 Metals
Metals, includirig beryllium, cadmium and chromium have been detected in the SEP waters at concentrations
greater than background. Aqueous concentrations (from Tables 2.1 through 2.5)" reponed for some metals
associated with ~ solar evaporation ponds ~ listed below:
TABLE 2.7
CONCENTRATIONS OF SELECTED METALS
Compound Aqueous (mg/l)
Beryllium ND to 0.1
Cadmium . 0.07 to 0.15
Chromium 13.7 to 16.7
Iron 1.5 to 8.0
Nickel 1.9 to 2.0
Zinc 0.62 to 0.78
2.6.2.3 Omanics
Organic chemicals have been reponed occasionally in samples (near the detection levels) obtained from
the ITS water. The data does not show consistent occurrence of organics. Organics reported to occur
infrequently that are notable from a human health perspective include carbon tetrachloride and
trichloroethylene. Other organics (such as phenols) occur sporadically and are also in low concentrations
in the data. 1bis occurrence does not suggest that they should be considered as COCs. Sporadically
occuning deteCtions of organics have been used in this risk assessment, therefore this assessment is
considered conservative.
2.6.3 Toxicitv Assessment
The groups. of compounds identified as contaminants of concern have the potential for producing adverse
health effects in humans under cenain conditions of exposure. A brief summary of the more relevant human
toxicity information on the groups of compounds identified as contaminants of concern follows.
2.6.3.1 Radionuclides
EPA regards radionuclides as human carcinogens. Normally, carcinogenicity is the principal human toxicity
concern.
RFPtJllm.3.R
2-41
-------
\".':. ..
2.6.3.2 Metals
Heavy metals, such as .those associated with the SEPs, are reported to produce systemic toxic effects in
humans. Additionally, EPA regards some heavy metals (e.g., beryllium, cadmium, chromium) as possible
~an"carcinogens: .
2.6.3.3 "olatile Or2anics
"OCS such as those associated with the ITS water, are reponed to produce systemic toxic effeCts in humans.
Additionally, EPA regards some "OCs (e.g., carbon tetrachloride and trichlorethylene), as possible human
carcinogens.
The qualitative pathway model employed in this analysis indicates that neither exposure concentration or
. duration of exposure would be sufficient to produce adverse health effeCts from chronic exposure.
_. .
2.6.4 Risk Characterization
'.~~Ii'qiWit3tive-perspeCiivi-operaiion:ofthe flash evaporator system will not introduce any additional
'..;.......,,- -r
-::r~~.to workers or the off-site: public nor willit appreciably reduce the existing site risks. Observations
~,";~tbat.suppott this evaluation are: '. .' ";
. There is no complete ground water pathway (see Figure 2-7). Rerouting contaminated
ground water to the flash evaporator system does not affect the risk associated with
exposure pathway AI.
.
The potentially completed airborne pathway from the SEPs to off-site receptors and workers
(exposure pathway A2) will be nuncated as a result of implementation of the IM/IRA.
This is because, as recirculation of contaminated ground water (back to the SEPs) ceases,
the source te1IIl (i.e., SEP water) will diminish. As the source te1IIl diminishes, the
potential for exposure to contaminants through the airborne pathway will also decrease.
As noted previously, exposure pathway A2 is considered to be a negligible source of
exposure to the off-site public and workers.
.
Implementation of the IM/IRA introduces the secondary B2 pathway. Conceptually, this
results in a translocation of the exposure pathway A2 to the flash evaporator system vents
(see Figure 2-7). As noted previously, exposure pathway A2 is considered to be a
negligible source of exposure to the off-site public and workers. The potential risks of
this pathway are funher reduced by application of the physical systems design feature of
the IM/IRA that interrupts the secondary pathway. The HEPA system is capable of an
approximately 99.9 percent removal efficiency for aerosolized particulates.
RFPQJlm-3.R
2-42
-------
~
.~~
~) .
...
SCALE. I"~ = 750'
o &00' IOCW
I ' I
ClJlllDUt INt[RVAL . !O'
FIGURE 2-4
TOPOGRAPHIC MAP OF
SOLAR EVAPORATION PONr
-------
o
'"
(II
I
t<)
o
0>
~
o
t<)
"0::
z",
!!Em
...:::1
0:::>
oz
...
~
x
~
ii:
FIGURE 2-2
ROCKY FLATS PLANT
AND VICINITY MAP
(\, / J Z-
J \(\/)/~'128 ~
. / 010(04
~~
o
'"
(1~
"'0-
i'i~
SCALE: I" = 1 MILE
. .
o 1/2 1 MILE
j .
...>-
o::m
o
REFERENCE: EOaO DRAFT PHASE I
-------
'"
N
m
I
'"
o
01
...
o
'"
~fS
~m
«~
,,:::J
az
i\ ;;
. .
~~
.0.0
~~
~~
S~
""0
~g:
i5~
«
~a;
~n
0:""
i>-
~m
o
),
--
j
fffi
/~
I
\ ~
~I ~
I
,,-:::;;-:':::-~,
,,, < ~
/ ',~ ,.
/1 McKAY "BYPASS " ----- ....
- .. ;:// .... - - -- )
,., - -... ---
,,' -- ",I
,{
~~~
=-
_-s:.
'=
~ ce:. \
~, \
a~\
'Z-'S)
""\"-
t-
W
W
It:
l-
I/)
-------
3.0 DESCRIPTION AND ANALYSIS OF SELECTED REMEDY
The selected remedy for this IMIIRA includes the use of temporary surge tanks and three ponable flash
evaporatOrs. The "No Action" alternative was dismissed because the ponds must be dewatered in order
to proceed with partial closure activities and final remediation of the ponds. Furthermore. the consequence
of the "No Action" alternative is inconsistent with the AlP and lAG.
3.1 DESCRIPTION OF SELECTED REMEDY
The selected remedy is the use of three ponable flash evaporators to accelerate the removal ofliquids from
the 2ff1-A and 2ff1-B SEPs. The three ponable.evaporators are also needed to treat water that is currently
discharged into the 2ff1-B Pond from the ITS located north of the ponds. In order to prevent additional
accumulation of water in the 2ff1 -B Pond. temporary surge tanks will be built. in the vicinity of the pond
to hold the ITS water before it is sent to the three ponable evaporators.
Water will be pumped from the ponds and the surge tanks to the three portable evaporator systems located
within a building near the solar ponds (Building 910). The final concentrate from the evaporators will
be cemented in the pondcrete and/or saltcrete processes to meet defense waste acceptance criteria for
disposal of low level mixed waste. Distillate from the evaporatOrs will be discharged into one of the three
7.000-gallon batch tanks for sampling. Section 3.1.1.4 and Appendix B of this document explains the
sampling and analytical requirements. Distillate exceeding the allowable conductivity limit (150 micro
mho/em) will be reprocessed. Distillate meeting the general characteristics of commercially available raw
water will be reused as makeup water in the raw water or condensate systems on plant site. A 500.000-
gallon tank will serve as a distillate holding tank from which water will be supplied on demand into the
raw water or condensate systems.
3.1.1 Treattnent SvstemComoonents
Three mechanical/thennal forced evaporator systems' will be installed. Each system consistS of a vapor
compression (VC) unit installed in series with a multiple-effect multiple-stage (MEMS) flash evaporator.
The distillate from both the VC and MEMS is moved by differential pressure intO a ~e tank. The system.
including VC and MEMS bodies is maintained at a vacuum by an eductOr system which has as itS motive
force. the recirculation of distillate. During system operations over pressure proteCtion is provided by a
temperature sensor (which equates to saturation pressure) which shutS the entire unit down when temperature
reaches 205° to 210°F. As a further precaution to prevent particulate air emissions from the system. the
...
RFPaum-3.R
3-1
-------
concentrate tank is vented to atmosphere via a HEP A filter, thus, there will be no contaminated air emission
from these units.
Operators of the evaporation units will be formally ttained and qualified. The ttaining"wiD: include ~eory
of operations, systeDi components, principles of operations, system interrelationships, protective devices,
and practical factors. The training and qualification will be validated in accordance with existing plant
procedures.
3.1.1.1 Location and Eauimnent DescriDtion
Building 910, located south of Pond 207-B South, will be used to house me-forced evaporation equipment
This building was originally consttucted .for a reverse osmosis (RO) system to treat RFP sanitary effiuent
The location of Building 910 and its existing tank storage capacity made it .the optimal location for the
evaporation equipment. Building 910 is a concrete structUre with concrete floors and roof. On the main
floor of Building 910, there are three rooms that will be used: the Process Room. Chemical Prep/Make-up
Room and Operating Personnel Room. The lower level (basement) of Building 910 contains holding tanks.
transfer pumps and ancillary equipment for the evaporator products. . Some equipment in Building .910 is
being snipped out to accommodate the evaporation equipment All existing equipment that will be reused
for the evaporation proje~ will be inspected and/or tested.
Main FJoor Building 910
. .
Process Room: The Process Room is located at the west side of the main floor of Building 910. There
will be three vapor co.npression (VC) units and three multiple-effect, multiple-stage (MEMS) .flash
evaporators centrally located. A duplex filter station, EDT A injection tank and nitric acid injection tank
will be located at the northwest comer inside a benned area. Three natUral gas-fired generators located
outside and east of Building 910 will provide electrical power to compressors, pumps and some ancillary
equipment, and exhaust heat to the MEMS. All of the doorways into this room will have benns across
them and the basement floors will be coated to provide secondary containment. See Figure 3-1 for the
main floor layout Both the main floor and lower level will be equipped with a wet fire suppression system.
Chemical PreD/Make-uD Room: The Chemical Prep/Make-up Room is located at the main floor of the
south comer of Building 910. The room contains the nitric acid make-up tank and will be used for the
pH adjustment The east side of this room will be used as a general laboratory, containing nittate analysis
equipment, a pH and conductivity meter. The emergency showers and eye wash are located in this room.
."
RFPaum-3.R
3-2
-------
All of the doolWays will have berms across them, and the floors will be coated with a sealant to provide
secondary containment. See Figure 3-1 for the main floor lay-out
Lo~er Level Building 910
Six existing tanks on this level will be used as rempo.rary holding tanks for the evaporation prod~cts. These
tanks will be struCtUr3l1y and seismically qualified for the new application. All six tanks have been
inspected for RCRA compliance in accordance with 6 CCR Section 265-191 and for seismic qualification
by a qualified professional engineer. Required actions have been incorporated into the installation plan
and certification will be issued when the installation has been completed. The distillate will be held in Tanks
D-2, D-6, and D-7. The concenttate (brine) from the MEMS units will be held in Tanks D-9 and D-18.
Tank D-I0 will be used as a surge tank for the distillate systeIi1. In addition, a new 600 gallon stainless
steel tank D-50 will be used for brine flushing. Pumps for recirculation and transfer of materials will be
located on this level~ The floor and sump of the lower level will be coated with a sealant to serve as
secondary containment for all the equipment within the building. The sump will have one layer of 60 mil
high density polyethylene liner on top of the sealant leak detection device. The sump will be lined to meet
the requirements of 6 CCR 1007-3 and piping will ensure sump liquids are not discharged outside the
containment of Building 910. The containment volume will be 110 percent of the volume of the largest
tank located within Building 910. See Figure 3-2 for the lower level floor lay-out.
Auxiliary Equipment
Each of the 207-A and 207-B Solar Ponds will have a pump inside the Pond berm connected to a double
containment pipe with leak detection to supply water to the evaporators.
A 2500 gallon stainless steel tank located north of the building 910 will be used to hold scale inhibitor
EDT A.
Tank 215-D, which has a capacity of 500,000 gallons, is located to the west of Building 910, north of
Building 928. This tank will be used as a holding tank from which the distillate will be supplied on demand
into the raw water or condensate systems.
A 500-gallon stainless steel tank located to the east of building 910. will be used to hold nitric acid for
pH adjustment
RFPawn-3.R
3-4
-------
.'#"'...
Three portable cooling towers. which will provide cooling water to the three ponable evaporation system.
will be located to the north of Building 910.
. .
."".
3.1.1.2 ~ss DescriDtion
A conceptual flow diagram of the thiee portable evaporators is provided in Figure 3-3. The water from
Pond 2crT-A and Ponds 2crT-B North. Center. and South and ITS water will be pumped via a double-pipe
transfer line which will .connect to a manifold station equipped with duplex strainers and duplex filters.
The duplex strainers will ttap the material of a size that cannot pass through 118" to 3/16" perforations.
An in-line 100 micron duplex filter will trap the sediments that occasionally are picked up by the transfer
pumps. The sttained and filtered material will be handled as low level mJxed waste as specified by existing
RFP waste guidance. The brine produced by the VC unit will be fed to the preheater of the MEMS flash
evaporator. The preheated pond water or ITS water will be fed to the VC unit for evaporation.
