EPA Superfund
Record of Decision;
Naval Reacto^sjacility,
Idaho Falls, ED,
9/27/94
EPA/ROD/R10-94/084
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
Naval Reactors Facility Industrial Waste Ditch and Landfill Areas
Operable Units 8-07, 8-06, and 8-05
Idaho National Engineering Laboratory
Idaho Falls, Idaho
STATEMENT OF BASIS AND PURPOSE
This document presents the remedial actions selected for the Naval Reactors Facility
Industrial Waste Ditch (Operable Unit 8-07) and Landfill Areas (Operable Units 8-05 and 8-06),
at the Idaho National Engineering Laboratory. The remedy was selected in accordance with
the Comprehensive 'Environmental Response, Compensation, and Uability Act, as amended
by the Superfund Amendments and Reauthorization Act, and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan. This decision was
based on the information in the Administrative Record for the Naval Reactors Facility
Industrial Waste Ditch and Landfill Areas.
The U.S. Environmental Protectipn Agency (EP A) approves of this remedy I and the State of
Idaho concurs with the selected remedial actions.
ASSESSMENT OF THE SITE
The Naval Reactors Facility Industrial Waste Ditch and Landfill sites 8-05-59, 8-06-35, 8-06-36,
8-06-48, 8-06-49, and 8-06-50 do not present an unacceptable risk to human health or the
environment, and therefore, require no further action. Hazardous substances disposed of in
landfill areas 8-05-1, 8-05-51, and 8-06-53 may present a potential threat to public health or
welfare, or to the environment if not addressed by implementing .the response action selected
in this Record 01 Decision. ~ .
DESCRIPTION OF THE SELECTED REMEDY
The Naval Reactors Facility has been designated as Waste Area Group f:NAG) 8 of the 10 .
WAGs at the INEL which are under investigation pursuant to the Federal Facility Agreement
and Consent Order (FFAjCO) between the Idaho Department of Health and Welfare (IDHW),
the EPA, and the U.S. Department of Energy (DOE). The Industrial Waste Ditch is
designated as Operable Unit 8-07, and the Landfill Areas are designated as Operable Units 8-
05 and 8-06. No action is recommended for the Industrial Waste Ditch or Landfill Units 8-05-
59, 8-06-35, 8-06-36, 8-06-48, 8-06-49, and 8-06-50. The recommended remedial action for
landfill sites 8-05-1, 8-05-51, and 8-06-53 is in accordance with the Presumptive Remedy for
CERC~ Municipal Landfill Sites. This consists of containment of landfill contents and soil
gas monitoring to reduce the risks associated with potential exposure to the contaminated
wastes. Ground water monitoring will be performed to provide information on the impact
these .areas may have had on ground water and to support the NRF Comprehensive Record
of Decision. .
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The major components of the selected remedy include:
Installation of a native soil cover, followed by planting with native vegetation to reduce
erosion; .
Periodic inspection and maintenance to ensure the integrity of the cover;
Soil gas monitoring to provide early detection of any release from the landfill areas to
the subsurface, ground water, or surface pathways; .
Ground water monitoring to evaluate these and other areas at NRF; and
Maintaining institutional controls, including signs, postings, and land use restrictions.
STATUTORY DETERMINATION
The selected remedy is protective of human health and the environment, complies with
Federal and State applicable or relevant and appropriate requirements, and is cost effective.
This remedy utilizes permanent solutions and presumptive remedies to the maximum extent
practicable; however, because the wastes can be reliably controlled in place, treatment of the
principle sources of contamination was not found to be cost effective. Therefore, this remedy
does not satisfy the statutory preference for treatment as a principal element of the remedy.
Because the remedy will result in hazardous substances remaining in some of the landfill
areas onsite, a review will be conducted within five years after commencement of remedial
actions, and every five years thereafter, to ensure that the remedy continues to provide
adequate protection of human. health and the environment.
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SIGNATURE SHEET
Signature sheet for the foregoing Industrial Waste Ditch and Landfill Areas of Naval Reactors
Facility at the Idaho National Engineering Laboratory Record 01 Decision between the U.S.
Department of Energy and the Environmental Protection Agency with concurrence by.the
Idaho Department of Health and Welfare.
/"') )
(-i:rv.riY ,& l_/ .v~£,!,-Z
1'1/Ji;~CK CLARKE
; Regional Administrator. Region 10
U .8.. Environmental Protection Agency
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. SIGNATURE SHEET
Signature sheet 10r the foregoing Industrial Waste Ditch and Landfill Areas 01 Naval Reactors
Facility at the Idaho National engineering Laboratory Record 01 Decision between the U.S.
Department of Energy and the Environmental Protection Agency with concurrence by the
Idaho Department of Health and Welfare. .
1\ ~---- ~ ~-~ {..
THERON M. BRADlEY. . .
Manager
. U.S. Department of Energy Naval Reactors Idaho_Branch
~-t ~~, l u.:i:-
Date
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SIGNATURE SHEET
Signature sheet for the foregoing Industrial Waste Ditch and Landfill Areas of Naval Reactors
Facility at the Idaho National Engineering Laboratory Recore of Decision between the U.S.
Department of Energy and the Environmental Protection Agency with concurrence by the
Idaho Department of Health and Welfare.
~//~
JERRY L. H:Z .
Director
Idaho Department of Health and Welfare
9:hc;/'~sL .
Date
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TABLE OF CONTENTS
TABLE OF CONTENTS 0 . . . . . . . . . 0 . 0 0 . 0 0 0 0 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0
DECLARATION OF THE RECORD OF DECISION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. i
SITE NAME AND LOCATION. .. ... . . . 0 . o. . . . 0 ... .. .. . . . . ., .. . . . . . . . . . . . .., i
STATEMENT OF BASIS AND PURPOSE. . . 0 . . . . . 0 0 0 0 . 0 . . . . . . . . . . . . . . . . . . . . ., i
ASSESSMENT OF THE SITE 0 . . 0 0.' 0 0 0 0 . . . 0 0 . 0 . 0 0 . . . 0 0 . 0 . 0 . . 0 . . . . 0 . . . . . . . .. i
DESCRIPTION OF THE SELECTED REMEDY 0 0 0 0 0 . . . . . . 0 . . . . . . . . . . . .. . . 0 . . . .. i
STATUTORY DETERMINATION. . . 0 . 0 . . . . . . . . 0 . . 0 . . . . 0 0 0 . . . . 0 . 0 . . 0 . . . . . . . .. ii
SIGNATURE SHEET. . 0 . 0 . 0 . .0' . . . . . 0 . . . . '0' . 0 . . . ~ . . . o. . . . . . . . . . . . 0 . .00' Hi
SIGNATURE SHEET. . . o. . O' . . . . . . . . . 0 0 . . 0.00.0." . . . . . 0 . ... ... . . .. . . ..
SIGNATURE SHEET. . . . . . . . . 0 . . .0. . . O' . .. .. 0 . 0 .0' . . . . . ., . . . .. . . . . 0 . . 0 0
TABLES 0 . . . . . . . 0 . . . . . . . . . . 0 . . 0 . . . 0 . 0 . 0 0 0 . 0 0 . 0 . 0 . . . . 0 . . . . . 0 0 0 . 0 . . 0 O' ix
FIGURES o. 0 0 . . . . . . . . . 0 . . . . . . . . ; 0 . . . 0 . 0 . .. . . . . . . . . . . 0" . . 0 . 0 0 . . . . . . . . .
ACRONYMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . 0 0 . . . . 0 . . . . . .
1.0 DECISION SUMMARY 0'" 0 . . . . . . . . 0 . . . 0 0 . . . . . . . . . . 0 . 0 . 0 . . . . . . 0 . . . . .
Site Name, Location, and Description o. . . 0 . . . 0 . . . 0 . . 0 . . . . . . 0 . 0 . . 0 0 0 . 0 .
Assessment 01 the Industrial Waste Ditch. . . . . . . . 0 . 0 . . . . . . . . . . . . . . . . . . .
Assessment 01 Landfi!1 Units. . . .~. . . . . . . . . . . . . 0 . 0 . . 0 . 0 0 . . . . ~ . 0 . . 0 . 0 . .
Description of the Selected Remedy. . . . . . . . . . . . 0 . . .'. . . . . . . . . 0 . . . . . . . .
2. SITE HISTORY AND E~FORCEMENT ACTIVITIES... . .,. . . 0..0."""""" .
3. HIGHUGHTS OF COMMUNITY PARTICIPATION 0 . 0 . . . . . . . 0 . . . . . . . . . . . . . . . . .
4. SCOPE AND ROLE OF OPERABLE UNITS AND RESPONSE ACTIONS. 0 0 . . 0 . . 0 . .
5. SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . 0 0 . . ; . . . . . 0 . 0 . . . . . .. 6
Industrial Waste Ditch. . . . . . ... . . . . . . . . . . . . . . . . 0 . . . . . . . . . . . . . . 0 . . . 0 0 6
Landfill Units. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 . 0 . . 0 0 0 . . . . . . . . . . . 0 8
Radioactivity Controls. . . . . . . . . . . 0 . . . . . . . . . 0 0 . . 0 0 . . . 0 . . . . . . . . . . . . ., 11
5.1 Summary of Environmental Monitoring Data. . . . . . . . . 0 . . . . . . . . . . . . . .. 13
5.1.a IWD Remedial Investigation Soil Samples. . . 0 . . . . . . . . . . . . . . ., 13
5.1.b Landfill Units. . . . . . . . . . . . . . . . . . . . . . . . . . 0 . . . . 0 . . . . . . . .. 16
, Surface Soil Gas Emissions Survey. . . . . . . . . . . . . . . . . . . . . . . 0 16
Soil Samples Analyzed for Inorganic Constituents O' 0 . . .0 . 0 0 . .. 16
Magnetometer Surveys. . . . . . . . . . . . 0 0 . . 0 . . . . . . 0 0 . 0 ., 0 . .. 17
5.2 Ground Water Samples. . 0 . . . . 0 . . . . . 0 0 0 . . 0 . . 0 . . 0 . . 0 0 . . . . . . . . . .. 17
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3
3
3
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Predicted Ground Water Values. . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . .. 17
5.3 Shallow Perched Water Table. . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. 19
6. SUMMARY OF SITE RISKS. . . .. . . . . . . . . .. ... . . . . . . .. . . . .., ..,. . . . . . ., 20
6.1 Human Health Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
6.1.1 Contaminants of Potential Concern. . .. . . . . . . . . . . . . .. . . . . . . .. 21
6.1.1.a Industrial Waste Ditch. . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
. 6.1.1.b Landfill Units. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
6.1.2 Exposure Assessment. . . ... . . ... . . . . . . . . . . . . . . . . . . . . . . . .. 22
6.1.2.a IWD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 23
6.1.2.b Exposure Concentrations for limiting Soil
. Concentrations for Landfill Units. . . . . . . . . . . . . . . . . . . .. 23
6.1.3 Toxicity Assessment. . . . . . . . . . . . . . . . . . ..~ . . . . . . . . . . . . . . .. 23
6.1.4 Risk Characterization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 23
6.1.4 a. Industrial Waste Ditch. . . . . . . . . . . . . . . . . . . . . . . . . . .. 23
6.1.4.b Landfill Units. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
6.1.5 Uncertainties and limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
6.1.5.a Industrial Waste Ditch. . . . . . . . . . . . . . . . . . . . . . . . . . .. 26
6.1.5.b Landfill Units. . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . ., 26
6.2 Environmental Risk Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 26
6.2.1 Exposure Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 26.
6.2.1.a IWD Qualitative Ecological Risk Assessment. . . . . . . . . .. 26.
6.2.1.b Landfill Units. . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .. 27
7.0 DESCRIPTION OF NO ACTIO~ DECISIONS. .. .. . . . . . . . . . . . . ... . ... . . .... 27
8.0 DESCRIPTION OF ALTERNATIVES...... ..,...... ..., .............. . .., 27
8.1 Remedial Action Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 27
8.2 Summary 01 Alternatives for Landfill Units. . . . . . . . . . . . . . . . . ., . . . . . . ., 28
8.3 Alternative 1: No Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 28
8.4 Alternative 2: Containment with Native Soil Cover. . . . . . . . . . . . . . . . . . .. 28
8.5 Alternative 3: Containment with Single Barrier Cover. . . . . . . . . . . . . . . . .. 29
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . ........... ... 29
9.1 Thr~shold Criteria. . . . . . . . J.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29
. 9.1.1 Overall Protection of Human Health. . . . . . . . . . . .. . . . . . . . . . .. 29.
9.1.2 Compliance with ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 30
9.2 Balancing Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 30
9.2.1 Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . . . ., 30
9.2.2 Reduction 01 Toxicity, Mobility, or Volume Through Treatment. . . .. 30
9.2.3 Short-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 30
9.2.4 Implementability....................................... 31
9.2.5 Cost...... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 31
9.3 Modifying Criteria. . . . . . . .. . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . ., 32
9.3.1 State Acceptance. . . . . . . . . . . ; . . . . . . . . . . . . . . . . . . . . . . . . .. 32
9.3.2 Community Acceptance. . . . . . . . . . . . . . . . . . ". . . . . . . . . . . . . .. 32
10.0 SELECTED REMEDY.. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
11. STATUTORY DETERMINATION. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33
11.1 Protection 01 Human Health and the Environment. ... . . . . . . . . . . . . . . . ., 33
11.2 Compliance with ARARs ....................................... 33
11.2.1 Chemical-Specific...................................... 33
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11.2.2 Action-Specific. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33
11.2.3 Location-Specific..................................... 33
11.3 Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 34
11.4 Use of Permanent Solutions and Alternative Treatment Technologies to
the Maximum Extent Practicable. . . . . . . . . . . . . . . . . . . . . .~. .~'. . . . .. 35
11.5 Preference for Treatment as a Principal Element. . . . . . . . . . . . . . . . . . . .. 35
12. DOCUMENTATION OF SIGNIFICANT CHANGES.................... .. ..... 35
APPENDIX A: RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . .". . . . . . . . . . . . .. A-i
APPENDIX B: PUBLIC COMMENT/RESPONSE LIST. . . . . . . . . .": . . . . . . . . . . . . . . .. B-i
APPENDIX C: ADMINISTRATIVE RECORD INDEX. . . . . . . . . . . . . . . . . . . . . . . . . . . .. C-i
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TABLES
Table 5-1 Categories of Discharges and Typical Annual Discharges to the IWD ....... 7
Table 5-2 Summary of Landfill Units (8-05 and 8-06) ........................... 9
Table 5-3 NRF Waste Generation After 1971 and Prior Inferred Generation for Landfill
Units Volume Calculation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .: 10
Table 5-4 Estimated Total Volume of Waste Disposal to NRF Landfill Units. . . . . . . . . .. 11
Table 5-5 Summary of Routine Radiological Monitoring at the NRF IWD in 1991 ....... 12
Table 5-6 Contaminant Concentrations in IWO Soils. . . . . . . . . . . . . . . . . . . . . . . . . .. 15
Table 5-7 Comparison of Results of Analysis of Selected Ions and Nutrients in NRF
Ground Water. . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . .. 18
Table 6-1 Summary of IWD Metals Analysis Results.......... :"................ 21
Table 6-2 Summary of Chemicals of Potential Concern in Landfill Units. . . . . . . . . . . .. 22
Table 6-3 Risk Based Soil Concentrations for Landfill Units. . . . . . . . . . . . . . . . . . . . .. 24
Table 6-4 Summary of Baseline Risk Assessment for the IWD ..................... 25
Table 9-1 Cost Estimate for Alternatives for Landfill Units. . . . . . . . . . . . . . . . . . . . . . .. 31
Table 11-1 Federal and State Action-Specific ARARS for Landfill Units. . . . . . . . . . . . ., 34
Table 11-2 Federal and State Location-Specific ARARS for Landfill Units. . . . . . . . . . .. 34
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FIGURES
Figure 1 The Idaho National Engineering Laboratory showing the location of the
Naval Reactors Facility. ...........................................
Figure 2 Photograph of NRF with the IWD Extending Northeast from the Northwest
Corner. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 3 Schematic of Operable Units Described. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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A1W
ARAR
ASTM
BTEX
BGS
BESWl
BlM
BTEX
CEC
CERCLA
CFA
CFR
CLP
COCA
CRP
CSM
DOE
DOE-ID
EPA
FFA/CO
FS
HO
ICR
IDHW
IWD
INEl
km
MOL
mi
NCP
NPl
NRF
OU
PCB
PCE
ppb
PPE
ppm
PVC
OA/OC
RAGS
RAO
RCRA
RfD
RI
RifFS
ROD
RPM .
SARA
ACRONYMS
Large Ship Reactor Prototype
Applicable or Relevant and Appropriate Requirements
American Society for Testing and Materials
Benzene, toluene, ethylbenzene, and total xylenes
Below Ground Surface
Below Elevation of the Static Water level
Bureau of Land Management
Benzene, toluene, ethylbenzene, and total xylene
Cation Exchange Capacity. .
Comprehensive Environmental Response, Compensation, and Uability Act
Central Facilities Area
Code of Federal Regulations
Contract Laboratory Program.
Consent Order and Compliance Agreement
Community Relations Plan
Conceptual Site Model
Department of Energy
Department of Energy, Idaho Field Office
Environmental Protection Agency
Federal Facility Agreement/Consent Order
Feasibility Study .
Hazard .Quotient
Increased Cancer Risk .
Idaho Department of Health and Welfare
Exterior Industrial Waste Ditch
Idaho National Engineering Laboratory
kilometer
Method Detection Umit
miles
National Contingency Plan
National Priorities Ust ~
Naval Reactors Facility
Operable Unit
Polychlorinated biphenyls
Tetrachloroethylene
parts per billion
Personal protective equipment
parts per million
Polyvinyl Chloride
Quality Assurance/Quality Control
Risk Assessment Guidance for Superfund
Remedial Action Objective
Resource Conservation and Recovery Act
Reference Dose
Remedial Investigation
Remedial Investigation/Feasibility Study
Record 01 Decision
Remedial Project Manager .
Superfund Amendments and Reauthorization Act of 1986
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SRPA
SOP
SOW
S1W
SVOCs
TAN
TCA
TCLP
TPH
TSD
USGS
UTL
VOCs
WAG
..
Snake River Plain Aquifer
Standard Operating Procedure
Statement of Work
Submarine Thermal Reactor Prototype
Semi-Volatile Organic Compounds
Test Area North
1,1,1-trichloroethane
Toxicity Characteristic Leaching Procedure
Total Petroleum Hydrocarbons
Treatment, Storage, and Disposal facility
United States Geological Survey
upper tolerance limit
Volatile Organic Compounds
Waste Area Group
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1.0 DECISION SUMMARY
Site Name, Location, and Description
The Idaho National Engineering Laboratory (INEL) is a government facility managed by the
U.S. Department of Energy located 51.5 kilometers (km) [32 miles (mi)] west of Idaho Falls,
Idaho, and occupies 23Q5 km2 (890 mi2) of the northeastern portion of the Eastern Snake
River Plain. The Naval Reactors Facility is located on the west-central side of the Idaho
National Engineering Laboratory (Figure 1). This Record of Decision applies only to that
portion of the Industrial Waste Ditch outside the NRF perimeter (Operable Unit 8-07,
hereinafter referred to the Industrial Waste Ditch). This segment extends about 3.2 miles to
the northeast from the northwest corner of the fence. The interior portion of the ditch will be
addressed as Operable Unit 8-09. The Landfill Units (Operable Units 8-06 and 8-05) include
nine separate locations situated on the west and northeast sides of the facility. The
maximum area of the combined landfill units is 0.16 km2 (0.06 mi2).
Current land use at the INEL is primarily dedicated to nuclear. research and development, and
waste management. Surrounding areas are managed by the Bureau of Land Management
for multipurpose use. The developed area within the INEL is surrounded by a 1295 km2 (500
mi~ buffer zone used for cattle and sheep pasture.
Of the 11,700 people employed at the INEL, approximately 830 are employed at the Naval
Reactors Facility. The nearest offsite populations are in Atomic City, Area, Howe, Mud Lake,
and T erreton. . .
INEL
To Idaho Falls
-
o 1 .. . .
r--' ---:-'
. . . II
-
To BIaddoot
--
Figure 1 The Idaho National Engineering Laboratory showing the location of the Naval
Reactors Facility.
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The INEL is located on the northeastern portion of the Eastern Snake River Plain (ESRP), a
volcanic plateau that is primarily composed of silicic and basaltic rocks and relatively minor
amounts of sediment. Underlying the INEL are a series of basaltic flows with sedimentary
interbeds. The basalts immediately beneath the Naval Reactors Facility are relatively flat, and
are covered by 6.1 to 9.1 meters (20 to 30 feet) of alluvium and loess.
