PB94-964142
EP AIROD/R05-941269
April 1995
EPA
Superfund
'Record of Decision:
Feed Materials' Production Center
(O.U. 3), Fernald, OH
7/22/1994
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
..,
EP A Report Collection
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
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OPERABLE UNIT 3
RECORD OF DECISION
FOR
INTERIM REMEDIAL ACTION
FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
FERNALD, OHIO
JUNE 1994
U.S. DEPARTMENT OF ENERGY
FERNALD FIELD OFFICE
FINAL
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Acknowledgement
The Operable Unit 3 Record of Decision for Interim Remedial Action was prepared with the
support of individuals representing expertise and organizations of wide variety. Contributors
represented Argonne National Laboratory, Fernald Environmental Restoration Management
Corporation (FERMCO), and the U.S. Department of Energy Fernald Field Office. The principal
authors and major contributors for this version of the document are:
u
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Todd Clark
Mike Davis
Christina Elsea
James Forrelli
Kathy Graham
Robert Janke
Cheryl Peterson
Craig Straub
Mike Strimbu
John Throckmorton
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RECORD OF DECISION DECLARATION
INTERIM REMEDIAL ACTION FOR OPERABLE UNIT 3
SITE NAME AND LOCATION:
U.S. Department of Energy
Fernald Environmental Management Project - Operable Unit 3
Fernald. Ohio
STATEMENT OF BASIS AND PURPOSE:
This decision document presents the selected interim remedial action for Operable Unit 3 at the
'U.S. Department of Energy (DOE) Fernald Environmental Management Project in Fernald, Ohio,
which was chosen in accordance with the comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable. the National Ojl and Hazardous
Substances Pollution Contingency Plan (NCP).
The proposed interim remedial action for Operable Unit 3 represents a major portion of the remedial
action for the operable unit and for the site as a whole. While DOE maintains an active
maintenance program, the former uranium processing support facilities contained within Operable
. Unit 3 are, in general, at or beyond their design life and in a state of advancing deterioration.
These current conditions indicate an increasing probability of future releases of hazardous
substances to the environment due to structural collapse or other failure mechanisms. While the
DOE and EPA are proceeding toward a decision on the final disposition of these structures as part
of the Operable Unit 3 RifFS process, the decision resulting from this effort will not likely occur until
late 1997.
The decision presented herein for the interim remedial action is based on information available in
the administrative record for operable unit 3 maintained in accordance with CERCLA. This
document was made available for public review and comment. This decision is also based on the
issues raised at the .public meeting held on January 5, 1994 and the comments received during the
public comment period following the issuance of the Proposed Plan/Environmental Assessment.
DOE and EPA have considered all comments received during the public comment period on the
Proposed Plan/Environmental Assessment in making this decision.
The State of Ohio concurs with the selected remedy.
ASSESSMENT OF THE SITE:
Actual or threatened releases of hazardous substances from Operable Unit 3. if not addressed by
implementing the response action selected in this Record of Decision for Interim Remedial Action.
may present a current or potential threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY:
This Interim Record of Decision addresses contamination of all Operable Unit 3 facilities and
structures, including former uranium production process buildings and equipment, support
structures, below-grade and above-grade utilities, and identified ponds and basins. The Fernald
Environmental Management Project is divided into five operable units, of which Operable' Unit 3 is
one, under investigation pursuant to the Amended Consent Agreement (EPA 1991a) between DOE
and EPA. In addition to these five operable units, a comprehensive site-wide operable unit would
evaluate the protectiveness of all site-wide remedial response actions.
The interim action selected remedy consists of decontaminating and dismantling all Operable Unit 3
structures and related facilities. The bulk of the debris and remediation waste generated will be
placed into temporary storage; decisions concerning treatment and final disposition of stored
remediation wastes and debris will be addressed and documented in the final remedial action
Record of Decision for Operable Unit 3 in 1997.
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The major components of the selected interim remedy include:
Decontamination of more than 200 buildings and structures in Operable Unit 3 by
removing loose contamination;
Dismantlement of the above-ground structures;
Removal of foundations. storage pads, ponds, basins, underground utilities, and
other at and below-grade structures;
Use of existing facilities or construction and operation of new interim storage
facilities in or near the former production area;
Off-site disposal at Nevada Test Site of some non-recoverable or non-recyclable
waste and debris generated by dismantlement;
Off-site recycling of some recyclable material from dismantlement;
Storage of the remaining waste and debris in interim storage facilities or existing
facilities until treatment and disposition are selected in the final remedial action
Record of Decision for Operable Unit 3.
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STATUTORY DETERMINATIONS:
The selected interim remedial action is protective of human health and the environment, complies
with Federal and State applicable or relevant and appropriate requirements directly associated with
the action, and is cost effective. The selected interim remedy best meets the evaluation criteria by
addressing risks to human health and the environment, accelerating the remediation process by
nearly four years, and reducing overall costs associated with Operable Unit 3 remediation.
This action does not constitute the final remedy for Operable Unit 3, the statutory preference for
permanent solutions and remedies that employ treatment to reduce toxicity, mobility. or volume as a .
principal element will be addressed by the final remedial action for Operable Unit 3. However, this
action does utilize permanent solutions and altemative treatment (or resource recovery through
recycling and reuse) technologies to the maximum extent practicable, given the limited scope of the
action. A subsequent final remedial action is planned to address the remaining scope of Operable
Unit 3. Although this remedy will result temporarily in radiological and/or hazardous substances
remaining on site above material free release limits, the final remedial action will address the
disposition of these remediation wastes and determine the need for future review to ensure that the
final remedial action provides adequate protection of human health and the environment. Because
this is an interim remedial action ROD, review of this site and of this remedy will continue as DOE
and EPA develop final remedial altematives for Operable Unit 3.
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Date
Acting Deputy Assistant Secretary
Environmental Management
U.S. Department of Energy
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Date
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SECTION
OPERABLE UNIT 3
RECORD OF DECISION FOR INTERIM REMEDIAL ACTION
JUNE 1994
TABLE OF CONTENTS
DECLARA TION
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PAGE
TABLE OF CONTENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. iii
NOTATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.0
2.0
3.0
4.0
5.0
SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES
. . . . . . . . . . . . . . . . . . . . . .
HIGHLIGHTS OF COMM~NITY PARTICIPATION
. . . . . . . . . . . . . . . . . . . . . .
SCOPE AND ROLE OF OPERABLE UNIT. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . .
5.1 Potential Contaminant Pathways and Exposure Routes. . . . . . . . . . . . .
5.2 Radiological Contamination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5.3 Chemical Contamination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5.4 Hazardous Waste Management Units. . . . . . . . . . . . . . . . . . . . . . . .
5.5 Mixed Waste. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.0
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ". . . . . .
7.0
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1 Alternative 1 -- No Interim Action. . . . . . . . . . . . . . . . . . . . . . . . . . .
7.2 Alternative 2 -- Decontaminate Surfaces Only. . . . . . . . . . . . . . . . . .
7.3 Alternative 3 -- Decontaminate and Dismantle. . . . . . . . . . . . . . . . . .
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . .
8. 1 Overall Protection of Human Health and the Environment. . . . . . . . . .
8.2 Compliance with Applicable or Relevant and Appropriate Requirements
8.3 Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . . . . . . .
8.4 Short-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.5 Reduction of Toxicity, Mobility, or Volume Through Treatment. . . . . .
8.6 Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.7 Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.8 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.9 Community Acceptance. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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5
6
8
9
10
11
11
12
12
13
14
14
15
20
21
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22
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23
24
24
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OU3 Decision Summary (Final)
iv
June 1994
9.0
SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10.0 STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10.1 Protection of Human Health and the Environment. . . . . . . . . . . . . . .
10.2 Compliance with ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10.2.1 Contaminant-, Location-, and Action-Specific Requirements. . . . .
10.2.2 Other Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10.3 Cost-Effectiveness.....................................
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable
10.5 Preference for Treatment as a Principal Element. . . . . . . . . . . . . . . . .
10.6 Review of the Interim Remedial Action. . . . . . . . . . . . . . . . . . . . . . .
11.0 COMMITMENT FOR FURTHER ANALYSIS AND SELECTION OF LONG-TERM
RESPONSE ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12.0 DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . . . . . .
13.0 REFERENCES..............................................
APPENDICES
Appendix A
Responsiveness Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. A-1
Appendix B
Written and Oral Comments
. . . . 8.' . . . . . . . . . . . . . . . . . . . . . . . .
Appendix C
Administrative Record Index. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. C-1
LIST OF FIGURES
1-1
Location of FEMP Facility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
1-2
FEMP Site Perspective. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
8-1
Comparison of Schedules for Alternatives 1, 2, and 3 .................,.. 22
LIST OF TABLES
5-1
Total Volume of OU3 Materials. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 9
7-1
Potential Decontamination Technologies. . . . . . . . . . . . . . . . . . . . . . . . . . .. 15
7-2
Interval Period Debris Bulk Volume Estimates. . . . . . . . . . . . . . . . . . . . . . . .. 18
8-1
OU3 Remediation Cost Comparison. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . .. 24
9-1
Summary of Cost Estimate for Implementing the Selected Remedy. . . . . . . . .. 26
24
25
27
27
27
31
32
32
32
33
33
33
34
B-1
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OU3 Decision Summary (Final)
v
June 1994
NOTATION
Abbreviations, Acronyms, and Initials
.c:
ADM
AEC
ALARA
,;
ARAR(s)
CERCLA
CFR
CSF
DOE
DOT
EE/CA
EIS
EPA
FEMP
FFCA
FMPC
FONSI
FR
FRESH
FS
HVAC
HWMU
IROD
MCL(s)
MCLG(s)
NCP
NCRP
NEPA
NTS
O&M
OAC
OEPA
OSHA
OU3
OU4
OU5
Action Description Memorandum
Atomic Energy Commission
as low as reasonably achievable
applicable or relevant and appropriate requirement(s)
Comprehensive Environmental Response, Compensation, and Liability Act of
1980
Code of Federal Regulations
central storage facility
United States Department of Energy
United States Department of Transportation
engineering evaluation/cost analysis
environmental impact statement
United States Environmental Protection Agency
Fernald Environmental Management Project
Federal Facilities Compliance Agreement
Feed Materials Production Center
finding of no significant impact
Federal Register
Fernald Residents for Environmental Safety & Health
feasibility study
heating, ventilating, and air conditioning
hazardous waste management unit
Record of Decision for Interim Remedial Action
maximum contaminant level(s)
maximum contaminant level goal(s)
National Oil and Hazardous Substances Pollution Contingency Plan,
40 CFR Part 300 .
National Council of Radiation Protection and Measurements
National Environmental Policy Act
Nevada Test Site
operation and maintenance
Ohio Administrative Code
Ohio Environmental Protection Agency
Occupational Safety and Health Administration
Operable Unit 3
Operable Unit 4
Operable Unit 5
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OU3 Decision Summary (Final)
PCB(s)
PEIC
RCRA
RD/RA
RI
RI/FS
ROD
S.R.
SARA
SBDC
STEP
SVOC(s)
TBC
TSS
USC
VOC(s)
vi
June 1994
polychlorinated biphenyl(s)
Public Environmental Information Center
Resource Conservation and Recovery Act
Remedial Design/Remedial Action
remedial investigation
remedial investigation and feasibility study
Record of Decision
"
State Route
Superfund Amendments and Reauthorization Act of 1986
Small Business Development Center
Science, Technology, Environment, and the Public
semivolatile organic compound(s)
to be considered
tension support structure
United States Code
volatile organic compounds(s)
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OU3 Decision Summary (Fina/)
1
June 1994
1.0 SITE NAME, LOCATION, AND DESCRIPTION
The Fernald Environmental Management Project (FEMP) or "the site" is located on a
1 ,050-acre site' in a rural agricultural area about 18 miles northwest of downtown Cincinnati,
Ohio (Figure 1-1). The site is near the villages of Fernald, New Baltimore, New Haven, Ross,
and Shandon, Ohio, located west and south of Ohio State Routes (S.R.) 128 and 126,
respectively. The street address of the Fernald site is: 7400 Willey Road, Fernald, Ohio
45030.
The FEMP is a government-owned, contractor-operated federal facility that produced
high-purity uranium metal products for the U.S. Department of Energy (DOE) and its
predecessor agencies during the period 1952-1989. Thorium also was processed, but on a
smaller scale, and still is stored on the site. Production activities were stopped in 1989, and
the production mission of the facility was formally ended in 1991.
Approximately 200 buildings and structures are located at the site and are all included
in the scope of Operable Unit 3 (OU3). Most of these structures are located within the former
Production Area, which occupies about 136 acres near the center of the FEMP site (see
Figure 1-2). Most buildings on-site are generally steel frame structures with transite siding,
concrete block structures, or pre-engineered facilities with metal siding and roofing. The
tallest building on-site is approximately 100 feet high and the tallest structure, the Elevated
Water Storage Tank, is about 265 feet high.
Most facilities and structures rest on a relatively flat plain about 580 feet above mean
sea level. The elevation slopes slightly toward Paddys Run, a small intermittent stream on the
west side of the site. Natural drainage at the FEMP generally flows from east to west, with
the exception of the extreme northeast corner, which drains east toward the Great Miami
River.
A portion of the FEMP property along the north-south corridor of Paddys Run at the
site lies within the 100- and 500-year floodplain. On-site surface waters are confined to
Paddys Run and its unnamed tributaries and total approximately 8.9 acres. Results from a
site-wide wetlands delineation indicate a total of 35.9 acres of freshwater wetlands on the
site. The Great Miami Aquifer is the principal aquifer within the FEMP study area and has
been designated a sole-source aquifer under the provisions of the Safe Drinking Water Act.
The land adjacent to the FEMP is primarily devoted to open land use such as agriculture
and recreation. There is some commercial activity adjacent to the site such as a panel truss
company and several nursery suppliers. However, the majority of commercial activity is
generally restricted to the village of Ross, approximately 2 miles northeast of the facility, and
along S.R. 128 just south of Ross. Industrial usage is concentrated in the areas south of the
FEMP, along Paddys Run Road, in Fernald, and in a small industrial park on S.R. 128 between
Willey Road and New Haven Road. Open acreage on the FEMP is currently being leased to
local dairies for livestock grazing, but there are no areas within the FEMP boundaries
, As defined by the Amended Consent Agreement (EPA 1991a) and used in this Record of Decision for Interim
Remedial Action, the term "site" refers to all areas within the property boundary of the FEMP (1050 acres) and
any other areas that received or potentially received hazardous substances, pollutants, contaminants, or hazardous
constituents. "Off-site" refers to all areas not included in this definition of "site."
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OU3 Decision Summary (Final)
2
June 1994
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FIGURE 1-1 Location of the FEMP Facility
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FEMP Site Perspective
The sewage treatment
IR 10CAtAd on the e:l~nt shown In the circle
s side of the FEMP.
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OU3 Decision Summary (Final)
4
June 1994
considered to be prime farmland under the Farmland Protection Act of 1981.
Concemrations of residential units are situated northeast of the FEMP in Ross and
southeast of the FEMP in a trailer park adjacent to the intersection of Willey Road and S.R.
128. Other residences are scattered around the area, generally in association with
farmsteads. An estimated 23,000 residents live within a 5-mile radius of -the FEMP.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Fernald site was constructed in the early 1950s to produce materials needed for
the nation's nuclear weapons program. The original Fernald project was developed on an
accelerated schedule by the Atomic Energy Commission (AEC) with the aid of the U.S. Army
Corps of Engineers. The site was selected in 1950, and site preparation and construction
began in May 1951. Construction of the main facilities (including ore receiving, refinery,
hYdrofluorination, hexafluoride reduction, reduction and casting, metals fabrication, special
products, pilot plant, recovery, laboratory, boiler plant, and administration) was completed in
three years, and operation began in May 1954.
This facility produced high-grade uranium metal used for plutonium production in
government reactors at Richland, Washington, and Aiken, South Carolina. Thorium was also
processed, but on a smaller scale. The site produced uranium and other special products for
37 years. .
Production activities were stopped in 1989, and the production mission of the facility
was formally ended in 1991. The Feed Materials Production Center (FMPC)2 was included
on the National Priorities List in 1989. SUbsequently the site was renamed the FEMP
reflecting its new mission of environmental restoration. This current mission is in accordance
with the requirements of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), here after jOintly referred to as CERCLA, and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
The CERCLA activities for the FEMP are defined by several agreements in addition to
the primary governing regulations, including the following:
In 1986, DOE entered into a Federal Facilities Compliance Agreement
(FFCA) with the U.S. Environmental Protection Agency (EPA) that provided
for a Remediallnvestigation/Feasibility Study (RI/FS) and remedial action at
the site.
In 1988, DOE entered into a Consent Decree with the State of Ohio that
provided for management of water pollution and hazardous wastes. This
was amended by the Stipulated Amendment to the Consent Decree, in
1993.
2 Throughout this Record of Decision for Interim Remedial Action, the acronym wFEMpw is used for this site, even
though it was known as the FMPC when in operation and also on the National Priorities List.
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OU3 Decision Summary (Final)
5
June 1994
In 1990, DOE and EPA entered into a Consent Agreement that amended the
1986 FFCA.
a
In 1991, the 1990 Consent Agreement was amended. The Amended
Consent Agreement (EPA 1991 a) defined five distinct operable units at the
site: Operable Unit 1, the Waste Pit Area (waste pits 1-6, clearwell, burnpit,
berms, liners, and soil within the operable unit boundary); Operable Unit 2,
Other Waste Units (flyash piles, other south field disposal areas, lime sludge
ponds, solid waste landfill, berms, liners, and soil within the operable unit
boundary); Operable Unit 3, the Production Area; Operable Unit 4, Silos 1-4
(silos 1-4, berms, decant tank system, and soil within the operable unit
boundary); Operable Unit 5, Environmental Media (groundwater, surface
water, soil not included in the definitions of Operable Units 1-4, sediments,
flora and fauna). A Comprehensive Site-Wide Operable Unit was also
defined in the Amended Consent Agreement. In .addition, the Amended
Consent Agreement defined several EPA-approved removal actions which
represented major projects within OU3 and which will be coordinated with
the selected remedy from this Record of Decision (ROD).
This Record of Decision for Interim Remedial Action (subsequently referred to as the
IROD) addresses OU3, which consists of the former Production Area, production associated
facilities and equipment, and all support facilities. It incorporates all above-, at-, and below-
grade improvements, including, but not limited to: all structures, equipment, utilities, drums,
tanks, solid waste, waste products, thorium, effluent lines, K-65 transfer line, wastewater
treatment facilities, fire training facilities, scrap metal and soil piles, feedstocks, and a coal
pile.
The former Production Area occupies about 136 acres near the center of the site and
contains many buildings, scrap metal piles, containerized materials, storage pads, a parking
lot, roads, railroad tracks, above-ground and underground tanks, utilities, and equipment.
Several impoundments, ponds, and basins are also included. OU3 does not specifically
include the soil and groundwater under the various facilities. These environmental media are'
important as potential pathways between sources of contamination in the operable unit and
the various potential receptors. Soil and groundwater remediation will take place as part of
Operable Unit 5 (OU5).
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
At the FEMP. selection of the interim remedial action for OU3 was conducted in
accordance with the requirements of CERCLA. The Proposed Plan/Environmental Assessment
for Interim Remedial Action (DOE 1993c) was developed and submitted to the public for
review and comment on December 8, 1993. A notice of availability for a 30-day public
comment period was published on December 8, 1993 in the legal section of the Cincinnati
Enauirer, Hamilton Journal-News, and Harrison Press newspapers. In an attempt to notify a
larger segment of the public, display advertisements were run in the same three newspapers
on December 15, 1993 announcing the public comment period and the public meeting held
on January 5, 1994. Also on December 15, 1993 an announcement of the public comment.
period and a fact sheet were mailed to approximately 1 ,000 stakeholders within the 3-mile
radius of the site as well as other key stakeholders and the media. An invitation
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OU3 Decision Summary (Final)
6
June 1994
advertisement for the public meeting was published in the Hamilton Journal-News and
Harrison Press on December 29, 1993 and in the Cincinnati Enauirer on January 2, 1994.
The Proposed Plan/Environmental Assessment, along with other documents in the
administrative record, have been made available for public review at the Public Environmental
Information Center, JAMTEK Building, 10845 Hamilton-Cleves Highway, Harrison, Ohio,
45030. An additional location of the administrative record is also maintained at EPA
Region 5, Waste Management Division Records Center, 77 West Jackson Boulevard, Chicago,
Illinois 60604.
()
During the public meeting on January 5, 1994, the Proposed Plan/Environmental
Assessment was discussed in detail. The format for the meeting included presentations, a
question and answer session, and a formal public comment session. During the meeting, at
the public's request, DOE extended the comment period for another 30 days until February
8,1994. Representatives from DOE and Ohio EPA (OEPA) answered questions and responded
to comments about the remedial alternatives under consideration. During the meeting both
written and oral comments were received and are attached as Appendix B of this IROD. The
transcript from this public meeting is contained in the administrative record.