The distillate will be collected from the VC unit and the MEMS flash evaporator unit into two separate
small surge tanks. From the surge tanks. distillate below a conductivity of 150 micro mho/cm will be
discharged into one of three 7.000-gallon batch tanks. Distillate exceeding 150 micro mho/cm will be
recycled. by a solenoid operated valve actUated by the conductivity probe. back to the feed stream for
reprocessing. An automatic composite sampling process will be initiated at the beginning of discharge
into the 7000 gallon batch tanks. When the accumulated distillate level reaches the high-level setpoint
on the batch tank, the composite samples will be collected and sent to the laboratory for analysis as specified
in the Waste Analysis Plan (WAP). Sections 3.1.1.3 and 3.1.1.4 of this document explains the sampling
and analytical requirements in detail. The distillate will then be transferred to the 500.000-gallon distillate
holding tank 21SD. From Tar.k 21SD. the distillate will be injected into the Raw Water System for plant
cooling tower usage on a demand basis. The concentrate from the MEMS flash evaporator will be collected
in holding tanks before being ttansferred to the pondcrete cementation process or Building 374. saltcrete
process. A composite sample of the concentrate Will be manually collected for analysis as specified by
the pond sludge solidification process or the saltcrete process as applicable.
Process Performance
Each portable evaporator system (VC unit in series with MEMS flash evaporator) has a designe~ output
of 18.000 gallons per day. There are three identical systems installed in parallel so that an operator can
operate any combination of the three systems simultaneously. The system will be capable of producing
a product water quality of 150 micro mho/em or better and meeting general characteristic of commercially
available raw water. The Waste Sampling Plan in this document (Appendix B) provides the specific
RFPawn-3.R
3-6
-------
FIGURE 3-3
CONCEPTUAL FLOW DIAGRAM
PORTABLE EVAPORATORS
POND
2078
NORTH
TOTAL OF THREE EVAPORATING SYSTEMS
IN PARAllEL (SYSTEM CONSISTS OF VC UNIT,
MEMS UNIT, FEED TANK, TWO DISTilLATE
TANKS, AND CONCENTRATE TANK)
POND
207A
POND
2078
CENTER
LEGEND:
SAMPLE POINTS:
DDISTILLA TE, COMPOSITE, AUTOMATIC
. CONCENTRATE, COMPOSITE, MANUAL
PRIMARY FEED
DISTILLATE
---------- SECONDARY FEED
VAPOR
.------ COOLING WATER
CONCENTRATE
COOLING
TOWER
POND
2078
SOUTH
BLDG. 910
~- ii~-- ~ 0 ° r- '-'-'-'-'-' -.-.-.-.-.-.-.- ._._~._._._._._._._._._._._._._._._._._._._._._._._._.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-. .-.-.-.-.-.- - -.-.-.-.-.-.-.-.-.-.-. -.-.-.-.-.-.-. '1
~ -, NATURAL! OFF SPEC. DISTilLATE 9 I
: GAS ~ HEPA ~ i
1 SUPPLY i ~4 -' .._-- -" -. ... ~ I
1 I ~ .
1 i !
1(. i I
1 500.000 i i
; GALLON ~ _J:
: TANK : R\~~CiE MEMS i
- / ~ i ~ .. I
I '. ~ I I 30;000 PPM (APPROX.) . i
: . i DISTilLATE 10S !
I ! ° TANK I
:'--RAWWAT'EA"I-v1~ ~g~~~~~m.TY . . ;JJ-.o1 I
1 LINE 1 SET POINT I
I . '. I 150UMHOICM DISTilLATE ..- .
: ! I. ~ TANK .m I
I' ( HEPA I
I i 6 r" DI&T\L.lATE i
: : 'H' CONDENSATE \ "t~.' . CONCENTRATE;
1 EXISTING i ) ,,/ TANK i
I : RAW WATER ! SYSTEM' n;; 1
r - SYSTEM! " . :
~ SURGE~' ./ i
L._!~N.~._._._._o_._._._._._'_'_'_'_'_'- .-.- .-.-.-.-.-.-.-.-.-.-.-.-.-.- .-.-.-.-.-.-.- .-.-.-.-.-. -.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-;
CJ
z
m
w
g
a:
11..
~
a:
o
c
z
o
-------
. ..""'1
! "-
\
constituents to be analyzed and the acceptable actiQn levels. Fmal concentrate produced will be controlled
to reach a total dissolved solids ("IDS) level ranging betWeen approximately 300,000 ppm and 400,000 ppm.
Logistics of Pond Water Removal
The three ponable evaporator systems will have the capability to treat the water from one pond or a
combination of ponds. However, neither tteated pond water nor byproduct from the evaporator will.be
returned to any of the four ponds after the initial verification process has been. completed. During initial
verification. the water may be discharged to the pond from which it came.
Distillate Disposition Plan
Upon approval of analytical results from the acceptance phase, distillate will be prod1Jced on a production
basis and will meet all performance specifications of the W AP prior to being transferred to the Tank 215-D
(500,000 gallon capacity). From there, the distillate will be pumped into the Raw Water header on a.
demand basis by a centrifugal pump. The distillate pumped into the Raw Water Header will be used by
plant cooling towers. The cooling tower blow down stteam will be discharged to the Sanitary Treatment
Plant of RFP.
. . .
The distillate from tank 215-D may be used as plant boiler feed water when the cooling tower demand
falls. For use as feed, operations will pump the distillate, into the condensate return receiver which is located
in Building 910. This will allow the distillate to be discharged into the 300,000 gallon condensate tank
located in Building 443 for supply of boiler feed water.
Concentrate Disposition Plan
The concentrate will be collected in the concentrate holding tank before being transferred to the pondcrete
cementation process or to the Building 374 saltcrete cementation process by a tanker tIUck.
Flow, Level and Spill Control
The main feed stteam, final distillate stream, and the final concentrate streams will be monitored for flow
rate and will have a continuous flow indication of the total volume transferred. All collection tanks and
holding tanks will be equipped with a high level alarm control and an automatic pump shut off to prevent
overflow of liquid. The 500,OOQ-gallon distillate holding 'tank 2l5D will not have secondary containment,
because distillate held in Tank 215D has been proven to meet the "re-use" criteria as stated in the W AP
(Appendix B) and thus there will be no release of contaminants that may threaten human life or the
environment Tank 215D will be equipped .with a high level alarm and a secondary high level alarm. The
RFPfJIIm-3.R
3-8
-------
high level alaIm alerts the operators to stop evaporation. The secondary high level alaIm will automatically
shut down the transfer pumps that feed into the 500,QOO-gallon holding tank.
3.1.1.3 SamDlin2 and Analytical Reauirement
The purpose of the sampling plan is to ensure the distillate will be an effective substitUte for water used
in the raw water system and therefore demonstrate that the distillate would have no adverse impact on the
quality of the water discharged from the plant or emitted from cooling tower.
Detailed cbaracterization of pond water was recently performed and the data is presented in Tables 2.1
through 2.6. All analytical procedures follow EPA SW-846 methods. Level IV, which is characterized
by rigorous QA/QC protocols and documentation. was used for analysis of all constiwents. This level
provides legally defensible qualitative and quantitative data. The constiwents analyzed consisted of the
parameters currently measured during the monthly sampling of the Building 374 evaporator distillate and
the parameters required for sampling of water discharged from the planL Distillate from the 374 evaporator
is currently reused in the building 374 cooling tower. The W AP detailed in Appendix B implements the
necessary actions to ensure that the distillate from these portable flash evaporators will also be an acceptable
substitUte for raw water.
3.1.1.4 Waste Analvsis Plan (VI AP)
The foundation for the development of the W AP is the characterization data presented in Tables 2.1 through
2.5 for the Solar Ponds and Table 2.6 for the ITS waters. ConstitUents not found within the characterization
reports have been deleted from the W AP.
3.1.1.5 Facilitv SafetY FeatUres
Fire Protection and Safety Equipment
There will be a new wet fire suppression system installed to cover the entire building. Approximately five
fire extinguishers will be provided throughout the entire building. Fire phones, safety shower(s) and eye
wash equipment will be located to adequately provide for personnel safety protection.
Alarms
The following is a list of the alarms for both the process and personnel:
- .~
RFPawn.3.R
3-9
-------
Process
.
Over temperature alarin(s) - Audible, Visual
Higb/low level alarm(s)- Audible, Visual
Power overload alaIm(s) - Audible
Loss of vacuum alarm(s) - Audible, Visual
Low flow alaIm(s) - Audible, Visual
Conductivity level high alarm(s) - Visual.
.
.
.
.
.
Personnel
Fl1'e alaIm - Audible, Visual
Inspection
Inspection requirements of the facility will comply with the appropriate procedures for operation of the
system. Tanks containing RCRA regulated waste will be included in the Plant Assessment/Surveillance
Program.
Operating Procedures
Operation of all equipment in this facility will follow the appropriate procedures. Procedures will be
completed at the completion of equipment installation. Fmal walkdown of the procedures and revalidation
will occur prior to equipment operation. The following is a list of procedures that will be implemented
prior to equipment operation.
.
WO-2210 Systems Line-up
WO-2211 Chemical Makeup System
WO-2212 Feed System
WO-2213 Evaporator System 1
WO-2214 Evaporator System 2
WO-2215 Evaporator System 3
WQ-2216 Distillate System
WO-2217 Concentrate System
WQ-2218 AbnormallEmergency Response
Alarm Response Procedure
Site Specific Health and Safety Plan
.
.
.
.
.
.
.
.
.
.
Spill Response
The spill response will be in accordance with the plant spill response procedure as contained in the
Hazardous Waste Requirements Manuall-lOOOO-HWRM.
RFPawn-J .R
3-10
-------
Personnel Training
Rocky FlatS personnel assigned to operate the Building 910 evaporatol'S will receive the following training:
.
Rocky Flats core and area-specific training
.. 4O-hour OSHA
.
Annual RCRA Training
.
On-the-Job training provided by the evaporator manufacturer during the initial trial run
.
Job-specific training to include theory of operations, system components, principles of
operations, system interrelationships, protective devices,JU1d practical factol'S.
3.1.2 StoIasze Comoonents
Water collected by the ITS is currently returned to the 207-B ponds (primarily the. North impoundment).
To allow pond dewatering to proceed, the ITS water will be held in three temporary surge tanks.
3.1.2.1 Location of Tanks
The three temporary surge tanks will be located well within the plant's buffer zone, north of the SEPs (see
Figure 3-4).
The proposed site is not located within the 100-year floodplain, wetlands, a saltdome fonnation. underground
cave or mine. or within 200 feet of a fault displaced by a Holocene Fault The proposed site is not an
area of known contamination and is not within a solid waste management unit Furthennore. the proposed
site would have no impact on known archaeological or historic resources and is not expected to affect the
black-footed ferret or the bald eagle (DOE, 1991b).
Excavation and grading will be required to prepare the site for the temporary tanks. The site will be graded
according to specifications as established in the geotechnical study of the proposed site. Excavation pennitS
will be reviewed and approved by appropriate environmental management staff prior to any work on this
site. Measures will be implemented for erosion conttol and soil stabilization and to facilitate restoration
of the pads after the tanks are removed.
3.1.2.2 EauiDment DescriDtion
Each tank will have a capacity of approximately 500.000-gallons and will be constructed of galvanized
steel and high-density polyethylene (HDPE). Each tank will be approximately 112 feet in diameter with
RFPawn-3.R
3-11
-------
V
V
.c(
I
I')
a
m
V
o
I')
00::
~w
::=ID
.c(::E
O:::J
OZ
//"..~
PERIMF.TP.R SP.CURITI ZON
"
.
-
~~:1;g~~yL~~~~~ / / ~ . //'.-'./
at~~ /
iJNT c;!~. -' 870
..-..-.. ,.;;,_.._._.._.:-..~"...::. ~. ~
"'" ~~MPHOUSE~ ~
~-096) - ~ ~
~5~...~ . .... . ~ .,....
" .... --t--J..
.. ~'JIO .
.. . . . . .
. . S920. . .
. . . . .
. .. . . ..
.. . . .
. .- . . .
.e . I .8 .8
. 8
-.J
930
5940
.5950
5960
S970
+711-
,.-
.
POND 2078
NOR11I
POND207A
POND 2078
CENTER
~
-ft-
,
POND 2078
SOUTII
o
I
300 feel
I
BUILDING 910
FIGURE 8-4
PROPOSED LOCATION FOR
TEMPORARY SURGE TANKS
APPROXIMATE SCALF.
REF"- ~IIJCE: ASI, ZERO OFF SITE DISCHARGE STUDY,
SO VAPOR AT ION PONDS, FIGURE 3,
-------
10 foot galvanized steel sidewalls. The bottom and inner sidewalls will be double-walled with HDPE
(see Figure 3-5).
The ~lX?rary holding ~ and ancillary equipment will be designed. installed, and operated in accordance
. .
with the tank requirements of 6 CCR-l007-3 Pan 264. Subpan 1. .The tank systems will incorporate double-
wall containment featUreS and provisions for detection and removal ofprimary containment leakage (EG&G.
1991a).
The subgrade will be prepared and graded to allow any leakage to be collected at the leak detection sump.