The depth to the Snake River Plain Aquifer (SRPA) at the INEL varies from 61 meters (200
feet) in the northern portion to 274.3 meters (900 feet) in the southern portion. The depth to
the aquifer at the Naval Reactors Facility is approximately 112.78 meters (370 feet). Regional
ground water flow is generally to the southwest.
The Idaho National Engineering Laboratory has semidesert characteristics with hot summers
and cold winters. Normal annual precipitation is 23.1 centimeters (9~ 1 inches). The only
surface water present at the INEL is the Big Lost River, which is approximately three miles
south of the Naval Reactors Facility. However, this river is typically dry due to the arid
climate. The only naturally occurring surface water at the Naval Reactors Facility results from
heavy rainfall or snow melt; usually during the period from January to April.
Twenty distinctive vegetative cover types have been identified. at the INEL, with big sagebrush
being the dominant species, covering approximately 80% of the ground surface. The variety
of habitats on the INEL support numerous species of reptiles, birds, and mammals. Several
bird species warrant special concern because of sensitivity to disturbance or their threatened
status. These species include the ferruginous hawk (Buteo regalis), bald eagle (Haliaeetus
leucocephalus), prairie falcon (Falco mexican us) , merlin (Falco cofumbarius), long-billed
. curlew (Numenius americanus), and the burrowing owl (Athlene cuniciJfaria). The ringneck
snake, whose occurrence is considered to be INEL-wide, is 'listed by the Idaho Department of
Rsh and Ga.me as a Category C sensitive species.
The areas of the Industrial Waste Ditch and landfill areas included within this Record of
Decision have been evaluated for compliance with the Wetlands Protection Act, Flood Plain
legislation, and Historical and Cultural Preservation, and were found to meet the applicable
and/or relevant and appropriate statutes.
The Naval Reactors Facility includes approximately 80 developed acres. Nonradioactive,
nonhazardous industrial waste water from ~water treatment operations and storm water runoff
has been discharged to the IWD since 1953. The crtch was originally an old stream bed, and. .
it has been modified to carry water away from the facility. The volume of water discharged
has varied greatly, depending on operational requirements. Due to recent reductions in
operations, water is rarely present beyond 1.2 miles beyond the outfall. When both the IWD
and Landfill units are discussed in Sections 5 through 11 of this Record of Decision, the IWD
will be discussed first, or will be labeled as subsection 'a'.
The landfill areas are primarily located west and northeast of the Naval Reactors Facility.
Operable Units 8-05 and 8-06 include nine separate areas which have been identified as
potential waste disposal sites. The wastes in these landfill areas are similar to those found in
municipal landfills; cafeteria wastes, construction debris, petroleum products, paper, and
small amounts of paints and solvents. Different landfill units were used at various times from
1951 through 1971. NRF discontinued use of the last landfill linit in 1971. When both the
IWD and Landfill units are discussed in Sections 5 through 11 of this. Record of Decision, the
landfills will be discussed second, or will be labeled as subsection 'b'.
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Assessment 01 the Industrial Waste Ditch
The no action decision is applicable to the Industrial Waste Ditch because there is no'
unacceptable risk to human or ecological receptors in the present or future land use
scenarios.
Assessment 01 Landfill Units
Landfill sites 8-05-59, 8-06-35, 8-06-36, 8-06-48, 8-06-49, and 8-06-50 were evaluated using
existing data, and risk calculations were performed for those constituents identified by the soil
gas analyses, surface soil samples, or based on historic information'. These six areas were
determined to contain primarily construction debris, did not present any unacceptable risk .to
human pr environmental receptors, and are recommended for no action. Landfill sites 8-05-1,
8-05-51, and 8-06-53 have contents similar to those found in. municipal landfills. As agreed to
by the three parties, intrusive sampling of the actual contents of the landfills was not
performed. Containment with a native soil cover is the recommended alternative for these
areas, based on the Presumptive Remedy for Comprehensive Environmental Response,
Compensation, and Uability Act (CERCLA) Municipal Landfill Sites, to provide assurance that
there will not be a release of contaminants to the environment in the f~ure. Five year reviews
will be condu.cted to verify that the actions taken remain protective of human health and the
environment.
Description 01 the Selected Remedy
The alternative selected for landfill sites 8-05-1, 8-05-51, and 8-06-53 is the Presumptive
Remedy for CERCLA Municipal Landfill Sites. Presumptive remedies are preferred
technologies for common categories of sites, based on historical patterns of remedy .
selection and EPA's scientific and engineering evaluation of performance data on technology
implementation. The objective 01 the presumptive remedies process is to use the EPA's past
experience to streamline site investigation and the remedy selection process, thereby.
improving consistency, reducing cost, and increasing the speed within which hazardous
waste sites are remediated. The specific actions are to survey and mark the areas, restrict
land use, monitor soil gases, and install and maintain a two foot thick native soil cover over
the landfill contents by means of administrative controls. Ground water monitoring will be
performed to evaluate these and other areas at NRF.
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Naval Reactors Facility was established in 1949 as a testing site for the naval nuclear
propulsion program. The Submarine Thermal Reactor Prototype (S1W) became operational
in 1953. At that time, the first section of-the Industrial Waste Ditch was constructed to
accommodate the disposal of nonradioactive, nonsewage liquid discharges. The three
landfill units received solid waste similar to that of municipal landfills (construction, petroleum,
cafeteria, and smalt quantities of paint products) from the prototype and support facility
operations.
The Large Ship Reactor Prototype (A 1 W) and the Expended Core Facility (ECF) became
operational in 1958, and the SSG Prototype became operational in. 1965. As the Naval
Reactors Facility .expanded, the Industrial Waste Ditch was modified to accommodate the
increased volume of waste water. The primary discharge constituents were nonradioactive
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cooling water, acidic and basic solutions from the water treatment facility, facility discharges
with occasional oily residues, storm water runoff, and small amounts of laboratory chemicals.
The landfill areas were used intermittently from the time construction started at NRF. In
general, construction debris and waste material was burned, then covered with soil. The
volume of construction debris decreased after the construction of A 1 Wand ECF in 1958, and
after the construction 01 SSG in 1965. Use of the last NRF landfill ceased by 1971.
In 1980, the Naval Reactors Facility ceased the discharge of all Resource Conservation and
Recovery Act (RCRA) wastes to the Industrial Waste Ditch except the acidic and basic ion
exchange regenerant solutions, which were self-neutralizing. In 1985, a facility was
constructed to neutralize these solutions prior to discharge. A Consent Order and
Compliance Agreement (COCA) was established between the Department of Energy and the
U.S. Environmental Protection Agency pursuant to the Resource Conservation and Recovery
Act Section 3008{h) in August 1987. The COCA required an initial assessment and screening
of all solid waste andjor hazardous waste disposal units at the INEL, and set up a process
for conducting any necessary corrective actions. In November 1989, the INEL was listed on
the National Priorities Ust (NPL) by the EPA under CERCLA as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA). The pOE, EPA, and State of Idaho
Department of Health and Welfare (IDHW) entered into the Federal Facility Agreement and
Consent Order (FFAjCO) on December 9, 1991.
Most of the discharge to the IWD has been directly proportional to plant operations,
particularly the amount of cooling water utilized. The reduction in work scope at the Naval
Reactors Facility over the past five years has resulted in a corresponding decrease in the
volume of water discharged to the IWD. When three prototype plants were operational, water
was present to the 4 kilometer (2.5 mile) mark in the ditch channel. As a result of the
inactivation of the S1W prototype in 1989, and the permanent shut down of the A1W
prototype in 1994, water is only present in the first 1.6 kilometer (one mile) of channel. The
S5G prototype inactivation scheduled to start in 1995 will further reduce the volume of water
discharged to the IWD.
The IWD was identified for a RemediallnvestigationjFeasibility Study (RljFS) under the
FFAjCO. The Landfill Units were investigated in accordance with Track 2 Sites: Guidance
for Assessing Low Probability Hazard Sit€s at the INEl. The entire NRF area will be
evaluated in the Waste Area Group ~AG) 8 Comprehensive RljFS, which is scheduled to
begin in 1995. .
3. HIGHUGHTS OF COMMUNITY PARTICIPATION
In accordance with CERCLA ~113(k){2){B){i-v), information on the investigations and
decision-making processes involved in the evaluation of the NRF Industrial Waste Ditch and
Landfill Areas was provided to the public from January through April 1994 through fact sheet
mailings, articles in the INEL Reporter, and publJc meetings. Opportunities to comment on
these plans were provided during the public comment period from April 12 until May 12, .
1994. A Fact Sheet and Proposed Plan were distributed to 7500 citizens by mail, telephone
calls were made, and announcements were made in the media and INEL publications. Public
information and scoping meetings and two open houses were also. conducted. 80th oral and
written comments were accepted. .
Display ads describing upcoming meetings were published in t~e following newspapers:
Idaho Falls Post Register; Pocatello Idaho State Journal; Burley South Idaho Press; Twin Falls
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Times News; Boise Idaho Statesman; Nampa Idaho Press Tribune; Lewiston Morning Tribune;
and Moscow Idahonian between March 15 - 23, 1994 to encourage citizens to attend the
public meetings and provide oral or written comments. During the week of March 27, 1994, a
press release addressing the Naval Reactors Facility public meetings and general information
on the investigations was released to approximately 40 media centers for dissemination to
the public. Articles were also published in the INEL Reporter, The INEL Citizens Guide to
Environmental Restoration at the INEL, and the INEL News"
Newspaper and radio advertisements were presented the week of April 10, 1994 to notify the
public of the information sessions at Pocatello and Twin Falls. Advertisements were placed in
two local newspapers, and radio advertisements were broadcast by six local stations five
times a day for three days in Pocatello, Burley and Twin Falls. Two"radio talk shows
broadcast from Burley on April 13, 1994 and Jerome on April 14, 1994 provided information
on the public meetings, and the locations of the INEL regional office. All media (letter, news
release, radio, and newspaper ads) gave public notice of two scoping meetings and
notification of the beginning of the 30 day public comment period from April 12 - May 12;
1994. .
Personal phone calls concerning the availability of Naval Reactors Facility documents and
public meetings were made to individuals, environmental groups, and organizations by INEL
Outreach Office staff in Pocatello, Twin Falls, and Boise. The Community Relations Plan
Coordinator made calls in Idaho Falls and Moscow.
Information sessions were held at the Pine Ridge Mall in Pocatello on April 12, 1994, and at
the INEL regional office in Twin Falls on April 14, 1994 prior to the public meetings. On April
13, 1994, representatives from the DOE. EPA, and IDHW conducted a technical briefing via
teleconference calls with members of the League of Women Voters and the Environmental
Defense Institute in Moscow, Idaho.
All media presentations gave public notice that Naval Reactors Facility documents would be
available before the beginning of the comment period in the Administrative Record section of
the INEL Information Repositories located in the IN.EL Technical Ubrary of Idaho Falls, as well
as in the city libraries in Idaho Falls, Pocatello, Twin Falls, Boise, and Moscow. Display ads
announced the same information. ~ .
Open houses were held in Pocatello on April 12, 1994, and Twin Falls on April 14, 1994.
Public meetings were held in Idaho Falls on April 19, 1994, Boise on April 20, 1994, and .
Moscow on April 21, 1994. A total of 83 people attended these meetings. Written comment
forms were available at all meetings. The reverse side of the meeting agenda provided a
form for the public to evaluate the effectiveness of the meetings. A court reporter was
present at each meeting to keep a verbatim transcript of discussions and public comments.
The meeting transcripts were placed in the Administrative Record section for the Naval
Reactors Facility Industrial Waste Ditch (Operable Unit 8-07), and Landfill Areas (Operable
Units 8-05 and 8.()6) in eight INEL Information Repositories.
A Responsiveness Summary has been prepared as part of this Record of Decision. All
formal oral comments made at the public meetings, and all written comments are repeated
verbatim in the Administrative Record. Those comments are annotated to indicate which
response in the Responsiveness Summary addresses each comment.
A total of nine written comments and six oral comments were received during the comment
period. All comments received on the Proposed Plan were considered during development
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of the Record of Decision. The decision for this action is based on the intormatio. n the
Administrative Record for these Operable Units. .
4. . SCOPE AND ROLE OF OPERABLE UNITS AND RESPONSE ACTIONS
f'"'"\
The exterior portion of the NRF
IWO (Operable Unit 8-07)
extends about 5.15 kilometers
(3.2 miles) to the northeast from
the northwest comer of the .
fenced perimeter of the Naval
Reactors Facility. The Industrial Waste Ditch was first used to dispose of nonradioactive,
nonsewage industrial waste water in 1953. The. primary component of the discharge stream
..
Under the FFA/CO, the INEL is
divided into ten WAGs. The
WAGs are further divided into
Operable Units (OUs). The Naval
Reactors Facility is designated as
WAG 8, and consists of nine
OUs. Monitoring data, process
knowledge, written
correspondence, and interviews
with current and previous
employees were used to evaluate
the IWO and Landfill Units. The
Remedial Investigation/Feasibility .
Study on the Industrial Waste
Ditch and the Track 2
Investigations of the Landfill
Areas evaluated the potential for
contamination and migration
from the soil, water, and air
affected by these areas. A
complete evaluation of all
cumulative risks associated with
the CERCLA actions at WAG 8
will be conducted as part of the
NRF Comprehensive RifFS to
ensure that all risks have been
adequately evaluated. This.
Re~ord of Decision is part of the
overall WAG strategy, and is
expected to be consistent with
any planned Mure actions.
5. SUMMARY OF SITE
CHARACTERISTICS
Industrial Waste Ditch
"
Figure 2 Photograph of NRF with the Iwe Extending
Northeast from the Northwest Comer
~
/~
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throughout the lifetime of the IWO has been cooling water from circulating water systems,
and ion exchange regenerant solutions. The ditch channel was modified around 1958 to
direct the original waste stream and additional discharge from the newly constructed A 1 W
plant toward the dry streambed at the northwest corner of the facility. In 1965, the channel
was expanded to the point 2.66 kilometers (1.65 miles) downstream from the outfall to
accommodate additional effluent as the SSG prototype became operational. After 1965, the
ditch was dredged occasionally'to improve drainage, but remained within the same channel.
The dredged sediments were placed along the ditch banks parallel to the channel.
Table 5-1 identifies various categories of chemicals used at the NRF during historical
operations, and provides an estimate of the source volum~ which may have been discharged
to the IWD. It is uncertain if all the listed compounds entered the ditch network. This
information is based on procurement records, process knowledge, and plant operation
records.
Table 5-1 Categories 01 Discharges and Typical Annual Discharges to the IWD
Categories of . Estimated Annual Examples of Wastes Potentially
Discharges to the Volume Discharged
Industrial Waste Ditch (Gallons IY ear)
Run-Off (rain and 33,000,0001 Residual oils, metals, hydrocarbons
snow melt)
Prototype and 70,000,0002 Waste oil, water treatment chemicals,
Auxiliary Operations chemical reagents, surfactants, cleaning
chemicals, chlorinated and fluorinated
compounds
Cooling Systems 500,000 Water treatment chemicals
Ion Exchange 4,000,0003 Acidic and basic solutions
Regeneration
Laboratory Operations ~1 ,000 Laboratory chemical analysis wastes,
including dilute metal compounds,
reagents, chlorinated compounds,
preservatives, acids and bases, nitrates
Photographic 1,000 Photographic solutions and reagents,
Operations . preservatives
I Total 107,503,000 gal/year I
Volume may range as high as 40,000,000 gallons
2
Volume may range as high as 79,000,000 gallons
Volume may range as high as 4,750,000 gallons
3
In 1980, NRF ceased the discharge of all RCRA wastes to the IWD except acidic and basic
ion exchange regenerant solutions, which were self-neutralizing. This change from previous
practice was part of a site improvement project, and was accomplished by replacing
hazardous chemicals with non-hazardous chemicals, collecting and properly disposing of
remaining waste streams, and implementing waste control procedures. Discharge 01 acidic
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and basic ion exchange regenerant solutions continued from June 1980 through March 1985.
In April 1985, a neutralization facility consisting of two 15,000 gallon neutralization tanks was
installed. Acidic and basic solutions were mixed, neutralized, and discharged to the IWO.
The optimal pH control level at the facility is between 6.0 and 9.0 pH units. Since April 1985,
the IWO has received only rain/snow run-off, facility discharge containing oily residues, non-
hazardous industrial waste water, neutralization tank discharges containing a solution of acids
and bases neutralized to a pH between 6.0 and 9.0, and infrequent discharges of laboratory
chemical solutions. .
.",
The total volume of the sediment in the IWO containing inorganic waste was calculated to be
7,542 cubic meters (270,744 ft3). This corresponds to a length of 1,768 meters (5,800 feet), a
width of 4.74 meters (15.56 feet), and a dept!') of 0.9 meters (3 feet). The IWO sediment
surface area was calculated to be 8,380 m2 (90,248 ft2).
1
. - . I
I
~. u
..J
o
Oil]
.."
8-06-50
8-05-51 ~
. .-:::*:"
:4::
&iiiiiiiiI
~~~?I""
. ,~f(.
8-06-'49/" ":""
:.)1:
l)O'/.'
:=
. ".5
80()6.48
~
8-O~S9
~
J.
o
.
Scale (It)
soo ..
1000
11IIIIIIII
AN 0'.
Figure 3 Schematic of Operable Units Described and NRF Wells
Landfill Units
The Landfill Units (Operable Units8-D5 and 8-06) include nine separate areas located on the
west and northeast sides of the facility~ The maximum area of the combined landfill units is
0.16 km2 (1.64 x 108 ft~. The landfill units are believed to have similar nonradiological
wastes, migration paths, and risk factors. The wastes consisted of office trash, construction
. debris, cafeteria garbage, waste oils, chromate compounds, and small quantities of
'"
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Table 5-2 Summary of Landfill Units (8-0S and 8-06)
Area Primary UsesjWastes Dates of Dimensions Appearance/Artifacts
Operation
8-05-1 Similar to municipal 1951-1960 107 x 137 meters (350' x Eastern portion has
landfill; construction 450'), depth of refuse construction rubble piles
debris and refuse such 1.2-7.6 meters (4-25') about 1 meter (3') high
as petroleum products,
small quantities of
paints and solvents,
cafeteria wastes
8-05-51 Similar to municipal 1957-1963 137 meters x 30.5 to Covered disposal trench
landfill; construction 53.4 meters x 3.05-4.6 approximately 76.2 x
debris and refuse such meters deep (450' x 100- 4.6-6.1 x 3.05-4.6 meters
as petroleum products, 175' x 10-15') deep (250' x 15-20' x
smail quantities of 10-15')
paints and solvents,
cafeteria wastes,
material staging area
and construction debris
disposal
8-05-59 Possible' landfill/bum 1951-1953 22.9 x 30.5 meters (75' x No evidence of a landfill
pit 100'), depth estimated at was found
6.1 meters (20')
8-06-35 Construction debris 196D-1971 91.4 x 121.9 meters Mounded area
disposal (300' x 400') containing gravel, sand
silty soil, concrete,
wood, scrap metal
8.{)6.36 Construction debris 196D-1971 Triangular, base about Very little surface debris,
disposal 91.4 meters (300') and some natural sagebrush
. altitude of 152.4 meters remains
(500)
8-{)6.48 Material staging area 1956-1964 198.1 (650') long x 22.9 Scrap wood and meta!.
and construction debris ~ to 53.3 meters wide (75' Much of area is
disposal to 175') undisturbed
8-06-49 Construction staging 1961-1963 106.7 meters (350') long . Scrap wood and .metal
area x 7.6 to 45.7 meters (25' and concrete debris, no
to 150') older vegetation
remains, soil cover
8-06-50 Construction material 1956-1959 137.1 meters (450') long No older vegetation
staging and parking x 15.2 to 45.7 meters present, no evidence of
(50' to 150') disposal
8-06-53 Similar to municipal 1956-1970 274.3 x 365.8 x 2 to 3 Disturbed vegetation
landfill; construction meters deep (900' x and soil, tire tracks
debris and refuse such 1200' x 7' to 10')
as petroleum products,
small quantities of
paints and solvents,
cafeteria wastes
Areas recommended for the selected remedy appear in bold type.
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miscellaneous chemicals from the Naval Reactors Facility. Chemicals which are known to
have been disposed of in the landfills include low concentrations of silver nitrate and mercuric
nitrate in solution, which were used in laboratory analyses. A review of historical records and
interviews with former employees indicate that the waste was placed in unlined trenches or
pits, burned, and the areas subsequently backfilled. Use of the last landfill was discontinued
in 1971. .
The objectives of the investigations were to determine the boundaries of the landfills, the
depth of the cover, and the potential for ground water contamination and/or particulate or
organic vapor release. Intrusive sampling to determine the landfill contents was not
performed due to the heterogenous nature of the landfill contents. Table 5-2 summarizes
information about the landfill units. .