Judging from the comments made during the public meeting, residents needed
additional explanation about the purpose of the Proposed Plan/Environmental Assessment as
well as more information about the preferred alternative. Issues of particular concern to the
public were material transportation, interim storage facilities, air monitoring, and integration
of the requirements of CERCLA and the National Environmental Policy Act (NEPA). To provide
more information about the regulatory process, DOE held a roundtable meeting on January 24,
1994 to discuss the CERCLA/NEPA integration approach for the site and OU3.
Based on the written and oral comments received during the 60-day public comment
period, a responsiveness summary was developed and is attached as Appendix A of this
IROD. Copies of the written and oral comments are contained in Appendix B. This decision
document presents the selected remedial action for the FEMP chosen in accordance with
CERCLA, and, to the extent practicable, the NCP. The decision for this site is based on the
administrative record; a listing of the administrative record for this decision is contained in
Appendix C.
4.0 SCOPE AND ROLE OF OPERABLE UNIT
The Amended Consent Agreement defined five operable units to organize the
evaluation and selection of appropriate actions to remediate the FEMP. The existing site
strategy for cleanup is the remediation of each individual operable unit with coordination
among the operable units with respect to treatment or disposition options, when appropriate.
The proposed interim remedial action for OU3 represents a major portion of the remedial
action for the operable unit and for the site as a whole. The OU3 RI/FS and the final OU3
remedial action ROD will contribute the remaining portion (treatment and disposition of wastes
generated by the interim remedial action) to the overall OU3 cleanup strategy.
Remedial actions for each operable unit will be coordinated to achieve overall risk
reduction for the FEMP. The selected OU3 interim remedial action will be consistent with
planned future actions for OU3 and the entire site, and will not preclude implementation of
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OU3 Decision Summary (Final)
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June 1994
the expected final remedy. The interim and final remedial actions for OU3 combined with the
other operable unit remedial and removal actions will constitute the overall remediation of the
FEMP.
(,
Many buildings. equipment and other facilities contained within OU3 exhibit levels of
radiological and other hazardous substances that exceed certain standards and guidelines for
protecting human health and the environment. The presence of these contaminants results
in ongoing exposures to workers and presents an unacceptable threat to off-site residents
through the potential for release.
While DOE maintains an active maintenance program, the former uranium processing
support facilities contained within OU3 are, in general, at or beyond their design life and in a
state of advancing deterioration. These current conditions indicate an increasing probability
of future releases of hazardous substances to the environment due to structural collapse or
other failure mechanisms. While the DOE and EPA are proceeding toward a decision on the
final disposition of these structures as part of the OU3 RI/FS process, the decision resulting
from this effort will not likely occur until late 1997.
DOE, as the lead agency for the FEMP, has the responsibility to reduce potential risks
to human health and the environment. Therefore. DOE is implementing an interim remedial
action in accordance with CERCLA and the NCP to accelerate the cleanup process within OU3
by eliminating potential sources of contaminant releases to the environment. DOE's selected
interim remedy is the decontamination and dismantlement of contaminated buildings,
equipment, and facilities within OU3. Included within the scope of this interim remedial action
is removal of all OU3 facilities. including former uranium processing buildings and equipment,
support structures, above-, at-, and below-grade utilities, and identified ponds and basins.
This action is considered reasonable due to: (1) the early opportunity to implement
cleanup actions to address the advanced state of facility deterioration and continued potential
for contaminant release; (2) the resulting reduced exposures to site workers; (3) the
substantial cost savings to the public from reduced maintenance costs; and (4) lack of a
future land use as yet identified for the OU3 facilities. Therefore, DOE considers the removal
of these facilities to be a prudent measure to ensure the protection of human health and the
environment.
An Interim Remedial Action Remedial Design/Remedial Action (RD/RA) Work Plan will
be issued subsequent to the IROD, to provide more details on how facilities are to pe
decontaminated and dismantled, consistent with the selected interim remedial alternative.
Remediation plans associated with current Removal No. 13 (Plant 1 Ore Silos) and Removal
No. 19 (Plant 7 Dismantling) will form a basis to develop and support the Interim Remedial
Action RD/RA Work Plan design. Before implementation of this interim remedial action, it is
anticipated that both of these removal actions will be complete or nearly complete. Therefore,
lessons learned from the design and implementation of these removal actions will be
incorporated into the Interim Remedial Action RD/RA Work Plan and subsequent designs.
The selected interim remedial action will be coordinated and integrated with ongoing
approved removal actions or newly identified removal actions. It is anticipated that most
removal actions will be completed before beginning the interim remedial action. The.
exceptions are the currently ongoing removal actions: Removal of Waste Inventories (Removal
No.9), Safe Shutdown (Removal No. 12), Improved Storage of Soil and Debris (Removal No.
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OU3 Decision Summary (Final)
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June 1994
17), and Asbestos Abatement (Removal No. 26). These removal actions are programmatic
in nature and represent actions being applied to the site as a whole. Each of these removal
actions is connected to the interim remedial action and requires coordination of activities to
ensure effective implementation.
Contaminated environmental media, including soils and groundwater in the vicinity of
or underlying the OU3 facilities, are being addressed within OU5, which is examining such
media on a site-wide basis. Interfaces between OU3 and OU5 will be required to ensure
removal of above-, at-, and below-grade facilities in coordination with remediation of
environmental media. OU3 interfaces with OUs 1, 2, and 4 are physically minimal due to
boundaries established around each operable unit; however, remediation activities and waste
storage facilities planning for all operable units are coordinated to maximize the use of
available resources and limited space.
The effect of this selected interim remedial action will be to isolate decisions
concerning decontamination and dismantlement activities from those concerning the final
disposition of wastes and potentially allow decontamination and dismantlement of OU3
structures and facilities to begin four years ahead of the current Amended Consent Agreement
schedule. Since the interim remedial action will remove the buildings and structures through
decontamination and dismantlement, the final remedial action ROD will not evaluate these
technologies or process options. The OU3 RI/FS will focus upon the evaluation of waste
treatment technologies, and methods and locations for the final disposition of the OU3
remediation wastes. Through implementation of this interim remedial action and the final
remedial action decision, all of OU3 will be remediated. For this document, "remediation
waste" is defined as any material generated as a result of the CERCLA interim remedial action
and is not meant to necessarily indicate the applicability of the regulatory definition to the
material.
In parallel with the completion of the OU3 RI Report, final treatment and disposal
options will be considered in the OU3 FS Report. Upon issuing the final OU3 remedial action
ROD for treatment and disposition, materials generated during the interim remedial action will
be controlled and managed to meet the requirements of the final remedial action ROD in order
to provide a total remediation approach. Discussion of this unified remedial strategy will be
provided within the RD/RA Work Plan issued subsequent to the final remedial action ROD.
To support this decision, DOE developed a Proposed Plan/Environmental Assessment
which evaluated remedial alternatives and documented the preferred alternative for interim
remedial action. To provide a NEPA review for the action, the Proposed Plan/Environmental
Assessment was written to incorporate NEPA values at the level of an Environmental
Assessment. Based on the analyses in the Proposed Plan/Environmental Assessment, DOE
has determined that the selected interim remedial action is not a major Federal action
significantly affecting the quality of the human environment, within the meaning of NEPA.
Therefore, the preparation of an Environmental Impact Statement is not needed and DOE will
issue a finding 01 no significant impact (FONSI).
II
5.0 S.UMMARY OF SITE CHARACTERISTICS
The processes and operations within the former Production Area at the FEMP required
the use of a variety of source feed materials and other radioactive and chemical materials for
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OU3 Decision Summary (Final)
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June 1994
both production and secondary operations. The production operations also generated a wide
variety of waste materials containing both radiological and chemical constituents. During
operations at the FEMP, material handling procedures resulted in chemical and radiological
contamination within many OU3 facilities. As a result, these facilities may serve as current
and future sources of environmental contamination.
Table 5-1 presents the volumes of materials estimated to be within the scope of OU3.
All of the materials have been grouped into the major categories listed under media. The
second column gives the estimated volumes of materials provided in the FEMP Waste
Information Manual (DOE 1993a) and portrays in-place volumes as the materials exist in their
current state. The third column represents estimated bulking factors from the Proposed
Plan/Environmental Assessment (DOE 1993c) that would apply to in-place volumes after
dismantlement actions occur. This results in a total estimated bulked volume as depicted in
the fourth column. The bulking factors represent the anticipated increase to the volume of
materials as a result of the dismantlement activities.
Table 5-1 Total Volume of OU3 Materials
In-Place Bulking Total Bulked
Media Volume (cubic yards) Percent (%) Volume (cubic yards)
Concrete 88,000 130 114,000
Cement Block 11 ,000 130 14,300
Steel 2,100 300 6,300
Transite 1 ,500 120 1 ,800
Other Metal 5,600 200 11 ,200
Soil/Rubble 36,000 100 36,000
Asphalt 16,500 130 21 ,500
Other 110,000 200 220,000
Total 270,700 425,100
The following subsections present an overview of contaminant pathways and exposure
routes and existing information on chemical, radiological, and mixed waste contamination
associated with the OU3 facilities. This summary is based upon data presented in the OU3
RI/FS Work Plan Addendum (DOE 1993d) wherein additional information is available.
5.1
Potential Contaminant Pathways and Exposure Routes
From the sources of contamination in OU3, contaminants could potentially migrate via
numerous pathways to reach potential receptors. Each pathway that potentially could
contribute significantly to overall risks if OU3 remediation is not undertaken is detailed below.
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OU3 Decision Summary (Final)
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June 7994
. Air: Removable contamination from building surfaces, equipment,
containerized waste, piles of waste and contaminated soils could be
suspended into the air as particulates by wind action or by human action.
Exposure routes for the air pathway could include inhalation, dermal
contact, and ingestion.
Groundwater: Material from OU3 components could cause groundwater
contamination through direct leakage from buildings and structures to
perched groundwater and leaching of contaminants from soils surrounding
buildings and structures. Exposure routes for the groundwater pathway
could include ingestion, inhalation and dermal contact during showering,
human consumption of livestock and crops that used groundwater, and
dermal contact during incidental activiti~s.
Surface Water and Sediments: Surface waters and associated sediments
of Paddys Run and its tributaries could be contaminated by runoff from
leaks or spills, the erosion of contaminants from soil piles, and the
deposition of contaminated particulates originating from building and
storage pad surfaces. Exposure routes for this pathway could include direct
human consumption of contaminated water, dermal contact during
recreational activities (e.g., swimming), incidental sediment ingestion, direct
radiation exposure, consumption of livestock watered with contaminated
surface waters, consumption of crops irrigated with contaminated surface
waters, and consumption of fish from contaminated surface waters.
Soil: Soils represent a potential exposure pathway to human receptors via
incidental ingestion, pica, dermal contact, and direct radiation. However,
soils are not considered a primary source of contamination in OU3 because
environmental media are addressed under OUS.
Direct Contact: Direct contact allows the direct transfer of contaminants
from waste materials or contaminated components to a receptor. This may
take place through direct irradiation from contaminated building materials
or direct exposure to contaminated components or wastes by dermal
contact or ingestion.
5.2
Radiological Contamination
Historical information and process knowledge indicate that the primary radiological
contaminants in OU3 are uranium (isotopes 234, 235, 236, 238, and, to a lesser degree,
233), thorium (isotopes 228, 230, and 232), radium (isotopes 226 and 228), and the
associated daughters, including isotopes of lead and polonium. Additional radionuclides within
OU3, which have been identified through analysis, include isotopes of neptunium, plutonium,
technetium, strontium, cesium, and americium.
Through the ongoing radiation protection program at the FEMP, radiation data on most
structures is available. As part of this program, the following radiological information was
collected:
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OU3 Decision Summary (Final)
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June 1994
Radiation smear and direct measurements for many individual OU3
structures,
Smear and direct survey information on some abandoned in-place
equipment,
Radon-222 and radon-220 monitoring, and
Airborne alpha and beta radiation concentrations.
,)
It should be noted that although some radiological information is available for most
structures and facilities, not all of this radiological information is currently available for every
structure or facility within OU3, and speciation of radioactive isotopes is generally not
available at the current time. .
5.3
Chemical Contamination
Current data on chemical contamination within OU3 is based on chemical analyses and
process knowledge for the 37 years of operations. This data is largely qualitative in nature,
and is presented in the OU3 RifFS Work Plan Addendum. The Information presented in
Appendix B of the OU3 RifFS Work Plan Addendum represents potential contamination which
may be present in the facilities. Additional characterization of OU3 including chemical
contamination data will be gathered as part of ongoing RI activities. This data will be
integrated with the remedial design activities to implement the selected interim remedial
action.
Several classes of chemical or contaminant groups of potential environmental concern
may exist in OU3. Principal chemical contaminant groups of concern are trace metals, other
inorganics, volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs),
asbestos, polychlorinated biphenyls (PCBs), and other materials such as oils used for
lubricating and heat treating. Based on the materials and relative volumes of the materials
used at the site during operations, it is expected that radiological contaminants are a more
significant source of carcinogenic risk than chemical contaminants.
Field characterization activities are scheduled to precede the selected interim remedial
action. The results from the field characterization will be used in developing the design to
implement the action for each component. Data will be used to develop health and safety
requirements and to design monitoring, decontamination, dismantlement, packaging,
transportation, and storage systems. Use of appropriate field monitoring equipment will be
employed during implementation of the selected interim remedial action to minimize worker
exposures. .
5.4
Hazardous Waste Management Units
The Resource Conservation and Recovery Act (RCRA) program at the FEMP currently
identifies a total of 43 Hazardous Waste Management Units (HWMUs) (36 inactive and 7
active units for storage of hazardous waste during remediation) within OU3. The closure
strategy for these HWMUs is currently being negotiated with OEPA. The lead approach in the
negotiations would employ three different closure strategies. Clean closure is anticipated to
be complete for 17 of the inactive units before the interim action field activities begin within
that unit/component. The remaining 19 inactive units would be remediated under the
CERCLA/RCRA integration process associated with the selected interim remedial action, which
is currently being developed. Each of the seven active units would be closed under RCRA
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OU3 Decision Summary (Final)
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June 1994
after hazardous or mixed waste storage is no longer required of these units and notice of
intent to close has been provided to OEPA.
5.5
Mixed Waste
Mixed wastes are hazardous (RCRA) wastes that also include radiological
contaminants. Radiological contamination appears to be relatively widespread throughout
many structures in OU3. Based on past materials handling practices and potential chemical
contaminants, some of the materials and wastes associated with OU3 facilities may fall into
the category of mixed waste. Mixed wastes resulting from the selected interim remedial
action will be managed in accordance with RCRA requirements. The volumes of material
included in this category are currently uncertain.
6.0 SUMMARY OF SITE RISKS
OU3 consists of over 200 buildings and structures, including the process and support
facilities at the FEMP, a large quantity of drummed inventory and waste, and various piles of
soil and scrap metal. In particular, the process facilities are complex chemical and
metallurgical process plants that contain equipment, process lines, dust collectors, and various
tanks, sumps, and dikes. OU3 contains no environmental media except for previously
excavated soil piles; the contaminated media in OU3 are generally the construction materials
contained in the structures. Although DOE maintains an active maintenance program, the
facilities in OU3 are generally at or beyond their design lives and in a state of advancing
deterioration. For example, long-term exposure to nitric acid fumes and splashes from the
uranium digestion process contained in Plant 2/3 has eroded the building support structure.
Additionally, areas of Plant 6 and the thorium storage buildings (64 and 65) are in a
deteriorated state and provide insufficient long-term protection of their contents from the
elements. Various sumps contain contaminants that could potentially be released to soils or
groundwater. Significant maintenance and renovation would be required in the future simply
to maintain the integrity of the structures, without guarantee of contaminant immobility.
On the basis of process knowledge, the most significant potential contaminants in OU3
are expected to be uranium and thorium and their decay products, along with various trace
metals, solvents, PCBs, and asbestos. These contaminants are expected to be located
primarily in the former processing and maintenance buildings and in waste residues, though
asbestos occurs in most of the original. buildings at the site.
Under current conditions, the primary routes by which individuals could be exposed to
OU3 contaminants are direct radiation, inhalation, and absorption of the contaminants present
in the OU3 structures. Small quantities of contaminants, such as uranium dust, could be
released to the air and discharged to surface water from sources in the operable unit. Also,
a potential exists for releases of contaminants to groundwater from building sumps, buried
piping, or other contaminated equipment.
Exposures of on-site workers and site visitors to contaminants could occur, as could
the exposure of any trespassers in OU3. However, because DOE controls access to the site
at this time, trespassers are not expected to have access to contaminated areas in OU3. On-
site workers currently have the highest likelihood of significant exposure to OU3
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OU3 Decision Summary (Final)
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June 1994
contaminants. Radiological doses to individuals currently working on-site are limited by DOE's
standards and actual individual doses are relatively low compared to those standards.
.,
Nearby off-site residents and users of foodstuffs produced near the site are potentially
exposed to contaminants released from OU3. However, risks associated with exposures to
OU3 contaminants are currently low for such off-site residents. It is estimated that a
hypothetical maximally exposed off-site individual currently receives a total annual radiological
dose from the FEMP (exclusive of the dose received from radon, which originates primarily
from non-OU3 sources) of about 1 millirem as referenced in the 1992 Site Environmental
Report (DOE 1993e). This dose corresponds to an excess risk of about 6 x 10-7 that such a
hypothetical individual will develop cancer as a result of the exposure. This dose is equivalent
to the natural radiation exposure received by an individual flying in an airplane at 39,000 feet
for approximately two hours. Because OU3 contributes only a fraction of the 1 millirem
annual dose from the site as a whole, this estimate provides an upper bound on the
carcinogenic risk to an off-site individual that results from radiological contaminants from
OU3. This is a small fraction of the dose received by the individual as a result of exposure
to natural background radiation.
Carcinogenic risks associated with exposures to chemicals from or within OU3 are
expected to be less than the risks associated with the exposures to radiological contaminants,
on the basis of the materials utilized at the site. Non-carcinogenic effects of exposures to
chemical contaminants from or within OU3 have not been quantified but are also expected
to be low. In its current state, OU3 poses no significant threat to human health as long as
access controls of contaminated areas are maintained and facilities and waste storage
systems are maintained.
However, significant release of contaminants and resulting exposures could occur if
no remediation of OU3 is undertaken, even if access controls are maintained. The major
concern for OU3 is the potential for increased future risks as structures further deteriorate,
increasing the potential for the release of contaminants. Actual or threatened releases of
hazardous substances from OU3 in the future may present an imminent and substantial
endangerment to public health, welfare, or the environment.
7.0 DESCRIPTION OF ALTERNATIVES
Interim remedial action alternatives were developed in accordance with the NCP (40
CFR 300) and EPA's Guidance for Conducting RifFS Under CERCLA (EPA 1988). A "No
Action n alternative was considered in the Proposed Plan/Environmental Assessment which
represented an "as is" condition for all facilities in OU3 with no further action occurring.
Under that alternative, none of the approved removal actions, other future remedial actions,
or maintenance activities would have been implemented. All facilities would have been
abandoned and allowed to deteriorate further, with resulting increased probability for releases
of radioactive and other contaminants to the environment. Because no action would occur
and the NCP threshold criterion for overall protection of human health and the environment
would not be met, the No Action Alternative was screened from further consideration. The
following subsections identify the interim remedial action alternatives considered under this
IROD.
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OU3 Decision Summary (Final)
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June 1994
7.1
Alternative 1 -- No Interim Action
The "No Interim Action" Alternative involves the continuation of all currently approved
programs. No acceleration of site remediation would occur under this alternative. This
alternative assumes that existing and approved removal actions and site maintenance
programs would continue. As required, additional removal actions might be proposed to
minimize potential risks. Other than ongoing maintenance activities and approved removal
actions, no further containment, stabilization, or removal of contamination within facilities
would be included in the scope of this alternative. Final remedial action for OU3 facilities
would be determined in the final remedial action ROD, presently scheduled for submittal in
draft to EPA in April 1997. This alternative would not incur additional costs and is considered
the baseline for cost comparison.
7.2
Alternative 2 -- Decontaminate Surfaces Only
Alternative 2 involves in-situ gross decontamination of interior and exterior surfaces
of OU3 above-grade structures and disposition of generated wastes through existing waste
programs. In-situ decontamination of facilities within OU3 would be pursued to minimize
releases of contaminants to the environment. This alternative would reduce existing surface
contamination levels, thereby reducing direct exposure potential, as well as reducing available
sources for wind-borne or water-b.orne contamination. All previously approved programs,
maintenance activities, and presently approved removal actions would continue under this
alternative. As required, additional removal actions might be proposed at some future time
to further minimize potential risks.
The methods that would be used for removing gross surface contamination would
depend on the type and lev~1 of contamination present and the matrix on which it is found (for
example, concrete block, transite, steel, etc). Surface decontamination technologies would
be selected from proven and effective techniques. Surface decontamination measures would
be used to remove contamination from interior and exterior walls, floors, ceilings, and
structural members. Vacuum systems and/or directed air flow would be utilized in order to
reduce the potential for contaminant release and migration during the decontamination
activities. Table 7-1 lists a variety of proven, potential decontamination technologies that
would be effective for use with the implementation of the action. The ultimate selection of
decontamination technologies would not be limited to these listed. New and/or innovative
technologies developed from the OU3 RifFS Treatability Studies would be incorporated into
the process as appropriate.