Non-earthen base material (i.e.. concrete and/or asphalt) will be placed over the subgrade to provide
stnlctural support for the base of each surge' tank. A l00-mil geotextile will be placed over the
concrete/asphalt base to protect the secondary wall from punctures or abrasions. A SO-mil HDPE secondary
wall will then be placed over the geotextile. A HDPE geonet will be placed over the secondary wall to
allow any leakage through the primary wall to be immediately collected in the leak detection sump. A
SO-mil HDPE primary wall will then be placed over the geonet In addition, a 20-mil HDPE liner will
be placed over the primary wall to protect the primary wall from ultraviolet degradation. The leak detection
sump will be located in the middle of each tank and will incorporate below grade piping to a standpipe
located outside the tank which will allow the immediate detection of any leakage through the primary wall.
The standpipe will be provided with a sensing device. In the event leakage occurs. an alarm will sound
in Building 374 which is continuously manned 24 hours a day. If a valid leak occurs, the contents of the
tank with the leak will be pumped to another tank. At least one tank will remain empty to provide this
capability.
Water will be pumped from the existing ITS pump house to the tanks and then from the tanks to the three
portable evaporators via double-walled piping. Above ground piping will be made of polyvinylchloride
and underground piping will be made of polyethylene. All exposed portions of the piping will be heat-
traced, insulated, or drained for freeze protection.
In order to prevent overfilling, each holding (surge) tank will be equipped with a high level and low level
alarm. The high level alarm will activate when there is approximately 2 feet of freeboard remaining in
the tank(s). The freeboard capacity will allow approximately 15 hours of normal fill time. Upon activation,
the high level alarm will automatically shut down the feed pumps and begin pumping excess water to an
adjacent surge tank which is not full. In addition, the alarm signal will be sent to Building 374 which is
continuously manned 24 hours a day.
RFPtJll/ll-3.R
3-13
-------
" ~~,
" .'.
. '
3.1.3 General Comoonents
3.1.3.1 Ouantitv of Waste to be Treated
The largest volume solar evaporation pond (pond 200 -A) contains approximately 3 million gallons of water
to be ev~rated to allow pondcreting of sludges to occur. ~e 2OO-B ponds contain a total of
approximately 5 million gallons of water to be evaporated. The collected ITS water. which will be stored
in the temporary surge tanks and will be a continuing source of water. will require treatment through the
evaporator system. The average amount of water collected by the ITS over the course of a year is estimated
to be 4 million gallons. based on observations made in 1987.
As previously mentioned, each portable evaporator system has a design output of 18,000 gallons per day. .
Therefore the utilization of all three systems would have a treatment capacity of 54.000 gallons per day.
. -
3.1.3.2 Treatabilitv Testin2
Treatability tests were performed using the proposed tteatment system by UCON. Incorporated of Pensacola,
Florida (LICON. 1990). In ihat LICON was not an authorized recipient of pond water. tests were conducted
using sunogate pond water. Tests were conducted with feed supply prepared to simulate each of the four
SEPs. The sUITOgate feed supplies were prepared based on the major ions contained in their respective
ponds.
Test results indicated that the 10.000 ppm total dissolved solids feed supply (pond average) could be reduced
to 1/5Oth of its present volume and produce an excellent quality of distillate averaging less than
75 pmhos/cm. According to recent pond water detailed characterization results. the heavy radionuclides
such as U. Pu. and Am detected. are at a treatable level with a high performance type of demister ~ -ad.
Although ttitium was detected. the level was well below established drinking water standards.
A ttial run (acceptance phase) of the installed system will be conducted and evaluated prior to full-scale
operations. The ttial run period will include extensive sampling and analysis of the distillate per the analysis
plan. This trial run and testing period will also be used to adjust operations and train operators.
3.1.3,3 Generallnst>ections
Inspections of the storage and treatment operations will be conducted in accordance with the applicable
requirements of 6 CCR 1007-3 Pan 264. standard plant operating procedures. and as needed. Specific
inspection schedules and record keeping procedures will be developed and implemented prior to initiating
"
RFPawn-J .R
3-15
-------
operations. Inspections will be conducted at a frequency wbich identifies problems in time to correct them,
prevents human health and environmental hazards, and ensures safe working conditions.
During operations:
.
Tank leak detection systems
Level of water and freeboard in the tanks
Ancillary equipment .
Above-ground tank equipment (piping, valves, etc.)
Structural integrity of the tanks
Area surrounding the tanks
Loading and unloading areas of hazardous waste.
.
.
.
.
.
.
Other items to be inspected will include, but not be limited to:
.
Operating and structural equipment
Safety and emergency equipment
Monitoring equipment
Security devices
HEP A filters.
.
.
.
.
3.1.3.4 Management of Waste
As mentioned previously, the concentrate generated by the evaporator system will be collected in the
concentrate holding tank and will also be sampled for waste characteristic data before being transferred
to either the pondcrete cementation process or to the saltcrete process.
The distillate (water) generated by the evaporator system will not constitute a solid and hazardous waste
because it will be used or reused as an effective substitute for a commercial product. Therefore, the
distillate is not a waste based on the commercial product exclusion contained in 6 CCR 1007-3 Pan 261.2
(e) (ii). The distillate (water) will be used or reused as an effective substitute for commercially available
water that could or otherwise would be purchased from the Denver Water Board (DOE, 1989a).
3.1.3.5 Institutional Controls
This IMJIRA will be conducted entirely within the Rocky Flats site boundary. Since current security
controls (Le., access control, fencing, etc.) do not allow the general public intO the area of this IM/IRA,
additional institutional controls are not warranted.
RFPawn-3.R
3-16
-------
.3.1.3.6 AssumDtiOns. Uncertainties and Continl!encies
As detailed in the process description for the evaporator system, distillate not meeting specified quality
requirements will be recirculated for additional treatment. In the event that specific quality requirements
are not obtained by the proposed system, addi.tional treattnent units will be evaluated and incorporated into
. .
the treatment system as needed "to meet or exceed performance requirements.
Each temporary surge tank will be equipped with a leak detection system. If a valid leak is detected, the
tank contents will be transferred to an adjoining tank. In the unlikely event that a catasttopbic failure of
a tank occurs. the released water would flow into Nonh Walnut Creek. Much of the water would percolate
back into the ground water system. The remainder would be contained in Pond A-3 because ponds A-I
and A-2 are not tributary to Walnut Creek. Sampling of Pond A-3 would then occur. If so determined.
the water could be collected and transferred to one or both of the remaining tanks or ttanSferred to the SEPs.
3.1.3.7 Closure of IM/IRA Structural ComDOnents
It is anticipated that the temporary surge tanks will be utilized at least into 1995. The tanks may be utilized
as part of the initial action that may be required following the Phase I RFI/RI source and soils
characterization as defined in the lAG. The temporary tanks will then be replaced by permanent tanks
if deemed appropriate. The temporary tanks and ancillary equipment will be closed in accordance with
the closure requirements of 6 CCR 1007-3 Part 264. Subpart G.
3.1.4 Costs
The estimated total cost to conduct this IM/1RA is $8,017,000. A breakdown of the estimated capital. and
operating and maintenance costs associated with this IM/1RA are included in Table 3.1. This cost is only
for the water evaporative effons and does not include the cost of processing the pond sludge into pondcrete.
3.1.5 Remediation Goals and Performance Standards
The overall goal of this IM/IRA is to remove the liquids from SEPs (207-A, 207-B Nonh, 207-B Center,
and 207-B South) as expeditiously as possible in order to be able to remove and solidify the remaining
sludges.
An associated goal is to implement a means to store and treat water collected by the ITS which does not
include the use of the SEPs.
RFPtUIm-3.R
3-17
-------
TABLE 3.1
ESTIMATED COSTS OF SELECTED REMEDY
.1. Temporary Surge Tanks (3) 500,000 gallons each
2. Associated Piping and Equipment
3.
$631,000
Site preparation. and installation
$227,000
$378,000
'i_t__¥~lt,...:....
1.
Flash Evaporators (3) systems
Associated Piping and Equipment
$2,000,000
2.
$700,000
. 3.
Site preparation and installation
$1,690,000
jf._li:lli!!!!il;!lli!ll~ilitiitI1f.iI11ill~~!ll;\1iii~~iii{t~iI{ili!!I!i!!!!~jli!ii!!iii!!!I!i!!i!i!!i!i!li!f:~~liliii
$1,221,000
'11II11Itl_1!f:1I1Ift_I~!!lIj1*'lllii~tl:I~r:1jil:iilil~i!ilii[~1~i!!I!:I:i\1Iiil[iii~li1~iii!~lill\~~1'tilt:l~t\::i!i:i~1~!I[;~!:iiiiili:i!iii:ii!'!
Pumping and Treatment Systems
I
(a) $1,170,000
$8,017,000
(a)
The annual costs will extend at least through 1995 until the OU-4 remediation IM/IRA will assess
long-term solutions
RFPQMm-3.R
3-18
-------
(.
. ...~.
The proposed site for the three temporary surge tanks complies with all applicable siting criteria. The
proposed site for the temporary tanks is not located within the' lOO-year floodplain. wetlands. a saltdome
formation. underground cave or mine. or with 200 feet of a fault displaced by a Holocene FaulL The
proposed site is not an area of known co~tion and is not within a solid waste management uniL
Furthermore. the proposed site would have no impact on known archaeological or historic resources and
is not expected to affect the black-footed ferret or the bald eagle (DOE. 1991b).
The principal compliance point is where the distillate enters the raw water system. specifically in the 7.000-
gallon capacity batch tanks.
Numerical goals to be attained for the distillate include:
. The maximum contaminant levels (MQ.s) as identified in 40 CFR ~art 141 Subpart B with
the exception of turbidity and microbiological contamination
. The surface water standards for Walnut Creek as identified in 5 CCR 1002-8. Section 3.8.6
(2). Table 2 - Site Specific Radionuclide Standards.
'.,
No numerical goals apply to the sludge concentrate. However. the concentrate will be managed within
the pondcrete or saltcrete operations in accordance with RCRA regulations for hazardous waste treatment
and storage facilities (6 CCR 1007-3 Part 264).
3.1.6 Prooosed Schedule of Milestones
The proposed schedule has been established to allow the DOE to meet its lAG obligations for Operable
Unit 4 and facilitate meeting commitments developed in the AlP. The proposed milestone schedule is
provided in Table 3.2.
3.2 ANALYSIS OF SELECTED REMEDY
This section provides an analysis of the selected remedy in accordance with the NCP. The analysis consists
of an assessment of nine evaluation criteria.
. '
"
RFPQ/ll1J.3.R
3-19
-------
TABLE 3.2
N.ULESTONESCHEDULE
INTERIM MEASURElINTERIM RESPONSE ACTION
SOLAR EVAPORATION PONDS
OPERABLE UNIT NO.4
I I Date I
Submit Proposed IMIIRA Decision Document.to EPA and CDH Aug. 15, 1991
Public Review of Proposed IM/IRA Decision Document Sept 1, 1991
Submit Draft Responsiveness Summary and Fmal IMIIRA Decision.Docu- Feb. 15, 1992
ment to EP A and CDH
Begin construction of Treatment and Storage System March 1, 1992(0)
Complete Construction of Treatment and Storage System June I, 1992(0)
Conduct Trial run of Treatment System June 8, 1992(0)
Begin full-scale operations June 15, 1992(0)
(0) ConstrUction will not start until this decision document is approved by the regulatory agencies.
\ .
\
RFPawn-3.R
3-20
-------
i
: '.
3.2.1 Overall Protection of Human Health and the Environment
The selected remedy has been assessed to determine whether it can adequately protect human health and
the environment, in both the short- and long-term, from unacceptable risks posed by hazardous substances,
pollutants, or COt1taminants pre~nt at the site by eliminating, reducing, or controlling exposures to' levels
consisteni with the remediation goals. :Overall.~teetion- of human health and the environment has
~"P":"'-"."",
-------
The proposed tteannent system and storage tanks are considered adequate and reliable to meet the objectives
of this IM/IRA.
3.2.4 Reduction of Toxicitv. Mobilitv or Volume throuEh Treatment
.. .
The degree to which the selected remedy: employs recycling or treatment that reduces toxicity, mobility,
or volume has been assessed, including how treatment is used to address the principal threats posed by
the site. .
The proposed mechanica1Jthermal forced evaporation system will significantly reduce the volume of waste
currently contained in the SEPs. Approximately 8 million gallons of liquid will be tteated from the ponds.
The removal of this liquid will allow the pondcrete process to occur, thereby reducing the mobility of
contaminants in the underlying ground water by eliminating the source.
The evaporation system produces a distillate and a concenttate. The distillate produced will be of high
water quality, suitable for use in the plant's raw water supply. The volume of waste concentrate produced
is estimated to be 1/50 of the present pond volume.
3.2.5 Shon-Term Imoacts
The shon-term impacts of the selected remedy has been assessed considering potential risks to the general
public, woIkers and the environment
The potential risks to the general public health and safety during implementation of this IM!IRA are
considered minimal.
Volatile chemical emissions from the forced evaporators are expected to be insignificant, because volatile
organic concenU'ations in the ITS water have only been sporadically found near the detection limits. The
forced evaporatOr process will be equipped with HEP A filters at the concentrate surge tanks thereby
precluding the carry-over of radioactive particulate emissions.