Records of what materials were deposited in the NRF landfills were not kept. However,
records were kept of the materials shipped from NRF to the INEL Central Facilities Landfill
after use of the last NRF landfill was discontinued in 1971. Since the operations and
processes used at NRF remained constant, the types and quantities of wastes generated are
not believed to have changed significantly over time. Therefore, these later records were
used to estimate the volumes and concentrations of wastes qisposed of prior to 1971 in the
NRF landfills. In addition, historic photographs were reviewed, and employee interviews and
a records search were conducted.
Table 5-3 NRF Waste Generation After 1971 and Prior Inferred Generation for Landfill
Units Volume Calculation
Waste Type Form Average Annual Volume Inferred Average
after 1971 (Cubic Annual Volume prior
\ metersfyear) to 1971 (Cubic
meters fyear)
Office trash Solid 4,655.8 3,119
Construction debris Solid 1,571.2 1,052
~
Municipal waste Solid 1 ,090 664
-
Waste oil Uquid 23.8 16
Paint, thinner, solvents Uquid 0.14 0.03
Acidic, basic, or metal-based Uquid 2.2 1.3
solutions used in plant
operations or analytical
chemistry procedures
Chromate solutions Uquid 2.5 1.7
Chemicals used for water . Solid 0.6 OA
treatment
Totals 7,346.2 4,854.4
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Based on the number of major construction evolutions which were in progress during the
time period the NRF landfills were in use, a considerable amount of the waste was probably
construction debris. After 1965, the quantity of construction debris disposed of probably
decreased due to the reduced number of construction projects. In addition, a smaller volume
of plant-related waste was generated and sent to the Naval Reactors Facility landfills prior to
1965, since only two prototype plants were operating. This volume of waste can be
conservatively estimated from later records by applying a reduction factor. Table 5-3
provides information about waste generated after 1971. and an estimate of the waste
generated prior to that time. Table 5-4 estimates the volume of waste disposed of in each
landfill unit. For the landfills, the three waste types of concern are waste oil, solvents, and
chemicals. Soil gas samples were collected and analyzed for volatile organic compounds to
screen for waste oils and solvents.
..
Table 5-4 Estimated Total Volume 01 Waste Disposal to NRF
Landfill Units (m:;
Year 8-05-1 8-05-51 8-06-53 Total CFA
1956 2,540 2,382 4,922
1957 2,310 230 2,382 4,922
1958 2,310 230 2,382 4,922
1959 2,310 230 2,382 4,922
1960 2,310 230 2,382 4,922
1961 230 2,382 4,922 2,310
1962 230 2,382 4,922 2,310
1963 230 3,555 7,346 3,561
1964 3,555 7,346 3,791
1965 t 3,555 7,346 3,791
1966 3,555 7,346 3,791
1967 3,555 7,346 3,791
1968 3,555 7,346 3,791
1969 . 3,555 7,346 3,791
1970 3,555 7,346 3,791
Total 11,780 1,610 45,114* 93,222 34,718
Capacity 55,064 1,612 22,585 79,261 NA
*Assumes this volume wa~ reduced by 50 percent as a result of incineration.
Radioactivitv Controls
At NRF, systems which contain radioactive liquids (e.g. reactor coolant, radiochemistry
laboratory liquid discharge)' with beta, gamma, and alpha emitting radionuclides are
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physically isolated from those systems which discharge to the iWD. Waste water containing
radioactivity is contained in separate, monitored systems which are isolated from those
carrying other site effluents. Waste water containing radioactivity is collected, processed to
remove the radioactivity, and reused rather than discharged to the environment. The process
systems include collection tanks, particulate filters, activated carbon columns, andjor mixed
bed ion exchange columns to remove radioactivity from the water. Strict operational
procedures have been used from the start of operations at NRF to control the release of
radioactive materials.
The effectiveness of this program is demonstrated by the results of sediment, soil, and
vegetation samples collected through routine environmental monitoring from the IWO. The
results indicate that radionuclides are not a contaminant of concern for au 8-07. Table 5-5
provides a summary of the routine soil, sediment, vegetation, and water samples collected for
radiological analysis in 1991.
Table 5-5 Summary 01 Routine Radiological Monitoring at the NRF IWD in 1991
Soil1 Sediment2 Vegetation Water3
(pCijgm) (pCijgm) (pCijgm) (10.8 uCijml)
MEAN MAX SL MEAN MAX MEAN MAX MEAN MAX SL
4
Cobalt-60 <0.1 0.22 <0.38 1.18 <0.36 <0.52 <5.5 <5.9 300
5 5 5
Cesium-137 0.25 0.49 1.3 0.36 0.60 <0.18 <0.26
pCijgm
SL
Picocurie (10.12 curie) per gram
Risk based screening level
< in front of a maximum value signifies LESS THAN the minimum detectable
activity (MOA). A mean value preceded by < contains at least one value below
MOA.
3
Sediment samples are collectet:! from the A 1 Wand S5G cooling towers, and the
sewage lagoons;. Le., material which has been deposited by water.
Water samples are analyzed for all gamma rays with energies between 0.1 and 2.1
MeV. This energy range includes Cobalt-60, Cesium-137, and a wide variety of
other radionuclides of both natural and man-made origin. The cOl)centrations
shown for Cobalt-60 are less than the minimum detectable concentrations for the
analysis, assuming all gamma rays detected had come from that one radionuclide.
2
4
While no specific screening level for Cobalt-60 has been established, the Cesium-
137 screening level may be used for comparison, since Cobalt-60 has a much
shorter halflife and comparable dose conversion factors for both internal and
external exposure. .
5
Cesium-137 is included in the equivalent Cobalt-60 concentration discussed in (2).
Since 1953, routine radiological monitoring 01 process water, cooling water, effluent water,
and buildings and grounds has been performed at NRF. Currently, water samples are
-------
collected weekly from the IWD and other discharge locations, and analyzed for gross gamma
radioactivity using gamma spectrometry. All samples collected for non-radiological analysis
are screened for radioactivity using a gamma detector prior to leaving NRF. Additionally,
radiological surveys are performed along the IWD, and sediment, soil, and vegetation
samples are collected and analyzed for gross gamma radioactivity on an annual basis from
five locations in the interior and exterior IWD. Cobalt-60 and Cesium-137 are the
predominant radionuclides identified during this analysis. These two radionuclides are used
to assess the presence of radioactivity during environmental monitoring at NRF, since they
are easily detectable and .are present with other NRF isotopes.
5.1 Summary 01 Environmental Monitoring Data
5.1.a IWD Remedial Investigation Soil Samples
Sediment samples from the IWD channel were first collected for characterization in 1985, and
were analyzed for chromium and silver concentrations based on process knowledge.
Detailed characterization sampling was initiated in 1986. Core samples collected in
November 1986 indicated that chromium, copper, lead, mercury, nickel, silver, and zinc were
present in the channel sediments. The only volatile organic compound present in the
samples was methylene chloride, which is a common laboratory contaminant. In 1987/88,
eighteen soil samples were collected to determine background levels. Composite core
dredge pile samples were collected in 1987, and analyzed for metals and Appendix VIII
constituents (chemicals which have been shown to have toxic, carcinogenic, mutagenic, or
teratogenic effects on humans). Only chromium and mercury were found to have
concentrations above background levels. .
Soil samples collected for the Remedial Investigation in 1992 were categorized into three
types; sediment samples from the ditch channel, dredge pile samples, and subsurface
samples from the beneath the ditch channel and on either side at set intervals. These
samples were analyzed for metals, volatile organic compounds (VOCs), semivolatile organic
compounds (SVQCs), polychlorinated biphenyls (PCBs), pesticides, total petroleum
hydrocarbons (TPH), and benzene, toluene, ethylbenzene, and total xyleries (BTEX). The
vast majority of vac and SVOC analyses" results reported concentrations below the Method
Detection Umit (MDL); however, there were a few indications of organic substances, such as
acetone, detected in some samples.. All of the volatile. organic values reported above MOL'
were interpreted as resulting from laboratory background, since many of these compounds
are frequently used in the laboratory or are common laboratory contaminants. None of these
identified contaminants were considered durin.g risk assessment calculations.
Compounds only identified in the dredge piles include one observation each of 1 ,2,4-
trichlorobenzene, naphthalene, phenanthrene, benzo(a)anthracene, benzo(a)pyrene, and
benzo(g,h,Qperylene, and two observations each of chrysene and benzo(b)fluoranthene.
These svacs are sometimes associated with coal tar and are possibly air deposited"
remnants buming heavy fuel oil (#5 & #6) at the NRF boilerhouse, which provides steam
lieating for the site. These compounds were detected in only a few locations and are not
considered to be contaminants of concem or representative of the site. Five observations of
the compound pentachlorophenol were" made in the dredge piles, with concentrations"
averaging 0.256 ppm. This compound is commonly used as a wood preservative, and may
have leached from the treated wood used in the cooling towers (part of the site circulating
water system).
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The majority of volatile organic compounds were reported at concentrations below the MDLs
of the chemical analyses. Volatile samples reporting concentrations above MDLs have been
identified as resulting from laboratory or field contamination, except for benzene, toluene,
ethylbenzene, and total xylene (BTEX) values reported in one ditch sediment sample. These
compounds are commonly associated with gasoline and other refined petroleum prod~cts,
and their presence is viewed as an isolated occurrence from a localized release of oil. No
further analysis of the volatile data was conducted, and no calculations for risks from volatile
compounds were made in the risk assessment.
The majority of the semi-yolatile organic compounds were reported at concentrations below
the MDLs. Some of the semi-volatile compounds were detected in the quality control
samples and the trip blanks. Because these compounds were detected in the quality control
samples, they were not included in the risk assessment. Most of tHe semi-volatile
compounds that were detected in the IWO sediments and dredge piles are related to a
constituent in coal tar, and were only found in one or tWo samples, and are not considered
representative of site conditions.
Pesticide, herbicide, and polychlorinated biphenyls (PCB) analyses were conducted on
samples from eight ditch sediment locations. All results were reported below the MDLs,
except for one sample which .showed lindane at 0.0006 milligrams per liter (mgjl). Undane
was not included in the risk assessment because. this one sample was not considered
representative of the site.
Total petroleum hydrocarbon (TPH) analyses were conducted on selected samples. Most of
the petroleum products found in the IWO are releases from pumps, compressors, and
turbines during normal operations. Seven sediment samples reported TPH values from 68 to
3,600 ppm. TPH values in background samples ranged from < 10 to 27 ppm with a mean of
16 ppm. There was not a consistent decrease in TPH concentration with distance from the
discharge . point. The lack of elevated BTEX concentrations indicates the elevated TPH values
are the result of longer chain hydrocarbons (e.g., motor oil, diesel, etc.) which tend to contain
small quantities of these constituents. This data is for general evaluation purposes only,
since TPH does not have a health-based standard for use in a risk assessment at this time.
The inorganic sample results for the IWO indicated that the constituents of concern were
barium, chromium, copper, mercury, nicltel, silver, and zinc. Table 5-6 summarizes the
results of sampling inorganics in the IWO.
Subsurface soil samples were. also collected from cross-sectional borings. . Only five samples
collected from these borings had slightly elevated metals concentrations. The distribution of
elevated metals concentrations in subsurface soils appears to be restricted to within at least
two, bUt no more than ten feet laterally from the IWO, and primarily within seven feet of below
the elevation of the static water level (BSWL). Occasional elevated concentrations were
observed at depths of between five and 30 feet below ground surface (BGS).
. .
Three areas of the'IWO displayed peak constituent concentrations which were generally
higher than surrounding areas. These "hot spot" areas of the IWO are located near the outfall
(discharge point) in the first 500 feet, . downstream between 3,00(J and 3,300 feet, and
do~nstream betwp.:n 5,500 and 6,500 feet. This appears to be the result 01 a longer period
01 accumulation or metals in the sediments plus the deposition of metal contaminated solids
remobilized by upstream dredging activities.
-------
I Table 5-6 Contaminant Concentrations In IWD Solis In Parts Per Million (ppm)
95% UCl of 95% UCl of 95% UCl of Average Hot Spot from Outfall to 500' Hot Spot from 3000' to Hot Spot from 5500' 10
Mean MeaD Mean of 95% of Average 3300' Average 6500' Average
Constkuent Background Sediment Dredge Pile UCL
(Normal (log Normal (Log Normal Sediment Sed Dredge Comb' Sed Dredge Comb' Sed Dredge Comb'
Distribution) Distribution) Distribution) + Dredge
Pile
Barium 263.61 271.07 234.44 252.76 282.17 218.0 238.26 222.25 238.78 233.69 246.33 325.77 300.68
Total 30.79 102.16 109.99 106.08 91.32 65.22 73.46 53.08 295.87 221.16 58.47 136.28 111.71
Chromium
Hexavalent 1 1 1 1 1 1 1 1 1 1 1 1 1
Chromium2
Copper 27.02 37.96 25.32 31.64 64.43 22.24 35.56 37.963 32.09 33.9 28.38 30.05 29.53
Mercury 0.11 1.84 0.39 1.12 1.28 0.26 0.58 1.844 0.52 0.92 1.80 1.19 1.38
Nickel 36.66 26.21 29.58 27.9 28.57 27.91 28.12 26.213 31.17 29.64 20.93 30.32 27.36
Silver 0.77 1.13 1.00 1.07 1.25 0.78 0.93 0.89 1.18 1.09 0.89 1.29 1.17
Zinc 162.68 156.46 176.06 166.26 130.45 156.07 147.98 156.463 420.43 339.21 112.48 176.69 156.42
..
'The combined averages for the hot spots are the averages of all samples collected in these areas, and: do not equal the
average sediment value + the average dredge pile value/2 shown on this table.
2The method detection limit Is used for hexavalent chromium in soil because of difficulty achieving the analysis time
requirement. See Section 4.5 of the Final RI/FS Report for the IWO for additional information.
. .
3The wrong laboratory analysis number was submitted with the data group in which this sample was Included. The 95% UCL
of mean sediment values Is used for risk calculation purposes. .
4Mercury analysis results from these samples were rejected by the data validator. The 95% UCL for sediment was used for
risk calculations.
-------
The dredge piles did not have areas identified as "hot spots". The total volume of soil in the
dredge piles was estimated to be 2,972.6 cubic meters (104,976 cubic feet). The surface
area of the dredge piles was calculated to be 7,583.7 m3 (81,633 fe).
5.1.b Landfill Units
Geophysical and soil gas surveys were conducted to determine the overall boundaries of the
waste disposal areas, and if they exist, the boundaries of specific trenches in these areas.
Magnetometer surveys were conducted in 8-05-1, 8-05-51, and 8-06-53. Soil gas samples
were analyzed for benzene, ethylbenzene, toluene, xylenes, and 1,1, 1-trichloroethane.
Portable gas detection instruments were also used to monitor for methane, combustible
gases, hydrogen sulfide, and total volatile organic compounds. Surface soil samples were
collected and analyzed for inorganic constituents. A soil gas/vapor surface emissions survey
was conducted over the estimated locations of the trenches as delineated in the
magnetometer survey.
Based on process knowledge, photographs, employee interviews, visual inspection, and
existing analytical data, 8-06-35, 8-06-36, 8-oS-48, 8-oS-49, and 8-0S-50 were determined to
pose no unacceptable risk. -
Surface Soil Gas Emissions Survev
A surface soil gas emissions survey recorded values at. 10 foot intervals between staked grid
locations within zero and six inches of the ground surface. No readings were found above
the ambient air upwind cpncentrations, except where vapors were released from disturbed
vegetation.
Soil gas surveys detected volatile organic compounds (primarily ethylbenzene and xylenes)
which may be associated with solvents at 8-05-1, 8-05-51, and 8-oS-53, and further defined
the boundaries of the landfills. Benzene was not detected in any of the soil gas samples,
and toluene was detected in four samples.
Although there were some positive detections of meta- and para~xylene at 8-05.59, these
results were, in general, only slightly elevated above associated blank samples (and were
considerably lower than the concentrations detected at 8-05-51). This area received a one-
time discharge of 50,000 gallons of waste oil. There is a large amount of uncertainty
associated with the location of the disposal pit, the presence of a building over rnuch of the
suspected site location, the short duration of the disposal period, and the long elapsed time
since the occun:ence 01 the disposal. Modeling was conducted to determine the possible
effect to ground water of a one time release of 50,000 gallons of waste oil containing
hazardous constituents. The results of this modeling showed that concentrations of the
representative compounds would not exceed MCLs. These results are considered
conservative because eyewitness reports indicate that the contents of the pit burned for three
days following.the oil discharge (which should have signifiGantly reduced the source volume).
Soil Samcles Analvzed for Inorganic Constituents
Thirty-two surface soil samples were collected from 8-06-53, and were analyzed for metals.
content. Cadmium, mercury, selenium, and silver were not detected in any of the 32
samples. Arsenic, barium, chromium, and lead were detected in all samples. Some soil
-------
samples from NRF-51 had concentrations of barium and mercury which exceeded the
background Idaho National Engineering Laboratory threshold level.
Maanetometer Surveys
Six small linear anomalies in 8-05-51 were interpreted as possible debris,-filled trenches. A
broad, moderate-sized anomaly zone corresponded with a visible trench approximately 2 to 3
feet deep. A section of the trench was scraped to very shallow bedrock. Another smaller,
moderate anomaly was also associated with a shallow depression. The magnetic survey
over8.oS-53 was successful in identifying possible debris-filled trenches. Six linear anomalies
with various ,orientations were interpreted as representing the exten~- of the trench and fill
activity at 8.oS-53. .
5.2 Ground Water Samples
The NRF water supply has been monitored for physical parameters (conductivity and pH),
radioactivity, chromium, sodium, and chloride from 1980 to tbe present by the United States
Geological Survey' (USGS). The quality of water in all samples was within the Idaho State
regulatory limits; there were no out-of-specification values noted. NRF has monitored the
domestic water system in accordance with Title 1 Chapter 8, Idaho Regulations for Public
Drinking Water Systems, from 1987 through the present. Other data has been collected by
subcontractor personnel. NRF has published the results of analysis of selected parameters in
the annual Naval Reactors Facility Environmental Monitoring Report. Portions from the 1990
and 1991 reports which summarize the results of sampling for those parameters of specific
concern are provided as Table 5-7. Figure 5-3 shows the loc~tion 01 NRF wells 1, 2, 3, 4, 6,
, and 7. Approximate locations and distances of wells downgradient from NRF are: USGS
well 97, 1.0 mile south; well 98, 2.7 miles southwest; well 99, 2.2 miles south; well 102, 0.25
miles west; and INEL-1, 2.5 miles west southwest. Approximate locations and distances of
wells upgradient from NRF are: USGS well 12, 2.5 miles north; well 15, 3.5 miles north; and
well 17, 3 miles northeast.
~
Predicted Ground Water Values
GWSCREEN is a semi-analytical model used for assessment of the ground water pathway
from the surface t~ an underlying aquifer. NRF used this program to assess the impact of a
contaminant release from the sediments associated with the IWD and from the contents of
the landfill. The limiting soil concentration is the soil concentration such that, after leaching
and transport, maximum allowable concentrations in ground water are not exceeded.
Maximum allowable concentrations are based on chemical toxicity, and maximum
contaminant levels (MCLs) as listed in Title 40 Code of Federal Regulations (CFR) 141 and
associated amendments. The concentration in ground water is proportional' to the soil
concentration (excluding solubility limited releases). Table 5-8 provides the maximum
predicted ground water concentration in each Operable Unit and ground water concentration
01 each constituent of concern. . '
-------
Table 5-7 Comparison of Results of Analysis of Selected Ions and Nutrients in NRF Ground Water(a)
Upgred,en'(kl Onsite Monitoring Downgroaient(kt
Standatdl (USGS wen. 12. 15. 171 (NRF Well. 1. 2. 3. 41 (NRF Well. 6. (USGS 97. 98. 99. 102. INEL.