Secondary liquid and/or solid waste streams generated during implementation of
Alternative 2 would be treated to the extent feasible using existing site systems in a manner
fully compliant with applicable or relevant and appropriate requirements (ARARs) and to be
considered (TBC) criteria identified in Section 10.2 to facilitate the action in a manner which
is timely apd protective of human health and the environment. All activities performed will
be in compliance with health and safety regulations and will follow the principles of ALARA
(as low as reasonably achievable). Decontamination actions within HWMU areas would be
separated from actions in non-HWMU areas to minimize generating mixed wastes.
After completion of this action, substantial removable contamination could exist in,
under, and around equipment, corners, roofs, utilities, and piping. An additional
decontamination procedure would then be necessary during dismantlement activities under
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OU3 Decision Summary (Final)
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June 1994
the final remedial action ROD. . Additionally, after decontamination the structures would
remain in their current state of structural deterioration with ongoing maintenance activities
potentially contaminating areas previously decontaminated.
It is estimated that about 900,000 person-hours would be required to implement
Alternative 2. Using an assumption for reasonable funding levels, it is estimated that
decontamination activities would take about 4 years and utilize approximately 108 full-time
workers. This alternative would cost an estimated $82 million (in 1994 dollars).
7.3
Alternative 3 -- Decontaminate and Dismantle
Alternative 3 primarily involves the decontamination and dismantlement of all OU3
facilities and structures and the interim storage of the resulting wastes until the final remedial
action ROD. Implementing Alternative 3 would effectively separate remedial action decisions
concerning the decontamination and dismantlement of OU3 structures from decisions
concerning material and/or waste treatment and disposition. Generally, waste and material
treatment and disposition would be addressed by the ongoing RI/FS process with a decision
provided in the final remedial action ROD for OU3. All activities performed will be in
compliance with ARARs and health and safety regulations and will follow the principles of
ALARA (as low as reasonably achievable).
Generally before implementation of the interim action within a facility, preparatory
actions will have been completed. The Safe Shutdown removal action, for example, will
probably have completed its assigned actions, the existing drummed wastes and inventories
will have been removed previously (either dispositioned off-site or relocated to storage
TABLE 7 -1 Potential Decontamination Technologies
Technology
Media
Secondary Waste Stream
Brushing, scraping, wiping
Scrubbing (manual or
mechanical)
Any solid
Concrete, metal, plastic,
transite
Dry residue
Residue
Scabbling
Vacuuming
Concrete
Concrete residue
Any
Collected. residue
Pressurized. steam
Concrete, metal
Any surface
Wet residue
Coating and contaminants
Strippable coating
Water jet (high or low
pressure)
Concrete, metal, plastic,
transite
Contaminated water
. Shot blasting
Grit blasting
Metals, concrete
Metals, concrete
Shot and residue
Chemical foams, gels,
pastes
Concrete, metals, plastic,
painted surfaces
Metals
Grit and residue
Residue
CO2 pellet blasting
Foams, gels, pastes, and
removed contaminants
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OU3 Decision Summary (Final)
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June 1994
facilities), and, where appropriate, friable asbestos will have been removed under the
Asbestos Abatement removal action. Facilities that are bein~: used for storage of drummed
wastes will likely be remediated last unless stored materials within it can be permanently
dispositioned.
The primary scope of Alternative 3 is removal of gross surface contamination from
material in structures, dismantlement of structures, and interim storage of the resulting
material! wastes. Gross surface decontamination for this alternative would be identical to the
techniques described under Alternative 2. To the extent practical, all efforts would maximize
recycling and minimize waste generation. In order to facilitate the implementation of the
interim remedial action and prevent constraints due to storage space limitations, a limited
quantity of wastes would be shipped off-site to the Nevada Test Site (NTS).
After decontamination, the next step in the sequence of implementing the interim
remedial action is the dismantlement of the structures. Most of the facilities associated with
this action are buildings. The remaining various structures include such items as tanks,
utilities, storage pads, roads, railroads, ponds and basins. Because many of the buildings and
other structures are unique in terms of construction type and past use, dismantlement
methods would vary with both building/structure type and configuration. Six main building
types are identified as generally representative of buildings at the site:
Structural steel with transite siding and roofing facilities (tor example, Plants
4, 5, 6, and 9);
Concrete block with built-up or composite roofing (for example,
Administration building and Services building);
Pre-engineered facilities with metal siding and roofing (for example, the
newer RCRA storage warehouses);
Wood frame with wood siding and metal roofing structures (for example,
the guard houses);
Tension support structures; and
'. Open steel frame structures (for example, the Nitric Acid Recovery tower).
Decontamination and dismantlement procedures would be customized to deal with the
unique features of any structure, as well as specific contaminants identified, action-specific
ARARs, and HWMUs located within the structure.
The following procedure presents an example applicable to the dismantlement of a
typical process building. The action would begin by removing yard structures and various
exterior equipment and machinery that could restrict heavy equipment mobility and wall-
removal operations. The surface decontamination process would typically begin with sealing
off the structure or areas of the structure and applying directed air flow or negative pressure
filtration to control airborne particles. A variety of surface decontamination techniques would
then be employed to reduce the potential for generation of airborne contaminants during
structure dismantlement. The dismantlement process of the facilities themselves would
typically begin with the removal of asbestos materials followed, generally, with the removal
of electrical equipment, piping, water lines, gas lines, tanks, heating, ventilation, and air
conditioning (HVAC) duct work, and electrical lines. Depending on the structure, the specific
dismantling activities may vary. For instance, the removal oftransite panels would, generally,
proceed from within the building outward. The last steps of the dismantling action would be
:\
9
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OU3 Decision Summary (Final)
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June 1994
the removal of any air filtration apparatus and the removal of the roof, exterior walls, and
internal structural members.
After above-grade decontamination and dismantlement, foundations, slabs, and pads
would be decontaminated or stabilized to minimize further soil contamination. Removal of
foundations, slabs, pads, and subsurface utilities (pipes, electrical lines, etc.) would be
scheduled to coincide with OU5 remedial actions involving soil excavation and treatment.
Materials resulting from dismantlement of the facilities would be segregated into two
groups: one would go to interim storage facilities until the final remedial action ROD for OU3;
the other would be containerized and transported off-site. Materials segregated for disposition
off-site would either be recyclable/reusable materials or non-recyclable/non-recoverable
materials and would be subject to the 10% limitation on the quantity of materials to be
dispositioned off-site.
Evaluation factors for the determination of which materials are recoverable, recyclable,
or non-recoverable include, but are not limited to, the following: economic considerations,
available decontamination and/or treatment technologies, volume of secondary waste
generated, monitoring capabilities, applicable contamination limits, availability of uses for the
materials, and the availability of disposition options. Materials transported off-site would be
recycled or reused to the maximum extent practical. As stated, opportunities for employing
resource recovery, recycling, and waste minimization would be factored into the planning
process for each activity conducted under the interim remedial action. Materials not capable
of being recycled would be dispositioned in accordance with the applicable waste acceptance
criteria.
The remaining materials that can not be dispositioned off-site would be placed in
interim storage until the final remedial action ROD for OU3 is issued. Depending on the
material type. some sorting and packaging might be required for transportation of the
materials to interim storage. For example, asbestos insulation from ducting would be wrapped
or boxed and structural steel would probably be transported in covered dumpsters by truck.
Materials that cannot be recycled or reused and that have no potential treatment would be
packaged for final disposition at NTS before being placed in interim storage.
Table 7-2 details the estimated volume of materials from Appendix G of the Proposed
Plan/ Environmental Assessment (DOE 1993d) to be addressed by this alternative in the
interval period before the final remedial action ROD for OU3. These volumes represent the
estimated quantity of material to be managed through interim storage or off-site disposition.
c.
Dust resuspension occurring from material and waste movements on site would be
minimized by use of the existing paved roadways and the use of dust control measures, as
necessary. Loose materials would be packaged and loads would be covered during transport,
as necessary, to reduce the potential for contaminant release and migration. Concrete blocks,
structural steel. or other materials which do not have high levels of remaining removable
contamination would likely be stored without additional packaging. Specific storage
requirements for the various types of wastes and materials that would be generated by
Alternative 3 are outlined in the Removal Action No. 17 Work Plan, Improved Storage of Soil
and Debris (DOE 1993b).
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OU3 Decision Summary (Final)
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June 1994
Table 7-2 Interval Period Bulk Volume' Estimates.
Stored Volume2 Shipped Volume Potential
Media (cubic yards) (cubic yards) Disposition3 "
Concrete/Cement Block 1,600 0 N/A
Structural Steel 0 600 Recycling
Miscellaneous Metal 800 2,000 Recycling
Equipment 12,600 8,500 Off-Site Disposal
Transite 0 400 Off-Site Disposal
Other 0 5,700 Off-Site Disposal
Decontamination Residues 1,300 1 ,300 Off-Site Disposal
Total 16,300 1 8,500
, Volume is based on total bulk volume estimates without applying containerization or compaction factors.
2 Stored volume indicates materials held in interim storage for potential treatment under the final remedial action ROD.
3 The anticipated disposition for each media may change due to re-evaluation of potential treatment/decontamination
options. .
To prevent constraints on the decontamination and dismantlement action due to
storage space limitations for the resulting construction debris, a limited quantity of wastes
would be shipped off-site for disposition. A maximum of 10 percent of all remediation wastes
generated by implementing Alternative 3 (42,500 cubic yards as calculated from Table 5-1 )
would potentially be shipped off-site for disposition and recycling prior to the final disposition
decision being determined by the final remedial action ROD for the majority of wastes in OU3.
The 10 percent limitation on waste volumes allowed to be dispositioned off-site refers to 1 0
percent of the total OU3 volume of remediation wastes generated; this was chosen as a limit
which would assure that a final disposition decision would not be biased by this action.
Small quantities of non-recoverable and non-recyclable materials destined for off-site
dispositioning would be containerized, using strong-tight containers such as B-25 metal boxes
(burial volume of 4 cubic yards) and/or SeaLand containers (burial volume of 50 cubic yards),
and shipped off-site by truck for disposition at the NTS. The identification of the NTS in this
document does not preclude the use of other licensed disposal facilities once NEPA
requirements for these facilities are met. Following NEPA review, these facilities would be
considered as options for receipt of interim remedial action wastes.
The shipment of wastes would be to the extent practical to facilitate the progress of
the interim remedial action by ensuring the availability of adequate on-site storage. The
quantity of non-recoverable/non-recyclable materials estimated to be dispositioned off-site
before the final remedial action ROD is approximately 15,900 cubic yards and represents
approximately 650 truck shipments over a 3,300-kilometer trip to the NTS. However, this
does not preclude the use of rail transport if rail lines become available during the interval
period.
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OU3 Decision Summary (Final)
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June 1994
The proposed tension support structures are designed only for temporary storage with
an intended design life of 25 years, and as such cannot be used for long-term storage. The
intent of building these facilities is twofold: for use as an interim or temporary storage area
for wastes generated from the action if existing storage space is not available and for use as
a staging area to support segregation, packaging, and transportation of materials for
disposition. To minimize constructing additional interim storage facilities, available storage
space within buildings or on the Plant 1 Pad would be utilized for interim storage or staging
to the maximum extent practicable. If storage and staging space is obtained within existing
facilities, it would not be necessary to construct all of the planned interim storage structures.
The final decision for material disposal, whether on-site or off-site, to be decided as
part of the OU3 final remedial action ROD in 1997, will determine the location for disposition
of OU3 remediation wastes including materials in interim storage and the storage structures.
A decision for on-site disposition of remediation wastes would preclude the use of the interim
storage structures for permanent storage and would require construction of structure(s)
specifically to meet the stringent requirements of permanent disposal. Whether the decision
is for on-site or off-site disposal, the interim storage structures would be used only long
enough to support staging operations for remediation wastes resulting from dismantlement
activities. Therefore, the timeframe for use of the structures is dependent upon the final
decision for disposition of the OU3 remediation wastes, which is expected to be made in
1997. Once staging is no longer necessary to support remediation waste dispositioning, the
structures would be removed as part of the OU3 interim remedial action and the resulting
wastes would be dispositioned as part of the OU3 final remedial action.
If existing storage space is unavailable, the design, siting, procurement, construction,
and operation of interim storage facilities (approximately five as presently envisioned) would
be used to store the demolition debris and secondary remediation wastes generated during the
decontamination and dismantlement action. The interim storage facilities as currently
envisioned would each be approximately 100 feet wide and 400 feet long and provide
approximately 30,000 square feet of usable floor space and approximately 300,000 cubic feet
of storage space. These facilities are planned to store wastes generated from the action
because the storage space necessary to support the action is not currently available. If
storage space within existing buildings or on the Plant 1 Pad becomes available, it would be
utilized to the maximum extent possible, as opposed to construction of these storage
facilities.
Based upon estimated maximum storage capacity needs, five storage facilities, ,in
addition to the first phase of Removal Action No. 17, the Central Storage Facility (CSF), are
presently envisioned. A worst-case interim storage situation would only occur if waste
generated by the interim remedial action is not dispositioned off-site and storage space is not
available in existing facilities. This would result in the construction of five interim storage
facilities. However, it is anticipated that storage space would be available in existing facilities
and that a portion of material can be dispositioned off-site resulting in no new additional
storage facility needs.
To address the public's concern regarding a potential increase in airborne radionuclide
concentrations above natural background levels, stringent engineering controls would be
applied to ensure the safety of workers and the general public. Complementing engineering,
controls used to minimize releases, the extensive air monitoring program at the FEMP would
continue to monitor air at both the site perimeter and at nearby locations for the duration of
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OU3 Decision Summary (Final)
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June 1994
cleanup activities. Mobile air samplers would be used in work areas to ensure that airborne
activity is maintained at low levels as a supplement to the existing air monitoring program.
If airborne concentrations are detected above background levels at nearby receptor locations,
contingency measures would be implemented to reduce contaminant emissions. For example,
work could be stopped, exposed areas covered or otherwise controlled, and engineering
measures could be increased prior to restarting work to ensure that nearby members of the
general public are not exposed to unacceptable human health risks.
o
Environmental monitoring and ongoing maintenance would be conducted during all
decontamination and dismantling activities and during the interim storage period associated
with the CSF. Administrative and engineering controls would be utilized throughout
implementation of the interim remedial action to control airborne emissions, minimize releases,
and maintain a safe work environment.
Using an assumption for reasonable funding levels, preliminary estimates have indicated
that the decontamination and dismantlement action would take approximately 1 6 years to
complete and utilize approximately 160 full-time workers to perform the decontamination and
dismantlement action and other miscellaneous activities along with approximately 1 6 workers
supporting the interim storage efforts. It is estimated that about 6 million person-hours would
be required to implement Alternative 3, not including efforts related to ongoing site operations
and maintenance. The cost of this alternative, in 1994 dollars, is estimated at $1,076 million,
and includes the decontamination and dismantlement of the OU3 buildings and structures,
interim storage of debris, containers, transportation, and disposition of a limited quantity of
material and remediation waste at the NTS. This cost does not include the care-taker
maintenance costs associated with maintaining the structures each year.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In this section, Alternatives 1, 2, and 3 are compared to allow selection of a preferred
alternative. This comparative evaluation is performed based on the NCP's nine evaluation
criteria. These nine criteria fall within three categories: threshold, balancing, and modifying.
The threshold criteria are overall protection of human health and the environment and
compliance with ARARs. Unless a specific ARAR is waived, each alternative must meet the
threshold criteria in order to be eligible for selection. The five primary balancing criteria are
long-term effectiveness and permanence; short-term effectiveness; reduction of toxicity,
mobility, or volume through treatment; implementability; and cost. State and community
acceptance are modifying criteria that shall be considered in remedy selection. These criteria
are listed and briefly defined below:
Overall protection of human health and the environment addresses how the
alternative, as a whole, achieves and maintains protection of human health
and the environment.
Compliance with Applicable or Relevant and Appropriate Requirements
(ARARsJ addresses how the alternative complies with ARARs and other
information from advisories, criteria, and guidance that the lead and support
agencies have agreed is "to be considered".
Long-term effectiveness evaluates the long-term effectiveness of
alternatives in maintaining protection of human health and the environment
after response objectives have been met.
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OU3 Decision Summary (Final)
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June 1994
Short-term effectiveness examines the effectiveness of alternatives in
protecting human health and the environment during the construction and
implementation of a remedy until response objectives have been met.
Reduction of toxicity, mobility, or volume through treatment evaluates the
anticipated performance of the specific treatment technologies an
alternative may employ.
Implementability addresses the technical and administrative feasibility of
alternatives and the availability of required goods and services.
Cost evaluates the capital and operation and maintenance costs of each
alternative.
State acceptance reflects the state's apparent preferences among or
concerns about the alternatives.
Community acceptance reflects the community's apparent preferences
among or concerns about the alternatives.
OU3 structures have generally exceeded their design life and no use has been identified
for them other than support for remedial activities at the site. In time, the structures will pose
a safety hazard. Therefore, DOE proposes eventual decontamination and dismantlement of
the facilities independent of the interim remedial action implemented. As a consequence, the
comparison of Alternatives 1 , 2, and 3 presented here assumes eventual decontamination and
dismantlement of OU3 facilities. This assumes that if Alternative 3 is not implemented, then
decontamination and dismantlement will occur under the final remedial action. The
comparative evaluation of the alternatives for interim remedial action is summarized in
Sections 8.1 through 8.9.
8.1
Overall Protection of Human Health and the Environment
Without eventual remediation, protection of human health and the environment could
not be ensured for the extended future because, over time, contaminants could migrate via
groundwater and be released via air to off-site receptors, resulting in possible impacts.
Therefore, through either the interim or final remedial action for OU3, each alternative would
eventually involve decontamination and dismantlement of OU3 facilities, but at differing time
periods. Because remediation of the facilities would ultimately occur, each alternative would
be protective of human health and the environment after remediation has begun.
8.2
Compliance with Applicable or Relevant and Appropriate Requirements
The NCP (40 CFR 300.400) identifies two categories of requirements which must be
identified by the lead and support agencies for a remedial action, ARARs and TBC criteria.
Applicable requirements are those which upon an objective determination specifically address.
a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance found at a CERCLA site. Relevant and Appropriate requirements are those
which, while not applicable to a specific release, may still address problems or situations
sufficiently similar to the circumstances of the release or remedial action contemplated and
be well-suited to the site.
In addition to ARARs, the lead and support agencies may, as appropriate, identify other
advisories, criteria, or guidance to be considered for a particular release. The TBC category.
consists of advisories, criteria, or guidance that were developed by EPA, other federal
agencies, or stat,es that may be useful in developing CERCLA remedies.
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OU3 Decision Summary (Final)
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June 1994
Assuming that facilities are eventually decontaminated and dismantled, each alternative
would comply with the ARARs identified in Section 10.2 during the decontamination and
dismantlement activities. However, during the period before the final remedial action ROD,
Alternatives 1 and 2 would allow the buildings to continue to age, weather, and deteriorate,
resulting in the potential for public exposure to airborne contaminants and contaminant
releases to air, surface water, and groundwater. Therefore, Alternatives 1 and 2 may not
adequately comply with ARARs before the final remedial action ROD. However, in accordance
with the NCP 300.430 (f}(ii}(C}(1), an alternative that does not meet an ARAR can be selected
if the alternative is an interim measure that will become part of a total remedial action that
will attain the ARAR.
8.3
Long-Term Effectiveness and Permanence
This criterion addresses the results of a remedial action in terms of the risk remaining
at a site after response objectives have been met. For an interim remedial action, no actions
are intended to achieve final remediation. For this reason, long-term effectiveness is not
meaningful in the context of an interim remedial action. The evaluation of alternatives with
resRect to this criterion will be performed in the OU3 FS to be completed in support of the
final remedial action ROD.
8.4
Short-Term Effectiveness
Each alternative would be effective in protecting human health and the environment
during remediation through the use of engineering and administrative controls, assuming that
decontamination and dismantlement of OU3 facilities would eventually occur for
Alternatives 1 and 2. However, a potential exists for increased risks to human health and
impacts to the environment associated with the delayed remediation for Alternatives 1 and 2.
Accelerating the decontamination and dismantling activities using Alternative 3 would allow
remedial action objectives to be achieved sooner and would provide protection against threats
earlier than Alternatives 1 or 2. It is estimated that the implementation of Alternative 3 would
allow completion of remediation in the year 2012, in comparison to completion under the final
remedial action ROD in the year 2016. Figure 8-1 compares schedules for the three
alternatives and details the potential for early remediation offered by Alternative 3.
Additionally, acceleration of the remediation within the Production Area may allow the
advancement of the remediation of OU5 soils and perched groundwater underneath the
. Production Area.
Alternative 1
Decontaminate and Dismantle (16 Vears)
(Final Action)
. I
Alternative 2
Surface
. Decontaminat~ I
(Interim Action)
Decontaminate and Dismantle (16 Years)
(Final Action)
I.,
Alternative 3 .