The risk of a catastrophic failure of a temporary surge tank is considered miirimal. In such an event,
contingencies as per the Surface Water Management Plan are in place to prevent off-site migration of
potentially contaminated water.
RFPaum-3.R
3-22
-------
...
The potential risks to wolkers during implementation of this IM/IRA will be minimi7.ed to the maximum
exteIU possible. Workers will be trained in and be required to comply with necessary health and safety
procedures. Standard operating procedures will be developed for the evaporation process. Personnel
protective equipment will be usc:d in. accordance with applicable procedures.
. .
, .
The potential environmental risks associated with the implementation. of this IMIIRA are considered
minimal.
3.2.6 ImDlementabilitv .
The ease or difficulty of implementing the selected remedy has been assessed by considering the technical
feasibility. the administrative feasibility. and the availability of services and materials.
The technical feasibility to conduct this IM/IRA is considered very good. The COnStIuction and operation
of the temporary surge tanks and the evaporator system will follow standard proven practices. Both the
storage and treatment systems will be monitored in accordance with the W AP to ensure that the
performance objectives are met met. Equipment parameters will be logged and the logs retained at the
facility. All RCRA tanks and the storage tanks will be included in the Plant Material Assessment Program.
The treatment system can be adjusted or modified as necessary to meet the required performance standards.
".
No problems are anticipated relating to administrative feasibility of this IM/IRA. The necessary funds are
available. Furthermore. this IM/IRA will be conducted entirely on-site.
No problems are ani icipated with the availability of the needed services and materials to constIuCt and
implement this IM/IRA.
3.2.7 Cost
The types of costs associated with the selected remedy have been assessed.
The costs associated with this action are considered necessary for the protection of human health and the
environment, and to -meet the intent of the lAG and AlP.
A breakdown of the estimated capital and operating and maintenance costs associated with this IM/IRA
have been previously included in Table 3.1.
RFPaJ/m-3.R
3-23.
-------
..'
3.2.8 State AcceDtance
The assessment of State concerns will be made following the State's review and comment on this proposed
IMIIRA Decision Document
3.2.9 CommunitY ACceDtance .
The assessment of community concerns will be made following the public comment period for this proposed
IMIIRA Decision Document
RFPaum-3.R
3-24
-------
~~
s~
"0
~g:
D~
...
~-
:I:
...
t-
o:
i>-
rim
a
....,.
..'
..
~ \o1'-~'~' 0;;:- .~
V-< .~, '
t"'-IC'~P'~' ---:: ;
.~ ~U11CIJ """ ~ ..
. ':-,
"~' ,
""<~~'....._--_......,..._...._...:... ~,"/"
-~
"- ;tatJe,TI!\JCfiOIJ ;)()IIJT + ~.
~ 1Oe
rTOPTI~R-'lJ (Ie (4) I'AIJ~L$
/ r»OlJI'U T'e~. ~ (10 GA ) P~I.I.'"
Pl:jAIL. -,"
r'""f~I~'''''
; NJ:I
. 101-0"
._.\.. ..1 -' .. .
.~l~VAT~ (lIorl0~U;)
REFERENCE: MODUTANK INC..
1500,000 GAL. MODULAR WATER SroRAGE TANK IN ACCORDANCE WITH
ROCKY FLANTS PLANT SPEC. NO. 888818-01 DRAWING, JULY 1881.
(4 eA) i'4>'2'~TtI7-
.'!"'-T.IIIII d WMU&? "
",17. ? 01< 9G1T1l< '
."""'" ""'1~ z: J~-"~' '"
(.A'. 'f 5'[~If" It> , '"
. i
r i".p Y4 Uvr ,. '
. r-- "nm 2:>. I ~b GA'V. ST~~ ~R"'7
r--'" t f ",~ 1JO\.1, u\If ~ WAOU'R.
. GRA 'e;UJ!.' . '" TOTAL
]/~t\IL- "17" .
'''''fTOIl T'E" "'"f'''
%''''~~«-r
iIz'l&up. I'1Lte~' 0'.
o.
t """ou 1"~
'lJ6u.. P'lUJf\...)
IMTf.lll.."l'."
TOP T1[ft f)Cq""l
~.'~_2r
;.il
~.;'" n'
.' +
4' r/-'
~tL
0001 'd'
W-1r
1~PI~l\L 0)~7T~
J"DnJ T
Ter GIJ{T" L z~:} :zf. t."
IJeT p,p (,ALVA""l~17 {,
"
1
a 1r:N ']
~~o'
TO' WAlt. pAlJeL- 19-4A-
~' . (0' MILlo 4A~V.
':if~L-,uIl"'T
1t.J01 t7'" O~ Tf.l14 K
5':0.
I' .
2- ~ t '2: U~ i30, IV,v.,UIiI ~ 99i~"'-. is R~.
p"" GIRTH /WA\.V PA ~(t--
~'f"'I"
//;/- :.~:'~::;;. ~UeR
, -"",..,,~ IJ'U"R
U. (1. p.~. 61W1JE.T
IJ!Ak "'1""f'O>./
ro'MII- U. Po Poe'. .
~p,,"Y IJNr;R,
IOOUII- (e-Cl-)
I G""fYTIU;;
/
F=I~.G~
::?~~
--- 4-'-0' --_.__.._._n__~_._..J
T,YP/{:::.I.\I.. ?;~&r. (lIorl0~U;)
,
,'::JC"''' .""0/1180
Wt'WED wlkE
fdeel('...
FIGURE 3-5
TYPICAL TANK
-------
o
N
N
m
I
".,
a
m
'-
~m
o
Go~ ! 4"
'Jj~III_'~'
~ ,1
~ II
I
I
I
I
"';
~1 I
i :N I
'!I
I
I .
I ~
N
~
..
IC'\ ~....' I "',0' .
II - !
",' i,!:..:~'1 ,'~i~1 ~,;",.~, 111--
\/1:\\'-(.\17- ! " '-'!_~"~7.P If-I' ",j) \"1) i '
~ ~...~~t_--~~_. I \
- I I :")./: i
: ....n.. : .
. I // " I.
~ I ~..,';;~, I
~~~~,_,,_"~I~ ~ i ~r~-,~~t ..! [~J'I:
'~ L~ J fi ~:: ~ ':-1, \ I "-/1 /~ : J L.. i
'.i~\Jl~\i ! H \ ,..! I~ _{i11 /"_"t~\ : rr\~('~ .~~ I: .Q..- __~~In--. - ,..,0: !
~ '~ U ~11\'v.t.: +-~~~~[j! I!"':::":
".1 2;l Of! ~ ~'JM"'-' ~ I ":.lDX ~:~-[fFfH i Ii I i. :i .:!_--J
I I '--- 1
cp
~
(O",t'NTItA1EP i!~I)JE
~TOIt,Ac..E 1"""10«.
o
c..
(O..(.U""""""£O p.-it.,..£..
~TOf:"(.E TAwil.,
@
M(. "
"I,U1.:J \.IAt(R ~OUI"" PA(ICNoE UNI~
' ~
!C;'.~#
;I. I' "l
1t"\.I~'JM~~
lC)..(.f.~IlI"2'
-z.....ye- lI'\.I""'f'""o
:,,,\.~'
';"i'\"
~'.o' .
,.'. ~..
~'..#
I
~')' .
, - i
£!.L.
,'...-
~ .f!!. ~I ~
~'.... I ~H.- I ~.... \..(I~ .,;,,,1
u - ~.q po'
~
'fV.I,II,''''''Jt4' ,.. ~
.J....G:1t..~ ~1fus
~,H" "'" ~:!U
~
f!~
L.i
l~"""
,'.2."
0:""10"
~
OI.,1H.1-AT'C 'f....~..fElt ru",~
p.t.' p...,
DF-f~n".....,e:
Il'''''''' .~M.f")
P8((.Q~1f.1It~
P,toC'l(...r.~ UNI"
.I21ID~
eArLI1 i""'~(
2:!.
:~~'~;i~~
?1..~.....11!
BJ.":'G" "'''N(.
..E!:AlL .
~ ~ ;:'IIJ ;::LDa2 ~~ 1;%0'.0
~
0-'.: Z 3 . ~..
@-.
@-'-i I :--.
~
!.CALC: hONE
b,
'~CE: ROCKY FLATS PLANT.
OND CLEANUP/AlP.
NT FLOOR EQUIPMENT LAYOUT.
3-.D38386-406A.II/28/8O.
h.3,to 4 fl.18
")Awt; fllT(R~
~A(o(...c..( .!""11
G)
I
,
:1~'. ~..
.,~
( ~~'I
~i~),
/'T" "
:' i=:i
-\j.)
I
.
~
~-
i
;
I
I~"I.
~
Altil COMPilE 5~oe S,v51EM
p.",
i!JLO(. ~p ~Ur1'
~
PCEtOA,T OJt~IN SUMP PUr\"
I.
FIGURE 3-2
LOWER LEVEL
-------
tS:J-
N
(])
I
..,
o
01
V
o
~~01 I
;i m I :.,
c.2 ..
"':J ~
oz !
I.
.1 ~I
to
~
. ~
''''1
CD
I
, l'
~I
>->-
mm
[;J~
~~
:J:n.
u~
j>-
~m
o
~
REFERENCE: ROCKY FLATS PLANT.
SOLAR POND CLEANUPIAIP,
1ST FLOOR EQUIPMENT LAYOUT.
DRAWING 8D38385-404A, 12/4/80.
u:r
iJ._~.
1(,:1-
~:.
! I
I
iJ
I
I
~
_L--
~~_.
I
I
I
15:6'
;:0'
a'.e"
@
14
I
.
1;1 I
'-1 !
j lfJ
",I /
ihj I Af.CBS HATCH
I I - .
---. ~
I'
b!
~!
-l
L!£!f.
---
C'.',::::~::
f1
C::::~:.
------
~!
~
~
L
! n:u.~ A:MC
1s:r
@
I
,
SWITDt:;[AA I 101(:: Roo...
JCl
\~ft£.eGc"'a
. ,wOJ./[P/EY! U<1!JH
IUI5T.;
Q-f[MICAl MAIt[ -UP POOu
'f
m
CoMC.
SLA/
lIJ ,'-
P
.
I ~I
I
~I
I
I .
FIGURE 3-1
MAIN FLOOR
BUILDING 910
..'"'~
IE'~$fIOV
V~PO'
K~~$rt:'N
",",PO"
1!Ef'A4("M$~/ON
~
PLA~
flU. 'L-A"ItB...S115,:"
CONTROL ROO'"
@--
KfV PLAN
-------
4.0 IDENTIFICATION AND ANALYSIS OF POTENTIAL ARARs
4.1 STATEMENT AND .BASIS OF PURPOSE OF POTENTIAL ARAR ANALYSIS
The analysis of ARARs in Section 4.0 is a review of Potential ARARs for this IM/IRA only. ARARs are
currently being negotiated and resolved by the DOE, EP A and CDH on a site-wide basis for the Rocky
Flats Plant. Appendix D contains tWo documents, a letter/agreement dated August 22, 1989 from DOE
to CDH concerning water recycling and reuse issues and an initially approved air emission permit number.
91JE316(1) from CDH for the flash evaporators as outlined in this IMIIRA. These documents as agreed
to by DOE, EPA and CDH are compliance related ARARs for this IM/IRA. Also, Maximum Concentrations
Limits (MCL) for radioactive constituents as presented in Table 4-3 shall be observed as compliance ARARs
for the IMIIRA.
. 4.2 SCOPE OF INTERIM MEASURES/INTERIM REMEDIAL ACI10~
The overall objectives of this IMIIRA for the 207- Solar Evaporation Ponds and ITS is to facilitate
pondcrete operations and to facilitate the closure of the 207- Solar Ponds. ARARs are used in defining
the remediation goals for the interim action. .
4.3 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS
(ARARs) AND PROTECI10N OF HUMAN HEALTH AND THE ENVIRONMENT
The NCP [FR Vol 55., No. 46, 8848; 40.CFR 300.430 (e») reqUires that, in development of remediation
. ..
goals, the following be considered:
1. :ARARs
2. ::For systemic contaminants, concentration levels that will not cause adverse. effects to the -.
human population and sensitive subgroups over a lifetime of exposure
3. For carcinogens, exposure levels represent an upper bound lifetime cancer. risk betWeen
10-- and 10". The 10" risk level is to be used as a point of depanure when ARARs are
not available or are not sufficiently protective because of multiple contaminants or multiple
exposure pathways.
4. Factors related to detection limits
5. For current or potential sources of drinking water, attainment of Maximum Contaminant
Level Goals (MCLGs) or Maximum Contaminant Levels (MCLs), if MCLGs are zero
6. Attainment of Oean Water Act (CW A) water quality criteria where relevant and
appropriate.
RFPQJlJft.3.R
4-1
-------
The lAG, in paragraph 150, states "Interim Remedial Actions/lnterim Measures shall, to the greatest extent
feasible, attain ARARs." Also for interim actions, the NCP [40 CPR 300.430(t)] specifically notes that
an ARAR can be waived-if the action is to become part of the final remedy that will attain ARARs. It
may not be practicable - to attain all ARARs for this interim action and ARAR waivers or alternate
concentration limits may be requested.