Parameter Units Guideline 71 11
1990 1991 1990. 1991 1991 onlY 1990 1991
Ammc>nla plu. mg/l Icl <0.3 <0.20 <0.3 <0.32 (il <0.3 <0.28
Or".n,c N '" Nl
Bromide mg/l Ic) <:0.02 0.05 :0.02 0.07: 0.01 0.07: 0.01 0.05:0.04 0.11 :0.11 0.11:0.11
Chlorida mg/l 250(bl 18:13 16:11 38:6 41:7.2 110:120 43:38 41 :33
O1romum mg/I O.05(al 0.006:0.003 <0.004 0.01 :0.002 0.010:0.002 0,021 :0.014 0.008:0.003 0.008:0.003
Fluoride mg/l 4.01al <0.2 0.2:0.1 <0.2 0.2 0.2:0.1 <0.2 <0.2
Iron '"9" 0.31bl <0.082 <0.11 <0.055 <0.13 0.33:0.24 <0.274 0.29:0.49
Laad mg/l O.05lel <0.001 <0.001 <0.001 <0.002 <0.001 <0.003 <0.002
Mercury mg/l 0.002(e' <0.0001 <0.0001 <0.0001 <0.0001 < 0.0001 <0.0001 <0.0001
Nickel ,;,g/l Icl <0.001 < 0.001 <0.002 < 0.002 0.011 :0.007 <0.002 < 0.002
Nitrite Ca. NI mg/l Icl <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Nitrite plu. Nit,ete mgll 1010.11 1.0:0.7 0.93 :0.67 1.7:0.2 1.8:0.11 0.94:0.65 2.4:1.7 2.33: 1.52
I.. N\
Nivogen, Ammonia mgll (gl iii <0.01 Iii <0.01 <0.01 ij) <0.21
Organic Carbon. mgll Icl <0.2 0.3:0.1 0.4:0.1 0.6:0.4 0.9:0.3 0.4:0.2 0.4:0.2
T....,
Or1t\ophosp!leto 181 mgJ\ Ic) <0.01 <0.01 <0.02 <0.02 0.03: 0.02 <0.01 <0.01
IPI
pH pH Units 6.S-8.5Ib) 7.9:0.2 8.0:0.2 7.9:0.2 8.0:0.1 8.2:0.4 7.9:0.1 8.0
Silver mgll O.05lel <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001
Sodium mgll 20ldl 10:4 9.':4.1 15:2 14:3.3 49:46 13:3 12:3.1
Specif1c Conductance prMoIcm tcl 425:130 412:131 587:41 592:28 809:648 588:124 583:120-
SuHeto ingIJ 250(bl 25:7 23:7 40:5 43:6 130:130 40:27 33:13
-.
(a)
(b)
Values preceded by < contain at least one less than minimum detection level value in
the analysis results.
Secondary maximum contaminant levels per Title 1, Chapter 8, Idaho Regulations for
Public Drinking yvater Systems are provided for comparison.
No standard or guideline available.
No maximum per Title 1, Chapter 8, Idaho Regulations for Public Drinking Water
Systems. 20 mg/I is suggested as optimum.
Maximum contaminant levels per Title 1, Chapter 8, Idaho Regulations for Public
Drinking Water Systems. . . .
The limit is for Nitrate (As N) only. Since nitrite values are near or below MOL, these
quantities represent Nitrate (As N).
The following parameter values are anomalously high for USGS Well 15 in the 8/6/90
sample: Chromium - 21 Jig/I; Iron - 4600 Jig/I; Manganese - 100 Jig/I; Nickel - 15
(c)
(d)
(e)
(1)
(g)
-------
(h)
(i)
0)
(k)
Jig/I; Organic Carbon, Total - 1.5 Jig/I; Turbidity - 22 NTU. These values are not
included in the values for the upgradient wells.
Anomalously high value of 1400 Jig/I reported for NRF Well 4 in the 6/19/90 sample.
This value is not included in the values for the onsite wells.
Ammonia plus organic nitrogen (as N) was not performed for NRF wells 6 and 7.
Not measured.
Upgradient and downgradient wells are off the map provided by Figure 3.
Table 5-8 GWSCREEN - Predicted Peak Ground Water Concentrations and Umiting Soil Concentrations
for IWD and Landfill Unit Constituents ..
Contaminant IWD' 8-05-1 8.05.51 8.06.53
Predicted Peak Limiting Soil PrediCted Peel< Ljmiting 50il Predicted Peele Limiting Soil Predicted Peak
Ground Wilt. Conc8ntr8tion Ground Wet. Concentrlltion Ground Wilt. Concentration Ground Wilt.
ConC8'ltr8lion (maim'! Concentration (mg/m'1 Concentration (mg/m» Concentr8lion
(mgIU (rnglU CrnglU (mg/U
Barium 43.0 NA NA 2.8 x 10' 2.67 x 10" NA NA
Chromium . J 3.5' 1.3 X 10" 5.87 x 10" NA NA 1.8 x 10" 9.0 X 10"
~ 5.6 NA NA NA NA NA NA
Mercury 0.2 1.8x1e" 3.57 X 10" 2.2 X 10' 1.34 X 10') 1.1 X 10" 5.19 X 10"
Nickel 4..1 NA NA NA NA NA NA
Silv. 0.01 2.7 X 10' 3.6 X 10~ NA NA. 1.82 X 10" 5.15xI0~
Zinc 144 NA NA NA NA NA NA
NA
The constituent was not identified in the waste disposal area
Umiting'soil concentration was not calculated for the IWD because data from
the RifFS was available for risk calculations
2
Umiting soil concentration from GWSCREEN Version 1.5
J.
3
Umiting soil concentration from GWSCREEN Version 2.02
5.3 Shallow Perched Water Table
Shallow perched water was only evaluated in the iWD RifFS. During the summer of 1991,
two deep monitoring wells and 15 shallow piezometer wells were drilled in the vicinity of the
IWD. Six of these wells encountered shallow perched water, and the rest were dry:
Samples were collected from the shallow perched water table and analyzed for the
constituents listed in Appendix VIII of Title 40 Code of Federal Regulations (CFR) Part 261.
Data on background water quality are not available for the shallow perched water. table, but
all volatile and semi-volatile organic analytes were reported at concentrations below Federal
Primary and Secondary drinking water standards, or were interpreted as resulting from
laboratory background influences. Observed concentrations of metals in the shallow perched
water zone were below Federal Primary and Secondary drinking water standards, and may
represent background levels. These data suggest that any impacts from the IWD are minor.
-------
<.
6. SUMMARY OF SITE RISKS
The RemediallnvestigationjFeasibility Study performed on the IWO evaluated the potential
risks for both human health and environmental effects in accordance with the EPA Risk
Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual, Volume II:
Environmental Assessment Manual, and other EPA guidance. The risks associated with the
Landfill Units were evaluated under the Track II Guidance. The Agencies agreed that the
Presumptive Remedy for CERCLA Municipal Landfill Sites was applicable to Operable Units
8-05-1, 8-05-51, and 8-06-53 because they are suspected to contain wastes similar to those
found in municipal landfills. This assumption allows corrective action to be taken without full
characterization of the landfill contents, and therefore, applies available funding to remedial
action, rather than additional investigation. Because the landfill contents were not fully
characterized, assessment of the associated risk presents a large amount of uncertainty.
The Presumptive Remedy relates primarily to containment of the landfill contents and
collection and/or treatment of landfill leachate. Although some of the potential risks
associated with the Landfill Units (8-05-1, -51, and 8-06-53) were evaluated for human health,
(see the Summary Reports for Operable Units 8-05 and 8-06) because the contents of the
units were not sampled, there is a large amount of uncertainty inherent to risk calculations for
these areas. An ecological risk assessment was not conducted for the Landfill Units.
However, the protectiveness of the presumptive remedy chosen for these sites will reduce the
potential risk to ecological receptors, and a detailed ecological risk assessment will be .
conducted in 1he Naval Reactors Facility Comprehensive Remedial Investigation and
Feasibility Study.
6.1 Human Health Risks
Evaluation of human health risk included contaminant identification, exposure assessment,
toxicity assessment, and health risk characterization. The potential contaminants were
identified based on existing inventory records, process knowledge, and initial screening. The
exposure assessments detailed the current and Mure exposure pathways that exist at the
sites for workers and residents. The toxicity assessments documented the adverse effects
that may be caused in an individual as a result of exposure to a site contaminant.
. ~
The human health risk assessment evaluated current and Mure potential carcinogenic and
noncarcinogenic risks associated with expo$ure to the identified contaminants. The risk
assessment used the exposure concentrations and the toxicity data 10 determine hazard
indices for potential noncarcinogenic effects and excess cancer risk levels for potential
carcinogenic contaminants. The chronic hazard index for each constituent and specific
exposure route was quantified as the constituent intake through the exposure route divided
by the corresponding constituent and route-specific reference dose (RID). A chronic hazard
index less than or equal to 1.0 indicates with a high degree of confidence that no adverse
health effects will be experienced by any member of the general population. Hazard indices
greater than 1.0 require further considerations and risk management decisions.
The excess cancer risk is the increase in the probability 01 contracting cancer as a result 01
exposure to hazardous constituents. The carcinogenic risk multiplies each constituent intake
by the route-specific slope factor. The National Oil and Hazardous Substances pollution
Contingency Plan (NCP) acceptable risk range is 1 in 10,000 to 1 in 1,000,000. An excess
lifetime cancer risk of 1 in 10,000 indicates that an individual has up to one chance in 10,000
of developing cancer over a lifetime of exposure to a site-related contaminant. .
-------
6.1.1 Contaminants 01 Potential Concern
".,
6.1.1.a Industrial Waste Ditch
The results of previous investigations and the Remedial Investigation for the Industrial Waste
Ditch indicated that the constituents of concern were barium, chromium, copper, mercury,
nickel, silver, and zinc. Table 6-1 summarizes the analyses results for the IWO. Analyses
results for mercury and chromium had the greatest deviation from the mean background
values, and elevated levels of silver, zinc, copper, and barium were also reported.
Table 6-1 Summary 01 IWD Metals Analysis Results in~arts per Million
(ppm)
Constituent tWD IWD Dredge Piles Dredge Piles NRF IWD NRF tWD
Sediment Sediment Mean 95% UCL Background Ba~ground
Mean 95% UCL Mean 95% UCL
Barium 231.34 271.07 210.32 234.44 240.45 263.61
Total 69.76 102.16 51.33 109.99 28.40 30.79
Chromium
Copper 31.16 37.96 21.24 25.32 24.35 27.02
Lead 9.99 11.21 10.98 11.94 15.94 . 17.89
Mercury 0.74 1.841 0.20 0.39 0.11 0.11
Nickel 21.24 26.21 27.91 29.58 33.68 36.66
Silver 0.91 1.13 0.83 1.00 0.72 0.71
Zinc 120.84 156.46 133.79 176.06 147.32 162.68
Mean
UCL
The arithmetic average of the analysis results
Upper Confidence Level of the mean value
s
6.1.1.b Landfill. Units
The initial scoping of the landfill units reviewed waste generation processes and waste.
disposal records from the time of the landfill operations, sampling evolutions performed
during subsequent construction evaluations, and subsequent records of waste shipments to
the Central Facilities Landfill. Sampling for the Track 2 evaluation focused on the chemicals
of potential concern identified through this data collection and evaluation process, and are
presented in Table 6-2. Because the volume and heterogeneity of landfill contents make
characterization extremely difficult, constituent concentrations in the landfill contents are
assumed, although magnetometer readings were used to better define the boundaries of the
. landfill areas. Surface contents and offgases were directly sampled.
Tetrachloroethylene and 1,1, 1-trichloroethane were detected in 8..()5-1 and 8-05-51, but were
not included in the table because they were also present in control samples. Ethylbenzene
was detected at 8-05-1, and m,p-xylenes and o-xylenes were detected in most of the soil gas
samples from 8-05-1 and 8-05-51. However, because no RIDs are available for the xylenes,
. they are not included in the risk assessment.
21
-------
Barium and mercury exceeded the background upper tolerance limit in soil samples from 8-
0S-51 and chromium exceeded the background upper tolerance limit in one surface soil
sample from 8-06-53. Chromium, mercury, and silver were identified as contaminants of
concern in buried waste in all units, based on historical records of waste streams at NRF.
..
,Table 6-2 Summary 01 Chemicals 01 Potential Concern in Landfill
Units
Chemical Surface Soils Soil Gas Predicted
(mgjkg) (ugjL) Concentration
8-05-1 .,..
Ethylbenzene NS 0.2 - 1.0 NA
m,p-Xylenes NS 0.3 - 5.2 NA
o-Xylene NS 0.3 - 4.8 NA
8-05.51 .
Barium 94.8 - 265 NS NA
Mercury 0.15 - 0.65 NS NA
m,p-Xylenes NS 0.3 - 0.5 NA
o':"Xylene ,NS 0.3 - 0.5 NA
8-06-53
1,1 ,1- Trichloroethane NS 1.25 NA
Tetrachloroethylene NS 1.39 NA
Chromium 21.1 - 72.3 , NS 11.8*
Mercury -NA NS 0.52*
Silver NA NS 4.6*
NA - Not Applicable
NS - Not Sampled
* - Assumed
6.1.2 Exposure Assessment
The potential populations at risk were identified for current and future use scenarios.
Occupational exposures were determined for current and future populations, and residential
exposure was considered for future scenarios. The IWO evaluation included a future
agricultural scenario, 'and the Landfill Units included a recreational scenario. General
assumptions 01 the frequency and duration of exposures were based on both EP A standard
default values and site-specific information. The Risk Assessment Guidance for Superfund
(RAGS) provided many of the default values for inhalation and ingestion rates, and food and
, water consumption. Site-specific information, such as climate and geology, were a,lso used
-------
to determine exposure pathways, and values. The exposure pathways evaluated for the IWD
and the Landfill Units were soil ingestion, dust inhalation, and ground water ingestion. The
IWD assessment also considered dermal exposure to surface soil and surface water, and
ingestion of homegrown fruits and vegetables.
6.1.2.a IWD
The constituent concentrations used in the IWD risk assessment were provided in Table 6-1.
6.1.2.b Exposure Concentrations for Umiting Soil Concentratio~s for Landfill Units
Because non-intrusive sampling was utilized for the Landfill Units, the soil concentrations
required to 'perform risk assessments had a high degree of uncertainty. To ensure that the
potential hazards associated with the area were thoroughly understood, risk-based soil
concentrations for these areas were calculated (Table 6-3). The risk based soil concentration
is that level of a constituent at which it becomes a cause for concern (screening level). The
equations for determining these risk-based soil concentrations are standard EPA equations
for exposure and risk assessment with modifications to calculate a concentration in a
medium at a specific risk level or target level.
6.1.3 Toxicity Assessment
The toxicity assessment data was obtained from the Integrated Risk Information System
(IRIS), the Heath Effects Assessment Summary Tables (HEAST), and other EPA guidance.
Contaminants of concem were evaluated for both carcinogenic effects and noncarcinogenic
effects. The intake of each contaminant for each receptor along each exposure route was
calculated. .
Th.e RID. is the toxicity value used to evaluate noncarcinogenic effects that result from
exposure to chemicals, and is based on the concept that there is a threshold that must be
reached before adverse effects occur. Fqr carcinogenic contaminants, the chemical-specific
slope factor (SF) is the toxicity value used to evaluate potential human carcinogenic effects.
.These toxicity values have been derived based on the concept that for any exposure to a
carcinogenic chemical, there is some risk of a carcinogenic response. The SF is used in a
risk assessment 10r the purpose 01 estimating an upper bound lifetime probability of an
individual developing cancer from the exposure to a specific level of a carcinogen.
6.1.4 Risk Characterization
6.1.4 a. Industrial Waste Ditch
The levels 01 risk associated with background levels of contaminants in soil, air, and ground
water were calculated to provide a comparison for future scenarios. These background
samples were used for both dredge pile and sediment values. Ground water samples
collected from the four NRF domestic water wells by the USGS from 1989 through 1992 were
used to calculate concentrations in ground water~ . .
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Table 6-3 Risk Based Soil Concentrations for Landfill Units
Pathway jUnitjConstituent Occupational Residential
RfD Slope Carcinogen Noncarcinogen Carcinogen Noncarcinogen
Soil IngeStion 5.7 jSF RfD*2E6 O.64jSF RfO*2.7E5
8-oS-1
Cr3 1.00E+OO 2.00E +06 2.70E+05
CrG 5.00E-03 1.00E +04 1.35E+03
Hg 3.00E-04 6.00E +02 8.10E+01
Ag 5.00E-03 1.00E+04 1.35E+03
Ethylbenzene 2.90E-01 5.80E + 05 ..
7.83E+04
8-05-S1
Sa 7.00E-02 1.40E+05 1.89E+04
Hg 3.00E-04 6.ooE +02 8.10E+01
8-06-53
Cr3 1.00E+OO 2.00E +06 2.70E+05
CrG 5.00E-03 1.00E +04 1.35E+03
Hg 3.00E-04 6.00E + 02 8.10E+01
Ag 5.ooE-03 1.00E+04 1.35E +03
1 ,1 ,1- Trichloroethane 5.20E-02 1.04E +05 1.40E+04
Tetrachloroethylene 1.10E+02 2.20E + 08 2.97E +07
Inhalation of Fugitive Dust 1.4E-05*PEF ISF RfD*S.1 *PEF 8.5E-6*PEF ISF. RfD*3.7*PEF
8-oS-1 Particulate Emission Factor = 7.60E+08
CrG 4.10E+01 2.60E + 02 1.58E +02
Hg 8.60E-05 3.33E +05 2.42E+05
8-05-51 particulate Emission Factor = 4.75E+08
Sa 1.ooE-04 ~ 2.42E +05
Hg 8.60E-05 2.08E +05 1.51E+05
..
8-06-53 particulate Emission Factor = 2.11 E + 08
CIS 4.10E+01 7.20E+01 1.58E+02
Hg 8.60E-05 9.25E+04 6.71E+04
Inhalation of Volatiles 1.4E-05*VF ISF RfD*S.1*VF 8.5E-6*VF ISF RfD*3.7*VF
8-05-1 Volatilization Factor for Ethylbenzene Occupational 3.77E +03 Residential 4.19E + 03
Ethylbenzene 2.90E-01 6.20E +03 0.00
8-06-53 Volatization Fador for 1,1,1- Trichloroethane Volatization Factor for Tetrachloroethylene
Occupational1.20E+03 Residential1.32E+03 Occupational 2.90E+03 Residential3.20E+03
1,1, 1-Trichloroethane 3.00E-01 1.84E +03 2.02E +03
Tetrachloroethylene 2.ooE-03 2.03E+01 2.24E +01
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A Baseline Risk Assessment was performed to determine if any unacceptable levels of risk
were associated with the Industrial Waste Ditch. Risk is characterized for human receptors in
four scenarios (current and future occupational, future residential, and future agricultural
receptors), and Table 6-4 summarizes the results of the IWD Baseline Risk Assessment
(BRA). The risk assessment calculated risk for exposure to receptors from the IWD as a
whole, using 95% upper confidence level of the mean soil concentration, and for three areas
of the IWD which may have elevated metals concentrations in comparison to the overall IWD
values ("hot spots") to ensure these calculations were truly protective of human health. The
three hot spot areas are identified as Outfall to 500', 3000' to 3300', and 5500' to 6500'. In
many cases, the risks are probably overestimated due to the conservative nature of the
assumptions. An example is assuming that residents are exposed to airborne constituents
350 days a year.
The risk of cancer in all scenarios, including background, exceeded the threshold value of 1 x
10.6 due to the consideration of inhalation of hexavalent chromium in ground water. Because
01 the lack of sampling data for hexavalent chromium in ground water, the concentration of
hexavalent chromium was considered equal to the total chromium value.
In conclusion, although there may be some health risk associated with the IWD in the future,
the risk is not significant when compared to the background risk, and considering the
conservative nature of the estimate. .
Table 6-4 Sum'mary of Baseline Risk Assessment for the IWD
Current Occupational Future Occupational Future Residential Future Agricultural
Hazard Risk Hazard Risk Hazard Risk Hazard Risk
Background 0.0557 1.65E-06 NA NA 0.749 1.39E-OS 0.796 1.39E-OS
95% UCL 0.057 1.65E-06 0.0696 1.66E-06 1.37 1.4E-OS 1.03 1.4E-OS
Outfall to 500' NA NA NA NA 1.32 1.4E-05 1.16 1.4E-OS
3000' to 3300' NA NA NA NA 1.99 1.4E-OS 2.13 1.4E-OS
5500' to 6500' NA NA NA NA 1.94 1.4E-05 2.23 1.4E-05
,
6.1.4.b Landfill Units
The evaluations performed in the Track 2 investigations of the Landfill Units determined that
there may be an unacceptable risk to future receptors from Landfill Units 8-05-01, -51, and 8-
06-53 based on the results of soil gas surveys, surface soil samples, and records review.
Landfill sites 8.()6-35, 8-06-36, 8-06-48, 8-06-49, and 8-06-50 were evaluated using the existing
data and historical information, and it was determined that these areas were primarily used as
material and equipment staging areas, and there was no unacceptable risk to receptors.
6.1.5 Uncertainties and Umitations
Uncertainties are associated with all estimates 01 cancer and noncancer health hazards.
These uncertainties result from incomplete knowledge of many physical and biological
processes, such as carcinogenesis. Where specific information is not available, it ,is
necessary to make assumptions and/or use predictive models to compensate for lack of
information. The assumptions, models, and calculations are chosen so that the resulting risk
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and hazard estimates are protective of human health. However, these assumptions usually
result in a conservative estimate of risk.