Decontaminate and Dismantle (16 Vears)
(Interim Action)
. I
I
1996
I
2000
I
2004
I
2008
I
2012
I
2016
FIGURE 8-1 Comparison of Schedules for Alternatives 1, 2, and 3
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OU3 Decision Summary (Final)
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June 1994
8.5
Reduction of Toxicity, Mobility, or Volume Through Treatment
Assuming eventual decontamination and dismantlement of facilities independent of
which alternative is selected, all three alternatives would result in gross surface
decontamination. Decontamination is a form of physical treatment, which does not fix the
contaminants in the host media, but merely transfers them to a secondary medium. Storage
or treatment would be used to manage removed contaminants collected in a secondary waste
stream, thereby reducing contaminant mobility. Remediation waste residues from the
decontamination process would be treated using existing on-site facilities. Because each
alternative would eventually result in a reduction of contaminant mobility through
decontamination, a comparison of alternatives requires an evaluation of the impacts of timing.
In the period before final remediation, Alternative 1 and 2 could potentially result in additional
contamination of soil and groundwater, increasing the volume of contaminated material at the
site. In addition, under Alternative 2, two surface decontamination efforts would ultimately
be required (during interim remedial action and final remedial action) and could result in an
increased volume of decontamination waste.
Alternative 3 would reduce the mobility of contaminants by containing and managing
removed contaminants in a secondary waste stream. Additionally, Alternative 3 would
minimize the potential for an increase in volume of contaminated material due to migration of
contaminants during the period before remediation is complete and would minimize the volume
of decontamination residues and other remediation wastes.
8.6
Implementability
Alternative 1 would be the easiest to implement because it would require no action in
the short-term with all remediation occurring under the final remedial action. However,
continuing to use removal actions to proceed with cleanup would require duplication of
studies, documents, regulatory reviews, and public comment periods for similar actions.
Alternatives 2 and 3 would use proven and reliable technologies, although the scope
for Alternative 3 would be considerably larger than the scope of Alternative 2. In the long
term, assuming eventual decontamination and dismantlement of OU3 facilities,
implementability issues associated with the action would be similar for all alternatives.
8.7
Cost
Costs associated with implementing each of the alternatives are presented in
Table 8-1. The base cost, as discussed in Section 7, is the 1994 dollar value to implement
the alternative itself. The total cost for Alternative 3 includes the costs for performing the
alternative plus the costs for site maintenance and monitoring. In addition, the total costs for
Alternatives 1 and 2 include the costs for performing the alternative plus the costs of eventual
decontamination, dismantlement, and interim site maintenance and monitoring.
A second method of cost comparison presented in Table 8-1 utilizes a present worth
analysis instead of comparing costs in 1994 dollars. A present worth analysis calculates the
amount of money that would have to be invested today in order to pay for the cleanup over
the entire duration of the project. The real discount rate applied in the present worth analysis
is based on the October 1992 Office of Management and Budget's recommended value of 4.4
percent for a 20-year project (1996-2016).
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OU3 Decision Summary (Final)
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June 1994
The differences in overall costs for the alternatives result from four additional years of
costs associated with the maintenance and monitoring of the structures and related facilities
while they remain in place (including security forces, utilities, etc.).
TABLE 8-1 OU3 Remediation Cost Comparison (Millions of 1994 Dollars)
Alternative Base Cost Total Cost Present Worth
1 -- No Interim remedial action $0 $2,520 $1,548
2 -- Surface Decontaminate Only $82 $2,602 $1,619
3 -- Decontaminate and Dismantle $1,076 $2,164 $1,476
Assuming eventual decontamination and dismantlement of OU3 facilities, Alternative
3 would result in the lowest overall cost. Alternatives 1 and 2 would be more costly due to
costs associated with the continuing operation and maintenance of the site for an additional
number of years. Additionally, for Alternative 2, the costs would increase due to the
assumption that the decontamination effort would be repeated prior to the dismantlement of
the structures under the final remedial action ROD. This effort would likely be required to
meet the health and safety requirements of the remediation activities. It is anticipated that
substantial removable contamination will remain in, under, and around equipment, corners,
roofs, utilities, and piping following decontamination in Alternative 2.
8.8
State Acceptance
The State of Ohio supports the preferred alternative, decontaminate and dismantle, as
identified in the Proposed Plan/Environmental Assessment.
8.9
Community Acceptance
The DOE solicited input from the community on the OU3 Proposed Plan/Environmental
Assessment for Interim Remedial Action during the SO-day public comment period. Verbal
comments received during the public meeting and written comments from the public comment
period indicate community support of the preferred remedial alternative (decontaminate and
dismantle) that was identified in the Proposed Plan/Environmental Assessment. Significant
issues raised during the public comment period are discussed in the Responsiveness Summary,
Appendix A of this document; copies of the written and oral comments are contained in
Appendix B.
9.0 SELECTED REMEDY
Based on the evaluation of the alternatives, Alternative 3 (Decontaminate and
Dismantle) has been identified as the selected remedy for the interim remedial action for OU3.
The selected remedy consists primarily of the removal of gross surface contamination from
material in facilities, dismantlement of facilities, and a combination of interim storage for the
majority of resulting remediation material/wastes and limited off-site disposal for non-
recoverable or non-recyclable remediation wastes until a decision concerning waste disposition
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OU3 Decision Summary (Final)
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June 1994
is made in the final remedial action ROD for OU3. The interim remedial action is neither
inconsistent with nor precludes implementation of final remedial actions for OU3 or the
Fernald site.
On the basis of currently available information, the selected remedy provides the best
balance of trade-offs among the alternatives with respect to the pertinent evaluation criteria.
DOE and EPA believe the selected remedy will meet the threshold criteria established in the
NCP: be protective of human health and the environment and comply with Federal, State, and
local ARARs directly associated with the interim remedial action.
The major goal of the interim remedial action is to reduce risks early, improve the
storage configuration of contaminated materials, minimize potential contaminant releases to
the environment, and contribute to the performance of the final remedial action. This interim
remedial action will achieve significant risk reduction early in the process. The final remedy
concerning disposition of contaminated materials is not addressed in this interim remedial
action ROD because such goals are beyond the limited scope of this action, but will be
addressed in the final remedial action ROD for OU3.
Table 9-1 presents summary estimated costs for the selected remedy. These costs are
based on preliminary conceptual design information. Some changes may be made to the
remedy as a result of the remedial design and construction processes. Such changes reflect
modifications resulting from t':1e engineering design process and could modify the cost
estimate identified in this table. This estimate summarizes the costs associated with the
selected remedy by direct and indirect costs. The direct costs represent the labor and material
costs associated with the de~ontamination, dismantlement, packaging, storage, and
transportation of the generated remediation wastes. Indirect costs represent the expense of
designing and managing the work including management, engineering, health and safety, sales
tax, and contingency costs.
10.0 STATUTORY DETERMINATIONS
The selected remedy must meet the statutory requirements of CERCLA Section 1 21
(40 USC ~ 9621). The selected remedy must:
Be protective of human health and the environment;
Comply with ARARs;
Be cost-effective;
Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and
Satisfy the preference for treatment that reduces toxicity, mobility, or volume as
a principal element.
Sections 10.1 through 10.5 discuss how the interim remedy will meet these statutory
requirements. Consistent with Section 121 of CERCLA, Section 10.6 discusses the
requirement for U. S. EPA to review the interim remedial action.
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OU3 Decision Summary (Final)
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June 1994
TABLE 9-1 Summary of Cost Estimate for Implementing the Selected Remedy
Itemized Description
Materials &
Labor Cost Expenses Total Cost
(millions) (millions) (millions)
$24.7 $17.2 $41.9
$24.5 $24.5
$49.3 $15.5 $64.8
Asbestos Abatement and Insulation Removal
Removal of Machinery, Process Equipment, and Piping
Building Demolition (includes removal of above-grade concrete, structural
steel, ductwork, transite and metal paneling, doors, windows, and
miscellaneous fixtures; also includes cost of cranes and other major rental
equipment)
Grade and Below-Grade Demolition (includes roads, railroads, sidewalks, .
storage pads, parking lots, below-grade piping, building foundations, etc.)
$17.4
Central Storage Facility (includes procurement, construction, and replacement
of skins)
$3.2
$17.4
$13.5 $16.7
$56.2 $56.6
$221.9
$222.9
$41.5 $45.3
$154.7 $1 67.9
$48.8 $220.6
$20.3 $20.3
$72.3 $176.7
$853.7
$1,075.8
$1.088.6
$2,164.4
$1,475.6
Debris Packaging and Handling
$0.4
Direct Cost
Engineering Design and Procurement
$222.9
$3.8
Small Tools, Consumables, Minor Rental Equipment, and Temporary Facilities
and Utilities
Health and Safety (includes training, personal protective equipment,
housekeeping/job site clean-up, safety reports, health physics, environmental
monitoring, and emission modeling)
$13.2
Overhead, Burdens, and Project Management (includes construction,
engineering, management, payroll, benefits, subcontractor bond, and office
support)
$171 .8
Sales Tax (6%)
Contingency (20%)
$104.4
Indirect Cost
Total Direct + Indirect Cost
Landlord (O&M) Cost
Cost of the Selected Remedy (in 1994 dollars)
Net Present Value of the Selected Remedy
(calculated using a 4.4% real discount rate)
Note:
All numbers have been 1'ounded to the nearest one hundred thousand dollars. Refer to the "Preliminary Cost
Estimate for the Operable Unit 3 Proposed Plan for Interim Remedial Action" (August 1993 draft) and the
"Present Worth Analysis for the Operable Unit 3 Proposed Plan for Interim Remedial Action" (October 1993
final) for more detailed information concerning the values presented in this cost summary table.
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OU3 Decision Summary (Final)
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June 1994
10.1
Protection of Human Health and the Environment
The selected interim remedy will be protective of human health and the environment
through removal of contaminated structures and facilities and containment of the resulting
remediation waste in existing facilities or interim storage facilities until a final decision is
reached in the OU3 final remedial action ROD concerning waste disposition. Removal of the
structures will eliminate the potential threat of exposure to contaminants in the structures.
Short-term threats associated with the selected remedy can be adequately controlled by
engineering measures and access restrictions. No adverse impacts are expected from the
remedy.
10.2 Compliance with ARARs
The following sections discusses ARARs and Other Requirements that the selected
remedy must comply with. The category of Other Requirements represents those laws, rules,
or regulations that are not environmental protection standards, but do apply to activities
performed at the Fernald site.
10.2.1
Contaminant-, Location-, and Action-Specific Requirements
The selected interim remedy will comply with all ARARs directly associated with the
interim remedial action and will be performed in accordance with all pertinent DOE Orders.
Listed below are those specific ARARs and TBC criteria that apply to the selected interim
remedial action for OU3. The ARARs are grouped according to contaminant-specific, location-
specific, and action-specific requirements.
CONTAMINANT-SPECIFIC REQUIREMENTS
Applicable
(1) Ohio Air Pollution Lead Control Regulations, Ohio Administrative Code, 3745-71-02, Lead
Emissions Limits [Sets the ambient air quality standards for lead, to be applicable throughout the
state of Ohio, at a maximum arithmetic mean of 1.5 micrograms per cubic meter during any
calendar quarter.]
(2) Ohio Air Pollution Regulations, Ohio Administrative Code 3745-20-02, -03, -04 and -05.
Demolition and Renovation Procedures for Asbestos Emission Control [Remove friable asbestos
materials from a facility being demolished or renovated before any wrecking or dismantling that
would break up materials or preclude access to the materials subsequent to removal. Wet and
encase friable materials with a suitable leak-tight container.]
(3) National Emission Standards for Hazardous Air Pollutants (40 CFR 61), Subpart H, National
Emission Standards for Emissions of Radionuclides Other Than Radon from Department of Energy
Facilities [Emissions of such radionuclides to the ambient air from DOE facilities shall not exceed
those amounts that would cause any member of the public in any year an effective dose
equivalent to 10 mrem/yr.]
(4) National Emissions Standard for Hazardous Air Pollutants (40 CFR 61, Subpart M, Sections
145. 149, 150 and 153), National Emissions Standard for Asbestos [Standards for demolition
and renovation, asbestos waste disposal.]
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OU3 Decision Summary (Final)
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June 1994
(5) Ohio Water Quality Standards, Ohio Administrative Code (OAC) 3745-1-01,3745-1-04,
3745~1-07, 3745-1-21; Ohio NPDES Permits, OAC 3745-33 {Sets surface water quality
standards for the state of Ohio. Discharges to surface waters must be pretreated to a level
which precludes degradation below the minimum standards.]
Relevant and Appropriate
(6) Ohio Air Pollution Control Regulations, Ohio Administrative Code, 3745-17-08, Restriction of
emission of fugitive dust {No person shall cause or permit any fugitive dust source to be
operated; or any materials to be handled, transported or stored; or a building or its
appurtenances or a road to be used, constructed, altered, repaired or demolished without taking
or installing reasonably available control measures to prevent fugitive dust from becoming
airborne.]
(7) Safe Drinking Water Act (42 USC 300G; Pl 93-523), National Primary Drinking Water
Regulations (40 CFR 141), Subpart B, Maximum Contaminant levels (40 CFR 141.11 through
.16); Subpart F, Maximum Contaminant level Goals, (40 CFR 141.50 through .52); Subpart G,
National Revised Primary Drinking Water Regulations (40 CFR 141 .60 through .63); Ohio
Drinking Water Regulations, Public Water System Primary Contaminant Control, OAC 3745-81
{Sets maximum contaminant levels (MCLs) and non-zero maximum contaminant level goals
(MCLGs) for drinking water. These requirements would apply to the interim remedial action if
ground water that was used or potentially used as drinking water was impacted by the
decontamination and dismantling activities.)
To Be Considered
(8) Toxic Substances Control Act, as amended (15 USC 2607-2629; Pl 94-469 et seq.),
Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use
Prohibitions (40 CFR 761), Subpart G, PCB Spill Cleanup Policy [Sets cleanup standards for PCB
contaminated materials.]
(9) Radiation Protection of the Public and the Environment (DOE Order 5400.5, especially
Chapter III) {Sets limitations for residual concentrations of radionuclides in air in uncontrolled
areas.]
(10) National Primary Drinking Water Standards, Maximum Contaminant levels for Radium-226,
Radium-228, and Gross Alpha Particle Radioactivity in Community Water Systems (40 CFR
141.15) and Ohio Drinking Water Regulations, Maximum Contaminant levels for Radium-226,
Radium-228, and Gross Alpha Particle Radioactivity in Community Water Systems (OAC 3745-
81-15); National Primary Drinking Water Standards, Maximum Contaminant levels for Beta
Particulate and Photoradioactivity from Man-made Radionuclides in Community Water Systems
(40 CFR 141 .16) and Ohio Drinking Water Regulations, Maximum Contaminant levels (OAC
3745-81-16) {Sets MCLs for radionuclides in drinking water.] . .
(11) Federal Water Pollution Control Act, Clean Water Act (33 USC 1251-1376), Water Quality
Criteria (40 CFR 122) {Sets limits on the concentration of contaminants in surface water for the
protection of human health and aquatic life. Federal water quality criteria are nonenforceable
guidelines used by states to set water quality standards for surface water. These criteria may be
considered if the decontamination and dismantling activities impact surface waters.)
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OU3 Decision Summary (Final)
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June 1994
LOCATION-SPECIFIC REQUIREMENTS
Applicable
(12) Protection of Wetlands (Executive Order 11990; 10 CFR 1022, 40 CFR Part 6) [Federal
agencies must avoid, to the extent possible, any adverse impacts associated with the
destruction or loss of wetlands and the support of new construction in wetlands if a practicable
alternative exists.]
(13) Nationwide Permit Program (33 CFR 330) [Nationwide permits are a type of general permit
issued by the US Army Corps of Engineers, in particular, under the Clean Water Act section
404.]
Relevant and Appropriate
None
To Be Considered
None
ACTION-SPECIFIC REQUIREMENTS
Applicable
(14) Noise Control Act, as Amended (42 USC 4901, et seQ.); Noise Pollution and Abatement
Act (40 USC 7641, et seQ.) [The public must be protected from noises that jeopardize health
and welfare.]
(15) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.), Solid Wastes
(40 CFR 262.11); Ohio Hazardous Waste Management Regulations, Ohio Administrative Code
3745-52-11 [Wastes must be evaluated (characterized) to determine if it is a hazardous waste,
either listed or characteristic.]
(16) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.), Solid Wastes
(40 CFR 264), Subpart B, General Facility Standards (Ohio Hazardous Waste Management
Regulations, Ohio Administrative Code (OAC) 3745-54-10 through -18); Subpart C,
Preparedness and Prevention (OAC 3745-54-30 through -37); Subpart D, Contingency Plan and
Emergency Procedures (OAC 3745-54-50 through -56); Subpart E, Manifest System, Record
keeping and Reporting (OAC 3745-54-70 through -77) [Establishes general requirements for
storage and treatment facility location, design and inspection, waste compatibility determination,
emergency contingency plans, preparedness plans, and worker training.]
(17) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.), Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities (40 CFR 264) Subpart
X for miscellaneous units; Ohio Hazardous Waste Management Regulations, Ohio Administrative
Code 3745-57 [Sets environmental performance standards and post closure requirements for
miscellaneous units.]
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June 1994
(18) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.l; Solid Wastes
(40 CFR 264), Subpart I, Use and Management of Containers (Ohio Hazardous Waste Manage-
ment Regulations, Ohio Administrative Code (OAC) 3745-55-70); Subpart J, Tank Systems
(OAC 3745-55-901; Subpart L, Waste Piles (OAC 3745-56-50 through 3745-56-601 [Containers
used to store hazardous waste must be closed and in good condition. Tank systems must be
adequately designed and have sufficient structural strength and compatibility with the wastes to
be stored or treated to ensure that it will not collapse, rupture, or fail, including secondary
containment. Waste piles must be designed to prevent any migration of wastes out of the pile
into adjacent subsurface soil or groundwater or surface water at any time during its active life.]
(19) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.l, Standards for Hazardous
Waste Generators (40 CFR 262) and Standards for Hazardous Waste Transporters (40 CFR 2631;
Ohio Solid Waste Management Regulations, Ohio Administrative Code 3745-52 and -53,
respectively [General requirements for packaging, labelling, and marking hazardous wastes for
temporary storage and transportation.]
(20) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.), Standards for Owners and
Operators of Interim Status Hazardous Waste Treatment, Storage and Disposal Facilities (40 CFR
265), Subpart G, Closure and Post-Closure; Ohio Hazardous Waste Management Regulations,
Ohio Administrative Code 3745-66 [Sets general requirements for closure of interim status
hazardous waste management units.]
(21) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.l, Containment Buildings, (40
CFR 2641, Subpart DD [Hazardous waste and debris may be placed in units known as
containment buildings for the purpose of interim storage or treatment.]
Relevant and Appropriate
(22) Toxic Substances Control Act, as amended (15 USC 2607 et seq., PL 94-469 et seq.),
Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use
Prohibitions (40 CFR 761 I, Subpart A, General [Inspection and testing are required for material
contaminated with PCBs.]
(23) Solid Waste Disposal Act, as amended (42 USC 6901, et seQ.), Solid Wastes (40 CFR 264
Subpart S), Corrective Action Management Unit [Allows remediation waste treatment, storage
and disposal within a corrective action management unit which can encompass one or more
units or areas where contaminants are found.]
To Be Considered
(24) Radiation Protection of the Public and the. Environment (DOE Order 5400.5, Chapter II, 5;
incorporates by reference CERCLA Section 120 and UMTRA Title I) [Structural debris that is
released from DOE facilities for reuse without radiological restrictions shall be decontaminated to
specified levels.l
(25) Radioactive Waste Management (DOE Order 5820.2A, Chapter III) [Sets external exposure
limits to any member of the public, requirements for releases to the atmosphere, and an
environmental monitoring program.]
(26) Radiation Protection of the Public and the Environment (DOE Order 5400.5, Chapter IV,
Section 6) [Sets standards for storage facility for waste containing uranium, thorium, and their
decay products.]
(27) Effluent Control and Monitoring (DOE Order 6430.1 A, Section 1324-7) [Exhaust outlets
that may contain fission products shall be provided with two monitoring systems.]
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OU3 Decision Summary (Final)
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June 1994
(28) Solid Waste Disposal Act, as amended (42 USC 6901, et seq.), Solid Waste, (40 CFR 264
subpart S), Corrective Action Rule (proposed at 55 FR 30797) [Establishes cleanup criteria for
RCRA solid waste management units.]
10.2.2
Other Requirements
In addition to ARARs, there are other requirements from Occupational Safety and
Health Administration (OSHA), Department of Transportation (DOT), and DOE Orders with
which this interim remedial action must comply. These other requirements include standards
which the EPA has determined not to be standards for environmental protection (for example,
worker protection and -off-site actions) and are therefore not ARARs. EPA classifies worker
protection, particularly OSHA's 29 CFR 1910.120, as a requirement rather than an ARAR
because: (1) it cannot be waived; and (2) it is not an environmental standard.
This listing of 'other requirements' is not an all inclusive list of requirements. There
are additional requirements which could result from off-site actions and would be required
under CERCLA Section 121 (d)(3). Under this requirement, the CERCLA Off-Site Rule,
activities that occur off-site shall be at facilities that are in compliance with RCRA, Toxic
Substances Control Act, and other environmental laws and applicable state requirements.