This section identifies and analyzes ARARs relevant to the solar evaporator ponds 207-A and 207-B and
the surface and ground water from the underground ITS and discusses how the action will be protective
of human health and the environment This remedial action is considered an on-site IMIIRA to be
administered under RCRA; therefore, both substantive and administrative requirements of the RCRA
regulations (such as RCRA permitting requirements) apply. The CERCLA-based ARAR process for this
IMIIRA is required under the lAG.
4.3.1 ARARs
"Applicable requirements," -as defined in 40 CFR 300.5, means "those cleanup standards, standards of
control, and other substantive requirements, criteria, or limitations promulgated under federal environmental
or state environmental or facility siting laws that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance found at a CERCLA site. Only those state
standards that are identified by a state in a timely manner and that are more stringent than federal
requirements may be applicable." "Relevant and appropriate requirements," also defined in 40 CFR 300.5,
- -
means "those cleanup standard,s. standards of control. - and other substantive requirements. criteria, or
limitations promulgated under .federal enVironmental or State environmental or facility siting laws, that,
while not "applicable" to a ~ardous subStance, pollutant. contaminant,-remedial action. location, or other
circumStance at a CERCLA site, address problems or situations sufficiently similar to those encountered -
at the CERCLA site that their use is well suited to the particular site.' Only those state sttndards that are
- .
identified in a timely manner and are more stringent than federal requiremems may be relevant and
appropriate. "
According to CERCLA Section 121(d)(2), in order to be considered an ARAR, a state requirement must
be "promulgated". As defined in 40 CPR 3OO.400(g)(4) of the NCP, the term "promulgated" means that
the requirement is of general applicability and is legally enforceable.
RFPQll11J.3.R
4-2
-------
4;3.2 :m9.
In addition to ARARs, advisories. criteria. or guidance may be identified "to be considered" (!'BC) for
a particular release. As defined in 40 CPR 300.400(g)(3). the TBC category consists of advisories, criteria,
or guidance developed by EP A. other federal agencies. or states that may be useful in developing remedies.
Use of TBCs is discretionary rather than mandatory as is the case with ARARs.
4.3.3 ARAR Cate20ries
In general, there are three categories of ARARs. These categories are:
.
Ambient or chemical-specific requirements
Location-specific requirements
Performance. design. or other action-specific requirements. .-
.
.
Each category is discussed in more detail below.
4.4 AMBIENT OR CHEMICAL-SPECIFIC REOUIREMENTS
Ambient or chemical-specific requirements set health- or risk-based concentration limits in various
environmental media for specific hazardous substances or pollutants. These requirements set protective
clean-up levels for the chemicals of concern in the designated media. or may act as action-related
requirements in indicating a safe level of air emission or wastewater discharge. The chemical-specific
ARARs identified herein are used in defining the remediation goals for clean up of contaminated surface
water and discharge of neated water.
ARARs are derived primarily from federal and state health and environmental statutes and regulations.
The following may be considered when establishing clean-up standards. but are not considered ARARs:
health effects assessments. health advisories. chemical advisories. and guidance document criteria. These
and any proposed standards are classified as items to be considered. or TBCs. Where background
concentrations for constituents are above the ARAR for that constituent, a waiver from the ARAR may
be appropriate. A summary of ARARs for the contaminants found in the surface and ground water of OU4
are presented in Tables 4.1 through 4.3. Table 4.3 presentS ARARs for volatile organics, metals.
conventional pollutants. and radionuclides and will be applied to operations involving treated water.
,
(
As dis~sed in 55 FR 8741 (Preamble to the NCP). when more than one ~ has been identified for
a contaminant, the most stringent standard has been identified as the ARAR which the IMJIRA will attain
to the greatest extent practicable. Where no ARAR standard exists. a TBC standard has been identified
RFPawn.3.R
4-3
-------
which the IM/IRA will treat as Ii goal to achieve. Federal and State ARAR spreadsheets used in the ARAR
analysis for volatile organics, metals, conventional pollutants, and radionuclides are presented in Tables
4.1 and 4.2. The standards identified in Table 4.3 are based on the most sttingent standards found in the
Safe Drinking Water Act (SDWA) MCLs and Water Quality Control Commission (WQCC) statewide
surface water standards. As described in Sections 4.3.1 through 4.3.5, the standards mentioned above were
found to be applicable or relevant and appropriate to RFP Solar Ponds 207-A and 207-B and the ITS waters.
The standards and criteria identified as TBC in Table 4.3 are based on the most stringent standards found
in WQCC Site-Specific Surface Water Standards and criteria in Tables I, n, and ill of 3.1.16 in the Basic
Standards for Surface Water. Additionally, CW A Ambient Water Quality Criteria (A WQC) were applied
whenever more appropriate ARARs or TBCs were not identified. Overall, TBC standards were identified
in Table 4.3 only when no ARAR standards were found.
As presented in Tables 4.1 and 4.2, the ARARs and TBCs summarized in Table 4.1 were developed using
the ARARs rationale described above and were identified by examining the following standards and criteria:
.
SDW A MCLs
Colorado WQCC Standards for Surface Water
CWA AWQC.
.
.
ARARs were not considered for the distillate from the evaporator. The distillate is not a solid or hazardous
waste because it is excluded from regulation pursuant to 6 CCR 1007-3, Part 261.2 (e)(ii).
This IM/IRA is limited in scope and only those ARARs associated with the activities and goals of the
IM/IRA are evaluated. The ARARs associated with the effluent, sludge, air discharges, and construction
and operation of the treatment units and tanks were considered. All other ARARs will be addressed in
the forthcoming record of decision for OU4.
4.4.1 Safe Drinking Water Act MCLs
SDW A MCLs represent the maximum permissible level of a contaminant in water that is delivered to the
free-flowing outlet of the ultimate user of a public water system [40 CFR 141.2(c)]. The OU 4 water to
be treated according to this IM/IR.A will be reused as an effective substitute for commercially available
raw water. As di~ by CDH, au ~ treated. water will be required to meet MCLs beca~se CDH has
determined that this water must meet the same water quality (drinking water quality, except for turbidity
and microbiological contamination) as water provided from the Denver Water Board (DOE, 1989a).
RFPQllm.3.R
4-4
-------
Consequently, MCLs are regarded as ARARs. Furthermore, the NCP [40 CFR 300.430(e)] requires that,
in development of remediation goals for evaluating alternatives for final remediation, the following be
considered for current or potential sources of drinking water: attainment of MCLGs or MCLs, if MCLGs
are zero, where relevant and appropriate; and attainment of CW A A WQC, where such criteria are relevant
and appropriate. CW A A WQC are discussed in Section 4.3.5. It should be noted that on January 30, 1991,
and June 7, 1991, (56 fR 3526 and 56 fR 26460, respectively) EPA published final roles amending MCLs
and MCLGs for a number of the constituents identified in Table 4.3. These standards are effective July
30, 1992, and November 6, 1991, respectively, and will be regarded as applicable at that time. For purposes
. of this worle plan, the new MCLs (MCLGs are zero or equal to the MCLs, except in the case of copper),
are, therefore, relevant and appropriate and are identified as such in Table 4.3.
(
4.4.2 Colorado WQCC Standards for Surface Water
The Colorado WQCC has established both state-wide and stream segment-specific standards for the
proteCtion of state surface waters. State-wide standards exist for certain radioactive materials as well as
organic standards adopted for all state sources of drinking water and areas requiring protection for aquatic
life (see Section 3.1.11,5 CCR 1002-8). These standards are consequently of general applicability. The
state-wide standards are enforceable through the state's NPDES permitting process. Having apparently
met the NCP state ARAR requirements of enforceability and general applicability [40 CFR 300.400(g)(4)],
the state-wide surface water standards have been applied as ARAR in Table 4.3.
Site-specific surface water standards also exist for certain organics, metals, inorganics, and radioactive
constituents in the form of goals for Segment 5. Accordingly, these standards do not appear to satisfy the
NCP requirements for state ARARs since all segment 5 standards and classifications are goals. These
standards have not been generally applied to the surface waters of Colorado. Furthermore, the site-specific
standards for radioactive constituents are significantly more stringent than any standards applied to the
surface waters of the State of Colorado. Consequently, the site-specific organic, metal, inorganic, and
radionuclide surface-water standards cannot be ARAR. These standards have been applied as TBC in
Table 4.3 because they reflect the degree of proteCtiveness determined to be necessary for Rocky Flats Plant
surface waters by the Colorado WQCC.
{
4:4.3 CW A Ambient Water Qualitv Criteria (A WOC)
The CW A A WQC are non-enforceable guidance developed under CW A Section 304, and are used by states
in conjunction with designated stream segment usages to establish water quality standards for the protection
of aquatic life and for the protection of human health. Standards include those established for drinking
RFPawn-3.R
4-5
-------
water and fish consumption, fish consumption only, as well as standards for the protection of aquatic life.
CERCLA Section 121(d) requires that CW A A WQC be considered in the development of remediation goals
in the FS process, where relevant and appropriate. Relative to this IMIIRA, A WQC are generally considered
relevant and appropriate. Pursuant to the preamble of the NCP and EPA guidance (55 FR 8754; EPA,
1990), A WQC will generally !!Q1 be considered relevant and appropriate .whenever other standards exist
that are specific to the constituents and the.use of the affected water. Consequently, since the WQCC has
designated RFP surface waters as drinking water usage and aquatic life protection stream reaches with
associated standards, the A WQC were used as ARAR in Table 4.3 only when more appropriate Federal
or Colorado standards were unavailable.
4.4.4 Protection of Human Health and the Environment
As illustrated by the hazard quotients and carcinogenic risks listed in Table 4.3, achieving the ARARs
should result in a clean-up action that is protective of human health and the environment For non-
carcinogens, the protectiveness goal is a hazard index of 1. The hazard index is the sum of the hazard
quotients [i.e., the estimated daily intake (dose) to reference dose ratios] for all of the contaminants
combined, which have been computed and are presented in Table 4.3. In assessing non-carcinogenic risk,
a hazard index of one or less is considered to be acceptable. If the hazard index exceeds one, it indicates
that there might be the potential for adverse non-carcinogenic health effects occurring. Unlike the method
used to evaluate the potential for carcinogenic toxicity, the hazard index does not indicate the probability
of adverse health effects occuning, but it is used as a benchmark for determining where there is a potential
concern. With respCct to carcinogens, cumulative cancer risk should be less than 1~, but no greater than
1~ (individual cancer risks shown in Table 4.3 are considered additive). As noted in Table 4.3, the
calculated incremental cancer risks exceed 1 ~ for some of the organic carcinogens as well as for beryllium.
However, the cancer risks are computed on the basis of the detection limit and therefore can only be
considered a possible maximum carcinogenic risk; the actual risk is unknown but likely to be considerably
lower. Removing these contaminants to non-detectable levels and attaining, to the extent practicable, the
other ARARs, the IM/IRA is considered protective of human health and the environment.
4.5 LOCATION SPECIFIC REOUIREMENTS
Location-specific ARARs are limits placed on the concentration of hazardous substances or the conduct
of activities solely because they occur in certain locations. These may restrict or preclude certain remedial
actions or may apply Qnly to certain portions of a site. Examples oflocation.,specific.ARARs which pertain .
to the IM/IRA are federal and state siting laws for hazardous waste facilities (40 CPR 264.18, fault zone
RFPawn.3.R
4-6
-------
and floodplain restrictions), and federal regulations requiring that actions minimize or avoid adverse effects
to wetlands (40 CFR Pan 6 Appendix A and 40 CFR Pans 230-231).
More specifically, in addition to the requirements described above, pertinent location-specific ARARs
include: Colorado requirements for siting of hazardous waste facilities and wastewater treatment facilities
(Colorado Revised StatUte 25-15-101, 203, 208, 302 and 25-8-292, 702. respectively), National Historic
Preservation Act requirements for preservation of significant articles and historic properties (36 CFR Parts
65 and 800, respectively), federal critical habitat protection requirements (50 CFR Parts 200, 402 and 33
CFR Parts 320-330), and federal requirements for the protection of fish and wildlife resources (40 CFR .
6.302).
. A summary of location-specific ARARs which the IMJIRA will attain to the greatest extent practicable
is presented in Table 4.4.
4.6 PERFORMANCE. DESIGN. OR OTHER ACTION SPECIFIC REOUIREMEl'ITS
Performance! design, or other action-specific requirements set controls or restrictions on particular kinds
of activities related to management of hazardous substances or pollutants. These requirements are not
triggered by the specific chemicals present at a site, but rather by the particular IMJIRA evaluated as pan
of this plan. Action-specific ARARs are technology-based performance standards, such as the Best
Available Technology (BAT) standard of the Federal Water Pollution Control Act. Other examples include
RCRA treatment, storage, and disposal standards. Action-specific ARARs, which the IMJIRA will attain
to the greatest extent practicable, are included in Table 4.5. Solar pond sludges and precipitate from the
Building 910 flash evaporators will be treated under pondcrete operations. Therefore, RCRA LDR [40
CPR Pan 268.40] requirements are not relevant and appropriate to the scope of this IMJIRA. RCRA LDR
requirements will be considered in the final SEP remediation decision process.