6.1.5.a Industrial Waste Ditch
Residential scenarios assumed that receptors consume homegrown products three meals a
day for 30 years and methylmercury would be present in future scenarios. This is unlikely,
because it does not account for the consumption of commercially prepared food, or for the
difficulty in converting inorganic mercury to methylmercury. The risk assessment also
assumes that the receptor inhales hexavalent chromium during showering, although this is
unlikely, and the toxicity data forthe inhalation of hexavalent chromium is for fumes and
particulates from industrial processes, rather than a residential exposure scenario.
6.1.5.b Landfill Units
The uncertainty associated with the identific;:ation of organic chemicals of potential concern for
this site is considered h,igh. However, since it was assumed ~hat the presumptive remedy for
landfills (EPA, 1993) was going to be used at this site and this would require monitoring,
restrict access, and preventing contact with landfill contents, the source characterization of
additional chemicals of concern was not investigated.' Assumptions included a 50%
reduction in waste volume during incineration, and that metals contamination was equally
distributed throughout the landfill mass. Other uncertainties associated with landfill unit 8-05-
59 were the location of the disposal pit, the presence of a building over much of the
suspected site location, the short duration of the disposal period, and the long elapsed time
since the occurrence of the disposal.
6.2 Environmental Risk A~sessment
6.2.1 Exposure Assessment
6.2.1.a IWD Qualitative Ecological Risk Assessment
J.
The ecological risk assessment qualitatively evaluated the potential ecological effects
associated with the presence of the Industrial Waste Ditch. This investigation was performed
in' accordance with the EPA Risk Assessment Guidance for Superfund Volume II. The
ecological risk assessment identified sensitive nonhuman species, and evaluated many of the
same exposure pathways and contaminants as the human health assessment.
There is no evidence of sensitive plants in the IWO vicinity. The closest occurrence of
sensitive plants to the IWO involves a tree-like Oxytheca COxvtheca dendroides) for which the
population of interest is located approximately six miles south of the IWD outfall, near the
INEL Central Facilities Area (CFA). From the perspective of the ecological assessment
endpoint, the risk posed to sensitive plants by the IWD appears to be negligible.
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The only metals in the soil significantly above background are chromium and mercury. For
sensitive species, such as raptors, to receive significant exposure, metals must be transferred
from the soil to plants, the plants ingested by the small mammals. then the small mammals
consumed by the raptors. The uptake level of chromium and mercury is 15.5 and 3.4
percent, respectively. When the plant is eaten by the small mammal, it will typically transfer
between 5 - 20 percent of the metals content from the plant to the animal. Comparisons
between metal concentrations in plants and algae at the IWO with those of similar species at
the control site at Mud Lake indicate that the IWO does not represent a significantly greater
risk through this segment of the food web than background areas.
The IWO poses no significant risk to sensitive plants at the INEL, since no credible proximity
of these plants to the ditch is known. The risk posed to sensitive animals is also considered
small, but is less well defined, since the animals are mobile. Comparisons between metal
concentrations in IWO plants and in plants from a control area indicate that the IWO is not
responsible for a significantly greater risk through this segment of the food web. Other food
web segments, as well as other exposure pathways, have not been quantified due to lack of
available data.
6.2.1.b Landfill Units
An ecological risk assessment was not performed as part of this evaluation, and ecological
risk will be assessed in the Naval Reactors Facility Comprehensive Remedial Investigation
and Feasibility Study.
7.0 DESCRIPTION OF NO ACTION DECISIONS
On the basis of the results of the human health and ecological risk assessments conducted
for the RIfFS, it was concluded that there are no unacceptable risks associated with the IWD.
Therefore, the DOE has determined that no remedial action is necessary for this site.
In addition, the DOE has determined that no further action is needed for units 8-05-59, 8-06-
35, -36, -48, -49, and -50. On the basis of the Track 2 evaluations, it was determined that no
significant sources of contamination exist at these sites. Consequently, it was decided that
these sites pose no unacceptable risks to receptors, and therefore; no remedial actions are
necessary. .
The EPA approves of these no action decisions, and the IDHW concurs. Both the EPA and
the IDHW have been involved in the development and review of the RIfFS and Track 2
reports, the Proposed Plan, this ROD, and other project activities such as public meetings.
The remainder of this ROD discusses landfill units 8-05-1, -51, and 8-06-53. These three units
may pose unacceptable risks to receptors, and thus require remedial action.
8.0 DESCRIPTION OF ALTERNATIVES
8.1 Remedial Action Objectives
The purpose of remedial action objectives (RAOs) is to set measureable goals for protection
of human health and the environment. RAOs were not developed for the IWD because no
unacceptable risks to human health or the environment were found. RAOs were developed
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for the three Landfill Units (OUs 8-05-1, 8-05-51, and 8-06-53) at which response action will be
taken.
The primary remedial action objective is to contain the landfill contents, minimizing the risk
associated with potential contact of the contents with ground water. The landfill contents
were not sampled or characterized. Consequently, it was difficult to accurately assess the
risk to future receptors. Development of the RAOs was guided by, and consistent with, the
Presumptive Remedy for CERCLA Municipal Landfill Sites. The Presumptive Remedy directs
that containment be accomplished by installing a cover to reduce permeability and imposing
land use restrictions to preserve the cover.
8.2 Summary of Alternatives for Landfill Units
The presumptive remedy for landfills (EPA, 1993) which requires monitoring, restricted
access, and prevention of contact with landfill contents will be used to protect potential
receptors. General Response Actions (GRAs) have been assembled into a set of remedial
action alternatives designed to represent a range of options. The remedial action alternatives
developed include:
Alternative 1: No Action
Alternative 2: Containment with Native Soil Cover
Alternative 3: Containment with Single Barrier Cover
The following descriptions of the remedial action alternatives explain the logic behind the
assembly of GRAs into specific alternatives. .
8.3 Alternative 1: No Action
Alternative 1 is required for consideration by NCP 300.430 (e) (6) as a baseline alternative.
Under this alternative, the landfill contents~ would be left in place. No sampling or r,nonitoring
would be performed for the no action alternative under the Feder~1 Facility Agreement and
Consent Order (FFA/CQ). . .
8.4 Alternative 2: Containment with Native Soil Cover
This alternative involves the containment of landfill contents by covering with a native soil
cover. There are four components of this alternative: obtaining a deed restriction; capping
each landfill area; monitoring; and performing operations and maintenance on each soil
cover. (1) A deed restriction would be obtained for each area, including an additional 50 feet
beyond each landfill boundary to protect the integrity 01 the cover. This would limit the sale
and use of the property. The area would be surveyed and signs would be installed to warn
of the presence of the landfill and potentially contaminated soils. (2)' The landfill areas would
be capped using conventional construction equipment to ensure a native soil cap 24 inches
thick covers the entire landfill area to prevent contact with the contents and minimize the
potential 10r infiltration. The 24 inch thick cover is the minimum landfill cover thickness. The
soil cover would be graded, and natural vegetation planted to stabilize the soil surface,
promote evapotranspiration, and decrease erosion of the soil cover. (3) Soil gas monitoring
would be performed to assess the effectiveness of the cover, and ground water monitoring
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would'be performed to assess these areas and other ,areas at NRF. (4) Periodic inspections
and maintenance would be performed to ensure the integrity ot the landfill cover.
8.5 Alternative 3: Containment with Single Barrier Cover
Alternative 3 includes the same components as Alternative 2 except that the soil cover would
consist of a single barrier cover composed of a 12 inch layer of compacted native soil, a 24
inch clay layer, and at least a 24 inch protective layer of vegetation and native soil.
Conventional construction equipment would be used to cap the landfill. Native vegetation
would be planted to stabilize the soil surface, promote evapotranspiration, and decrease
erosion of the soil cover. '
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Each remedial alternative must be compared according to nine evaluation criteria that serve
as a basis for conducting the analysis of alternatives, and for subsequently selecting an
appropriate remedial action. The evaluation criteria are divided into three categories: (1)
threshold criteria that relate directly to statutory findings and must be satisfied by the chosen
alternative; (2) primary balancing criteria that include long and short term effectiveness, .
implementability, reduction of toxicity, mobility, and volume, and cost; and (3) modifiying
criteria that measure the acceptability of the alternatives to State agencies and the
community. The following sections summarize the evaluation of each remedial alternative
according to these criteria. .
9.1 Threshold Criteria
..
The remedial alternatives were evaluated in relation to the, threshold criteria: overall
protection of human health and the environment, and compliance with ARARs. The theshold
criteria must be met by the remedial alternatives to be considered as potential remedies.
~
9.1.1 Overall Protection 01 Human Health
The remedial alternatives for the Landfill Units were assessed to determine whether they
protect human health and the environment. Protection is determined by assessing whether
the risks associated with each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls.
Alternative 1, the No Action Alternative, would not satisfy the criterion of overall protection of
human health and the environment. Alternative 2, Containment with Native Soil Cover, and
, Alternative 3, Containment with Single Barrier Cover, satisfy the criterion to the degree that
both altematives protect human health by potentially reducing the level of contaminant
migration to the ground water and the release of contaminants to the atmosphere. The
amount of reduction under Alternatives 2 and 3 is unclear because the potential migration of
contaminants may be affected by factors other than moisture infiltration at the surface of the
landfill.
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9.1.2 Compliance with ARARs
The selected remedial action must comply with identified substantive applicable requirements
under Federal and State laws. Remedial actions must also comply with laws and regulations
that are not directly applicable, but do pertain to situations sufficiently similar to those
encountered at the site, so that use of the requirements is well suited to the site. .
Determining compliance with ARARs requires evaluation of the remedial alternatives for
compliance with chemical, location, and action-specific ARARs.
The ARARs for Alternatives 2 and 3 are identified in Tables 11-1 and 11-2. Both Alternatives
meet the identified ARARs through engineering controls and operating procedures. The No
Action alternative for the landfills is for comparative purposes only, and does not comply with
ARARs. ""
9.2 Balancing Criteria
Each alternative that satisfies the threshold criteria is evaluated against the five balancing
criteria. The balancing criteria include: (1) long-term effectiveness and permanence; (2)
reduction of toxicity, mobility, or volume through treatment; (3) short-term effectiveness; (4)
implementability; and (5) cost.
9.2.1 Long-Term Effectiveness and Permanence
This criterion evaluates the long-term effectiveness of the alternatives in maintaining
protection of human health and the environment.
Alternatives 2 and 3 prevent direct contact with contaminated soils, and would reduce the
migration of contaminants from soils and landfill contents to the ground water. The
~Iternatives do not, however, provide permanent treatment. The covers provided under both
alternatives would be equally effective in the long-term with proper maintenance, monitoring,
and land use restrictions. The No Action Alternative provides the lowest level of long-term
effectiveness and permanence because it does not provide recovery or measures to reduce
the migration of contaminants to the ground water. .
9.2.2 Reduction of Toxic~, Mobility, or Volume Through Treatment
This criterion addresses the statutory preference for selecting remedial actions that use
treatment technologies that permanently reduce toxicity, mobility, or volume of the hazardous
substances.
Alternatives 2 and 3 reduce the mobility of contaminants by restricting infiltration of surface"
water through the landfills." The alternatives "do not, however, reduce either the toxicity or
volume of contaminated soils, or treat any of the contaminants. The No Action Alternative
provides no reduction in toxicity I mobility I or volume of the contaminants in the landfill units.
9.2.3 Short-Term Effectiveness
Short-term effectiveness addresses the effects of each alternative during its construction and
implementation phase until remedial action objectives are met. The alternatives are evaluated
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with respect to their effects on human health and the environment during implementation of
the alternative. '
Both Alternative 2 and Alternative 3 will require a significant level of construction activites to
install a cover over the landfill units. Alternative 2 would require less onsite activity than
Alternative 3' and therefore, provides greater short-term effectiveness. The No Action
Alternative ranks the highest under this criterion because it requires no additional onsite
activities, and does n6t result in additional hazards to human'health or the environment.
9.2.4 Implementability
The following three factors must be evaluated under the implementability criterion: (1)
technical feasibility; (2) administrative feasibility; and (3) the availability of services and
materials. '
, Alternatives 2 and 3 are both highly implementable because they use established techniques
and materials. Alternative 2 is considered more implementable because there is less
construction' activity and soils may be available locally.
9.2.5 Cost
Evaluation of project costs requires an estimation of the net present value of capital costs
and operation and maintenance costs. The costs presented are estimates. Actual costs
could vary based on the final design and detailed cost itemization. Table 9-1 presents the
cost estimates for each Alternative.
Table 9-1 Cost Estimate for Alternatives for Landfill Units
Alternative Sample Deed Monitoring Excavation Total Cost4
Collection Restrictions' Well and ($)
and 0 & M ($1 Installation 1 Capping 1
($) ($) ($)
Alternative 1 NA NA NA NA 0
Alternative 2 21,4002 12,000 800,000 813,800 2,004,800
379,0003
Alternative 3 21,4002 12,000 800,000 6,325,000 7,516,000
379,0003
NA
Not Applicable
These are one time only costs to conduct the work in 1994 and would not'
have to be amortized.
2
, . ,
These costs are costs associated for 1994 only, time value of money equations
are used to determine 30 year cost.
This is the life cycle cost for 30 years of operation and 5% discount 'rate.
3
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4
The total cost is an upper-limit cost estimate. The actual costs are expected to
be less than these values, and will be determined during the Remedial
Design/Remedial Action (RD(RA) phase.
9.3 Modifying Criteria
The modifying criteria are used in the final evaluation of remedial alternatives. The two
modifying criteria are state and community acceptance. For both of these criteria, the factors
that are considered include the elements of the alternatives that are supported, the elements
of the alternatives that are not supported, and the elements of the alternatives that have
strong opposition.
9.3.1 State Acceptance
The IDHW concurs with the selected remedial alternative for the Landfill Units as described in
Section 10.0. The IDHW has been involved in the development and review of the RifFS
report, the Proposed Plan, this ROD, and other project activities such as public meetings.
Comments received from IDHW were incorporated into these documents, which have been
issued with IDHW concurrence.
9.3.2 Community Acceptance
This assessment evaluates the general community response to the proposed alternatives
presented in the Proposed Plan. Specific comments are addressed in the Responsiveness
Summary (Appendix A) of this document.
10.0 SELECTED REMEDY
Th6 results of the investigations of OU 8-05-1, 8-05-51, and 8-06-53 show that these sites are
not fully characterized, and that some future unacceptable risk may exist due to the migration
of potential contaminants from the landfills to the Snake River Plain Aquifer, and from
intrusion into the landfill contents. The selected remedy for these Operable Units will include -
the installation of a native soil cover designed to incorporate erosion control measures to
reduce the effects from rain and wind. The selected remedy provides for maintenance of the
landfill covers, including subsidence correction and erosion control. Monitoring of the
landfills will include sampling of soil gas to assess the effectiveness of the cover, and
sampling ttie ground water to evaluate these areas and other areas at NRF using risk.based
concentrations. The Agencies will continue to review this action within five years and at least
every fIVe years thereafter. Institutional controls (access/land use restrictions, controlling
public access, posting signs, and erecting and maintaining barriers) will be implemented to .
prevent direct exposure to the landfill contents. Snort.term risks will be evaluated and
minimized during implementation of the. selected remedy.
. .
The selected remedy provides a barrier against direct contact, restrictions on access and
land use, and early detection of potential contaminant migration.
The remediation goals for the landfill areas were developed in accordance with the RifFS
CERCLA Landfill Guidance (EPA 1991). These. goals include preventing direct contact with
landfill contents, and meeting all. ARARs.
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11. STATUTORY DETERMINATION
Remedy selection is based on CERCLA, as amended by SARA, and the regulations
contained in the NCP. All remedies must meet the threshold criteria established in the NCP:
protection of human health and the environment, and compliance with ARARs. CERCLA also
requires that the remedy use permanent solutions and altemative treatment technologies to
the maximum extent practicable, and that the implemented action must be cost-effective.
Finally, the statute includes a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of hazardous wastes as their
principal element. The following sections discuss how the selected remedy meets these
statutory requirements.
11.1 Protection 01 Human Health and the Environment
As described in Section 10, the selected remedy satisfies the criterion of overall protection of
human health and the environment by minimizing the risk of potential contaminant migration
to ground water and by preventing direct contact with the landfill waste materials. The
remedy will ensure that cumulative risks are maintained within the NCP risk range.
11.2 Compliance with ARARs
The selected remedy of containment with a native soil cover with vegetation will be designed
to meet all ARARs of Federal and State regulations. The ARARs that will be achieved by the
selected alternative are described in Sections 10.2.1 and 10.2.2.
11.2.1 Chemical-Specific
No 'chemical-specific ARARs are identified for the selected remedy.
The future concentrations of inorganic contaminants in the groundwater are predicted to be
below the risk-based concentrations as determined by the GWSCREEN modeling program.
However, due to the'uncertainty regarding the source term (regarding both organic and
inorganic constituents), long-term monitoring of the ground water and landfill soil gas would.
provide .early indications if migration of contaminants occurs. The soil over the landfills does
not exceed any known soil contamination standards.
11.2.2 Action-Specific
The selected remedy triggers the applicable or relevant and appropriate action-specific
. requirements listed in Table 11-1. Although 40 CFR 258 is also appropriate for the Landfill
Units, the more rigorous requirements for Hazardous Waste Management Units were selected
in this instance due to the uncertainty in the types of wastes disposed.
11.2.3 Location-Specific
The selected remedy will trigger ARARs under the Archeological Resources Protection Act,
Archeological and Historic Preservation Act, and Preservation of American Antiquities Act.
These acts are applicable to the remedy since the cultural resources must be protected if
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additional native soil1rom another site is needed 10r the installation of caps on the landfills.
Table 11-3 provides a description of the pertinent ARARs.
Table 11-1 Federal and State Action-Specific ARARS for Landfill Units
Regulation Title Category
40 CFR 264.310 (RCRA Closure and Post-Closure Care Relevant and
Subtitle C) Appropriate
IDAPA 16.01.05.008 Closure and Post-Closure Care Relevant and
.,. Appropriate
IDAPA 16.01.01.650 - Rules for Control of Fugitive Dust Applicable
01651 and General Rules
Table 11-2 Federal and State Location-Specific ARARS for Landfill
Units
Regulation Title Category
36 CFR 800 Protection of Historic and Applicable
Cultural Properties
43 CFR 7 Protection 01 Applicable
Archeological Resources
11.2.4 To-be-Considered Guidance
In implementing the selected remedy, the~gencies have agreed to consider a number of
procedures or guidance documents that are not legally binding. The follo~ing list of
documents are to be considered as guidance documents:
OSWER9234.2-04FS, October 1989, "RCRA ARARs: Focus on Closure
Requirements";.
OSWER 9476.00-1, September 1982, "Evaluating Cover Systems for Solid and
Hazardous Waste" (Revised).
These OSWER directives provide additional guidance on the design specifications for
constructing and maintaining a cover system.
11.3 Cost Effectiveness
The selected remedial action is cost effective because it is protective of human health and the
environment, achieves ARARS, and its effectiveness in meeting the remedial objectives is
proportional to its costs. .
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11.4
Use of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective marmer. In accordance with the
EPA's Presumptive Remedy for CERCLA Municipal Landfill Sites, the selected remedy
provides protection by minimizing the risk of contaminant migration to the aquifer and limiting
access to the landfill contents. Presumptive remedies, such as the containment remedy
selected for the landfill units, are based on historical patterns of remedy selection and
scientific and engineering evaluation of performance data on technology implementation at
similar sites.
Implementation of the selected cover remedy will reduce the mobility of hazardous
substances, polilutants, and contaminants from the landfill units to the aquifer. The selected
cover remedy does not employ alternative treatmOent or resource recovery technologies. The
use of alternative treatment technologies was determined to be impracticable due to the
availability and applicability of a presumptive remedy. .
11.5 Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a principal element will not be
met. Extraction and treatment of the landfill contents is not considered a cost effective
means of reducing the risks to human health and the environment. The identified risks will
be reduced to acceptable levels by implementing the presumptive remedy. That remedy,
which includes containment, monitoring, and land use controls, is based on historical
patterns 01 effective risk reduction.
12. DOCUMENTATION OF SIGNIFICANT CHANGES.
No significant changes have been made from the recommendations presented in the
Proposed Plan.
~
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APPENDIX A: RESPONSIVENESS SUMMARY
I.
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RESPONSIVENESS SUMMARY
Overview
A Remedial Investigation of the Naval Reactors Facility Industrial Waste Ditch (Operable Unit
8-07) was performed due to known discharges of waste water containing .organic and
inorganic constituents. Track 2 investigations were performed on nine suspected historical
landfill areas (Operable Units 8-05 and 8-06) based on past disposal practices of wastes
similar to those found in municipal landfills. The Proposed Plan was released to the public
on April 9, 1994, with a comment period from April 12 to May 12, 1994. The Proposed Plan
summarized remedial action alternatives for the two different types of investigations and was
the first to include Track 2 investigations for public comment. The agencies determined that
each Track 2 site would need to be presented in a Proposed Plan in order to formalize
decisions on Track 2 sites. . Agency representatives proposed no action for the Industrial
Waste Ditch and, based upon cleanup remedies used at similar sites, recommended
containment of three historical landfill areas.