Determinations under this rule will be made during the interim remedial action. Listed below
are only those other requirements that apply to the selected interim remedial action for OU3.
Other Requirements
(1) Radiation Protection for Occupational Workers (DOE Order 5480.11, Chapter 9) [This
requirement establishes DOE radiation protection standards to ensure protection of the worker
from ionizing radiation. The requirements set forth in this order require the establishment of an
ALARA policy, radiation protection standards for internal and external exposure for occupational
workers, planned special exposure, radiation protection standards for internal and external
exposure to minors and students, radiation protection standards for public entering a controlled
area, and various procedural requirements.]
(2) Radiation Protection Rules, Ohio Administration Code; Chapter 3701-38: General Radiation
Protection Standards; Rules 3701-38-13, 3701-38-15 and 3701-38-16 [Individuals in restricted
areas may not be exposed to airborne radioactive material in average concentrations in excess of
those listed.]
(3) Occupational Safety and Health Adminis1ration Standards (29 CFR 1910; 1910.1000),
Subpart Z. TOXIC and Hazardous Substances; 1910.1025, Lead; 1910.1028, Benzene;
1910.1101. Asbestos; 1910.1018, Inorganic arsenic [Sets worker exposure limits to toxic and
hazardous substances and prescribes the methods for determinations of concentrations.]
(4) Occupational Safety and Health Adminis1ration Standards; Occupational Health and
Environmental Con1rol (29 CFR 1910; 1910.95), Subpart G, Occupational Noise Exposure [Sets
limits of worker exposure to noises during the performance of their duties.]
(5) Hazardous Material Transportation Act, as amended (49 USC 1801-1812); Solid Wastes (40
CFR 263), Standards Applicable to Transportation of Hazardous Waste [Adopts certain DOT
standards and requires compliance with the manifest system for hazardous wastes.}
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OU3 Decision Summary (Final)
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June 1994
Hazardous Materials Regulations; Shippers -- General Requirements for Shipments and
;":':;kaging (49 CFR 173), Subpart I, Radioactive Materials [Establishes requirements for the type
and strength of various packaging used for the shipment of hazardous and radioactive materials.]
(7) Occupational Safety and Health Administration Standards for Hazardous Waste Operations
and Emergency Response (29 CFR 1910.120) [Sets the training standards for workers
conducting hazardous waste operations and emergency response.]
10.3 Cost-Effectiveness
OU3 facilities and structures have generally exceeded their design life and no use has
been identified for them other than support for remedial activities at the site. In time, the
facilities will pose a safety hazard. Therefore, DOE will propose eventual decontamination and
dismantlement of the facilities independent of the interim remedial action implemented. By
implementing the selected remedy as an interim remedial action, the remediation process is
accelerated by nearly four years. The selected interim remedy is cost effective because it
reduces costs associated with the continued operation and maintenance of the site; it costs
less overall than the other alternatives (coupled with assumed eventual decontamination and
dismantlement) and it is, proactive toward protection of the public through early risk reduction.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable
Because the selected remedy is an interim remedial action rather than a final remedial
action, the selected remedy does not utilize permanent solutions or consider alternative
treatment technologies. The selected remedy provides the best balance of trade-offs among
the alternatives with respect to the balancing criteria, given the limited scope of the action.
It does not satisfy the statutory preference for remedial actions that employ treatment to
reduce toxicity, mobility, or volume as a principal element of the action. However, permanent
solutions will be utilized in the final remedial action and alternative treatment (or resource
recovery) will be utilized to the maximum extent practicable. The final remedial action will
satisfy the statutory preference for treatment as a principal element or will provide justification
for not meeting the preference. During the interim remedial action, resource recovery through
recycling and reuse will be utilized to the maximum extent practicable.
The selected interim remedy best meets the evaluation criteria by addressing risks to
human health and the environment, accelerating the remediation process by nearly four years,
and reducing overall costs associated with OU3 remediation. DOE and EPA believe the
selected interim remedy will protect human health and the environment. The community
supports the selection of this interim remedy.
10.5 Preference for Treatment as a Principal Element
Through physical treatment of the materials that cause the principal threats for the
operable unit (contaminated structural materials), the selected remedy attempts to satisfy the
statutory preference for remedial actions that employ treatment to reduce toxicity, mobility,
or volume as a principal element of the action. Through decontamination, surface
contaminants will be 'removed and consolidated, thereby reducing their mobility. Secondary
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OU3 Decision Summary (Final)
33
June 1994
liquid waste streams resulting from the decontamination activities will be treated using the
site water treatment system. Secondary solid wastes will be containerized and managed.
Recycling and reuse will be pursued to the maximum extent practicable. Additionally, the final
remedial action for OU3 will meet the statutory preference for treatment as a principal element
or will provide justification for not meeting the preference.
10.6 Review of the Interim Remedial Action
Section 1 21 (c) of CERCLA and the Amended Consent Agreement require that EPA
review remedial actions no less than each five (5) years after the installation of the final
remedial actions to ensure that human health and the environment are being protected by the
remedial actions being implemented. However, because this is an interim remedial action
ROD, review of this site and this remedy will continue as DOE develops final remedial
alternatives for OU3.
11.0 COMMITMENT FOR FURTHER ANALYSIS AND SELECTION OF LONG-TERM
RESPONSE ACTION
Consistent with the terms of the Amended Consent Agreement, DOE is currently in the
process of performing a RI/FS for OU3. The completion of the OU3 RI/FS will provide the
selection of the long-term response action for the operable unit. In accordance with the
milestones established in the Amended Consent Agreement, DOE must submit an RI and
baseline risk assessment report to EPA by March 13, 1996, and an FS report and proposed
plan by August 7, 1996. The proposed draft ROD for the final action is scheduled to be
submitted to EPA by April 2, 1997.
. 12.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan/Environmental Assessment for Interim Remedial Action for OU3 was
released for public comment in December 1993. The Proposed Plan/Environmental
Assessment identified Alternative 3, Decontaminate and Dismantle, as the preferred
alternative. The DOE reviewed all written and verbal comments submitted during the public
comment period. Upon review of these comments, suggestions and observations from the
public were incorporated into this IROD to further clarify the description of Alternative 3.
Portions of Alternative 3 that required clarification were the maximum utilization of existing
structures for purposes of interim storage (as a means to avoid construction of the CSF
structures) and a guarantee that interim storage would not inadvertently become long-term
storage. Additional comments received that did not require clarification, but that DOE is
committed to satisfying, are to provide air monitoring information updates to the local public'
regularly and to emphasize the removal of waste from the site as an important step in allowing
the interim action to proceed as planned. Finally, from the comments received, it was
determined that no significant changes to the interim remedy, as it was originally identified
in the Proposed Plan/Environmental Assessment, were necessary.
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OU3 Decision Summary (Final)
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June 1994
13.0 REFERENCES
Federal Register (FR), March 7, 1979, Compliance with FloodPlain/Wetlands Environmental
Review Requirements, 10 CFR Part 1022.
Code of Federal Regulations (CFR), July 1, 1992, National Oil and Hazardous Substances
Pollution Contingency Plan; Final Rule, 40 CFR Part 300.
State of Ohio vs. United States Department of Energy, et ai, 1993, Stipulated Amendment
of Consent Decree Entered December 2, 1988, as amended on January 22.
U. S. Department of Energy, 1990, Radiation Protection of the Public and the Environment,
DOE Order 5400.5, Office of Environment, Safety and Health, Washington, D.C.
U. S. Department of Energy, 1993a, FEMP Waste Information Manual, prepared by the Fernald
Environmental Restoration Management Corporation, Cincinnati, Ohio.
U. S. Department of Energy, 1993b, Improved Storage of Soil and Debris, Removal Action 17
Work Plan, prepared by the Fernald Environmental Restoration Management Corporation,
Cincinnati, Ohio.
U. S. Department of Energy, 1993c, Operable Unit 3 Proposed Plan/Environmental
Assessment for Interim Remedial Action, Final, prepared by the Fernald Environmental
Restoration Management Corporation, Cincinnati, Ohio.
U. S. Department of Energy, 1993d, Operable Unit 3 Remedial Investigation and Feasibility
Study Work Plan Addendum, Final, prepared by the Fernald Environmental Restoration
Management Corporation, Cincinnati, Ohio.
U. S. Department of Energy, 1993e, 1992 Site Environmental Report, prepared by the Fernald
Environmental Restoration Management Corporation, Cincinnati, Ohio.
U. S. Environmental Protection Agency, 1988, Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA, Interim Final.
U. S. Environmental Protection Agency, 1989, Guidance on Preparing Superfund Decision
Documents: The Proposed Plan, The Record of Decision, Explanation of Significant
Differences, The Record of Decision Amendment, Interim Final.
U. S. Environmental Protection Agency, 1991a, Consent Agreement as Amended under
CERCLA Sections 120 and 106(a) in the Matter of: U. S. Department of Energy Feed Materials
Production Center, Fernald, Ohio, Administrative Docket No. V-W-90-C-052, Region V,
Chicago, Illinois, Sept. 18.
U. S. Environmental Protection Agency, 1991 b, Guide to Developing Superfund No Action,
Interim Action, and Contingency Remedy RODs, Fact Sheet.
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APPENDIX A
RESPONSIVENESS SUMMARY
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Page left intentionally blank.
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APPENDIX A
RESPONSIVENESS SUMMARY
A.1
Purpose
As stated in U.S. Environmental Protection Agency (EPA) Guidance on Preparing
Superfund Decision Documents (EPA 1989), the responsiveness summary serves three
important purposes. First, it provides U.S. Department of Energy (DOE), the lead agency, with
information about community preferences regarding both the proposed remedial alternative
and general concerns about the site. Second, it demonstrates how public comments were
integrated into the decision-making process. Third, it allows DOE to formally respond to
public comments.
This responsiveness summary has been prepared pursuant to the terms of the 1991
Amended Consent Agreement between DOE and EPA, as well as relevant Federal laws,
regulations, and guidelines, including:
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act, 42 United States Code, Sections 9601, et. seq.;
National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
40 Code of Federal Regulations, Part 300;
Community Relations in Superfund: A Handbook, January 1992,
EPA/540/R-92/009; and
Guidance on Preparing Superfund Decision Documents: The Proposed Plan,
The Record of Decision, Explanation of Significant Differences, The Record
of Decision Amendment, Interim Final, July 1989, EPA/540/G-89/007.
This responsiveness summary allows DOE to demonstrate the public's involvement in
the development of the Proposed Plan/Environmental Assessment for Interim Remedial Action
and the Record of Decision for Interim Remedial Action, subsequently referred to as the IROD.
After public comments and concerns had been formally submitted to DOE, in oral and written
form, the comments were then summarized into issue statements with DOE's responses and
the comments are attached as Appendix B of this document.
Section A.2 of this responsiveness summary gives an overview of public involvement
for the Fernald Environmental Management Project (FEMP). Section A.3 gives an overview
of the public's involvement in the development of the interim remedial action concept.
Section A.4 discusses the development of the issue statements and presents public concerns
and DOE responses. Section A.5 summarizes the responsiveness of DOE to public comments
by discussing the effects of public input on this IROD. Section A.6 discusses public
comments not directly affecting the proposed action.
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June 1994
A.2
Public Involvement for the FEMP
Environmental issues at Fernald first became public in 1984 when it was reported that
nearly 300 pounds of slightly enriched uranium oxide had been released to the atmosphere
from the Plant 9 dust-collector system. It was also disclosed during this time that three off-
property wells south of Fernald had been contaminated with uranium in 1981.
In 1986, DOE entered into a Federal Facilities Compliance Agreement (FFCA) with EPA.
The FFCA provided for a RemediallnvestigationfFeasibility Study (RifFS) followed by remedial
action for the site. The RifFS was initiated to assess the nature and extent of contamination
at the site and to recommend cleanup strategies. In 1989, production was suspended. In
that same year, Fernald was designated a Superfund site when it was placed on the National
Priorities List. The FFCA was superseded in 1990 by a Consent Agreement between DOE and
EPA, which established the operable units and cleanup schedules. Further refinement of this
agreement occurred in 1991, with the Amended Consent Agreement, which modified the
cleanup schedules and the operable unit definitions for the site. In that same year, Fernald
officially closed as a production facility and its operations were transferred to DOE's
Environmental Restoration and Waste Management Division.
When monitoring wells showed elevated levels of uranium in 1989 and 1990, DOE
agreed to provide bottled water to homes with uranium levels above 2.7 parts per billion
(ppb). As work on the RifFS continued, DOE completed several near-term activities aimed at
reducing the potential for a release of contamination that would endanger public health and
the environment. Also in 1990, DOE authorized opening an information repository called the
Public Environmental Information Center (PEIC) in the JAMTEK Building, 10845 Hamilton-
Cleves Highway, Harrison, Ohio 45030. The administrative record, on which cleanup
decisions are based, is al50 located at the JAMTEK Building; a copy of this administrative
record is also maintained at EPA Region 5, Waste Management Division Records Center,
77 West Jackson Boulevard, Chicago, Illinois 60604.
DOE's community relations activities include the following:
A community assessment (1986);
A community assessment (June - July 1989); .
A Community Relations Plan (August 1992 version approved
October 15, 1992);
Public reading rooms and administrative record;
Regular briefings at local township trustee meetings;
Presentations to the local environmental group, FRESH;
Community meetings approximately each quarter;
Workshops and roundt~bles for interested parties;
Press releases, fact sheets and a newsletter;
Public comment periods for decision documents and responsiveness
. sum manes;
Tours. as requested;
Annual environmental monitoring reports; and
The Fernald Citizens Task Force.
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June 1994
A.3
Public Involvement for Operable Unit 3
In addition to the sitewide community relations activities discussed above, a series of
specific public involvement and response activities have been undertaken as part of Operable
Unit 3 (OU3) initiatives. DOE proposed an interim remedial action to accelerate a remediation
decision for the OU3 structures well ahead of the original schedule: The proposal was also
consistent with addressing public concerns about the length of time before full-scale remedial
action at the FEMP would begin. The following information illustrates the significant levels
of public involvement in the project and the responsiveness of DOE to public concerns about
the project since its beginning.
The concept for this interim remedial action was first formally discussed with EPA and
Ohio EPA (acting on behalf of the state) on January 13, 1993 and met with favorable
response. On Februa'ry 18, 1993, DOE discussed the schedule, scope, and form of the
project with EPA and Ohio EPA (OEPA). Following discussions at this meeting, DOE began
detailed development of the project plans.
The local public was informed of DOE's intent to pursue the development of an interim
remedial action during a January 12, 1993 public meeting for Removal Action 27, the
Engineering Evaluation/Cost Analysis (EE/CA), known as the Management of Contaminated
Structures at the FEMP. During that meeting the public expressed to DOE concerns about the
lack of progress on large-scale remediation efforts at the site, reinforcing the benefits of the
interim remedial action. In addition, notification to the public through the FFCA monthly
report from the FEMP began highlighting the activities that were underway for development
of the interim remedial action decision documents.
Several of the FEMP's regular events, which support the site's ongoing comprehensive
public information program, included discussions of DOE's pursuit of an interim remedial
action. During the spring and fall of 1993, updates on the DOE effort were included in several
of the monthly meetings held with FRESH. The STEP program (Science, Technology,
Environment, and the Public), which involves the public in the remediation decision-making
process, held several meetings in September and October of 1993, and included displays and
discussions on the interim remedial action being planned.
During development of the Proposed Plan/Environmental Assessment for Interim
Remedial Action,EPA and OEPA provided review comments and project guidance on behalf
of the public through the process outlined in the Amended Consent Agreement. Approval of
the Proposed Plan/Environmental Assessment was received from EPA and OEPA, on
December 3 and 6, 1993, respectively. The public was formally notified of a 30-day public
comment period by advertisement in the legal section of three local, general distribution
newspapers on December 8, 1993, initiating the formal comment period. Additional public
notification by display-type newspaper advertisement and direct mailing distribution to site's
mailing list was also undertaken on December 15, 1993. Both the Proposed
Plan/Environmental Assessment and a condensed fact sheet were made available to the public
in the FEMP administrative record located at the PEIC. Over 1 ,000 copies of the fact sheet
were distributed by direct mailing to local residents, local media, public officials, and other key
stakeholders.
To facilitate public involvement in the project, a public meeting was held January 5,
1994, including a presentation session, a question-and-answer session, and a formal comment
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June 1994
session. Invitation to the meeting had been provided through the fact sheet mailing, as well
as the legal section and display advertisements in the local newspapers. The formal comment
session provided an opportunity for the public to contribute oral and written comments. The
entire meeting was transcribed by court reporter to provide an official transcript of the
meeting. A copy of the transcript has been placed in the administrative record file for OU3
for public review. During that meeting, the public indicated a need for more time to fully
evaluate the proposed action and to formulate comments on the plan; therefore, during that
meeting, DOE extended the public comment period by 30 days to close on February 8, 1994.
Additional advertisements were published in the same local newspapers to inform the public-
at-large.
Issues of particular concern voiced during the January 5, 1994 public meeting included
material transportation, interim storage facilities, safety from emissions, and National
Environmental Policy Act (NEPA) and CERCLA integration in FEMP clean-up decision
documents. To provide more information about the regulatory process, in particular the
NEPA/CERCLA integration approach for the site and OU3, DOE held a roundtable meeting with
the public on January 24, 1994. At the roundtable, issues of public concern were discussed
including the Proposed Plan/Environmental Assessment and its relationship to the Operable
Unit 4 (OU4) Environmental Impact Statement (EIS) and future NEPA documents for the
remaining operable units.
On February 4, 1994, a meeting was held with the vice president of FRESH to discuss
the safety of the planned decontamination and dismantlement actions, using detailed air
emissions monitoring data from two decontamination and dismantlement actions underway
(Plant 1 Ore Silos and Plant 7).
Public comments were received in written and verbal form during the formal comment
portion of the public meeting and in written form through the mail during the GO-day public
comment period. DOE received comments from OEPA and the State of Nevada, as well. The
following section summarizes the significant issues resulting from the public comment period
and provides DOE's responses to these comments.
A.4
Issues Summary
This responsiveness summary focuses on the formal comments submitted during the
Public Comment Period. Within this responsiveness summary, oral and written comments
(see Appendix B) are categorized into significant issues. For each of these issues, an issue
statement has been prepared that addresses the concerns expressed by one or more of the
commentors. In many instances, the issue statements are paraphrased from the original
comments to succinctly represent the concerns of several commentors. The issues resulting
from formal comments have been compared with the questions raised during the question and
answer sessions with the public to ensure that all significant issues have been represented
by the following issue statements.
For the purpose of developing issue statements, a comment is considered significant
if it involves:
The definition or scope of the preferred alternative,
Public or state acceptance of the preferred alternative,
The implementation or impacts of the preferred alternative,
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June 1994
Conclusions drawn from evaluations or assessments
Proposed Plan/Environmental Assessment,
Safety of the work performed, or
The enforceability of the decision reached.
provided in the
At the end of each issue statement, the specific comment letter(s) or oral comment(s)
in which the issue was raised is identified by an alphabetic identifier. Table A-1 provides a
cross-reference of the alphabetic identifiers with the commentors. These comments are
included in Appendix B and are part of the administrative record for this action. Significant
comments that were not considered to be issues have been addressed in Section A.6 with
summary explanations.
Issue 1
The definition of the term "interim storage" should be presented within the Record of
Decision for Interim Remedial Action. (Comments H, I, J, N, and 0.)
Response: For the interim remedial action, the definition of the time frame for interim
storage is the period from the initiation of the interim action until the decision is reached for
the final remedial action. In reality, once the final decision is reached, all materials in storage
cannot immediately be removed for treatment or disposition. Some time will be required for
the development of the treatment and/or disposal facilities before interim stored materials can
be removed. Because the final treatment and disposal option for OU3 is not selected at this
time (and will not be until the OU3 final remedial action Record of Decision [ROD], which is
due in 1997), an estimate of the time frame for remediation of stored materials cannot be
made until after the final remedial action decision. The time frame for removal of these
materials and the dismantlement of the interim storage facility will be addressed in the
Remedial Design/Remedial Action (RD/RA) Work Plan for the final remedial action.
Issue 2
The interim action should make the maximum effort to utilize existing storage facilities
and areas rather than construct new storage facilities. To support this, DOE should make a
commitment to manage and ship existing waste residues to obtain space for interim storage.
(Comments I, K, N, and 0.) "
Response: It is the intent of DOE to construct interim storage structures for storage
of the interim remedial action wastes only if necessary. Available storage space within the
Production Area will be utilized to the maximum extent practicable. To address the concern
over the construction of new storage facilities, the following statements have been added to
the IROD in Section 7 .3 under the description of Alternative 3 (Decontaminate and Dismantle):
The proposed tension support structures are designed only for temporary
storage with an intended design life of 25 years, and "as such cannot be used
for long-term storage. The Intent of building these facilities is twofold: for use
as an interim or temporary storage area for wastes generated from the action
if existing storage space is not available and for use as a staging area to
support segregation, packaging, and transportation of materials for disposition.