As explained in the National Contingency Plan (see 55 FR 8666) OSHA requirements for worker proteCtion
in hazardous waste operations and emergency response (29 CPR 1910.12Q) are applicable to worlcers
involved in hazardous substance-related activities, as well as other OSHA requirements related to specific
circumstances or activities. These requirements must be satisfied, however, the requirements are not
enyironmental in nature, and therefore are not considered ARARs.
RFPaum.3.R
4-7
-------
TABLE 4.1 POTENTIAL CHEMICAL SPECIFIC ARARslTBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EV APORA TION PONDS AND INTERCEPTOR TRENCH SYSTEM
STATE SURFACE WATER QUALITY STANDARDS '
NOTE: Units are ug/I, unlea otberwlse spedned
--
Total Diaolved SoUdl IndiC8lOr
Bicarbonate AnIon
Chloride AnIon
Cylllide AnIon
Fluoride AnIon
N u Nlblle+Nilrlle AnIon
N u Nitrile AnIon
Sulfate AnIon
5
5
~OOOO/
1000/200
2000
!rQXJ/
1000110000
250000/
3
3
ss
ss
1.000
250,000
1,000
250,000
Atumirllm MdIl 950 150
Amimony MdIl
Anenlc MdIl 360 15 50/100 50
BlIrlum MdIl 1,000
Beryllium Met8l 100
. 10.78(1)
CadmIum MdIl 1.21(1) 10/10 10.78(1) 1.21(1)
Caldom Met8l
Cesium MdIl \
Chromium Md81
Cuomium m MdIl 1,850.9(1) 220.6(1) 50/100 50
Cuomium VI MdIl 16 11 50/100 16 11
Copper MdIl 19.09(1) 12.64(1) 200 19.09(1) 12.64(1)
Iron MdIl 1,000 300 (dial)
Lead MdIl 108.7(1) 4.34(1) 50/100 108.7(1) 4.34(1)
Uthlum MdIl
Mqnesium MdIl
M8I1pIeIO MdIl 1,000 50 (dll)/200 50 (dig)
Merc:my MdIl 2.4 0.1 2.0/
Molybdenum MdIl
-------
TABLE 4-1 POTENTIAL CHEMICAL SPECIFIC ARARslTBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EV APORA TION PONDS AND INTERCEPTOR TRENCH SYSTEM
. ST ATE SURFACE WATER QUALITY STANDARDS
NOTE: Units are ugII, unless otherwise speclfted
--
Powllum Md81
Selenium Md81
Silver Md81
Sodium Md81
Strondum Md81
Tin Md81
V8W!ium Md81
7Jnc Md81
135 ug/l
TVS
t7ug/l
TVS
10/20 ug/l
50/
10 ug/I
TVS
TVS
23U(I)
45(1)
5000/2000
231.9(1)
45(1)
AtruJne
Paticide
3
Americium 241 RadlonucHde
Cesium 137 RadlonucHde
010111 Alpha RadlonucHde
010111 Beta RadlonucHde
PlulOnlum 238+239+240 RadlonucHde
RadIum 126 RadlonucHde
RadIum 118 RadlonucHde
Strondum 89,90 RadlonucHde
Tridum RadlonucHde
Unnlum (tocal) RadlonucHde
Unnlum 233,234 RadlonucHde
Unnlum 235 RadlonucHde
Unnlum 238 RadlonucHde
Acetone VoIlIi1c
C8rbon TdnlChlorlde VoIld1c 5 35,200
Mdhylene OI1oride Vo1Id1e
Tridtlorodhylene Vo1Id1e 5 45,000 11,900
0.05pC111
UpCUI
I1pC111
19 pCIII
O.O.5pC111
2,617.6 UIfI(1 1,635 ug/I(l)
8 pCJ/I
.500 pCIII
10 pCIII
8pCUI
1O,OOOpCI/I
-------
TABLE 4-1 POTENTIAL CHEMICAL SPECIFIC ARARslTBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
STATE SURFACE WATER QUALITY STANDARDS
NOTE: Units are ug/I, unless otherwise 8
Ineel
._-
BXPLANATION OPTABLB
CDH - CoIor8do Departmed of Health
TVS - Tlble Value Standanl (hInInea depa1dc:nt), lee Table Olin (a)
WQCC - Wilei' Quality ConIroI Commlaion
(1) Calc:uliled uslnlll1 e-.lmlled avenae h8rdne8. of 108.1 mall of CaCO , baled on the BlCtground GeotecIInic:aI
Oww:teriudon Report. BOctO, 1989.
(2) In the Ib8ence of 1pCdftc, mmerlc II8nd8rdI for non-lIIIIuraDy occurrlna OIJanlCl, the IIIII1dive IUndmt i. bUrprded u zero with enforcemed baled on
pr1ICticai qumdftc:ation level. (PQL8) u ddIned by CDH/WQCC or aPA
(3) All are 3O-day 8Undards except for NitI1Ite a: Nibite.
(4) Stand8rd is for Iota! trlhaIomdh...: dIIorofonn, bromoform, bromocHdlloromdhme. clibrornochlOlOllJdh8ne
(6) AmmonJ8, 8Ul.ftde. dIIoride. IUlfIle, coppeF, Iron. m.q8lele, and zinc are 3O-day 8t.IncIIIrd8.
all odIen are l-day 81and1rd8.
(7) Seament 5 ItIndIrd8 are aoaf8
(9) Tlble 1 - phydcal ~ biological pnmden
Table 0 - inorall1lc paramdell
Table 01- metal puuneten
Vl1uelln T8bl1II .. O,8Dd 01 for m:reaIfonal Ulet, cold wiler biota 8Dd domestic WIler supply are not Included.
(a) CDH/W'QCC, Colorado Wiler QJaHty St8ndatd8 3.1.0 (5 OCR 1002-8) 1115/1974; amended 9/30/1989
(b) CDH/W'QCC, CludftC8donI and Numeric StIndanb for S. PI-to Rivei' BaIn, LaramIe Rivei' Basin, RepubllCIJI Rivei' Bain,
Smoky HID River Baln 3.8.Q (5 CCR 1002-8) 41611981; IIIIfItded 2115/1990
-------
TABLE 4.2 POTENTIAL CHEMICAL SPECIFIC ARARslTBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
FEDERAL SURF ACE WATER QUALITY STANDARDS
NOTE: Units are uRIL unless otherwise s~lfied
Total Dissolved Solids Indicator S8 88 250.000
Bk:arbonate Anion
Chloride Anion
Cyanide Anion
Fluoride Anion
N as Nilrate+Nitrite Anion
N as Nitrite Anion
Sulfate Anion
2.2
5.2
200
4.,000: 2,~
10,000(b)
'1,000(b)
4,000
10,000(b)
1,000(b)
4,000
Aluminum
Antimony
Anenic
Barium
BerylUum
Boron
C8dmium
Calcium
Chromium
Chromium m
Chromium VI
Cesium
Copper
Iron
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
Metal
9000 1600
50
1,000
130 5.3
10/5(b) 5(b) 3.9(3) 1.1 (3)
SO/IOO(b) l00(b)
1.700 210
16 11
1,3OO{c) 18(3) 12(3)
1.000
SO. O(c) 82(3) 3.2(3)
146
0.0022
1,000
0.0068
10
,
170.000
SO
45000
O.017S
0.117
3,433,000
300
SO
2
2
2.4
0.012
50
0.144
100
0.146
-------
.
TABLE 4-2 POTENTIAL CHEMICAL SPECIFIC ARARslfBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
FEDERAL SURFACE WATER QUALITY STANDARDS
NOTE: Units Ire uall. unless otherwhe speclOed
Nickel Metal 1.400(3) 160(3) 13.4 100
Potassium Metal
Selenium Metal
Silver Metal
Sodium Metal
Strontium Metal
Tin Metal
Vanadium Metal
Zinc Metal
10~O(b)
~O
5O(b)
100.
260
4.1(3)
36
0.12
10
~O
120(3)
110(3)
Alrazine Pesticide
Ammcium 241 RlldionucUde
Cesium 137 RidionucUde
Gross Alpha RadionucUde I~ pCVI
01088 Beta Radionucllde 4 mrem/yr
Plutonium 238+239+240 R8dionucllde
Radium 226 Rldionucllde ~ ~
Radium 128 Radionucllde 5 ~
Strontium 89,90 Radionucllde
Tritium Radionucllde
Uranium (total) Rlldionucllde
Uranium 133,234 RadionucHde
Uranium 13~ Radionucllde
Uranium 238 Radionucllde
Acetone Volatile
Clrbon TelrlChioride Volatile ~ 0 3~,2OO(1) 0.4.. 6.94..
Methylene Chloride Volatile
. roethylene Volatile 5 0 4~,OOO(I) 11,900(1) 1.7.. 80.7..
j
-------
TABLE 4.2 POTENTIAL CHEMICAL SPECIFIC ARARsffBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EV APORA TION PONDS AND INTERCEPTOR TRENCH SYSTEM
. FEDERAL SURFACE WATER QUALITY STANDARDS
NOTE: Units are u unless otberwlse II Ifled
EXPLANATION OF TABLB
. MCL for lead wu deleted in (c), effective November 1991
.. Humm health criteria for carcinogens reported for three risk levels. Value presented is the 10-5 risk level.
A W~ = Ambient Wiler Quality Crltaia
CW A = Clean Water Act
SDWA = Safe Drinking Water Act
SS = species specific
(1) criteria not developed; value presented is lowest observed effects level (WEL)
(2) cotal trlhalomethanes: chloroform, bromoform, bromodichloromethane. dibromoch1oromethane
(3) hardness dependent criteria
(4) pH dependent criteria (7.8 pH used)
(5) Criteria it for dichloroethene
(a) EPA National Primuy IixI Seconduy DrinJdnR Wiler Regulll1ions, 40 CPR 141 and 40 CFR 143 (II of May 1990)
(b) EPA National Primary and Seconduy DrinJdnR Water Regulll1ions, 40 CPR Partl141. 142 and 143. Final Rule (1130191), eft'ecdve July 3D, 1992
(c) EPA National PrimarY. DrinkinR Water Reguladons. 40 CPR P8I1S 141 and 142. Final Rule (6(7191). effecdve November 6, 1991
(d) EPA, Quality Criteria for Protecdon of Aquadc Life, 1986
. .
-------
TABLE 4-3 PROPOSED CHEMICAL SPECIFIC ARARsffBCs FOR PARAMETERS
,AT OPERABLE UNIT NO.4, SOLAR EV APORA TION PONDS AND INTERCEPTOR TRENCH SYSTEM
NOTEr Units are uWl. unless otherwise lpeclllecl; RadlonucUdes are pCIII
TotII Dillolved SolIdi Indicator 16,000 maJI 250 man CW A A WQC Water and Filb No oral RPD/D~ cOluklered
Inaellion Standard. .. oral c:an:iJIosen
No SUndard No oral RPDha« conlklered
.. oral c:an:inoaen
No oral RFDta~ conliclered
Bicubonale
Anion
Odoride
Anton
Fluoride Anion
Cyutide Anion
N al NItr8te+Nltrire Anion
N u Nitrite Anion
Sulfate Anion
Aluminum Meul
Antimony Meul
Arsenic Meul
Barium Meul
Beryllium Meul
Cadmium Meul
Caldum Meul
Caium 'Meul
Ouomlum Meul
OIromium III Meul
OIromium VI MeW
Copper Meul
-
350 man
763 man
O.OO5U mill
73ppm
37.8 man 0.005 mill
3,205 mill 10 m8/1(I)
724 man I mill
784 mall 250 mill
5,000 150
142 146
16.4 50
2O'l 1,000
100 5U
150
5(2)
10
46Z maJI
50
30.30
50
-
50
-
II
308
25U
WQCC Sudace Water SlancIarcl;
Site-Spec:ific Incqlllic Standard II THe.
WQCC Sudace Water SlancIarcl;
Site-Spec:irlC Incqlllic Standard II THe.
SDW A MCL (40 CFR 141.51(b»)II THC
WQCC Sudace Water SlancIarcl;
Site-Spec:ific Incqlllic Standard II THe.
WQCC Sudace Water Sranclarcl;
Site-Spec:if1C IncqIDic: Standard II TBC.
WQCC Sud,ce Water SlancIarcl;
Aquatic Ufe Standard II TBC
CW A A WQC Water and Fiab fnaellion
Slanclarcl.
SDWA MCL(4OCFR 141.1I(b»)
SDWA MCL(4O~ 141.1I(b»)
CW A A WQC Water and Pilb fnaellion
Slanclarcl.
SDW A MCL (40 CFR 141.1 I (b»)
No StIncIard
No Standard
SDWA MCL(4OCFR 141.1I(b»)
WQCC Sudace Water Sranclarcl;
Slte-Spec:irlC MeIal SUndard II THe.
WQCC Sudace Water Sranclarcl;
Site-Spec:ific MeIal Slandard II THe.
WQCC Sulface Water Sranclarcl;
Site-Spec:i~ MeW Scandanlil THe.