This Responsiveness Summary recaps and responds to the c.omments received during the
comment period. In general, comments supported the selected alternatives. Several
com mentors offered suggestions on cleanup methods for the Track 2 investigations to be
considered during the remedial design phase. A few comments opposed implementation of
the preferred remedial alternatives, but supported an. action of some type. Written comments
were submitted in writing during the comment period and verbal comments were received
during public meetings held the week of April 18, 1994.
Community Involvement Highlights
Informative Publications
The March issue of the INEL Reporter contained an events calendar highlighting public
involvement activities scheduled for the Naval Reactors Facility.
The INEL Citizens Guide to Environmenta/~Restoration at the INEL contained updates on
projects at the Naval Reactors Facility and was distributed on April 9, 1994 to 7,500 citizens. -
An informative update on the investigations completed at the Naval Reactors Facility was
provided through an update fact sheet on both the Industrial Waste Ditch and landfill projects.
The fad sheets were distributed to approximately 7,500 citizens via the INEL Community
Relations Plan mailing list on March 17, 1994, and conveyed general information concerning
public involvement opportunities.
In March 1994, the INEL News, a newspaper distributed to all employees, published an article
concerning the Naval Reactors Facility Proposed Plan and associated public meetings.
Notice of Availabilitv
The first public informational meetings ever held concerning environmental restoration
investigations performed at the Naval Reactors Facility were announced in a Notice of
Availability display ad. Display ads were published in eight major Idaho newspapers between
March 15 and March 23, 1994: the Post Register in Idaho Falls, Idaho State Journal in
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Pocatello, South Idaho Press in Burley, Times News in Twin Falls, Idaho Statesman in Boise,
Idaho Press Tribune in Nampa, Lewiston Morning Tribune in Lewiston, and The Daily News in
Moscow. Personal telephone calls were made to key individual stakeholders. environmental
groups, and community organizations from INEL regional offices in Pocatello, Twin Falls,
Boise, and Moscow.
Press Release
During the week of March 27, 1994, a press release regarding the Naval Reactors Facility
public meetings and general information on the investigations was released to approximately
40 media c.enters for dissemination to the public. Also during this time, an electronic mail
press release was sent to INEL employees. ,.
Information Sessions IBriefinas
Prior to holding the public meetings, information sessions were held at the Pine Ridge Mall in
Pocatello on .April 12, 1994, from 10 .a.m. to 9 p.m., and the lNEL regional office in Twin Falls
on April 14, 1994, from 10 a.m. to 7 p.m. Representatives from the Department of Energy I
Environmental Protection Agency Region 10, and Idaho Department of Health and Welfare
attended these events to discuss the project and answer questions. On April 13, 1994,
agency representatives conducted a technical briefing via a teleconference call with members
of the League of Woman Voters in Moscow and the Environmental Defense Institute. .
The Community Relations Plan coordinator and INEL Twin Falls regional office personnel
participated in two radio talk shows; talk shows were broadcast from Burley on April 13th and
from Jerome on April 14, 1994. Topics covered during the radio shows included information
on the public meetings, how the public could obtain information on the projects, locations of .
the 10caiiNEL regional office, and other upcoming public involvement opportunities.
Newspaper and radio advertisements regarding the information sessions at Pocatello and
Twin Falls were run during the week of April 10, 1994. Advertisements were placed in two
local newspapers and radio advertisements were broadcast by SIX local stations in both
Pocatello, Burley and Twin Falls for three .tdays - five times a day at each station.
Public Meetinas
Public meetings on the Naval Reactors Facility Industrial Waste Ditch and historical landfill
areas were held in Idaho Falls on April 18, Boise on April 20, and in Moscow on April 21,
1994. A total of 83 people attended the public meetings. Display sessions were held at all
locations from 10 a.m. to 9 p.m., and informal discussion periods preceded each public
meeting. Representatives from the Department of Energy, Environmental Protection Agency
Region 10. and Idaho Department of Health and Welfare attended the meetings to discuss
the project and answer questions. Project managers were also available to answer questions
or provide detailed information during the informal discussion periods as well as during the
public meetings. Each public meeting was recorded by a court reporter.
Newspaper advertisements regarding the public meetings were placed in one local
newspaper in Boise, Moscow, and Idaho Falls the week of April 18, 1994. Radio
advertisements were also run by nine local radio stations in Boise, Moscow, and Idaho Falls
during the week of April 18, 1994 for three days - five times a day at each station.
-------
Public Comment Period
The public comment period on the Proposed Plan for the Naval Reactors Facility was held
from April 12 to May 12, 1994. No requests to extend the public comment period were
received. A total of nine written comments and six verbal comments were received during
the comment period for both projects presented in the Naval Reactors Facility proposed plan.
No oral comments were received during the information sessions in Pocatello and Twin Falls.
This Responsiveness Summary has been prepared as part of the Record of Decision. All oral
comments, as given at the public meetings, and all written comments, as submitted, are
repeated verbatim. If appropriate,. individual comments have been further broken. down and
categorized in order for DOE to address specific issues raised by each commentor. A
matrix is provided that associates the numbered comment in the ReSponsiveness Summary
. to the commentor. The Department of Energy has provided a response to each comment
and or issue raised by the commentors. If the comment impacted the agencies' decision
outlined in the Record of Decision, this fact is highlighted and impacts are identified.
The Naval Reactors Facility Record of Decision presents the No Action alternative for the
Industrial Waste Ditch, the presumptive remedy of containmef'!t for three landfill areas, and
No Action for six landfill areas. The decisions meet and satisfy the intent of the
Comprehensive Environmental Response, Compensation, and Uability Act, as amended by
the Superfund Amendments and Reauthorization Act. The decision for these projects is .
based on information contained in the Administrative Record. .
Copies of the proposed plan and the entire Administrative Record are available to the public
in six regionallNEL information repositories: the INEL Technical Ubrary in Idaho Falls;
University of Idaho Ubrary in Moscow; Shoshone-Bannock Ubrary in Fort Hall; and INEL
regional offices located in Pocatello, Twin Falls, and Boise.
~
-------
Summary 01 Comments Received During Public Comment Period
Comments on both the Naval Reactors Facility Industrial Waste Ditch and Landfill Units
submitted during the entire comment period are addressed and categorized in separate
sections below. Responses address issues pertinent to the IWO and Landfill Units.
Alpha/numerical characters contained in brackets after the comment relate the comment to
the commentor in the matrix provided in Appendix B.
Naval Reactors Facility Industrial Waste Ditch
General Comments on Procosed Alternatives
General Backaround Information on the Naval Reactors Facilitv
1.
Comment:
The way these systems operate is that when you put water in the ditch,
most of it seeps in the ground. A little bit evaporates, usually 10
percent or less evaporated. Most 01 it infiltrates into the ground, goes
down through the sand, gravel, silt, and clay down to the top of the.
basalt.
..
And while basalt in itself is highly permeable, some of the most
permeable rocks any where in the country, the top of the basalt usually
. spreads the water out, contrary to your drawing which was incorrect. .
But it spreads the water out, and the. perched water is above the basalt,
not in the top of the basalt. .
It spreads it out, which is a really good system because the sediments,
as the water moves through, removes a lot of the contaminants. . And
then spreads out and seeps down in much smaller quantities and then
can be perched on other sediment beds within the basait beds. And
each one of these' helps remove contaminants. And so the system has
a lot of natural cleanup just during the operation of it. .
And the fact that the aquifer is like 365 feet below there is a long way
with a lot of these processes to attenuate the waste. And then the
monitoring we have, done over the past 30 years in' the Snake River
Plain Aquifer below Naval Reactors Facility has o~ly shown 'plumes of
sodium and chloride principally and a little bit of nitrate at times, so it
doesn't show any of the heavy metals. And so the system has
operated over the years, you already have the conclusion that there's
not many contaminants going down. (T-13)
And I carried a deal in the legislature this year that to my knowledge is
the first in Idaho that introduces the fact that risk is a very viable thing in
looking. at any contaminants. We'll never be able to afford to clean up
all the waste to what Lewi.s and Clark would have found had they drilled
-------
Response:
2.
Comment:
Response:
a well there. But we need to spend our money wisely and aiways factor
in what is the risk to humans with these contaminants. (T-14)
And so I strongly support the No Action alternative with the waste ditch.
And then when NRF is ever closed, I would use some native materials
and fill it in. (T-19)
The agencies appreciate the time and effort that the commentor took to
evaluate the material, attend the presentations, and provide comments
on the information. Visual aids used in future presentations will be
reviewed in detail to ensure that they are more representative of actual
conditions. ,.
Risk Assessment
Wht!e the hazard index ratings of 1.2 and 1.3 are, indicative of risk if
fruits and vegetables, etc., are grown in the area and persons
consumed these materials. The probability of this means of uptake is
extremely small due to the arid climatic conditions which render this
area unsuitable for farming and due to the fact that access is controlled.
Previous irrigation attempts under the Powell project in 1907 also
showed insufficient water reserves for surface i'rrigation of the tract of
land that is involved.
I am concerned however that the tack taken by the Environmental'
Protection Agency is overly conservative and costly in that they have
considered the associated risks based on methyl mercury (an organic
form of mercuric compound frequently found in grain treatment as a
fungicide and rodenticide). While this is a hazardous material, it, is not
the form of mercury that is involved in the NRF ditch. There are many
areas in the western~ United States where mining activities have
,contaminated soils with non-organic forms of mercury. Elemental
mercury or nitrated forms such as found in the ditch. should have the
risks applied which are applicable to their type as opposed to using a
non-related methyl mercury. When one looks at the broad overview of
the many mining sites, which may require cleanup, the utilization of
incorrect compounds in the figuring of associated risk factors co.uld
translate into excessive costs. When this is multiplied by many
locations it demonstrates a callous lack of prudence and fiscal
responsibility towards the taxpayers. (W-125)
The species of mercury was not identified in the laboratory analysis.
The methylmercury form was used for risk assessment purposes for
two reasons; microorganisms in an aquatic environment can transform
inorganic mercury to methylmercury, and the risk assessment process
is conservative by nature. The uncertainties of the calculations were
presented in Section 6.5 of the Remedial Investigation report and were
used by risk managers to reach the no further action decision. The
EPA guidance provides a process for obtaining toxicological information
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5.
3.
Comment:
Response:
4.
Comment:
Response:
Comment:
on substances. such as inorganic mercury, when information is not
available in the published sources. If the risk calculations had shown
an unacceptable risk, then the uncertainty and conservatism could have
been reduced with more specific information. However, unacceptable
risks were not shown using the cons.ervative assumptions. Therefore,
further refinement of the species of mercury present was not necessary.
oJ'
Assessment and planning seem exceptionally thorough and well done.
Too much reliance on computer modeling, unless assumptions and
technical basis are periodically reevaluated based on actual physical
inspection, can be very misleading and result in gross error either way.
(W-BS)
The commentor is correct that modeling alone should not be used.
Modeling is used to standardize assessments and predict future
impacts from potential releases. Th~ selected remedy includes actual
monitoring and periodic evaluations (every five years) of landfill remedial
actions to ensure early detection of any potential migration of
contaminants and periodically assess modeling results.
No Action Recommendation
As far as the ditch project goes, I would much rather see a lined
evaporation pond being used for on-site discharges, because I don't
have...! would not like to see continued washing leachate migration of
those contaminants that are already in that ditch and the possibility of
introducing more contaminants into the ditch. (T-M1)
Field investigations indicate that there is little leaching occurring at this
time, and the Base1ine Risk Assessment determined that there are no
unacceptable risks. The agencies have determined that the low
potential for migration does not warrant the need for additional action.
Additionally, the shut down of two of the three prototype plants has
significantly. reduced the volume of water discharged to the Industrial
Waste Ditch because most of the discharge was cooling water from the
prototype plants. The planned shut down of the remaining prototype
plant will further reduce the discharge.
I'd like to .come back to the industrial waste ditch and the no treatment
recommendation. I'm still struggling with the implied~..or assertation
that it's okay to have continued six million gallons per year or whatever,
which presumably would consist largely of site runoff and so on,
continuing to go through this area. To me, I guess, I'd have to know a
little bit more about the costs involved if possibly relocating where the
site runoff could go versus leaving it here. If it costs a few thousand.
dollars to relocate it, why not relocate it versus--you know, if it costs a
million dollars to relocate it so it no longer runs through the polluted
ditch, why, that's a different story. 50 I guess it's a question of what the
-------
Response:
6.
Comment:
Response:
geography is and what it would cost to convince the runoff to go
somewhere else. (T-M7)
The NRF site drainage flows naturally to .the northwest corner, which is
the outfall of the Industrial Waste Ditch. In order to relocate site run off,
a new run off collection system would be required which would include
excavation and installation of at least 2,000 feet of piping and several lift
stations. Creation of a new discharge point would cost in excess of $1
million. Because the Remedial Investigation showed that contaminant
. levels are only slightly above background levels, and the risk
assessment determined that there is no significant health or
environmental risk present, these additional costs would not be justified.
. Four comments (three written and one verbal) agreed with the No
Action Alternative for the NRF Industrial Waste Ditch. (W-18, W-B10; W-
111, T-112)
The Agencies appreciate the time and effort that the com mentors took
to evaluate the material, attend the presentations, and provide
comments on the information. .
Naval Reactors Facility Landfill Units
..
7.
Comment:
General Comments to Procosed Alternatives
Several years ago DOE-ID created a large gravel pit about a mile north
of NRF along the road way to Test Area North. It is located just beyond
the Big Lost River bridge on the west side of the road as one heads
north. Gravel mining stopped as the lacustrine clay layers of the
Ancient Lake Terreton were.encountered. The utilization of the same pit -
for the cover of the landfills serves several purposes:
1.
It avoids natural surface disturbance of additional areas of the
site, hence larger amounts of.forage and native grasses would
remain for wild life. Environmental impact for this area has
already been determined and money could be saved by reuse of
this same area. .
2.
It provides a short haul path for materials to NRF thereby saving
tax dollars.. I would estimate that it could be accomplished
. within the $2 million budget estimate of option #2.
3.
It provides a clay .and silt content greater than native soils which
tend to be largely alluvial gravels and loess type materials. This
would improve the impervious nature of the cap.
-------
Response:
4.
The final closure of the pit could be done with a ponion of the
clay materials and thereby sealing the bottom of the pit. This
would transform a dry pit into a water storage reservoir adjacent
to the Big Lost River.
During high-water years when there is flow in the Big Lost River the
gravel pit basin could be filled and provide a 20 to 25-foot-deep pond.
While the INEL area near NRF area has about an 8 to 9-inch annual
rainfall, the .evaporation rate is about 3 to 4 times that amount, resulting
in a net evaporation loss of about 2 feet per year. A pond this deep
could provide a wetland environment for migrating waterfowl and a
watering hole for wildlife. With the depth crea1ed, it could provide water
carry-over for several years. Some funding offset may be available
under wetland improvement programs or Idaho state wildlife habitat
improvement programs.
With the downsizing of NRF and the reduced flows of sewage to the
lagoons, and reduced industrial waste ditch flows, the availability of the
ditch for wildlife watering will diminish. .Remediation of the gravel pit to
a pond could provide the needed transitional establishment of another
water source.
Currently, the state of Idaho is paying deprivation money to the farmers
to the north as antelope and other wildlife seek forage and water on
farmers irrigated acreages. This is largely caused by OOE-IO rerouting
01 the Big Lost River to diversion areas near the Big Southern Butte.
Upstream irrigation uses of the water have also contributed to the loss
of this traditional water source for wildlife. Nowadays water seldom
flows to the traditional "sink" areas 01 the playas where the wildlife have
migrated for centuries.
By using this pit I 1eel that the following can be accomplished:
a.
b.
c.
d.
Costs could pe controlled
An improved product could be delivered
Another dry hole in the desert will not be formed.
It provides the DOE the opportunity to finally do something
positive for the environment. (W-113)
The gravel pit described in the comment will be considered as a source
of material during the engineering evaluation and design of the landfill
covers. The landfill covers will consist of native soil, and the limiting
factor is the permeability 01 the cover material. The' primary purposes
of the cover are to prevent direct contact with the landfill contents, and
reduce infiltration, which can be effectively done with native soil. if soil
which meets the design criteria at a minimum cost can be found closer
to the landfill. areas than the referenced gravel pit, it will be used as the
lanclfillcover. Other cost factors include excavation, transportation,
contouring, compaction, and revegetation. Although the creation of a
pond may improve the wildlife habitat in the area, it is unfortunately
outside the scope of this remedial action. The commentors's
A-8
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8.
Comment:
Response:
9.
Comment:
Response:
suggestion will be shared with the INEL organizations responsible for
evaluating wildlife habitat.
As far as the characterization, that is, the self-characterization of the
constituents in the landfills, I'm real dubious of that particularly within
the context of what's going on right now when the Navy has refused for
nearly two years to release its worker exposure and dosimetry records
to the National Centers for Disease Control that's conducting the
dossier construction study of workers on the INEL site and also
effective off-site populations. You know, when the Navy is pulling
stunts like that and refusing to release those records for those kinds of
studies, I'm a little bit concerned when there's"not an independent
assessment of some of those records of material that may have gone
into those landfill sites. That's it. (T-M14)
The Agencies. acknowledge that the contents of the landfill areas are
not fully characterized. Available historical information was used to
estimate the landfill contents. However, because of the uncertainties
involved, the agencies support the selected remedy I which includes
monitoring. The full characterization of a heterogenous source such as
that found in municipal landfills is a costly and difficult process. As
stated in the Investigation Reports, Feasibility Study, and the Record of
Decision, the Agencies believe that Government funds are better spent
on remedial actions rather than further characterization. The selected
remedy is designed to control and monitor any releases from the sites.
Regarding the Naval Reactors Facility Industrial Waste Ditch and landfill .
areas, I have read the three remedial alternatives and I recommend
none of the alternatives be used. Too much risk in assuming one of
the alternatives could be successful.
).
Use the same logic as used in the disposal of underground storage
gasoline tanks (this portion of statement was unreadable due to
damage to the response form in themail)...ByEPAandAIL.by1998.
There will be no deviation, no changes, regardless. The same
decisions should be used on landfill units.
The Federal Government caused the problem, they should replace the
land like it was originally. (W-118) .
The methodology used for the assessment of the NRF Landfill Units is
the Presumptive Remedy for CERCLA Municipal Landfill Sites. This
method of capping and monitoring landfill sites has been demonstrated
across the country in a variety of settings to be protective of the
environment. The Agencies' expectation was that containment
technologies generally would be appropriate for municipal landfill waste
because the volume and heterogeneity of the waste generally make
treatment impracticable. On the other hand, petroleum products are
generally liquid, and leave a homogeneous waste pattern in the soil.
-------
10.
Comment:
Response:
11.
Comment:
Response:
12.
Comment:
Response:
The investigation techniques, the remediation technoiogies. and the
risks associateo with these tWO types of remediation sites are
significantly different, and are not readily comparable.
But my thoughts about the landfills kept coming back that there are
much worse sites in the U.S. that need to be cleaned up and are right
now a threat to drinking water supplies of a larger population. This
problem of potential contamination after 30 years of being there doesn't
appear to be an emergency whereas 82 million - the proposed
expenditure - could be used better elsewhere. (W-M19)
The Agencies agree that the funding for aggressive remediation should
be used for high priority sites. We have evaluated the potential risk.
associated with these sites in comparison to other remediation projects
on the INEL Since these areas are not fully characterized, there are
uncertainties regarding the site risk. To reduce these uncertainties
would cost nearly as much as the selected alternative. Therefore, the
Agencies believe that this level of funding is appr6priate for this project.
Capping the landfills and monitoring is a reasonable action to
compensate for the uncertainties, and yet be protective of human health
and the environment.
Agree with INEL preferred alternatives. Suggest that landfill areas be
treated even more conservatively, if possible, Le., higher integrity "cap"
and frequent monitoring to assure contamination has not spread. Paint
waste contains high levels of lead and other hazardous components;
other industrial chemicals could have included VOCs which may move
more rapidly than anticipated. (W-B20)
The primary purpos~s of a soil cover are twofold: (1) prevent direct
contact by personnel with the landfill contents, and (2) reduce
infiltration. Based on the low precipitation and infiltration in this area,
the installation 01 a clay cover would not provide enough additional
benefit to warrant the additional expense. Monitoring will be performed
to provide early detection of any potential contaminant migration.
On the landfills, I did mention the bio-barrier, and the very best landfill
at all is something that has a geomembrane and then about six feet of
material on it so that the -- and the gravel soil cover for burrowing
animals so that the water can infiltrate the cap, be held at.a time until
evaporation removes all the water, and you actually can-- and that's
how caliche is formed. So you actually make the soil cover less
permeable with time by natural processes. (f-121)
The exact- design of the soil cap will be determined by an engineering
evaluation during the remedial design stage. This comment will be
considered when the final design specifications are determined.