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June 1994
TABLE A-1 Written and Oral Comments Received
Letter
Commentor
WRITTEN COMMENTS
L
M
N
o
Q
R
S
T
U
V
W
X
Y
A
B
Kenneth J. Wurzelbacher, Hamilton, Ohio
Carl A. Woycke, Harrison, Ohio
C
D
Maggie Merritt, Harrison, Ohio
Paul Ruttencutter, Hamilton, Ohio
E
F
Laura Jane Whitesides, Las Vegas, Nevada
Lawrence L. Stebbins, Hamilton, Ohio
G
H
Edwa Yocum, Harrison, Ohio
Vicky Dastillung, Vice President of FRESH, Hamilton, Ohio
J
K
Pam Dunn, Harrison, Ohio
Lisa Crawford, President of FRESH, Harrison, Ohio
Karen Bell, President Crosby Elementary PTA, Harrison, Ohio
Norma Nungester, Harrison, Ohio
Holly Schick, State Director of the Ohio Small Business Development Center (SBDC),
Columbus, Ohio
Unsigned letter submitted by the Fernald Atomic Trades & Labor Council, Ross, Ohio
P
Graham E. Mitchell, Project Manager, Ohio Environmental Protection Agency,
Dayton, Ohio
Maud Naroll, State Clearinghouse Coordinator, Department of Administration,
Carson City, Nevada
ORAL COMMENTS AND ATTACHMENTS
Oral Comment by Bob Tabor
Oral Comment by Jerry Monahan
Submitted Attachment to Bob Tabor's Oral Comment
Oral Comment by Vicky Dastillung
Oral Comment by Robert Richardson
Oral Comment by Pam Dunn
Oral Comment by Lisa Crawford
Submitted Attachment to Robert Richardson's Oral Comment
Oral Comment by Richard Miller
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OU3 Decision Summary (Final)
A-9
June 1994
To minimize constructing additional interim storage facilities, available storage
space within buildings or on the Plant 1 Pad will be utilized for interim storage
or staging to the maximum extent practicable. If storage and staging space is
obtained within existing facilities it will not be necessary to construct all of the
planned interim storage structures.
The final decision for material disposal, whether on-site or off-site, to be
decided as part of the OU3 final remedial action ROD in 1 997, will determine
the location for disposition of OU3 remediation wastes including materials in
interim storage and the storage structures. A decision for on-site disposition
of remediation wastes would preclude the use of the interim storage structures
for permanent storage and would require construction of structure(s)
specifically to meet the stringent requirements of permanent disposal. Whether
the decision is for on-site or off-site disposal, the interim storage structures will
be used only long enough to support staging operations for remediation wastes
resulting from dismantlement activities. Therefore, the time frame for use of
the structures is dependent upon the final decision for disposition of the OU3
remediation wastes, which is expected to be made in 1997. Once staging is
no longer necessary to support remediation waste dispositioning, the structures
will be removed as part of the OU3 interim remedial action and the resulting
wastes will be dispositioned as part of the OU3 final remedial action.
DOE recognizes the need to emphasize the removal of existing waste from buildings
and pads to the maximum extent practicable to allow use of these structures for storage and
staging of wastes generated during the interim remedial action. Under this approach,
hazardous remediation wastes resulting from the interim remedial action would be stored in
the existing permitted hazardous storage facilities on-site until a decision for their disposition
is obtained.
Issue 3
Concern was expressed over placing interim storage facilities on the northeast corner
of the site, outside of the Production Area, due to prevailing wind directions from the
Southwest and the possibility for airborne emissions reaching off-site residents. Additional
concern was expressed over potential leaks from these interim storage facilities and
associated migration of contaminants to the Great Miami Aquifer. (Comment L.)
Response: The location of any new interim storage facilities for remediation wastes
will be based on several requirements: (1) that it be large enough to house six 40,000 square
foot tension support structures; (2) that there be no known chemical contaminants
(hazardous, PCB. asbestos, or petroleum products); (3) that construction of the facility would
not interfere with other planned uses (other remediation facilities); (4) that it not be in an
environmentally sensitive area such as a floodplain, wetland, or habitat for threatened, rare,
or endangered species; and (5) that it provide the greatest protection to the Great Miami
Aquifer from the interim storage facility. Satisfying these requirements means that any
interim storage facility needs to be located in the northeast corner of the site.
Although the prevailing winds tend to rise from the southwest, the risk associated with
a storage facility at this location has been estimated to be low and acceptable, as detailed in
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OU3 Decision Summary (Final)
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June 1994
Appendix E of the Proposed Plan/Environmental Assessment. Further, the facility should be
viewed as an improvement to the existing storage configuration of contaminated building.
materials, since the first step in the interim remedial action will be in-place decontamination
of the buildings. Following dry vacuuming, all exposed surfaces within the buildings will be
washed with water to dislodge removable surface contamination; this will minimize the
contaminants which could become airborne during dismantling of the building. The dismantled
materials sent to interim storage would be cleaner than they had been as a standing structure
prior to the action. After dismantlement, these construction materials will be placed in boxes
or drums, if appropriate, to further contain and prepare the materials for eventual disposition.
This process will allow for the safe storage of materials in interim storage.
If additional interim storage facilities are required to be constructed for the improved
storage of debris, the interim storage facilities would be designed in accordance with the
requirements of Removal No. 17, Improved Storage of Soil and Debris. The interim storage
facilities would be designed as structural steel frames with heavy synthetic liner covers that
are capable of withstanding severe weather conditions such as heavy snow, strong winds,
and rainfall. In addition, rainwater collected at the interim storage facility would be routed to
the existing storm water collection system. By storing the bulk and containerized materials
out of weathering conditions on pads and under structures, releases from the materials will
be minimized. Therefore, it is not anticipated that water will be released from the interim
storage facilities to the underlying till.
As discussed in the response to Issue 2, DOE would attempt to utilize existing facilities
to the extent practical for interim storage and staging purposes to avoid constructing all of
the proposed structures. The storage of materials in existing or new facilities would be in
compliance with NEPA and CERCLA. . .
Issue 4
What happens if the Nevada Test Site (NTS) does not accept the wastes proposed for
disposition at that site? (Comment G.)
Response: The FEMP waste management program has previously secured approval
from NTS for the disposition of construction debris. NTS currently receives low level
radiological waste shipments from the FEMP on a regular basis. At this time, it is anticipated
that the volumes of materials estimated in the Proposed Plan/Environmental Assessment,
Appendix G, will be accepted by NTS. Waste acceptance criteria for NTS are known, and
non-hazardous radioactive wastes generated by this project are compatible with them. If
these materials cannot be disposed of at NTS, onsite interim storage or commercial disposal
could be utilized for the remediation wastes generated before the OU3 final remedial action
ROD in 1997.
Issue 5
Would off-site traffic be increased as a result of the action and would construction
traffic potentially spread contaminants? (Comment K.)
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OU3 Decision Summary (Final)
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June 1994
Response: The socioeconomic analysis performed for the Proposed Plan/Environmental
Assessment estimates no significant increase in traffic. Any increase to current traffic could
be attributable to off-site shipments of material, and this is expected to have minimal impact.
As a result of the OU3 interim remedial action, it is anticipated that approximately 650 truck
shipments of remediation waste would be shipped off-site for disposal at NTS, prior to the
OU3 final remedial action ROD. These shipments would occur over a 3 year period equaling
an -average of less than 1 truck load per day and would have little impact on existing traffic.
During remediation activities, current procedures will be followed for inspecting
vehicles exiting contaminated zones on-site. All exposed surfaces of the vehicle will be
surveyed for contamination, and if contamination is detected, the vehicle will be washed to
remove it. The procedures for containerization of materials for transportation minimize the
possibility for removable contamination to be present on the exterior surfaces of the
containers. In addition, all containers are surveyed during and after packaging. Therefore,
no contamination is expected to be spread off-site as a result of construction or transportation
traffic associated with the OU3 remediation wastes.
Issue 6
A commentor expressed that the use of NTS as the selected site for disposition of a
limited Quantity of materials is not technically in compliance with DOE Orders and NEPA
because the OU3 Proposed Planl Environmental Assessment does not assess disposal impacts
at the NTS and no other NEPA documentation exists supporting this action. (Comment P.)
Response: Alternative 3 includes the proposal to ship up to 10 percent of all waste
generated from implementing this remedial action (i.e., up to 42,500 cubic yards or
1 .15 million cubic feet) off-site for disposition and recycling prior to the final disposition
decision to be determined by the final remedial action ROD for OU3. Of this quantity, it is
estimated that 15,900 cubic yards (429,000 cubic feet) of non-recoverable/non-recyclable
materials may be dispositioned off-site before the final remedial action ROD is reached
(expected to be in 1997). The NTS is identified as a possible disposal site.
DOE recognizes the need to update the NEPA reviews and documentation for activities
at the NTS. Currently, DOE proposes to prepare a single, site-wide environmental impact
statement (EIS) that would address activities sponsored by Defense Programs, environmental
restoration at the NTS, waste management activities, and other actions being considered for
possible siting and initiation at the NTS. DOE is committed to accelerating the schedule for
completion of this EIS and a Notice of Intent to inform the public and invite comments during
the scoping process is in draft. DOE anticipates publication of the Notice of Intent by summer
1994. Any wastes that may be shipped to the NTS would meet the Nevada Operations Office
waste acceptance criteria and the estimated quantity from the OU3 interim remedial action
between now and 1997 represents about 3 percent of the total waste currently disposed of
at the NTS. Furthermore, the remedial actions contemplated for OU3 will take place over a
number of years, with the first years concentrating on remedial design planning and
implementation. Consequently, the majority of the waste shipments from the FEMP
addressed by this interim remedial action would take place following completion of the site-
wide EIS for the NTS. The site-wide EIS for the NTS is expected to be completed in 1996.
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OU3 Decision Summary (Final)
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June 1994
Under DOE Order 5820.2A, DOE facilities with disposal sites must prepare and
maintain site-specific radiological performance assessments for waste disposal. Draft
radiological performance assessments for th8 disposal facilities at the NTS have been
prepared. A preliminary review of the Area 5 disposal facility performance assessment was
conducted by a peer review panel. Although the panel agreed with NTS representatives that
additional technical justification was necessary to finalize the performance assessment, it was
generally accepted that the facility would easily meet the radiological performance objectives.
The performance assessments for Area 5 and Area 3 are currently being revised and updated.
Issue 7
Environmental monitoring data should be collected as buildings are removed to ensure
that engineering controls are effective in controlling potential environmental releases. Data
collected for the RIfFS should be incorporated into the design to control any unexpected
contaminants during remediation. Lead-based paint has been shown to be dangerous to
children and, as such, should be included in any monitoring program. Monitoring data must
be made available to the public via roundtable meetings, fact sheets, etc. (Comments F, H,
J, K, and 0.)
Response: The dismantlement techniques used for the OU3 interim remedial action will
include a series of engineering controls and methodologies designed to minimize the release
of loose airborne contaminants. Each structure will be subjected to gross decontamination
prior to dismantlement, minimizing the potential for airborne contaminants during
dismantlement. During decontamination, airflow control and collection of airborne
contaminants within the buildings will be performed. RIIFS data is currently being collected
for OU3 and will be extensively used to anticipate the contaminants to be encountered during
the remedial activities. Some unknown or unexpected contaminants may be encountered
during remedial activities, but precautions and procedures will be in place to account for these
possibility. All data collected will be factored into the design approach to control unexpected
contaminants; to minimize airborne releases, and to tailor the specific decontamination and
dismantlement techniques to the contaminants present.
In addition, during decontamination and dismantlement, air monitoring will continue at
. both the FEMP fence line perimeter and at nearby off-site locations. Air samples for
radiological and asbestos contaminants will also be collected at work area perimeters to verify
that airborne releases from the job site are maintained at low. levels and within limits
established for respiratory protection and worker safety. If data collected during the OU3
RifFS highlight other chemical contaminants of concern, such as lead, monitoring for these
contaminants will also be performed. .
Because interior decontamination work will utilize the building shell as a containment
barrier in combination with directed airflow systems, minimal ambient airborne releases are
expected. Once the exterior building sides and roof have been removed, the materials left in
the building would generally be the structural steel frame and concrete floors. Both of these
will have been decontaminated leaving little surface contamination that could become airborne
during dismantlement. Because of this approach to the building dismantlement and the
engineering controls used, ambient airborne releases are expected to be maintained at low
levels. If work zone or perimeter fence line airborne concentrations are detected at levels
significantly above background, contingency measures will be implemented to reduce
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OU3 Decision Summary (Final)
A-13
June 1994
contaminant emissions. For example, work would be stopped, exposed areas covered or
otherwise controlled, and engineering measures would be increased before restarting work to
ensure that nearby members of the workforce and the general public would not be adversely
impacted.
Data resulting from the interim remedial action will be made available to the public
regularly through placement in the public reading room, roundtable meetings, and updates in
fact sheets and monthly reports.
Issue 8
How will the preferred alternative reduce the costs of site remediation when interim
storage structures requiring monitoring are constructed? What is the cost of each structure?
(Comments G and I.)
Response: The cost of constructing and operating the interim storage structures at the
site is very small compared to the overall cost of the decontamination and dismantlement of
the OU3 structures. Their cost is also very small when compared to the projected savings
from the early implementation of the interim remedial action; therefore, the preferred
alternative could have required many more structures and still resulted in significant savings
for the overall action. The savings primarily result from the early implementation of the action
(with resulting early completion and avoidance of many costs associated with operating the
buildings). However, during implementation of the action, every effort will be made to utilize
existing facilities, such as the Plant 1 Pad, and aVoid construction of additional structures.
Costs for engineering, siting, and construction of the interim storage structures of the
size and type proposed for this project (40,000 square foot tension support structures) have
been estimated at approximately $2 million per structure (compared to a cost of about $2,200
million for the entire interim remedial action and approximately $350 million savings from early
implementation). Costs foroperation of storage/staging in new structures would likely be
equivalent to costs of operations based in existing structures. Maintenance costs for the new
structures would be significantly less than maintenance costs for the aging existing structures.
Maintenance costs for the new structures would primarily be associated with the replacement
of the fabric covering as needed.
Issue 9
While long-term effectiveness is not required to be considered for an interim action,
it is important to the community that this evaluation criterion be considered as much as
possible. (Comment H.J
Response: Long-term effectiveness addresses the results of a remedial action in terms
of the risk remaining at the site after a final remedial action is implemented. It assesses the
level of risk remaining at the site and how well human health and the environment will be
protected from treatment residues and untreated materials. The long-term effectiveness of
the OU3 remediation will be evaluated within the Feasibility Study for the final remedial action.
ROD.
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OU3 Decision Summary (Final)
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June 1994
For an interim remedial action, such as this, the actions are not intended to represent
final remediation. The interim action is taken to reduce potential risks in the short-term while
the site undergoes the RIIFS process. For this reason, long-term effectiveness is not
addressed in the context of an interim remedial action and this is consistent with the NCP and
CERCLA. This evaluation will be performed under the OU3 Feasibility Study to be completed
in support of the OU3 final remedial action ROD.
However, long-term effectiveness is important to DOE as well, because this interim
remedial action must be consistent with the final remedial action, which will include a formal
assessment of the long-term effectiveness. DOE believes that the long-term impacts of
decontaminating and removing the aging and contaminated structures of OU3 are positive
because through the action the reusable materials will be recycled, the contaminants and
contaminated materials will be consolidated and stored in a more environmentally sound
manner, and the physical hazards of the deteriorating structures will be eliminated.
Decontamination and dismantlement of the structures would be consistent with the final
remedial actions for the operable unit and the FEMP site because the action provides improved
storage of contaminants and contaminated materials in the interim, but does not bias the
treatment or disposal options available to the final remedial action ROD. Through this form
of assessment, DOE believes that long-term effectiveness of the project has been
satisfactorily considered.
Issue 10
The actions proposed for the interim remedial action must not bias the final remedial
action ROD or eliminate options for final disposition of the remediation wastes. However, the
interim remedial action proposed to decontaminate and dismantle the buildings will result in
a final decision for how the buildings are to be remediated. The final disposal of the wastes
must be evaluated and documented in the final remedial action ROD. (Comments H, K, and
N.)
Response: The OU3 final remedial action ROD will not be biased by the decision
reached for the OU3 interim remedial action because decontamination and dismantlement is
expected under all reasonable alternatives for remediation of OU3. The OU3 interim remedial
action does represent a decision for removal of the buildings as a.source for environmental
releases; however, the OU3 final remedial action ROD will document the ultimate treatment
and disposition for the OU3 remediation wastes. This final decision will result from
consideration of many issues and inputs, including the Fernald Citizen's Task Force.
During the interim action, a limited quantity of material will be dispositioned off-site
before the OU3 final remedial action ROD is issued. This waste quantity will be small
compared to the overall volumes anticipated for the project and therefore would not produce
a bias in the final disposition decision for the materials.
The interim action was proposed because DOE, as the lead agency for the FEMP, has
the responsibility to reduce risks to human health and the environment as quickly as possible.
Therefore, DOE is implementing an interim remedial action in accordance with CERCLA and
the NCP to accelerate the cleanup process within OU3. The interim remedy is the
decontamination and dismantlement of contaminated buildings, equipment, and facilities
within OU3 which are potential sources of contaminant releases to the environment. This
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OU3 Decision Summary (Final)
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June 1994
action is reasonable due to: (1) the early opportunity to implement cleanup actions to address
the advanced state of facility deterioration and continued potential for contaminant release;
(2) the resulting reduced exposures to site workers; and (3) the substantial cost savings to
the public from reduced maintenance costs. DOE has identified no future use for the OU3
facilities, and therefore considers the removal of these facilities to be a prudent measure to
ensure the protection of human health and the environment. Some facilities can be used to
support remediation activities and will. be decontaminated and dismantled late in the
remediation sequencing, once they are no longer necessary.
The final decision for the disposal of OU3 remediation wastes will occur in the final
remedial action ROD. The public will have opportunities to contribute to the evaluation of
potential alternatives. Through operable unit Feasibility StudylProposed Plan Public Comment
Periods and ongoing public involvement programs, public involvement in the planning and final
decision regarding disposal of remediation wastes is presently underway and will continue
throughout the decision-making process.
Issue 11
The OU3 baseline schedule and budget estimate calls for the replacement of the
current hourly workforce and is at odds with the Environmental Assessment evaluation of
minimal socioeconomic impacts. (Comments K, L, N, Q, R, and X.)
Response: The OU3 baseline is not inconsistent with the OU3 Proposed
Plan/Environmental Assessment. The current planning baseline has anticipated a transition
of the onsite work from that of maintenance activities to remediation project activities. This
transition is not anticipated to result in fewer jobs for an hourly workforce, but may shift the
definition of the work .from primarily managing the existing facilities (landlord activities) and
legacy wastes to actively decontaminating and dismantling the site structures. The larger
impact occurs for the salaried workforce, which is currently heavily involved with the
preliminary and detailed planning of the remediation projects. This work will transition to
implementation activities, which could be expected to involve a higher percentage of hourly
workers.
The socioeconomic evaluation made in the OU3 Environmental Assessment was based
on the following: (1) it is the DOE's position that current on-site employees will be used,
where practical, for activities associated with environmental restoration at the Fernald site;
and (2) DOE will help with the employee transition from production to restoration through the
development of a workforce transition management program that focuses on such issues as
skill level classification, training programs, and transition foresight schedules. Based on the
understanding that DOE will comply with all labor laws applicable in this case, the evaluation
was made that no net increase or decrease in the number of employees would result from the
implementation of the interim remedial action. Consequently, minimal socioeconomic impacts
would result, as is stated in the OU3 Proposed Plan/Environmental Assessment.
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OU3 Decision Summary (Final)
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June 1994
Issue 12
Concern was expressed over the methodology for incorporating NEPA values into a
CERCLA document (the Proposed Plan/Environmental Assessment). Additional concern was
expressed about the relationship between this Environmental Assessment and the OU4
Environmental Impact Statement. (Comments H, T, and Y.)
Response: It is DOE's policy to integrate the requirements of NEPA and CERCLA,
whenever practical. The intent is to incorporate NEPA values in CERCLA documents when
similar levels of study are conducted, thereby meeting the requirements of both NEPA and
CERCLA. However, it is not DOE's intent to make a statement about the legal applicability
of NEPA to CERCLA activities.
As such, the Proposed Plan/Environmental Assessment was developed to meet the
requirements of both NEPA and CERCLA. The objective of both laws is to assess the impacts
from the action proposed and the Proposed Plan/Environmental Assessment meets these
requirements. To clarify many of the issues involved in the integration of NEPA and CERCLA,
a roundtable meeting was held for members of the public on January 24, 1994. At this
roundtable, both the Proposed Plan/Environmental Assessment and the EIS for the OU4
remediation were discussed. The OU4 EIS includes a comprehensive assessment of the
impacts resulting from the leading remedial alternative for each operable unit. Each
subsequent operable unit will perform cumulative assessments updating the EIS.