. ~4
Standard (3.0) II below cletecrion
limit. TBC defauJII to deIecdoa limit.
.. oral c:an:iDopn
HQ < 1.0
No oral RPDha« conlldered
.. oral c:an:iDopn
2.9B.oI,bot COIIIldered
.. oral cardnoaen
No oral RPDha« conlldered
.. oral c:an:iDopn
No oral RPD1aot conlklered
.. oral c:an:iDopn
HQ.. 10 II IlIA
HQ.. I (I 35 u811
PropoaecI AltAR Standard aUJ068 (u8ll) II
below ~ IlmiL AltAR defauha to
cIetedioa limit.
4.1 B.oI,bot COIIIldered
.. oral c:an:iDopn
2.9B.o2I8.4B.05
2.9B.oI,bot COIIIldered
.. oral cardnopn
No oral RPDr'aat conliclered
.. oral c:an:iDopn
Analytical mull IIIdII chromium
No oral RPDha« conliclered
.. oral cardnoaen
1.4B-03,bot COIIIldered
.. oral can:inoaen
1.6B-021not OOIIIldered
.. oral can:inoaen
No oral RPDr'D~ conlldered
.. oraI~~
Analytical mull IIIdII chromium
Analytical mull illdli chromium
Standard (12.6u8ll)(3) II below cletecrion
-------
TABLE 4.3 PROPOSED CHEMICAL SPECIFIC ARARsffBCs FOR PARAMETERS
AT OPERABLE UNIT NO.4, SOLAR EV APORA TION PONDS AND INTERCEPTOR TRENCH SYSTEM
NOTE: Units are ug/l, unlea otherwise lpedfIed; RlldlonucUdes are pCIII
Iran Meul 1,550.00 1,000(300) WQCC Surface Waler StIndud; Dillolved bon in ~ No on! RFD/ncI ccmlldaed
Site-Spec:ific Metal Su.ndard il THe. In on! c:ardnopn
SDW A MCL (40 CFR 141.11(b») Standard (4.34u1ll)(3) IllelllNn detection No on! RFD/nol ccmlldaed
IimiL ARAR defauJu to detec:don limit. In on! cardnopn
No on! ~ ccmllclered
In on! cardnopn
No on! RFD/nol ccmllclered
In on! c:ardnop
2.9B.oI(I.4B.02)not con.
liclereclln on! cudnoaen
HQ = 1 @ 11 q/I
Lead
Meul
3.6
50
5U(4)
Meul
84.10 mill
181 mall
No Sbndard
Ulhium
Meul
Mqnelium
No Sbndard
Manaeneae
Meul
334
1,000(50)
WQCC Surface Waler St.Indard;
Site-Spec:ific Metal Su.ndard il THe.
SDWA MCL (40 CFR 141.1I(b»)
Dillolved IIWIpneae In pareMhe8ea.
Mercury
Meul
0.4
2
Molybdenum Meul 122 No Sbndard
Nickel Meul 200 101.4(3) WQCC Surface Water Standard;
Site-Spec:if1C MeW Su.ndard II me.
Potalliwn Meul 791 mall No Standard
Seleniwn Meul 17.0 10 SDWA MCL (4OCFR 141.1I(b»)
i
SUver Meul 82 50 SDWA MCL (40 CFR 141.1I(b»)
Sodium Meul 2,940 mill No Standard
Strontium Meul 3,870 No Suncl8rd
Tm Meul 155 No Standard
Vlnadium Meul 8.4 No Suncl8rd
Zinc Meul 116 45 WQCC Surface Waler Standard;
Si.e-Spec:ific Me88l Slandard II TBC.
Americium 241 Radimuc:lide 5.5 0.05 pCl/I WQCC Surface Waler SLandlrd; Site-
Specific Radionlc1icle St8ndant II THC
Caium 137 Radimudide 0.2+/.0.5 No Standard
Groll Alpha Radimuc:lide 2,400 15 pCIA SDWA MCL(4OCFR 141.15(b»
Groll Beta Radimuc:lide 3,900 4mranlyr SDWAMCL(40CFR 141.16)
PlulOlliwn 239 Radimuc:lide 240 15 pCIA WQCC Surface Waler StIndud;
State-Wide Radionudlde ScIndard
R8dium 226 Radimuc:lide 4.4+1.0.8 5 pCi/I SDWA MCL(4OCFR 141.15(a»)
R8dium n8 Radimuc:lide 5.3+/-4.0 5 pCi/I SDWA MCL(4OCFR 141.15(a»)
Strontium 90 Radimuc:lide 0.44+/.0.62 8 pCi/I WQCC Surface Water SLandlrd;
Stale-Wide Radionuc:licle StandaJd
4-15
HQ= 1 @ l40aaJI
1.4B.oI/Dot COIIIldmId
In on! can:inoten
No on! RFD/nol conlldaed
In on! can:inoten
No on! RFD/ncI conlidered
In on! can:inoten
No on! RFD/ncI conlldaed
In on! cardnop
No on! RFD/ncI ccmllclered
In on! c:ardnop
4.1B.oI/Dot COIIIlclereci
In on! c:ardnop
6.4B-03/Dot COIIIlclereci
In on! cardnop
Noon! RFDI3.3B-07
/170.q/I=18-4 Rim
No on! RFD/NA
No on! RFD/NA
No on! RFDJ8.8B.05
SDWA MCL II for Radium 226. n8
SDWA MCL II for Radium 226. n8
/1 B-5 Rille
/IB-5 Rim
-------
TABLE 4.] PROPOSED CHEMICAL SPECIFIC ARARslTBCs FOR PARAMETERS
. AT OPERABLE UNIT NO.4, SOLAR EV APORA TION PONDS AND INTERCEPTOR TRENCH SYSTEM
NOTE: Units are uWl, unless .otherwlse lpecIfIed; R8dlonueUdes are pCIII
.. ...,........................ :M@~if!(tttt . [[[ - - -
[[[
. .,.............,............
:lrlr.«ililliliilililli:: .
:IiW8iHttttt:'
:itiLAhlHttt
Tritiwn Radionudicle 3,200 20,000 pan WQCC SurflCe Water Standard; No on! RPD(1.3~
State-Wide Radionuclide Standard
Urmlum (total) Radionudicle 206.8 40 pan WQCC Surface Water Standard; No on! RFDII.1 .04
State-Wiele Radionuclide Standard
Uranium 233,234 Raclionudicle 780
Urmlum 235 Radionudicle 36
Urmium 238 Radionudicle 900
Auuine Peillidcle 13 ppb
Acetone Volatile 80 No SUrIdarcI 2.9B.Q3/l1ot ODIIIidemi
.. on! c:ardDoaeD
Carbon Teuadlloride Volatile I I 5 SDWA MCL (40 CPR 141 .61(a») 2.0B-()ln.6B.(J6
Methylene Odoride Volatile 71 ppb
TrichloroethYlene Volatile 5 5 SDWA MCL 140 CPR 141.6I(a\1 No on! RPIW.5B-a7
BXPLANATION OF TABLB
(I) Muimwn compound conoenlntiOlll cletennined from available dala
(2) EPAN.ional Primuy..d Secondary Drinltina WrU:I ReauJationl, 40 CPR Pam 141, 142111C1143, F'maI Rule (IOONI), efl'ec:tlve July 30,1992
(3) Calculated ulioa and eltimated avenae bardne.. of 108.1 mall of Caco , buecI on the Bac:Jcaround Oeocec:mical Otaracterization Report, BOAO, 1989
(4) eumnt MCL for Lead (50 mall) wu deleted In 56 FA. 26560, 6n 191 (efI'ecdve I1I6NI)
I. I
. Huard Quotient II calcullled with Ihe fouowiria equ&lon: (ARAR or TBC uall).(O.OOI ma!u,r(2 Utenlday)/(70 k,).(Cbronic On! Ref_ce Dole m""'day)
Carcinoaen ri. = (ARAR or TBC uaJI).(O.OOI mafulr(2 Utenlday~(Carclnoaenlc Slope F8CIOr k,-da)'llma).(350 dayl/yeur(30 yean)l(70 k&r(365 dayl/yelwr(70 yun)
-------
. ~eLE 4.4
ANALYSIS OF LOCATION-SPECIFIC ARARs .
FOR INITIAL REMEDIAL ACTIONS AT OPERABLE UNIT NO.4. SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
ARAR
LOCATION CITATION REQUIREMENT !YfE COMMENTS
Fault zones 40 CFR 264.18(a) RCRA regulations specify that R&A No faults displaced during
hazardous waste treatment, Holocene times exist within 200
storage, or disposal must not feet of this site.
take place within 200 feet of a
Holocene fault.
Flood plain 40 CFR 264.18(b) Any RCRA treatment, storage, R&A This site Is not located within a
or disposal facility which lies 100-year floodplain.
within a 100-year floodplain
must be designed, constructed
and operated to avoid washout.
Siting of hazardous waste Colorado Hazardous Waste Outlines siting criteria for R&A Although the proposed action
disposal sites Act, Sections 25-15-101, 203, hazardous waste disposal sites. Involves the treatment of water
208,302 rather than disposal of
hazardous wastes, these
criteria are considered in the
siting of the unit.
Siting of wastewater treatment Colorado Water Quality Control CDH Water Quality Control R&A Applicable to domestIC
facilities Act Section 25-8-202 and 25-8- Division must approve locations wastewater treatment facilities,
702 of wastewater treatment relevant and appropriate to the
facilities. proposed action.
;
Siting within an area where 36 CFR Part 65, National Planned actions must avoid Applicable Proposed activities will not
action may cause Irreparable Historic Preservation Act threatening significant scie~lfic, threaten significant scientific,
harm, loss, or destR:Jctlon of prehistorical, historical, or historic, prehistoric, or
significant articles. archeological data. archeological artifacts.
Siting on or near historic 36 CFR Part 800, National Action to preserve historic Applicab~ Proposed activities will not
property owned or controlled by Historic Preservation Act properties; planning of action to disturb known or suspected
Federal agency. minimize harm to National historic sites.
Historic Landmarks, Included In
or eligible for the National
Register of Historic Places
-------
TABLE 4.4 (continued)
ANALYSIS OF LOCATION-SPECIFIC ARARs
FOR INITIAL REMEDIAL ACTIONS AT OPERABLE UNIT NO.4. SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
ARAR
LOCATION . CITATION REQUIREMENT TYPE. COMMENTS
Siting on critical habitat of 50 CFR Parts 200, 402 33 CFR Action to conserve endangered Applicable Proposed activities will not
endangered or threatened Parts 320-330 or threatened species. adversely affed endangered or
species, Includes the Migratory 50 CFR Ch.1 (10.13) threatened species.
Bird Treaty Act (MmA) and the 50 CFR Part 22
Bald and Golden Eagle There are no potential Platte
Protection Act (BEPA). River drainage Impacts
regarding activities related to
the Interfm Measure/Interim
Remedial Action (1M/IRA) at
Operable Unit 4 (OU4).
Related activities for the OU4
IMIIRA consist of changing the
present evaporation system
(I.e., use of the solar
evaporation ponds) to the use
of forced evaporation utilizing
flash evaporators In the 910
building. Ground water will
continue to be collected by the
Interceptor trench system (ITS)
and Instead of being
discharged to the solar ponds
will be routed to temporary
storage tanks and subsequently
treated by the (lash
. evaporators. No net changes
In discharge to the Platte River
Drainage system are
anticipated from Implementation
of the IMIlRA for OU4.
Wetlands 40 CFR Part 6, Appendix A Actions must minimize the Applicable 0 Proposed activities will not
destruction, loss, or adversely affect wetlands.
degradation of wetlands, as
defined by Executive Order
. '0-4990, Section 7. .
-------
. .
. .
TABu: 4.4 (continued)
ANALYSIS OF LOCATION-SPECIFIC ARARs
FOR INITIAL REMEDIAL ACTIONS AT OPERABLE UNIT NO.4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
LOCATION
CITATION
REQUIREMENT
ARAR
TYPE.
Applicable
COMMENTS
40 CFR Parts 230, 231
Actions must not discharge
dredged or fill material Into
wetlands whhout permh.
Proposed activhles will not
adversely affect wetlands.
Area affecting stream or river.
40 CFR 6.302
Action mJst protect fish or
wildlife.
Applicable
Proposed act~n will be
protective of potentially affected
fish and wildlife resources.
. The ARAR types designated reflect the application status of each requirement when preparation of this IMIIRA began.
In response. to these requirements, investigations were perfonned and the results are Indicated in the Comments column
which reflect the lack of any location-specific ARAR requirements which would preclude the proposed activity.
RFPaumT4.4
4-19
-------
~
Treatment
Hazardous Waste
Generation
Hazardous Waste
Transportation
Excavationl
consolidation
Treatment or
Stonqe in
Tanks
RFPaum US
TABLE 4-5
ANALYSIS OF ACTION SPECIFIC ARARs .
FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR mENCH SYSTEM
Requirement
Hazardous Waste must be
treated to meet treatment
standard or usinq specific
technology. .
Standards applicable to
qenerators includinq waste
accumulation, recordkeepinq,
container labellinq,
manifestinq, etc.