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13.
Comment:
Response:
14.
Comment:
Response:
15.
Comment:
Response:
Risk Assessment
I didn't see any results of a baseline risk assessment for alternative 2
and 3 considered for landfill areas. Was there any performed? (W-15)
Due to the incomplete characterization of these sites, a quantitative
baseline risk assessment was not possible. The Agencies applied the
presumptive remedy process to these areas to reduce the overall cost
of the project and still implement the appropriate remedial action. No
baseline risk assessment was performed. The qualitative risk
calculations are provided in the Summary Assessment reports, and
show there is no significant risk to human health.
... in my judgement, the amount of risk from the contaminants in the
landfills and the relatively small amount of water infiltrating is never
going to be an insult to the aquifer. So. I really support your preferred
alternative on that: on the landfills.
And again, I think your analysis is very good... basically because it
confirms my preconceived notion. (T-116)
The agencies appreciate the time and effort that the commentor took to
evaluate the material, attend the presentations, and provide comments
on the information.
Landfill Units Alternative #1. No Action
Gentlemen, again, given an un-pressured choice, it would make more
sense to apply alternative 1, No Action. It is doubtful there would ever
be an occasion to build homes and playgrounds over that site in three -
or four lifetimes. When we become serious about spending tax money
the above would apply. (W-T22)
[Having said that,] the only alternative would be alternative 2, which
should be more than adequate to meet the criteria 01 the Nuke Kooks.
We see the day when our government will be bankrupt. Then what
alternative will "you apply? (W-T24) .
The Agencies rejected Alternative One (No Action) because these areas
were not fully characterized, and the cost to support a No Action
"rlecision would be prohibitive. Alternative One has no provision to
restrict access to these areas. Although it may appear unlikely that
these areas will be used for residential purposes, it is possible. The
Agencies believed that the cost 01 Alternative Two is reasonable for the
protection it will provide to public health and the environment.
-------
16.
Comment:
Response:
17.
Comment:
Response:
Landfill Alternative #2. Containment with Native Soil Cover
I do not agree that a $2,026,000 expense is warranted for the landfill
operable units. With finite funds available and the minuscule risk of
. these landfill units, it would appear that an inexpensive 30-year
"monitoring only" program would be satisfactory. If there has been so
little migration of contaminants that some landfill units can't even be
found after 30 to 40 years, it is a waste of resources to do more than
monitor (call it Alternative 1).
With either alternative 2 or 3, monitoring coul~ show the need for more
action after 30 years. 00 the same with alternate 1 and save millions of
dollars to attack the problems that can use additional resources.
(W-123)
Currently, the landfill areas are unevenly covered and debris is present
on the surface in some places. This condition does not reduce the
potential for wind erosion, infiltration by rain or snowmelt, and does not
minimize the potential migration of leachate to the aquifer. Although
there is no current evidence that migration has occurred, this remedy is
not protective of the environment.
The installation of the soil cover is only a small portion of the cost to
implement this action. The installation of monitoring wells and the long
term analysis of water samples make up the majority of the cost. The
Agencies believe that the cost to install the cover is reasonable and
worthwhile for the added protection achieved.
The Agencies concur that Alternative 2 is the best choice.
At the public prese~tation, I noted that the proposed native soil cover
(option #2) is the proposed method of capping the landfill areas.
Option #3, which was over 3 timeS more costly would include an
engineered soil covering with clay to prevent the infiltration of water
through the cap.
I support the proposed action of capping, however, I feel that a
combination of these two options could be accomplished in a
reasonably easy manner. (W-125) (See comment W-113 for complete
comment) .
Alternative 2 will prevent contact with the landfill contents, and use of
native soil will cost less than any combination of soil with clay. In an
arid climate, such as that present at the INEL, leaching is not as great a
concern as it would be in other areas, and the additional cost would not
result in any additional benefit. .
-------
18.
Comment:
Response:
19.
Comment:
Response:
20.
Comment:
Response:
21.
Comment:
Landfill Alternative #3. Containment with Sinale Barrier Cover
Two or more of the audience and a respected engineer with much
experience differed regarding whether or not the impervious layer
should be installed over the municipal waste. The impervious layer is
vital and might be as presented the preferred choice (#3 - at some $32
million) but less costly and more effective in the long run than choice
#2 (about $12 Million). (VV-B26)
The Agencies have determined that a native soil cover is adequate to
prevent direct contact with the landfill contents; in an arid climate, use
of an impervious layer does not necessary provide a significant added
benefit. Monitoring will also be performed to ensure the effectiveness of
the covers.
General Comments on Public Meetina /Public Particioation
I'd like to thank the presenters for bringing this to us tonight. I am glad
that they were kind 01 lumped together in that I would have hated to
have blown a perfectly good evening on a landfill and a ditch. And with
that in mind, I think that the landfills and ditches certainly are a very
minor part of the problems we have at INEL I would hope, however,
that DOE and others do continue to monitor these sites for future
problems and that they continue to bring these sites, as insignificant as
they may seem, forward to the public and let the public make their
decisions based on the-information that is available rather than
assuming that these are too small for our concern. Thank you. (T-B27)
Monitoring will contir}ue at the Industrial Waste Ditch and Landfill Sites,
and the Agencies will continue to provide public comment opportunities
for alilNEL remediation projects.
I would like to comment on your plans for clean up at nine separate
landfills at your Naval Reactors Facility at INEL I attended your
information meeting in Moscow, ID on April 21, 1994 and was very
impressed by the presentation. I feel that any cleanup is of course
good and worthy. (VV-M28)
. The Agencies appreciate the time and effort that the commentor took to
evaluate the material, attend the presentations, and provide comments -
on the information presented by the Agencies.
The amount of advertising on radio and T.V. before the 20 April 94
Boise meeting was commendable and probably responsible for more
public attendance.
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22.
Response:
Comment:
Response:
23.
Comment:
Response:
The visuals of.the presentation boaras on easels were superb. The
speakers seemea cordial and well prepared with others available with
on-site experience to address questions and other aspects.
I hope the presentation boards and visuals will be preserved to use
again at schools and other public meetings. We do hope for
continuous consideration of costs for effective solutions. (W-B29)
The Agencies will evaluate the use of the presentation materials in other
settings. The INEL Community Relations office retains these materials
for future use. A comparison of cost versus 9.enefit will continue to be
performed for all environmental restoration activities at the INEL.
No comments at this time, but would like to receive a copy of the
Record of Decision and Responsiveness Summary. (W-P30)
The Agencies appreciate the time and effort that the commentor took to
evaluate the material. Copies of the Record of Decision with the'
Responsiveness.Summary will be provided to individuals who request
them.
First, I would like to thank both you and the Westinghouse Electric.
Corporation representative, Mr. Nieslanik, for the presentation provided
at the Grand Teton Mall. It was informative, well presented and the
visual displays were easily understood. (W-131)
The Agencies appreciate the time and effort that the commentor took to
evaluate the material, attend the presentations, and provide comments
on the information ~resented.
-------
APPENDIX B: PUBLIC COMMENT/RESPONSE LIST
J.
-------
PUBLIC COMMENT/RESPONSE LIST
All of the comments submitted by the public in either written or verbal form were tabulated
and assigned a code number. The com mentors are listed alphabetically in the first column,
the comment code appears in the second column. The first symbol in the code indicates if
the comment was written 0N) or transcribed by the court reporter present at the public
meetings. The second symbol indicates the geographic area the comment was received
from; 'B' for Boise, 'I' for Idaho Falls, 'M' for Moscow, 'P' for Pocatello, or 'T' for Twin Falls.
The page number the response to the comment appears on is listed in the third column.
I NAME I COMMENT CODE \ RESPONSE PAGE \
Barraclough, Jack T-13 A-5
Barraclough, Jack T-14 A-5
Barraclough, Jack T-19 A-5
Barraclough, Jack T-116 A-11
Barraclough, Jack T-121 A-10
Barry, Warren W-T24 A-11
Barry, Warren W-T22 A-11
Bjornsen, Fritz T -B27 A-13
Brissenden, Marjorie W-B26 A-13
Brissenden, Marjorie W-B29 A-14
Broscious, Chuck T-M1 A-6
Broscious, Chuck T-M14 A-9
Creek, Alex W-118 A-10
Drewes, Kenneth W-111 A-7, A-8
Drewes, Kenneth W-113 A-8
Drewes, Kenneth W-I25 A-5, A-12
Drewes, Kenneth W-131 A-14
Hamilton, Joel T-M7 A-7
Hampsen, W. L W-B6 A-6
Hampsen, W. L W-B 10 A-7
Hampsen, W. L W-B20 A-10
Leedom, George L. W-M19 A-10
Leedom, George L. W-M28 A-13
Rice, Charles M. W-18 A-7
Rice, Charles M. W-123 . A-12
Sorensen, Stan W-P30 A-14
Straka, M. W-15 A-11
White, C. E. T-112 A-7
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APPENDIX C: ADMINISTRATIVE RECORD INDEX
..
J.
-------
IDAHO NATIONAL ENGINEERING lABORATORY
ADMINISTRATIVE RECORD Fll..E INDEX FOR THE NRF
TRACK 2 INVESTIGATION OPERABIE UNIT 8-()5
. OSf25I94.
FILE NUMBER
AR3.6
TRACK 2 INVESTIGATION
....
Document #:
Title:
Author:
Recipient:
Date:
NR:mO-94/082
DOE Decision Statement and Feasibility Study fLc Operable Units
8-()5 and 8-06 and Summary Report for Operable Unit 8-06
Newbry, R.D.E.
Nygard, D.; Pierre, W.
04/11/94
AR3.14
TRACK 2 SUMMARY REPORTS
....
Document #:
Title:
Author:
Recipient:
Date:.
NR:mO-93/301
Track 2 Summary Report for NRF Operable Unit 8-05
Newbry, R.D.E.
Nygard, D., Pierre, W.
11/15193
AR4.2
FEASffiILITY STUDY REPORTS
....
Document #:
Title:
Author:
Recipient:
Date:
.....
Document #:
Title:
Author:
Recipient:
Date:
NR-ffiO-94-048
Draft Feasibility Study for NRF Landfill Areas (Operable Units 8-
0S and 8-06)
Newbry, R.D.E.
Nygard, D., Pierre, W.
03/11194
5668
Feasibility Study for NRF Landfill Areas (Operable Units 8-05 and
8-06) . .
Newbry, R.D.E.
Nygard, D., Pierre, W.
11/15193
-------
05{l5194
TRACK 1 INVESTIGATION OF au 8-05
FILE NUMBER
AR4.3
PROPOSED PLAN
...
Document #:
Title:
Author:
Recipient:
Date:
...
Document #:
Title:
Author:
Recipient:
Date:
NR:ffiO-94/034 .
Transmittal Letter and Draft Proposed Plan for NRF Operable
Units 8-03,-20 and 22 (Track 1 Investiga~jons), 8-05 and 06
(Landfill Site Track 2 Investigations, and 8-07 (Exterior Industrial
Waste Ditch RIIFS)
Newbry, R.D.E.
Nygard, D.; Pierre, W.
02128/94
5770
Proposed Plan for NRF au 8-03,-20 and 22 (Track 1), 8-05 and 06
(Landfill Site Track 2) and 8-07 (Exterior Indusu1al Waste Ditch
RIIFS) .
INEL Community Relations
N/A
04/01194
AR6.1
COOPERATIVE AGREEMENTS
...
Document #:
Title:
Author:
Recipient:
Date:
...
Document #:
Title:
Author:
Recipient:
Date:
...
Document #:
Title:
Author:
Recipient:
Date:
ERDl:.070-91*
Pre-signature Implementation of the CERClA Interagency
Agreement Action Plan
EP A, Findley, C. E.
DOE, Solecki, J. E.
05/17191
3205*
U.S. DOE INEL Federal Facility Agreement and Consent Order
N/A .
NIA
07122/91
2919*
INEL Action Plan For Implementation of the Federal Facility
Agreement and Consent Order
N/A
N/A
07122/91
-------
TRACK 1 INVESTIGATION OF OU 8-05
OS/25/94
FILE NUMBER
AR6.1
COOPERATIVE AGREEMENTS (continued)
4
4
4
4
AR9.1
4
Document #:
Title:
Author:
Recipient:
Date:
Document #:
Title:
Author:
Recipient:
Date:
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Title:
Author:
Recipient:
Date:
Document #:
Title:
Author:
Recipient:
Date:
Document #:
Title: .
Author:
Recipient:
Date:
1088-06-29-120.
U.S. DOE INEL Federal Facility Agreement and Consent Order
N~ .
N/A
12104191
3298.
Response to Comments on the Idaho National Engineering
Laboratory Federal Facility Agreement and Consent Order
N/A
N/A
02121/92
DOEJID-10340(92).
Track 1 Sites: Guidance for Assessing Low Probability Hazard
Sites at the INEL
~L, EPA, IDHW
NIA
07101/92
DOEJID-10389 Rev. 6.
Track 2 Sites: Guidance for Assessing Low Probability Haiard
Sites at the INEL . .
INEL, EP A, IDHW
N/A
01/01194
NOTICES ISSUED
AMlSES-ESD-92-2S6.
Natural Resource Trustee Notification
Pitrolo, A.A. .
Andrus, C,D,
07/07/92
3
-------
TRACK 1 INVESTIGATION OF OU 8-D5
05125/94
FILE NUMBER
AR9.1
.
Document #:
Title: .
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
NOTICES ISSUED (continued)
AMlSES-ESD-92-2578
Natural Resource Trustee Notification
Pitrolo, A.A
Polityka, C.
07/07/92
AMlSES-ESD-92-258*
Natural Resource Trustee Notification
Pitrolo, A.A.
Edmo, K.
07/07/92
AM/SES-ESD-93-007*
Invitation to Natural Trustee Representatives to Discuss Natural
Resources and Environmental Restoration at the INEL
Hinman, M.B.
Addressee List
01125/93
AM/SES-ESD-93-097*
Agenda for Meeting of Potential Natural Resource Trustees' on
Match 17, 1993
Twitchell, R.t- ~
Addressee List
03102193
AM/SES-ESD-93-159* .
INEL Natural Resource Trustee Meeting "Group Memory" March
17, 1993
Hinman, M.B.
Addressee List
03130/93
-------
TRACK 1 INVESTIGATION OF OU 8-05
05(25194
FILE NUMBER
AR9.1
NaTICES ISSUED (contimied)
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
..
Document #:
Title:
Author:
. Recipien~:
Date:
AM/SES-ESD-93-162*
Department of Energy Idaho Field Offi~ (DOE-ill) Proposal for
Consultation and Coordination between Natural Resource Trustees
Hinman, M.B.
Addressee List
04/02193
AM/SES-ESD-93-276*
Department of Energy Idaho Field Office (DOE-ID) Action Item
Report to Potential Natural Resource Trustees
Hinman, M.B.
Addressee List
06/16193
5337*
Natural Resource Trustee Representation Designation
Andrus, C.D., Governor
Pitrolo, AA
08/11/92
5338* .
Response to Natural Resource Notification
Polityka, C.S. ~
Pitrolo, AA
08(12,/92
ARIO.4
PUBUC ~llNG TRANSCRlYI'S
.
. Document #:
Title:
. Author:
Recipient:
Date:
5703
Public Meeting Transcripts for the NRF Industrial Waste Ditch
and Landfill Areas
Ecology and Environment, Inc.
N/A
OS/24194
This document can be found in the INEL OU 8-07 Administrative Record Binder
-------
TRACK 11NVESI1GATION OF OU 8-05
05125/94
FIlE NUMBER
AR10.6
PRESS RELEASES
'"
Document #:
Title:
Author:
Recipient:
Date:
5640
DOE Seeks Public Comment on Industr!~l Wastt. Ditch and
Landfills at the NRF .
N/A
N/A
03/01/94
ARH.1
EPA GUIDANCE
Document #: 5163 Revision 3.
Title: .Administrative Record list of Guidance Documents
Author: EP A
Recipient: N/A
Date: 08/12/92
'"
ARll.4
TECHNICAL SOURCES
'"
Document #:
Title:
..
Author:
Recipient:
Date:
NR-IBO-94-076 .
Radioactivity controls In Prototype Plants at the Naval Reactors
Facility
Newbry, R.D.E.
Nygard, D.; Pierre, W.
03131194 ~
1bis document can be found in the INEL au 8-01 .Administrative Record Binder
AR12.1
EPA COMMENTS
'"
Document #:
Title:
Author:
Recipient:
Date:
5636
Track 2 Summary Report for the Naval Reactors Facility Operable
Unit8-0S .
Meyer, L. .
Newbry, R.D.E.
12120/93
-------
TRACK IINVESfIGATION OF au 8-05
05125194
FIT..E NUMBER
ARl2.1
EP A COMMENTS (continued)
...
Document #:
Title:
Author:
Recipient:
Date:
5663
Draft Feasibility Study for NRF Landfill Areas (Operable UnitS
(OU) 8-05 and 8-06)
Meyer, L
Newbry, R.D.E.
03n.9194
AR122
IDHW COMMENTS
Document #: 5657
Title: . . IDHW-DEQ Recommendations for Track-Two Operable UnitS
8-05 and 8-06
English, M.
Newbry, R.D.E.
. . 03123/94
...
Author:
Recipient:
Date:
...
Document #:
Title:
Author:
Recipient:
Date:
...
Document #:
Title:
Author:
Recipient:
Date:
5664
Review of the qraft Proposed Plan for Operable UnitS (OU) 8-05,.
8-06, and 8-07
English, M.
Newbry, R.D.E.
03131194 .
5666
IDHW Comments - Review of the Draft Focused Feasibility Study
for Operable Units (OU) 8-05 and 8-06
English,M.
Newbry, RoO.E.
04/04/94
.
Document filed in INEL Federal Facility Agreement and Co~nt Order
(FFA/OO) Adminktrative Record Binder
-------
IDAHO NATIONAL ENGINEERING LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR TIlE NRF
TRACK 2 INVESTIGATION OPERABLE UNIT g.{)6
. . 05125194
ADMINISTRATIVE RECORD VOLUME 1
Fll.E NUMBER
TRACK 2 SUMMARY REPORT
AR3.14 .
.
Document #:
Title:
Author:
Recipient:
Date:
5669
Track 2 Summary Report for Naval Reactors Facility au g.{)6
Golder Associates, Inc.
N/A
04101194
ADMINISTRATIVE RECORD VOLUME 11
ARJ.6
TRACK 2 INVES11GATION
.
. Document #:
Title: .
Author:
Recipient:
Date:
NR:ffiO-941082
DOE Decision Statement and Feasibility Study for Operable Units 8-05
and 8-06 and Summary fReport for Operable Unit 8-06
Newbry, R.D.E.
. Nygard. D.; Pierre, W.
04/11194
AR3.21
SCHEDULES
.
. Document #:
Title:
Author:
Recipient:
Date:
NR:IBO-941018 ~
Revised Schedules for OU 8-06 and 8-09 Track 2 Investigations
. Newbry, R.D.E.
Nygard. D.; Pierre, W.
00./07194
AR4.2
FEASmILlTY STUDY REPORTS .
.
Document #:
Title:
Author:
Recipient:
Date:
NR-mO-94~
Draft Feasibility Study for NRF Landfill Areas
(Operable Units 8-05 and 8-(6)
Newbry, R.D.E.
Nygard. D., Pierre, W.
-------
IDAHO NATIONAL ENGINEERING lABORATORY
ADMINISTRATIVE RECORD Fll.E INDEX FOR THF NRF
EXTERIOR INDUSTRIAL WASTE DITCH RI I FS OPERABLE UNIT 8-07
05(1.5/94
ADMINTSTRA11VE RECORD VOLUME I
FILE NUMBER
AR3.3
RI/FS WORK PIAN
..
Document #:
Title: .
Author:
Recipient:
Date:
..
Document #:
Title:
Author:
Recipient:
Date:
..
Document #:
Title:
Author:
Recipient:
Date:
5195
RIJFS Fmal Work Plan For the Exterior Industrial Waste Ditch OU 8-07,
Naval Reactors Facility, Idaho Falls, Idaho
Westinghouse Electric Corporation
N/A
09124192
NR:IBO-921328
DOEJIBO Transmittal of Fmal Work Plan for the RIIFS for the NRF
Industrial Waste Ditch
Newbry, R.D.E., DOE-mO
Nygard, D., EP A
11126191
5196
Corespondence between EP A, State of Idhao, and DOE-mO
N/A .
N/A
09124192
~
ADMINISTRATWE RECORD VOLUME H
AR3.4 .
REMEDIAL INVFSI1GATION REPORTS
..
Document #:
Title:
. Author:
Recipient:
Date:
.. :'
NR:1BO-93/19&, VOL 1
Transmittal Letter and Draft Remedial Investigation Report for NRF
Operable Unit 8-07
Newbry, R.D.E.