The OU3 Proposed Plan/Environmental Assessment was not identified in the OU4 lead
EIS because this interim remedial action was decided upon after the cumulative impact
analysis was formulated for the lead EIS. Before the interim remedial action was conceived,
the leading remedial alternative for OU3 was decontamination and dismantlement of OU3
buildings and structures in conjunction with a disposal decision. This alternative, assumed
to be implemented after the final remedial action ROD, is addressed in the cumulative impact
analysis for the lead EIS. In addition, final disposition of OU3 remediation waste from this
interim remedial action will be addressed in the OU3 Feasibility Study/Proposed Plan (also
incorporating NEPA values) which will tier from the OU41ead Environmental Impact Statement
and will include the updated cumulative assessment relevant at that time.
. Issue 13
A Finding of No Significant Impact (FONSI) should not be developed before public
comments are received on the Environmenta/ Assessment. (Comments H, N, and Y.)
Response: Early in the development of the plan for the interim remedial action DOE
prepared an Action Description Memorandum (ADM) to determine the appropriate level of
NEPA documentation required for the project. Based on the ADM, a decision was made that
an Environmental Assessment would be the most appropriate NEPA review for this project.
An ADM is not required to be submitted for public comment or published in the Federal
Register because it is an internal document prepared and used by DOE to facilitate a
determination of the appropriate level of NEPA documentation required for a proposed action.
Information provided in response to questions at the January 5, 1994 public meeting was
incorrect in indicating that the ADM had been published in the Federal Register for public
comment and that the draft FONSI would be made available for a 30-day public review.
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OU3 Decision Summary (Final)
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June 1994
The purpose of an Environmental Assessment is to assess impacts to human health
and the environment and to determine whether to prepare an Environmental Impact Statement
or issue a FONSI. This decision is made by DOE. For the interim remedial action, comments
received on the Proposed Plan also represent comments received on the Environmental
Assessment. This responsiveness summary represents the summation of the public
comments and concerns and will be used in determining whether a FONSI is appropriate. A
draft FONSI may be prepared early by DOE to facilitate the overall timeliness of the NEPA
process.
Under certain limited and unusual circumstances, DOE regulations require that a
proposed FONSI be issued for public review and comment before DOE makes a final.
determination on the FONSI (10 CFR 1021.322(d». The unusual circumstances are: (1) the
proposed action is or is closely similar to one which normally requires an Environmental Impact
Statement; and (2) the nature of the proposed action is one without precedent. Neither of
these circumstances apply for this action. Public hearings are held if there is substantial
environmental controversy concerning the proposed action or substantial interest in holding
the hearing (40 CFR 1506.6 (c)). As a result, DOE does not plan to hold a public review or
hearing on the draft FONS!. However, if DOE does issue a FONSI for this project, it will be
available in the public reading room located at the PEIC in the JAMTEK Building, 10S45
Hamilton-Cleves Highway, Harrison, Ohio 45030.
Issue 14
Risks associated with the interim action should be assessed before any dismantling of
the buildings begin. An accident scenario should be considered for the storage facility.
(Comments F and N.)
Response: A risk assessment was performed for the OU3 interim remedial action. This
assessment is included in Appendices D, E, F, I and J of the Proposed Plan/Environmental
Assessment. This assessment used the EPA recommended CAPSS-PC model to determine
atmospheric dispersion of releases and also resultant radiation doses. Risks were calculated
based on NCRP 116 ("Limitation of Exposure to Ionizing Radiation", National Council of
Radiation Protection and Measurements, April, 1993). A major advantage of the model used
is the capability to incorporate variables such as wind speed, mixing heights, deposition
patterns, various isotopes, and different exposure routes (inhalation, immersion, external
exposure, and ingestion). Doses and associated risks to the public were determined out to
a five mile radius, in one mile increments, and in 16 directions .from the site. The results
show that the risks to off-site residents would be well below regulatory limits and applicable
guidance. Estimated risks to off-site receptors are very small.
A credible accident scenario was considered for this action. The accident scenario
considered assumes a rupture of the collection filter used during the decontamination
activities. This filter would be the collection point for all airborne contaminants from within
the building. Release of such collected contaminants over a 24-hour period would involve a
greater hazard to off-site residents than an accident scenario involving the storage facility.
A credible accident scenario involving the storage facility is anticipated to result in a lower risk
because: (1) most surface contaminants that could become airborne and be a threat to off-
site residents would have been removed through decontamination prior to storage; (2) most
materials after decontamination would be containerized in boxes or drums for storage; and (3)
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OU3 Decision Summary (Final)
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June 1994
the storage configuration for the materials would be improved by storage in the interim
storage facility.
Impacts associated with a tornado striking the site have not been quantified. However,
because the material located within the interim storage facility would have been
decontaminated and many of the materials and waste streams would be containerized, the
potential impacts to human health and the environment of a tornado striking a storage facility
are anticipated to be less than those associated with the impact of a tornado striking an
existing production facility. Even if a facility had been decontaminated, surface contamination
would still exist within and around duct work, process lines, and process equipment. The
proposed new storage facilities are designed to comply with current standards and are more
than adequate to address normal and severe weather conditions. None of the site structures
can be considered tornado-resistant, but the early removal of site structures and the improved
storage of materials would be expected to result in a lower risk associated with tornado
events.
Asbestos contamination is categorized by friable and non-friable asbestos, which
defines the likelihood of asbestos fibers being released. Asbestos containing materials that
are friable will be remediated under full enclosures to provide containment and collection of
all airborne fibers. For these reasons, asbestos fiber emissions will be contained during
remediation. For non-friable asbestos materials, engineering controls such as wetting will be
used during remediation to prevent airborne asbestos releases. The site has undergone an
extensive characterization program to identify and locate the friable and non-friable asbestos
containing materials. For the reasons stated above, asbestos modeling has not been
performed on this site and will not be performed.
In summary, the results of the risk assessment for both the normal action and the
accident case show that the on-site workers and the off-site residents would be safe during
the action. Additionally, during implementation of the action, monitoring will be continuously
performed to assure that any releases resulting from the action remain within safe limits. The
monitoring data that r.esults from the interim remedial action will be made available to the
public on a timely basis through placement in the public reading room, roundtable meetings,
and updates in fact sheets and monthly reports.
Issue 15
A concern was expressed that historical risk data that is used in the Proposed
Plan/Environmental Assessment is unreliable. Why were airborne concentrations increased
by a factor of 10 for the risk assessment? (Comments Hand N.)
Response: The historical results presented in the 1987 emissions report risk
assessment were not used to estimate the discharges or risks associated with the proposed
action because separate calculations were developed. The 1987 report, however, did contain
analytical data for samples of airborne contaminants that were accumulated in dust collectors
during production operations; this data was used to estimate the ambient airborne
concentrations of significant radionuclides within the buildings. The 1993 revised emissions
report also relied on these raw analytical data, but utilized a different calculation strategy for
determining emissions from the data. The approach used for the 1987 and 1993 reports was
not practical for predicting emissions and risks associated with the proposed decontamination
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OU3 Decision Summary (Final)
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June 1994
and dismantlement project because it estimated production stack emissions associated with
production of uranium products.
In developing the risk assessment for the OU3 interim remedial action, the 1987 report
data were used to confirm the radioactive isotopes present and the relative quantities of each
for six major production facilities. Air sample data for these six facilities, provided in
Appendix B of the Proposed Plan/Environmental Assessment and representing post-production
airborne radioactivity measurements, were utilized to estimate levels for each of the 1 6
isotopes. The risk assessment for the OU3 Proposed Plan/Environmental Assessment utilized
the calculated" air concentrations for each of the isotopes and also 18 more associated
radionuclides with short half-lives.
Typical work zone airborne concentrations that could be expected in these buildings
during decontamination and dismantlement activities were multiplied by a factor of 10 and
inserted into the CAP88-PC model, in order to conservatively assess airborne concentration
, levels, which could be created by the activities. Although speculative, increasing the existing
airborne concentrations by a factor of ten allowed the assessment to conservatively estimate
the potential conditions resulting from decontamination activities within the structures. The
process of removing surface contamination through high pressure washing, scabbling, and
other techniques is expected to increase airborne contaminant levels in the work areas as
evidenced through the Plant 7 dismantling, but not by a factor of 10. Engineering controls
will be implemented to collect, control, and maintain airborne levels as low as possible in
accordance with the principles of ALARA (as low as reasonably achievable). '
Issue 16
DOE, as the lead agency, should not be allowed to prepare risk assessments to
estimate impacts from proposed actions due to potential conflicts of interest. An
administrative agency may not delegate its public duties to private entities, particularly private
entities whose objectivity may be Questioned on grounds of conflict of interest. (Comment
N.)
Response: The FEMP performs its own risk assessments because it is specifically
required to under the Consent Agreement and the Amended Consent Agreement between the
DOE and EPA. Pursuant to Executive Order 12580, DOE is the lead agency for CERCLA
response activities at the FEMP. As the lead agency, DOE is required to act in the best
interest of the public. EPA's policy is that under certain circumstances the potentially
responsible party may conduct risk assessments. In accordance with the Amended Consent
Agreement, DOE as the lead agency and its contractors are required to perform the risk
assessments to support all RI/FS documentation.
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OU3 Decision Summary (Final)
A-20
June 1994
Issue 17
Commentors expressed that in the past, significant deficiencies have been found in the
site health and safety plan for work performed at Fernald and that these deficiencies are
inconsistent with the assumptions in the Proposed Plan/Environmental Assessment concerning
the adequacy of safety standards and practices. Additionally, the Proposed Plan/
Environmental Assessment estimates approximately 420 injuries as a result of the action. All
work should be performed within the principles of ALARA. (Comments H, L, 9, R, and S.)
Response: DOE's responsibility is to ensure that all work complies with DOE Orders,
requirements, and health and safety plans. Any deficiencies in the health and safety plan
would certainly be addressed and corrected before the interim remedial action work would be
performed. DOE will ensure compliance with all health and safety regulations and will follow
the principles of ALARA in conducting all activities at the FEMP, including this interim remedial
action, to ensure protection of workers and the public.
Since work will only be performed under approved health and safety plans, no health
and safety deficiencies have been incorporated into the assumptions of the Proposed Plan risk
assessments. Additionally, all training programs associated with the approved health and
safety plans to perform the work are assumed to be in place.
The Proposed Plan/Environmental Assessment calculated 420 potential injuries from
approximately 5.7 million person-hours of work during the 16 years of the OU3 interim
remedial action based on statistics from the Department of Labor for annual average injuries
associated with heavy construction activities. The decontamination and dismantlement of the
OU3 buildings and structures are categorized as heavy construction activities. In contrast to
the number of injuries from the Department of Labor statistics, the number of injuries for Fluor
Daniel, DOE, and the FEMP have been calculated for the last 6 years from 1988 through
1993. Using the projected personhours required for the 16 years of the OU3 interim remedial
action and the statistics based on Fluor Daniel projects for heavy construction activities, an
estimated 144 injuries is calculated. For all DOE sites and the FEMP specifically, the numbers
are 87 and 81 injuries, respectively. The Proposed PlanlEnvironmental Assessment statistics
calculated for the DOE and FEMP are based on operation statistics, and represent the site
work conditions with work occurring under an approved health and safety plan.
Issue 18
The Assistant Secretary of Environmental Restoration and Waste Management, Mr.
Thomas Grumbly, must sign the Record of Decision for the Interim Remedia/ Action with the
Fernald Site Manager (Mr. Hamric), the U.S. EPA Director, and the President of FERMCO.
Additionally, the Ohio EPA must submit a letter of concurrence with the document.
(Comment Hand J.)
Response: The Record of Decision for the Interim Remedial Action represents a legal
document binding both DOE and EPA to implementation of the selected action. The
signatures on the OU3 interim remedial action ROD will consist of the Acting Deputy Assistant
Secretary for Environmental Restoration (Mr. John Baublitz) and the Regional Administrator
for the EPA, Region V (Mr. Adamkus) or his designee. In addition, Mr. Grumbly, Assistant
Secretary for Environmental Management, will send a letter of concurrence to the DOE Fernald
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OU3 Decision Summary (Final)
A-21
June 1994
Field Office Manager supporting the Operable Unit 3 Interim Remedial Action. This Record
of Decision will be an enforceable document for this site once it is signed by DOE and EPA,
and as such, no other signatures are required. Additional signers and/or concurrences would
not result in additional legal enforceability and potentially could delay the enactment of the
action. DOE does anticipate that a concurrence letter will be submitted by the OEPA
indicating State support for the OU3 interim remedial action ROD.
Issue 19
A number of commentors concur with the selected alternative to decontaminate and
dismantle the former production area at the Fernald site. The commentors also felt that it is
about time that the site starts major field action. (Comments A, B, D, G, K, N, 0.)
Response: DOE believes it has acted in the best interests of the public and the
environment in proposing this interim remedial action and has been responsive to public
concerns about the speed of the cleanup actions at the site. This action was proposed in part
to address public concerns over the apparent lack of progress towards full-scale remediation
actions similar to that expressed at the January 12, 1993 public meeting for the approved
EE/CA, Removal Action 27. In addition, the interim remedial action itself is responsive to the
public's request for accelerated remediation of the site. DOE appreciates the support
expressed in these letters and looks forward to continuing to work with the nearby community
in an open and productive manner as the cleanup proceeds in the most effective and
expeditious manner possible.
A.5
Summary of Responsiveness to Public Comments
This section represents a summary of issue responses that have resulted in either a
revision to the OU3 interim remedial action ROD, or in significant additional commitments by
DOE to the public during the implementation of the interim remedial action.
Revisions/Commitments
Maximize utilization of existing structures at the site for the purposes of
interim storage and staging to avoid construction of new structures solely
for these purposes. Compliance with this request hinges on the ability of
the site to remove in the near-term significant quantities of waste inventory
currently in storage in site structures and to comply with appropriate
storage requirements for the remediation wastes.
The interim remedial action ROD provides additional commitment with
respect to this issue. See discussion in the Declaration (Description of the
Selected Remedy); page 19; and page 33.
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OU3 Decision Summary (Final)
A-22
June 1994
Guarantee that interim storage does not inadvertently become long-term
storage. Since many of DOE's own orders and various regulations and legal
agreements are in place to assure this cannot happen, it is unlikely that it
could become long-term storage; however, this is a concern of the local
public and is recognized as a sensitive issue which is addressed in the
interim remedial action ROD.
The interim remedial action ROD provides additional commitment and
explanation with respect to this issue. See discussion in the Declaration
(Description of the Selected Remedy); page 19; and page 33.
Provide the local public with regular air monitoring information updates
representing the impacts of ongoing remediation projects. The format of
this information transfer would be developed with members of the public
to comply with their request and will be addressed in the upcoming revision
of the Community Relations Plan.
Interim remedial action ROD language is not affected by this commitment.
DOE concurs that continued emphasis on removal of waste from the site
is important to allow the interim remedial action to proceed as planned, and
is committed to expediting this process.
Interim remedial action ROD language is not affected by this commitment.
DOE commits to maximize the public involvement in the environmental
restoration process through information in the public reading room and
updates in fact sheets and monthly reports. Specific additional public
involvement initiatives are also planned during the RDIRA and
implementation phases of the project and will be addressed in the upcoming
revision of the Community Relations Plan.
Interim remedial action ROD language is not affected by this commitment.
The interim remedial action ROD represents the fulfillment of the DOE
commitment to expedite the remediation of the FEMP, and specifically OU3.
Interim remedial action ROD language is not affected by this commitment.
A.6
Summary of Comments Not Resulting In Issues
During the public comment period for the proposed interim remedial action, the project
received several comments which were either not directly related or relevant to the action,
or were of a more minor nature. Response to these unrelated comments can be handled
within the regular FEMP programs for public involvement and education. Comments discussed
below were not considered to be significant comments with respect to the decision document
and are addressed below.
Commentor E Questioned the scope of Alternative 2. The commentor incorrectly
assumes the decontamination actions under Alternative 2 and 3 differ in magnitude and
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OU3 Decision Summary (Final)
A-23
June 1994
scope. The commentor's proposal would generate significant volumes of waste to disposition
without removing the OU3 structures. In addition, given the processing activities that
occurred at this site for 37 years, it would be virtually impossible to perform a
decontamination to the extent that allows an entire facility to be "free released". For this
reason, this option was not examined.
Commentor G indicated that monitoring and maintenance are not mentioned within the
scope of the preferred alternative. This specific information was not included in the fact
sheet, but is contained in the description of the alternative within the Proposed
PlanlEnvironmental Assessment. Additionally, Removal Action 17, upon which the design and
operation of interim storage facilities will be based, requires continuous monitoring and
maintenance.
Commentor H requested that accurate real-time monitoring techniques be developed.
Real-time monitoring, which would provide quantitative results on a demand basis, is not
currently possible when monitoring for airborne uranium and thorium. Due to current
technology limitations, "real-time" monitoring for airborne uranium and thorium will probably
not be available in the near future. This is due to the short-lived radon daughters that are
present in the ambient air, which interfere with accurate alpha radiation detection.
Commentor L questioned the reference to the average annual dose to a U.S. individual
of 300 mil/irem per year. The 300 millirem dose per year reference is the dose that an
average person living in the United States receives each year from natural background, and
is unrelated to the interim remedial action. This apparent misunderstanding will be discussed
with the commentor.
Commentor N requested information as to the environmental and health risks
associated with the Central Storage Facility if it becomes a long-term or permanent storage
facility. DOE has stated in responses to this issue that these facilities are ineligible for
consideration as long-term or permanent storage facilities, and therefore no long-term
assessment is to be performed.
Commentor N questioned the worker exposure levels estimated in the Proposed Plan/
Environmental Assessment in comparison to the annual average exposure to an individual.
The annual doses estimated for workers from the interim remedial action represent annual
doses that are in addition to average annual exposures from natural and manmade sources.
Commentor N questioned the impacts of funding constraints on the interim storage
facility. Budget cuts by Congress could impact the interim action by minimizing the number
of structures and facilities to be remediated before the final remedial action ROD. Therefore,
the impact of budget cuts would reduce the quantity of materials placed within interim storage
and once the final remedial action decision is made, these materials will be dispositioned.
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OU3 Decision Summary (Final)
A-24
June 1994
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OU3 Decision Summary (Final)
B-1
June 1994
APPENDIX B
. WRITTEN AND ORAL COMMENTS
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OU3 Decision Summary (Final)
B-2
June 1994
Page left intentionally ~Iank.
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OU3 Decision Summary (Final)
8-3
June 1994
APPENDIX B
WRITTEN AND ORAL COMMENTS
The written comments received during the comment period and verbal comments received
during the January 5, 1994 public meeting are contained in this appendix. Each specific
comment letter, oral statement, and submitted attachments are referenced by an alphabetic
identifier as noted in Table 8-1. These comments are a formal part of the Administrative
Record for this action.
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OU3 Decision Summary (Final)
8-4
TABLE B-1 Written and Oral Comments Received
June 1994
Letter
Commentor
Page Number
W
X
Y
A
8
C
D
E
F
WRITTEN COMMENTS
Kenneth J. Wurzel bacher, Hamilton, Ohio
Carl A. Woycke, Harrison, Ohio
8-5
8-6
8-7
8-8
8-9
8-10
8-12
8-13
8-15
8-16
8-18
8-20
8-22
8-28
8-36
8-38
8-41
8-54
8-57
8-93
8-94
8-94
8-94
8-95
8-96
Maggie Merritt, Harrison, Ohio
Paul Ruttencutter, Hamilton, Ohio
Laura Jane Whitesides, Las Vegas, Nevada
Lawrence L. Stebbins, Hamilton, Ohio
G
H
Edwa Yocum, Harrison, Ohio
Vicky Dastillung, Vice President of Fernald Residents for Environmental
Safety and Health (FRESH), Hamilton, Ohio
J
K
L
M
Pam Dunn, Harrison, Ohio
Lisa Crawford, President of FRESH, Harrison, Ohio
Karen 8ell, President Crosby Elementary PT A, Harrison, Ohio
Norma Nungester, Harrison, Ohio
Holly Schick, State Director of the Ohio S8DC, Columbus, Ohio
N
Unsigned letter submitted by the Fernald Atomic Trades & Labor
Council, Ross, Ohio
Graham E. Mitchell, Project Manager, Ohio Environmental Protection
Agency, Dayton, Ohio
Maud Naroll, State Clearinghouse Coordinator, Department of
Administration, Carson City, Nevada
o
P
ORAL COMMENTS AND ATTACHMENTS
Q
R
S
T
Oral Comment by80b Tabor
Oral Comment by Jerry Monahan
Submitted Attachment to 80b Tabor's Oral Comment
Oral Comment by Vicky Dastillung
Oral Comment by Robert Richardson
U
V
Oral Comment by Pam Dunn
Oral Comment by Lisa Crawford
Submitted Attachment to Robert Richardson's Oral Comment
Oral Comment by Richard Miller
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OU3 Decision Summary (Fina/)
8-5
June 1994
Comment A
r
COMMENT SHEET
DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed . Plan / Environmental Assessment for Interim Remedial Action of Operable
Unit 3. including the preferred alternative to decontaminate and dismantle the former
production area at the Fernald site. Please use the space provided below to write your
comments. then fold. staple or tape. and mail this form. We must receive your
comments on or before the close of the public comment period on January 7. 1994. If
you have questions about the comment period. please contact Ken Morgan. the DOE
Public Information Officer at Fernald. at (513) 648-3131.
alE ;1/ Ek L) ~ .Ij :77.LE" /?~/8G' A £- //~/'
/,v S TEA // c)"::: a/ pClLJ..5. ~ ~7 '.f G~
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Name: &;I//pt!'~# :T tV .rc~J~;Zff,t.A'J:lc#tP.e.