Hazardous waste shipment
off-site is subject to DOT
regulations, manifesting,
recordkeeping, and discharge
cleanup, etc.
Consolidation in storage
piles/storage tanks will
triqqer storage
requirements.
placement on or in land
outside unit boundary or
area of contamination will
triqqer land disposal
requirements and
restrictions.
Tanks must have sufficient
shell strength (thickness),
and, for closed tanks,
pressure controls, to assure
that they do not collapse or
rupture.
Waste must not be
incompatible with the tank
material unless the tank is
protected by a liner"or by
. other means.
New tanks or components must
be provided with secondary
containment.
Prerequisite
Waste must be identifiable as
hazardous per 40 CFR Part 261
Waste must be identifiable as
hazardous per 40 CFR Part ?6l
Wastes must be identifiable as
hazardous per 40 CFR Part 261.
Movement of hazardous waste
(listed or characteristic I
from one unit or area of
contamination into another.
Consolidation within a unit or
area of contamination does not
triqqer applicability.
RCRA hazardous waste (listed
or characteristic), held for
temporary period before
treatment, disposal, or
storaqe elsewhere, (40 CFR
264.10) in a tank.
Citation
RCM sections
3004(dl(31, (el(31
42 U.S.C.
6924(dl (31, (el (3)
40 CFR Part 262
40 CFR Part 263
40 CFR Part 264
Subpart L/40 CFR Part
264 subpart J
40 CFR 268
(Subpart DI
40 CFR 264.190
40 CFR 264.~'~
40 CFR 264.193
4-20
~
Applicable
Applicable
Applicable
Applicable
R5A
R5A
R5A
R5A
Canments
Placement of excavated soil (from
storaqe tanks inplacement locationl
on-site or transportation of soil
off-site for disposal must be
treated to attain levels achievable
by best demonstrated available
treatment technoloqies before being
land-disposed. tf soil and debris
and not hazardous waste, EPA policy
is that LDR is qenerally not
relevant and appropriate, per EPA.
Wastes qenerated in proposed action
may be identifiable as hazardous
wastes. An example may include
excavated soils from storaqe tanks.
tmplacement location. R5A if
wastes are not hazardous.
Wastes identifiable as hazardous
must comply with applicable
hazardous waste requirements for
off-site shipment. R5A if not
hazardous.
RCM requirements for storage in
waste piles or tanks are applicable
to interim storage of excavated
soil destined for consolidation or
off-site disposal.
Soil excavated durinq installation
is subject to land disposal
restrictions for wastes if
placement occurs outside the area
of contamination. Requirements are
applicable for RCRA hazardous
waste, R5A if not RCM hazardous
waste.
Applicable to treatment and storaqe
tanks used in treatinq or .
containing water contaminated with
hazardous waste. R5A if units
would be excluded under RCRA, such
as wastewater treatment units or if
wastes are not RCRA hazardous
waste.
-------
~
Treatment or
Storage in
Tanks (cont.)
Container
Storage
(On-Site)
RFPaumT4.5
TABLE: 4-5 (oontlnued)
ANALYSIS OF ACTION SPECIFIC ARARs
FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
Requirement
Tanks must be provided with
controls to prevent
overfilling, and sufficient
freeboard maintained in open
tanks to prevent overtopping
by wave action or
precipitation.
Inspect the following: "
overfilling control, control
equipment, monitoring data,
waste level (for uncovered
tanks), tank condition,
above-ground portions of
tanks, (to aS8ess their
8tructural integrity) and
the area surrounding the
tank (to identify signs of
leakage).
Repair any corrosion, crack,
or leak.
At closure, remove all
. hazardous waste and
hazardous waste residues
from tanks, discharge
. control equipment and
discharge confinement
structures.
Store ignitable and reactive
waste so as to prevent the
waste from igniting or
reacting. Ignitable or
reactive wastes in covered
tanks must comply with
buffer zone requirements in
"Flammable and Combustible
Liquids Code," Tables 2-1
through 2-6 (National Fire
Protection A8sociation, 1976
or 1981).
Container8 of hazardous
waste must be:
Maintained in good
condition,
Compatible with
hazardou8 waste to be
stored, and
Closed during storage
(eKcept to add or remove
waste).
Prerequisite
RCRA hazardous waste (listed
or characteristic) held for a
temporary period before
treatment, disposal, or
storage elsewhere, in a
container (i.e., any portable
device in which a material is
stored, transported, disposed
of, or handled) (40 eFR
264.10) .
citation
~
CaDlllents
40 eFR 264.194
IUA
40 CFR 264.195
R'A
40 CFR 264.196
R'A
40 eFR 264.197
R'A
40 eFR 264.198
RIOA
40 eFR 264.171
Applicable
RCRA container storage requirements"
are applicable if hazardou8 wastes
are stored, R'A if stored wastes
are not RCRA hazardous wastes.
40 eFR 264.172
40 eFR 264.173
4-21
-------
~
Container
Storaqe
(On-Site)
(cont .)
off-Site
Treatment
Storage or
Disposal
RFPaumT4.5
TABLE 4-5 (continued)
ANALYSIS OF ACTION SPECIFIC ARARs
FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
Requirement
Prerequisite
Citation
~
Comments
Inspect container storaqe
areas weekly for
deterioration.
40 CFR 264.174
Place containers on a
sloped, crack-free base, and
. protect from contact with
accumulated liquid. Provide
containment system with a
capacity of lOt of the
volume of containers of free
liquids. Remove spilled or
leaked waste in a timely
manner to prevent overflow
of the containment system.
Keep containers of iqnitable
or reactive waste at least
50 feet from the facility's
property 11ne.
40 CFR 264.175
40 CFR 264.176
Keep incompatible materials
separate. Separate
incompatible materials
stored near each other by a
dike or other barrier.
40 CFR 264.177
At closure, remove all"
hazardous waste and residues
from the containment" system,
and decontaminate or remove
all" containers, liners.
40 CFR 264.178
In the case of any removal
, ,or remedial action involvinq
the transfer of any
hazardous substance or
pollutant or contaminant
off-site, such hazardous
'substanc!! or pollutant or
contaminant shall only be
transferred to a facility
which is operatinq in
compliance with section 3004
and 3005 of the Solid Waste
Disposal Act (or where
applicable, in compliance
with the Toxic Substances
control Act or other
applicable Federal law) and
all applicable State
requirements. Such
substance or pollutant or
contaminant may be
transferred to a land
disposal facility only if
the President determines
that both of the followinq
requirements are met:
SARA sectior.
121 (d) (2) (C)
Applicable
Applicable to the off-site
treatment, storaqe, or disposal of
wastes qenerated durinq on-site
remedial actions.
4-22
-------
~
off-Site
Treatment
Storage or
Disposal
(cont.)
Discharge of
Treatment
system
Effluent
U.S. EPA
Ground-Water
protection
Strategy
RFPsumT4.5
,"'~ -...... ~
~
TABU: 4-5 (continued)
ANALYSIS OF ACTION SPECIFIC ARARs
.FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
Requirement
The unit to which the
hazardous substance or
pollutant or contaminant
is transferred is not
releasing any hazardous
waste, or constituent
thereof, into the ground
water or surface water
or sol1.
All such releases from
other units at the
facility are being
controlled by a
corrective action
program approved by the
Administrator under
subtitle e of the Solid
Waste Disposal Act.
Wastes must bo treated using
technology or to
concentration level by best
demonstrated.available
technology (BDAT) for each
hazardous constituent in the
waste, prior to land
disposal.
Use of best available
technology (BAT)
economically achievable is
required to control toxic
and non-conventional
pollutants. Use of best
conventional pollutant
control technology (BCT) is
required to control
conventional pollutants.
Technology-based limitations
may be determined on a
case-by-case basis.
The strategy includes
guidelines on classifying
ground water for EPA
decisions affecting ground
water protection and
corrective actions.
Criteria include ecological
importance, replaceability,
and vulnerability
consideration.
Prerequisite
Wastes must be identifiable as
hazardous per 40 erR Part 261
The protection strategy does
not involve applicable ARARs
but does contain policy
statements to be considered.
citation
~
Comments
40 eFR Part 268
Applicable
Applicable to wastes, other than
treated effluent, such 8S treatment
sludge, excavated soils, used
treatment materials. Also
applicable to on-site land disposal
or RplacementR outside the area of
contamination. R'A if not RCRA
hazardous waste.
40 eFR 122.44
R'A
TBC
This strategy is to be considered
regarding ground water remedial
alternatives for operable Unit 4.
4-23
-------
TABLE 4-5 (continued)
ANALYSIS OF ACTION SPECIFIC ARARs
FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
~
National
Ambient Air
Quality
Radionuclide
NESHAP
New Source
Performance
Standards
Transportatl,on
of Hazardous
Materials
Horker
Safety
Emergency
Planning,
Preparedness,
and Response
for Operations
RFPaum T4.5
Requirement
National ambient air quality
standards have been set to
attain and maintain primary
and secondary standards to
protect public health and
the environment.
Requirements Include a
major-source permit,
prevention of significant
deterioration permit,
non-attainable area permit,
and visibility permit. '
National Emission Standards
for Hazardous Air pollutants
have been established to
protect public health and
the environment.
Requirements include a
permit for emissions of rads
greater than 10' of the
standards monitoring and
inclusion in the effective
, dose equivalent calculation.
Standards for new sources of
air emissions. Requirements
are source-specific.
Specific DOT requirements
exist for labeling,
packaging, shipping
papers/manifesting, and
transporting by rail,
aircraft, vessel, and
highway. '
occupational Safety and
Health program for DOE
contractor employees at
government-owned
contractor-operated
facilities.
Provide coordination
direction of planning,
preparedness, and response
to operational emergencies
in which there is a
potential for personal
injury, destruction of
property, theft, or release
of toxic, radioactive, or
other hazardou8 material
, which present a potential
threat to health, safety, or
the environment.
Prerequisite
Citation
Comments
~
CM Section 109
and 40 CFR 50
Remedial actions at Operable Unit 4
that may result in new sources of
air emissions include natural gas
emissions from heat source for
flash evaporator and excavation.
R'A
40 crR 61
Subpart H
Applicable
It is highly likely that neither a
permit nor monitoring viII be
required because the emissions of
radionuclide viII be too small.
Need to determine if these
,standards apply to potential
remedial actions.
eM Section II I
R'A
49 crR 100-199
Applicable
Applicable to vastes or materials
shipped off-site.
OSHA, 29 crR
1910.120, DOE 5483.1A
TBC
NCP, 40 cm 300,'
DOE 5500.2
TBC
..
4-24
-------
~
General
Environmental
Protection
Program
Environmental
Compliance
Issue
Coordination
Hazardous and
Radioactive
Mixed Waste
Program
Radiation
Protection
Packaging and
Transportation
of Hazardous
Materials,
Hazardous
Substances,
hazardous
wastes, and
radioactive
materiah
Comprehensive
Environmental
Response,
Compensation
and Liability
Act Program
Environmental
Protection
Safety, and
Health
Protection
Information
Reporting
Requirements
RFPaumT4.6
.
TAb....: 4-5 (continued) .
ANALYSIS OF ACTION SPECIFIC ARARs
FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
Requirement
Prerequisite
Citation
Comments
~
Establishes environmental
protection program
requirements,
authorities, and
res~onsibilities for DOE
operations for ensuring
compliance with federal and
state environment protection
laws and regulations,
federal executive orders,
and internal department
policies.
Establishes DOE requirements
for coordination of
significant environmental
compliance issues.
DOE 5400.1
TBC
DOE 5400.2A
TBC
Establishes DOE hazards and
radioactive mixed waste
policies and requirements
and implements RCRA.
Establishes radiation
protection standards and
requirements including
occupationally related
exposure of individuals in
controlled areas.
DOE 5400.3
TBC
DOE 5480.1
TBC
Establishes requirements for
psckag~ng and
transportation.
DOE 5480.3
TBC
Establishes basic
requirements for
'imp1ementation of the
superfund at DOE facilities.
DOE 5480.14
; TBC
Establishes requirements and
procedures for reporting
informstion having
environmental protection,
safety, or health
significance for DOE
operations.
DOE 5484.1
TBC
4-25
-------
~
Radioactive
Waste
Management
RFPsumT4.5 .
. ""'.
TABLE 4-5 (continued)
ANALYSIS OF ACTION SPECIFIC ARARs
FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4, SOLAR EVAPORATION PONDS AND INTERCEPTOR TRENCH SYSTEM
Requirement
Establishes policies and
guidelines by which DOE
manages radioactive waste,
waste byproducts, and
radioactively contaminated
surplus facilities.
Prerequisite
4-26
Citation
COll1lllsnts
~
DOE 5820.2A
TBC
,.'.' ....
\
..
-------
,
~
5.0 EXPLANATION. OF SIGNIFICANT CHANGES TO THE IMIIRA
!
\.
- Significant changes which change or alter this IMIIRA may result based on comments received by the
public, ~A or the~. D~E will respb~ to comments which change or alter the selected remedy ~
will included those resPonses in the Final Decision Document for this IMIIRA. Comments have not been
received that require a change in the selected remedy.
RFPawn-3.R
5-1
------- |