Nygard, D.; Pierre, W.
07/15193 .
-------
EXTERIOR INDUSTRIAL W ASrE DITCH RI I FS OU 8-07
05(25/94
ADMlNlSTRA11VE RECORD VOLUME III
FILE NUMBER
AR3.4
REMEDIAL INVFSl1GA110N REPORTS (continued)
'.
Document #:
Title:
Author.
Recipient:
Date:
NR:IBO-93/198,VOL 2 ,-
Draft Remedial Investigation Report for NRF OU 8-07
Newbry, R.D.E. '
Nygard, D.; Pierre, W.
07/15/93
ADMINISTRATIVE RECORD VOLUME IV
AR3.12
RIIFS REPORTS
.
Document #:
Title:
Author.
Recipient:
Date:
NR:IBO-93/296,VOL 1
Transmittal Letter and Draft Remedial Investigation 1 Feasibility Study
Report for NRF Operable Unit 8-07 (EXterior Industrial Waste Pitch)
Newbry, R.D.E.
Nygard, D.; Pierre, W.
11108193
ADMIN1STRAl1VE RECORD VOLUME V
.
Document #:
Title:
Author.
Recipient:
Date:
NR:IBO-93/296,VOL 2
Draft Remedial Investigation 1 Feasibility Study Report for NRF Operable
Unit 8-07 (Exterior Industrial Waste Ditch) ,
Newbry, R.D.E. J.
Nygard, D.; Pierre, W.
11108193
ADMINISTRATIVE RECORD VOLUME VI
.
Document #: 5626,VOL. 1
Title: Fmal Remedial Investigation I Feasibility Study Report forNRF Operable
Unit 8-07 (Exterior Industrial Waste Ditch) ,
Lee, S.D.
N/A
02101/94
Author.
Recipient:
Date:
2
-------
,.
EXTERIOR INDUSTRIAL WASTE DITCH RI 1 FS OU 8-07
05125/94
ADMlNlSTRA T1VE RECORD VOLUME Y1
ALE NUMBER
ARJ.12
RIJFS REPORTS (oontinued)
&
Document #:
Title:
Author:
Recipient:
Date:
5626,VOL 2
Fmal Remedial Investigation / Feasibility Study Report for NRF Operable
Unit 8-07 (Exterior Industrial Waste Ditch)
Lee, S.D.
N/A.
02/01/94
ADMINISTRATIVE RECORD VOLUME V11
AR4.3
PROPOSED PLAN
.&
Document #:
Title:
Author:
Recipient:
Date: .
..
.
Document #:
Title:
Author:
Recipient:
Date:
AR6.1
.
Document #:
TItle:
Author:
Recipient:
Date:
NR:mO-94!034
Transmittal Letter and Draft Proposed Plan for NRF OU
8-03,-20 and 22 (Track 1), s..o5 and 06 (Landfill Site Track 2) and 8-07
(Exterior Industrial Waste Ditch RIIFS)
Newbry, R.D.E.
Nygard, D.; Pierre, W.
00/1i3I94
5770
Proposed Plan for NRF OU 8-03,-20 and 22 (Track 1), 8-05 and 06
(Landfill Site Track 2) and 8-07 (Exterior Industrial Waste Ditch RIIFS)
INEL Community Relations
N/A
04101/94
COOPERATIVE AGREEMENTS
~1~~91. .
Pre-signature Implementation of the CERCLA Interagency Agreement
Action Plan
EPA, Fmdley, C. E.
DOE, Solecki. J. E.
05/17191
-------
EXTERIOR INDUSTRIAL WASTE DITCH RI I FS OU 8-07
05{25194
FILE NUMBER
AR6.1 OPERATIVE AGREEMENTS (continued)
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
. Recipient: .
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient: .
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
AuthQr:
Recipient:
Date:
3205'
U.S. DOE INEL Federal Facility Agreement and Consent Order
N/A
N/A
07/22/91
2919" .
INEL Action Plan For Implementation of the Federal Facility Agreement
and Consent Order
N/A
N/A
07/22/91
1~29-120" .
U.S. DOE INEL Federal Facility Agreement and Co~n~ Order
N/A .
N/A
12/04191
3298"
Response to Comments on the Idaho National Engineering Laboratory
Federal Facility Agreement and Consent Order
N/A
N/A
00./21192
~
DOEJID-I0340(92) "
Track 1 Sites: Guidance for ~ing Low Probability Hazard Sites at the
INEL
INEL. EP ~ IDHW
N/A
07101192
DOEJID-I0389 Rev. 6' . .
Track 2 Sites: Guidance for Assessing Low Probability Hazard Sites at the
INEL
INEL, EP ~ IDHW
N/A
01101194
-------
..
EXTERIOR INDUS'I1UAL W ASrE DITCH RI I FS OU 8-07
OSfl5194
ALE NUMBER
AR9.1
.
.
.
.
.
NaTICES ISSUED
Document #:
Title:
Author:
Recipient:
Date:
Document #:
Title:
Author:
Recipient:
Date:
Document #:
Title:
Author:
Recipient:
Date:
Document #:
Title:
Author:
Recipient:
Date:
Document #:
Title:
Author:
Recipient:
Date:
&
Document #:
Title:
Author:
Recipient:
Date:
AMlSES-ESD-92-256"
Natural Resource Trustee Notification
Pitrolo, AA
Andrus, C,D,
07107/92
AMlSES-ESD-92-257"
Natural Resource Trustee Notification
Pitrolo, AA
Polityka, C.
07107/92
AMlSES-ESD-92-25S"
Natural Resource Trustee Notification
Pitrolo, AA
EdIno, K.
07107192
AMJSES-ESD-93-OO7" .
Invitation to Natural Trustee Representatives to Discuss Natural Resources
and Environmental Restoration at the INEL
Hinman, M.B.
Addressee List
01flS193
~
AMlSES-ESD-93-097"
Agenda for Meeting of Potential Natural Resource Trustees' on
March 17, 1993
Twitchell, R.L.
Addressee List
03!CW93
AMlSES-ESD-93-1S9"
INEL Natural Resource Trustee Meeting "Group Memory" March 17, 1993
Hinman, M.B.
Addressee List
03130193 .
-------
.,
OS/25/94
EXTERIOR INDUSTRIAL WASTE DITCH RlI FS OU 8-07
F1LE NUMBER
AR9.1
NGnCES ISSUED (continued)
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
.
Document #: .
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
Date:
AMlSES-ESD-93-162"
Department of Energy Idaho Field Office (DOE-ID) Proposal for
Consultation and Coordination between Natural Resource Trustees
Hinman, M.B.
Addressee List
04102J93
AM/SES-ESD-93-276"
Department of Energy Idaho Field Office (DOE-ID) Action Item Report
to Potential Natural Resource Trustees .
Hinman, M.B..
Addressee List
06/16/93
5337"
Natural Resource Trustee Representation Designation
Andrus, C.D., Governor
Pitrolo, AA .
08111192
5338"
Response to Natural Resource Notification
Polityka, c.s.
Pitrolo, AA
08128192
ARIo.4
4-
PUBUC ~llliG TRANSCRIPTS
.
Document #:
Title:
Author:
Recipient:
Date:
5703
Public Meeting Transcripts for the NRF Industrial Waste Ditch and
Landfill Areas
Ecology and Environment, Ine.
N/A
OS/24194
ARl0.6
PRESS RELEASES
.
Document #:
TItle:
Author:
Recipient:
Date:
S640 . .
DOE Seeks Public Comment on Industrial Waste Ditch
N/A
N/A
03/01194
-------
,"
EXTERIOR INDUSTRIAL WASTE DITCH RI I FS OU S-m
05(}.5194 .
F1LE NUMBER
AR11.1
.
AR11.4
.
EPA GUIDANCE
Document #:
TItle:
Author:
Recipient:
Date:
5163 Revision 3.
Administrative Record List of Guidance Documents
EPA
N/A
08112/92
"lECHNICAL SOURCES
Document #:
TItle:
Author.
Recipient:
Date:
NR-IBO-94-076
Radioactivity controls In Prototype Plants at the Naval Reactors Facility
Newbry, R.D.E.
Nygard, D.; Pierre, W.
03f31194
'Ibis document can be found in j\dmini~trative Record Binder au 8-01
AR121
.
.
. AR122
EPA COMMENTS
Document #:
TItle:
Author:
Recipient:
Date:
Document #:.
TItle:
Author.
Recipient:
Date:
~ . .
EP A Comments: Draft Remedial Investigation for th~ Exterior Industrial
Waste Ditch Operable Unit 8-07
Meyer, L
Newbry, RD.E.
(y)f(J].J93
J.
S638
EP A Comments: Draft Remedial InvestigationIFeasibility Study for the -
Exterior Industrial Waste Ditch
Meyer, L
Newbry. R.D.E.
12'23193
IDHW OOMMENTS
Document #: 563S
TItle: IDHW Comments:
Author:. . English, M.
Recipient: Bradley, T.M.
Date: . (y)f(J].J93
.
Technical ReView of the Draft RI/FS
-------
EXTERIOR INDUSTRIAL W ASrE DITCH RI I FS OU S-07
OS/25/94
FILE NUMBER
IDHW COMMENTS (continued)
ARl22
A
Document #:
Title:
Author:
Recipient:
Date:
.
Document #:
Title:
Author:
Recipient:
. Date: .
5637
IDHW Comments:
English, M.
Newbry, R.D.E.
12121193
5664
Review of the Draft Proposed Plan for Operable Units (OU) 8-05, 8-06,
and 8-07
English, M.
Newbry, R.D.E.
03/31194
Technical Review of the Draft RIIFS
ARl2.3
DOE RESOLUTIONS ro COMMENTS
.
Document #:
. Title:
Author:
Recipient:
Date:
NR-mO-931272
Response to EP A/IDHW Comments On IWD RI Report
Newbry, RD. E. .
Nygard, D.; Pierre, W.
10104193
~
.
])ocumP.l1t filed in INEL Federal Facility Agreement and Consent Order (FFNCO)
j\.tfminimatiYe Rc:cord Bin~
-------
"
IDAHO NATIONAL ENGINEERING lABORATORY
ADMINISTRATIVE RECORD Fll.E INDEX FOR TIIE NRF
EXTERIOR INDUSTRIAL WASTE DITCH RlI FS OPERABLE UNIT &-m
05125194
ADMINISTRATIVE RECORD VOLUME I
HLE NUMBER.
RIIFS WORK PLAN
AR3.3
6
Document #:
Title:
Author:
Recipient:
Date:
6
Document #:
Title:
Author:
Recipient:
Date:
6
Document #:
Title:
Author:
Recipient:
Date:
5195
RIJFS Fmal Work Plan For the Exterior industrial Waste Ditch OU 8-07,
Naval Reactors Facility, Idaho Falls, Idaho
Westinghouse Electric Corporation
N/A
09124f12
NR:IBO-921328
DOElIBO Transmittal of Fmal Work Plan for the RIIFS for the NRF
Industrial Waste Ditch .
Newbry, R.D.E., DOE-IBO
Nygard. D., EP A
11126191
5196
Corespondence between EP A, State of Idhao, and DOE-IBO
N/A
N/A
09f24192
.ADMINISTRATIVE RECORD VOLUME H
;.
ARJ.4
REMEDIAL INVES11GATION REPOR1:S
.
Document #:
TItle:
Author:
Recipient:
Date:
NR:IBO-93/198, VOL 1
Transmittal Letter and Draft Remedial Investigation Report for NRF
Operable Unit 8-07 .
Newbry, R.DE
Nygard, D.; Pierre, W.
07/15193
-------
. ,
EXTERIOR INDUSTRIAL WASTE DITCH RlI FS OU g..(J7
OSfl5194
ADMINISTRATIVE RECORD VOLUME III
FIT...E NUMBER
AR3.4
REMEDIAL INVESTIGATION REPORTS (continued)
.
Document #:
Title:
Author:
Recipient:
Date:
NR:IBO-93/198,VOL 2
Draft Remedial Investigation Report for NRF OU S:-07
Newbry, RD.E.
Nygard. D.; Pierre, W.
07/15/93
ADMINISTRATIVE RECORD VOLUME W
AR3.12
RI/FS REPORTS
.
Document #:
Title:
Author:
Recipient:
Date:
NR:mO-931296,VOL 1
Transmittal Letter and Draft Remedial Investigation 1 Feasibility Study
Report for NRF Operable Unit 8-07 (Exterior Industrial Waste Ditch)
Newbry, RD.E.
Nygard. D.; Pierre, W.
11108193
ADMINISTRATIVE RECORD VOLUME V
.
..
Document #:
Title:
Author:
Recipient:
Date:
NR:mO-931296,VOL 2 .
Draft Remedial Investigation I Feasibility Study Report for NRF Operable
Unit 8-07 (Exterior Industrial Waste Ditch)
Newbry, RD.E. J.
Nygard. D.; Pierre, W.
11108193 .
ADMINISTRATIVE RECORD VOLUME VI
.
Document #:
Title:
Author:
Recipient:
Date:
5626, VOL 1
Fmal Remedial Investigation I Feasibility Study Report for NRF Operable
Unit 8-07 (Exterior Industrial Waste Ditch) . .
Lee, S.D. .
N/A
02101194
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EXTERIOR INDUSTRIAL WASTE DrraI RI 1 FS OU 8-07
05125/94
ADMINISTRATIVE RECORD VOLUME Yl
FTI..E NUMBER
AR3.12
RIJFS REPORTS (continued)
.
Document #:
Title:
Author:
Recipient:
Date:
S626,YOI- 2
Fmal Remedial Investigation 1 Feasibility Study Report for NRF Operable
Unit 8-07 (Exterior Industrial Waste Ditch)
Lee. S.D.
N/A
02101194
ADMINISTRATIVE RECORD VOLUME VlI
AR4.3
PROPOSED PlAN
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Title:
Author:
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.
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Author:
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NR:mO-941034
Transmittal Letter and Draft Proposed Plan for NRF OU
8-03,-20 and 22 (Track 1), 8-OS and 06 (Landfill Site Track 2) and 8-07
(Exterior Industrial Waste Ditch RIIFS)
NewbJ)', R.D.£.
Nygard. D.; Pierre, W.
(f}J}1?J94
5770 .
Proposed Plan for NRF OU 8-03,-20 and 22 (Track 1), 8-OS and 06 .
(Landfill Site Track 2) and 8-07 (Exterior Industrial Waste Ditch RIIFS)
. INEL Community ~elations .
N/A
04101194
AR6.1
OOOPERA11VE AGREEMENTS
.
Document #:
Title:
Author:
Recipient:
Date:
ERD1-070-918
Pre-signature Implementation of the CERCLA Interagency Agreement
Action Plan
EPA, Fmdley, C. E.
DOE, Solecki, J. E.
05/17191
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EXTERIOR INDUSTRIAL WASTE DITCH RI I FS OU 8-iJ7
05125/94
FILE NUMBER
AR6.1 COOPERATIVE AGREEMENTS (continued)
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Date:
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.
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.
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Date:
.
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Recipient:
Date:
.
Document #:
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Author:
Recipient:
Date:
3205"
U.S. DOE INEL Federal Facility Agreement and Consent Order
N/A
N/A
07 (l2J91
2919"
INEL Action Plan For Implementation of the Federal Facility Agreement
and Consent Order
N/A
N/A
07 (l2J91
1088-06-29-120"
U.S. DOE INEL Federal Facility Agreement and Consent Order
N/A
N/A
12104191
3298-
Response to Comments on the Idaho National Engineering Laboratory
Federal Facility Agreement and Consent Order
N/A
N/A
02121192
,
DOE'JID-I0340(92)" .
Track 1 Sites: Guidance for Assessing Low Probability Hazard Sites at the
INEL .
INEL. EP A, IDHW
N/A
07101192
DOE'JID-I0389 Rev. 68 .
Track 2 Sites: Guidance for Assessing Low Probability Hazard Sites at the
INEL
INEL, EP A, IDHW
N/A
OWll94
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IDCI'ERIOR INDUSTRIAL WASTE DITCH RI I FS au 8-m
FILE NUMBER
AR9.1
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NOTICES ISSUED
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Author:
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Date:
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Author:
Recipient:
Date:
Document #:
TItle:
Author:
Recipient:
Date:
AMJSES-ESD-92-256"
Natural Resource Trustee Notification
Pitrolo, AA
Andrus, C,D,
07107/92
AMJSES-ESD-92-257"
Natural Resource Trustee Notification
Pitrolo, AA
Polityka, C.
07107192
AMJSES-ESD-92-25S"
Natural Resource Trustee Notification
Pitrolo, AA
Edmo,K.
fJ7lO7l92
05~194
AMlSES-ESD-93-007"
Invitation to Natural Trustee Representatives to Discuss Natural Resources
and Environmental Restoration at the INEL
Hinman, M.B.
Addressee List
01!l5193 .
J.
AMlSES-ESD-93-097°
Agenda for Meeting of p'otential Natural Resource Trustees' on
March 17,1993
Twitchell, R.L
Addressee List
03mt93
AMlSES-ESD-93-159°
INEL Natural Resource Trustee Meeting "Group Memory" March 17, 1993
Hinman, M.B. .
Addressee List
03130193
5
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05125194
EXTERIOR INDUSTRIAL WASTE DITCH RI / FS OU 8-07
FILE NUMBER
AR9.1
NOTICES ISSUED (continued)
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Date:
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TItle:
Author:
Recipient:
. Date:
AM/SES-ESD-93-162.
Department of Energy Idaho Field Office (DOE-ID) Proposal for
Consultation and Coordination between Natural Resource Trustees
Hinman, M.B.
Addressee List
04102J93
AM/SES-ESD-93-276.
Department of Energy Idaho Field Office (DOE-ID) Action Item Report
to Potential Natural Resource Trustees
Hinman. M.B.
Addressee List
06116/93
5337.
Natural Resource Trustee Representation Designation
Andrus, C.D., Governor
Pitrolo, AA
08111192
5338.
Response to Natural Resource Notification
Polityka, c.s. .
Pitrolo, AA.
08f}J3/92
ARI0-4
PUBUC ~llNG TRANSCRIPTS
I-
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Author:
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Date:
ARl0.6
..
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TItle:
. Author:
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Date:
5703
Public Meeting Transcripts for the NRF Industrial Waste Ditch and
Landfill Areas
Ecology and Environment, Ine.
N/A
05124/94
PRESS RELEASES
5640
DOE Seeks Public Comment on Industrial Waste Ditch
N/A
N/A
03/01194
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EXTERIOR INDUS1RIAL W ASrE DITCH RI I FS OU 8-07
OS/25/94
f1LE NUMBER
ARl1.1
EPA GUIDANCE
...
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Title:
Author:
Recipient:
Date:
5163 Revision 3' .
.Admini..trative Record List of Guidance Documents
EPA
N/A
08/12192
ARll.4
'IECHNlCAL SOURCES
...
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. Title:
Author:
Recipient:
Date:
NR-mO-94-076
Radioactivity controls In Prototype Plants at the Naval Reactors Facility
Newbry, R.D.E.
Nygard. D.; Pierre. W.
03/31/94
This document can be found in j\dministratnoe Record Binder au ~1
AR121
EPACOMMENTS
...
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Date:
...
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Author:
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Date:
AR122
...
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Title:
Author:
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Date:
5634
EP A Comments: Draft Remedial Investigation for the Exterior Industrial
Waste Ditch Operable Unit ~7
Meyer, L .
Newbry, R.D.E.
(1J1OOJ93
~
S638
. EP A Comments:. Draft Remedial InvestigationIFeasibility Study for the ,-
&terior Industrial Waste Ditch
Meyer, L
Newbry, RoD.E.
12123193
IDHW COMMENTS
S63S
IDHW Comments:
English,M.
Bradley, T.M.
(1JJC1}./93
Technical Review of the Draft'RIIFS
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EXTERIOR INDUSTRIAL W ASrE DITCH RI / FS au 8-07
OS!2.Si94
~ NUMBER
AR12.2
IDHW COMMENTS (continued)
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.
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Title:
Author:
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Date:
5637
IDHW Comments:
English. M.
Newbry, R.D.E.
12121193
Technical Review of the Draft RIJFS
5664
Review of the Draft Proposed Plan for Operable Units (OU) 8-05, 8-06,
and 8-07
English, M.
Newbry, R.D.E.
03/31194
AR123
DOE RESOLUTIONS TO COMMENTS
.
Document #:
Title:
Author:
Recipient:
Date:
NR-ffiO-93/272
Response to EP AlIDHW Comments On IWD RI Repon
Newbry, R.D. E.
Nygard, D.; Pierre, W.
10104193
l
.
])oc;umeftt filed in INEL Feaeral Facility Agreement and Consent Order (fF NCO)
jYministrative Record Binder
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