Address: 417.~ .8f?1)(,(/ft/ ,&'".4Jt:!/f'1 LJJfE
City: PA ~ / L ;;i'O /1/ StatelZip: t!7A1/~
Phone; 7.38-4~':71?
!
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4~CJ~
MAILING LIST ADDITIONS:
Please add my name to the Fernald Mailing List to receive additional information on the
cleanup progress at the Fernald Environmental Management Project:
VES~
NO-
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OU3 Decision Summary (Final)
8-6
June 1994
Comment B
COMMENT SHEET
DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed Plan / Environmental Assessment for Interim Remedial Action of Operable
Unit 3, including the preferred alternative to decontaminate and dismantle the former
production area at the Fernald site. Please use the space provided below to write your
comments. then fold, staple or tape, and mail this form. We must receive your
comments on or before the close of the public comment period on January 7, 1994. If
you have questions about the comment period, please contact Ken Morgan, the DOE
Public Information Officer at Fernald. at (513) 648-3131.
~ ~fk ~
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MAILING LIST ADDITIONS:
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Name: (/'I. If R L A IA.M YC KE
Address: /! ~ FER NI+Lf) "R.
City: ~' ~ rtR! 36 N StatelZip: CH ( C.
Phone 73 R~:; 75"If
LI S-O ,1 (.J
Please add my name to the Fernald Mailing List to receive additional information on the
-:Ieanup progress at the Fernald Environmental Management Project:
YES-
NO-
-------
OU3 Decision Summary (Final)
B-7
Comment C
COMMENT SHEET
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DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed Plan / Environmental Assessment for Interim Remedial Action of Operable
Unit 3. including the preferred alternative to decontaminate and dismantle the former
production area at the Fernald site. Please use the space provided below to write your
comments. then fold. staple or tape. and mail this form. We must receive your
comments on or before the close of the public comment period on January 7. 1994. If
you have Questions about the comment period. please contact Ken Morgan. the DOE
Public Information Officer at Fernald. at (513) 648-3131.
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Phone: / -..s- / ~ - 75
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OU3 Decision Summary (Final)
8.8
Comment D
COMMENT SHEET
DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed Plan / Environmental Assessment for Interim Remedial Action of Operable
Unit 3. including the preferred alternative to decontaminate and dismantle the former
production area at the Fernald site. Please tJse the space provided below to write your
comments. then fold. staple or tape. and mail this form. We must receive your
comments on or before the close of the public comment period on January 7. 1994. If
you have Questions about the comment period. please contact Ken Morgan. the DOE
Public Information Officer at Fernald. at (513) 648-3131.
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Address: L.I 0 .; <
City: m~!,-7li;v
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MAILING LIST ADDITIONS:
Please add my name to the Fernald Mailing List to receive additional information on the
cleanup .progress at the Fernald Environmental Management Project:
YESL
NO-
June 1994
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-------
OU3 Decision Summary (Fina/)
8-9
Comment E
COMMENT SHEET
, '
DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed Plan I Environmenral Assessmenr for Interim Remedial Action of Operable
Unit 3. including the preferred alternative to decontaminate and dismantle the former
production area at the Fernald site. Please use the space provided below to write your
comments. then fold. staple or tape. and mail this form. We must receive your
comments on or before the close of the public comment period on January 7. 1994. If
you have Questions about the comment period. please contact Ken Morgan. the DOE
Public Information Officer at Fernald. at (513) 648-3131. '
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-------
OU3 Decision Summary (Final)
8-10
Comment F
:';9~4 Si lax Dr.
HamIlton. OR 45013
.January i. 1994
Department of Energy
Attention: ~~. Hamric
Fernald Environmental Management
P. O. Box 398705
CincInnati. Ohio 45239-8705
ProJect
After reVlewUlI! the available im'ormat Ion reli!ardlng the ear jy
dismantling of the production DUI!dings at Fernaid. I wouid 11ke voice
to YOU some of my concerns as a resIdent wno lives dO~~WlnQ of the
proposed act l'\/i ty.
The information sent to my home for reVIew stated that the ~~sk to local
resIdents was small. Is that rIsk known. and how was it ca: cuiated. If
1 t is not known. as a resident I would I ike to ask that any plan I'or
dismantling Include air pollution modelIng which will show what the risk
to my fami ly and nei~hbors IS. I would I ike to know 11' there have been
an\' aIr pollution models run which show the distnDutlon of the
('omamination that will be caused as a resul t of these actIvIties. Sot
screemng types modeis. but specifically. canprehenslve models which
take Into ~onsideration terraIn. \~ind speed. weather ~onditlons. mixing
height and the deposition patterns.
Only radioiogical COntamInatIon was mentioned in the lIteratUre sent to
the public. Once of my maJor concerns is the potential threat of
asbestos contammatlon. Has any model ing specifica! ly been done tor
this. either screenIng type or comprehensive.
One of the Important consIderations for risk based calculations is that
Elda Element.ary School. the Ross Middle School. and the Ross Senior High
School are all in the direction of the prevailIng wInd patterro.
I feel that the plan to perform early dismantl ing of the production
buildings IS not a bad idea. However. I would like to reauest that risk
June 1994
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OU3 Decision Summary (Final)
8-11
Comment F (Cant.)
based calcuiallons be applied ir. conJunction wIth a.Irborne contamlIlation
:node!s: ~o the actual risk quantif:ea. :Jrlor to any cl1smantlltlg of the
crcductlOn buiidl~S.
I maKe thIS request in good faith. and t!"ust 1t will be received as a
good faith effort to improve the ImDiementation of the proposed action.
ana that no effort will be made by any party to affect my employment at
the FEiP.
Respect fu 11 y yours.
~~x/f~
Lawrence L. Stebbins
June 1994
-------
OU3 Decision Summary (Final)
8-12
June 1994
Comment G
;
I
I
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I
I
DOE is interested in your comments on the cleanup alternatives being considered in the !
Proposed Plan / Environmental Assessment for Interim Remedial Action of Operable:
Unit 3. including the preferred alternative to decontaminate and dismantle the former :
production area at the Fernald site. Please use the space provided below to write your !
comments. then fold. staple or tape, and mail this form. We must receive your!
comments on or before the close of the public comment period on January 7. 1994. If !
you have questions about the comment period, please contact Ken Morgan. the DOE:
Public Information Officer at Fernald. at (513) 648-3131. :
t~~~;j,~<:>\:\~~~L~~~~MJ!/':j. I
.... \:- ("'m.-tsJ\"\~ ~.L.V\c;VC"v-d- \~~"'-ti_rLw\.Vr1q !
(PrY-. £)..jt~)-(
-------
OU3 Decision Summary (Final)
8-13
Comment H
'.::or'lI'IEH'fS ON THE OU 3 PROPOSED PL.b,N / EA FOR THE INTERIM
REI'IEDIAL ACTION
. The terms "Interim storage" ano "temporary storage" can
mean very dIfferent things to different people. The public
needS and oeserves a guarantee that the" Interim storage"
WI I I not be al lowed to become .permanent" because of
schedule slippage or funding problems. An agreement that
spells out how long" Inter-im" may be and how the publ ic can
enton:e' ttlis is sorely needed. It shoul'd be signed by top
officials who have the power- to sign such a guarantee.
* Be sur-e that proceeding with this IROD does not bias the
ROD or el iminate options, such as off-site vs. on-site
storage. '
~ because the annual Environmental Monitoring report IS
Issued so long after the monitoring \s actually oone, the
pUblic deserv~s to see the envlronemtal monitoring results
otten. perhaps monthly. so they can be assured that the au ~
IROD activities are not affecting the community's air. '
water. or environmental quality.
~ Also. the monitoring done specifically for the IROD should
be made easily available to the public. ~n update at RI/FS
meetings would be nice. Fast turnaround on analyZIng samples
I s important so that any prob! ems \...i II be detected prompt I Y
enough for mitigating measures to be taken.
* Developing accurate r-eal-tlme monitoring should be a DOE
priority.
. On page 1-) and )-2 it states that It is DOE pol icy to
Incorporate NEPA values into the RI/FS process "wherever
practical". Where was it not practical? How does the
general public know that aJ I of NEPA was really incorporated
In the document if they aren" t NEPA experts?
1
* How does an EA 00 an OU relate to the RI/FS EIS being done
tor the whole site?
~ The terminology used is not exactly up-front and honest
with the public. The tact is that the "interim" ROD 1s
3ctually a "final" ROD for the portion of au 3 that dealt
with the buildings. Once the IROD is chosen and ouildings
come down. ',Ie won" t be able to change that. It.s final.
A A FONSJ should not be written before the publ ic and
regulatQ~S have had the opportunity to comment on the EA.
June 1994
-------
OU3 Decision Summary (Final)
8-14
Comment H (Cant.)
~ Throughout the document it says that data on contaminants
is still being collected. 1s there much potential tor
surprises to pop up as mo~p. data IS collected?
~ Whi Ie long-term effectiveness 15 not required to be
considered for an IROD. it is Important to the community
that thi~ be considered as much as possible. After 01 I It
was a lack of considering the long-term effects of
activities at the FEMP that got us in this mess to start
_I i th .
~ On page 4-10 it states that "airborne concentrAtions of
contaminants. on the average. are assumed to increase by a
:actor of ten due to remedial actions," Why a tactor ot 107
ft The principle ot ALARA should be emphasized to protect the
'.lorkp.r!'l and the commun i t Y as much .:J.~ poss i b Ie,
ft Thi document was refreshingly readable and included many
~nort but InformatIve statements that explained .why. things
were beIng done.
Submitted by
Vicky Dastll lung
~~01 Klenk Place
Hamilton.OH 45013
<513> 738-5535
June 1994
-------
OU3 Decision Summary (Final)
8-15
June 1994
Comment I
January 28. 1994
:0:
~r. ?:en Morgan
:erna1d EnV1ronmen~al Managemen~
~.s. =epar~men~ 0: Energy
:erna..d. :~10
ProJec~
?_E:
:ommen~s C:1 ~he Proposed Plant £nv:1.ronmen~al ;.ssessmen~ - .;)t] :3
~hile I agree 1:1 pr1nc1ple w1~h ~he early 1mplemen~a~10n of remed1ation of au
3 : am concerned w1~h in~er1m s~orage discussed 1n ~h1S docurnen~ W:1.~ no
:u~ure cons:1.dera~:1.ons being discussed in regards ~o ~he ~oss1Dility of
permanen~ s:orage on S1~e of this ma~er:1.al. ~E's pas~ h1S~Ory of in~er1m
s~orage ~s anywhere from one. two. ~wen~y-five ~o indef~~e years. A~ ~he
meet1ng ~onciay January 24. 1994 1~ was expressed tha~ ~his s~orage fac1lity
was more-or-less ~o be a scag1ng facility; this :1.S no~ ~he ~erm1nolo9Y used i:1
the PP/EA ciocumen~ for the Inter1m Record of DeC1S10n. ~here i:1 a difference~
It is ~herefore reques~ed. s~rongly and urqen~ly reques~ed. t~~~ ~he Proposed
Inter1m ROD language De moc1ified to s~ate that this ~emporary s~orage facility
will not =e 1n eX1stenCe once the remediation of au 3 is eventually completed
and ~he decC1lllll1ss10lUDg and demo1i~1cn of this ~emporary s~orage facility will
be 1ncluded i:1 the f~l ROD for ot] 3. ! am also concerned w:1.~h the cos~
assoc1a~ed W1~ ~he cons~ruct10n of this 1nter1m storage fac~lity. that ~s
tha~ a cons1derable sum of func1s will be expec~ed for a structure ~hat will be
destroyed 1n a short period of time. It::.s unclear if :here are other
al~ernat1ves which may be sU1table for the purpose of :emporary/interim
storage or stag1nq. whichever its 1nten~10ns; peraaps ~he use of struc~ures
c~rently of s1te for shor~-~erm while ~he 1SSue of poss1Dle permanen~ on
S1te storage 1S addressed and ~he funds 1ntended for ~he ::':1ter1m fac11i~y
applied to this. I am also s~ill wa1~inq for an answer to my quest10n a~ the
';anuary 24. :994 meet1ng pertain:i.ng to the differences 1:1 cost for this
temporary facility as presented in two DOE documen~s. the s1te deve10pment
:sma1l) :ook states 534 million and volume ~wo the Gold bOOK for OU 3 sta~es
58 m:1.11ion: ! would like clarifica~1on of this var1&nce. r.g&1n I w1sn ~o
re1terate the need for wording moc1ification to the OU 3 PP/EA and lnter1m ROD
stat1ng ~hat this telll!;)Orary storage facility will not be in ex1stence once the
:'emea1at10n of OU 3 is eventually completed and the decC1lllll1ssioning and.
~emo1it::.on of this ~emporary storage facility will be included in the final
i1.::>D for ot] 3.
Sincerely
~~.
Ms. Pam DImD
7781 New Haven Rd.
Harrison. Ohio 45030
cc: :.R.E.S.H. Inc
Mr. John Applegate. chair. Citizens. Task Force
file
-------
OU3 Decision Summary (Final)
8-16
Comment J
. .
J~ouary 30. 1994
RE:
Public Comments a.v.
3 Fr(lposed Plan
Mr. Ktill MorfJ.:..n
Public Rel.tions
V.S. D~partment. elf Eller'qy
P.O. Bc)x 398705
Cincinnati. OH 45239-8705
Deat' Mr. Morgan:
Th~ pyrpose of this letter is tn provide official comments on the
Operabl~ Unit 3 Proposed Plan:
1 .
The Assistant Secretary of Env. Rest. & Waste Manaqement, Mr.
Thomas Grumbly, must sign t.he final IROD; along with the
F~rnald Site Manager (Mr. Hamric); U.S. EPA Director. rre~id~nt
of FERMCO and al~o .n added letter of concurrence from the Ohio
EPA.
2.
The public must have a guarantet:: that waste storage is intet'im
and that the long.'t.erm Jilla.n f01' waste is made in u. timely
manner. Interim must be defined in number of years.
:1.
There should b~ ~ontinuous monitoring of buildings as they are
torn down and the results should be made available in a timely
£a:;hion.
4.
The public must he involved in the long-term storage and
disposal planning phase. They.must also be kept apprised of
situation on a regular basis. They must be allowed to see the
spec's of interiru-st.orage plans and ideas. As each a.v. waste
storage i5sue a ris~~, they must b~ add~d t0geth~r and then
work toward the long-term plan for waste storage' disposal.
5.
Final perman~nt storage facility must be that. and not the
interim-storage site. One cannot b~come the other -- they must
be totally separate of one another.
6.
Any documents relevant to this O.U. that are placed in the
Administrative Record or the R~adinq Room. the community must
be notified and afforded the opportunity to comment on them. if
.:tppropriate.
7.
DOE/FERMCO must show how this will save money and time.
must share their plAns for D & D as we move through the
proce::s.
They
s.
DOE/FERMCD must look at the long-term waste plan before it can
even think about interim-storaqe. It should be called
"interim" \Jnt.il it'~ d.~ellled "long-tel"m" & "permanent"! They
mllst define how long "interim" really is -- with a deadline Ot"
~'l'opost!.'d deadlin.... nl~Y must re-evaluate at that time. with
June 1994
-------
OU3 Decision Summary (Final)
8-17
Comment J (Cant.)
(2 )
community input, for th~ rea9gn~ ~s to why it's longer or
ther~'s no long-term plan &$ of yet.
9.
The community must and will be walked through this process.
Thi~ must be gUdldlJLeed. R()undtables should be held as futurF.-
plans ar upd~tes occurr.
If y0\1 have questions about th~se comments, please contact me as
soon as possible." I look torwa~d to seeing your official comments
with r~qard to these attachprl rnmm~nts.
~~it:lC"E-l'el Yr. , I (
! I . I .
('1Y.~v:.- - ./l t,CU..f' ,~~/,~O' ----
LJ so Ct';"wford
Pr~siQ~nt, F.R.E.S.H., INC.
LC/eac
cc:
files
June 1994
-------
OU3 Decision Summary (Final)
Comment K
8-18
June 1994
Crosoy f£,t:em£ntary Schoof PTJ-t
8382 ~w :J{aven ~
1larriscm.. OIiUJ 45030
2(aren 'Bdf. Pre.si4mt
H-3-\S't.
.. '" .
January 4, 1994
Mr. K. L. Mo~gan
Public Information Officer
DOE Field Office, Fernald
U. S. Department of Energy
P.O. Box 398705
Cincinnati, Ohio 45239-8705
Dear Mr. Morgan:
The members of Crosby Elementary PTA's Executive Board and Crosby
Elementary School's staff, which are members of the PTA, have read
and discussed the information t)resented in the "Fact Sheet
Decontamination and Dismantlemen~ of Buildings and Structures at
Fernald, dated December 1993" and the "Proposed Plan/Environmental
Assessment for Interim Remedial Action of Operable Unit 3".
We are submitting our comments and concerns as an attachment to
this letter. We are submitting them after the specified public
comment period closing date of January 7, 1994, as we were informed
that the public comment cericd was extended for 30 days as
announced at the public meeting held on January 5, 1994.
The PTA Board has taken the position that the PTA's
responsibilities and actions are based in representing the issues
of Parents and Teachers out of concern for our children and
students. Because of the croxirnitv of the school to the Fernald
Site, Crosby Elementary Scheol's PTA would like to have an informed
membership. The PTA would :ike DOE and PERMCO to maintain
community relations with our school membership and their families.
~he Board has adopted the following position:
"!n general, the Crosby Elementary School PTA supports the
clean-up effort at Fernald and the concept the clean-up
schedule could be improved."
-.. adopting this position the Board has tried to maintain
se:-.s:::.vity to the fact that t:he different alternatives could
a::ec: job and financial security of families at our school. This
affec: could in turn be impacted on the children at our school.
Sincerely,
i1 ~.
I .. ~ .
. / ... ~~ - , .
. ~l~"'~1 t O:L~~
Crosby Elementary PTA
Karen 3ell, President
(>
-------
OU3 Decision Summary (Final)
8-19
June 1994
Comment K (Cant.)
Attachment:
C~osby Elementary PTA. January 4. 1994
COMMENT SHEET
Would the reauired i~formation en effects to
environment be available for the areas to be
the site RI/FS. Could any contamination be
site. If so what additional i~formation does
Dersonal health and
demolished ahead 0:
brought out of the
RI/FS provide.
Would limits be established and monitored (air and water) at the
work area boundaries. How a~e limits established, for adults or
children. The school generally is not downwind or downstream of
Fernald. Many of the students however live in the trailer park
south-east of Fernald.
Lead-paint has been shown to be dangerous for children. Do you
monitor for lead. could construction work inc~ease this hazard.
Could it be brought off-site.
Would the tearing down of the buildings affect
material is stored.
where
hazardous
Would the start of demolition in any way affect the outcome of the
RI/FS as far as continuing to store construction waste on site. The
promise has been to return the site to a clean area.
There have been articles i~ the DaDer that land i~ our area has
been looked at for storage of waste. Is this t:"'.le. That seems
like a breach of promise.
Would the traffic be i~creased affecting the school bus routes.
would constructior. traffic coine off-site be monitored to keep
~oads clean from mud spreading contamination.
How will it affect the jobs of our parents. Will there be job loss
affecting the fi~ancial situatio~ of families and students at our
school. Will there be stressful home situations created affecting
students at school.
Fernald :::-eceives national attention. Would the clean-up effort
att:::-act any violence to the area. The site has had bomb threats in
the past.
,"
Althouch Fernald is in our school dist~ict. it receives no gain 0:
school- tax. No additional SUDDort aDpears -- :::ome from the
construction phase. Could DoiiFernald financial:y assist the
school in hook-up to the new public water system?
-------
OU3 Decision Summary (Final)
Comment L
8-20
June 1994
COMMENTS ON PROPOSED PLAN/
ENVIRONMENTAL ASSESSMENT FOR
INTERIM REMEDIAL ACTION
OF OPERABLE UNIT 3
Norma J. Nungester
8574. Mt. Hope.Road
Harrison, OH 45030
February 2, 1994
Page 5-5
5.2 Preferred Alternative
I have serious reservations about storage under tent-like
structures of drums of mixed and hazardous waste and do not believe
it is stable or sturdy enough for weather conditions. While
interim action is not supposed to address long-term, it must be
strong enough to withstand weather conditions such as heavy snow,
strong winds, and rainfalls. All of which can and do occur in our
area.
Since the storage location is northeast of the production area, we
could have drums exposed with any emissions travelling via the
prevailing winds. If your desiqned water collection system
overflows, as the current water retention system has been known to
do, clay or till underneath may serve as a pathway or conduit for
contaminants to the south and/or east where there is less or no
clay or till to protect the aquifer and through any cracks
contained therein.
While the preferred alternative may provide the best alternative of
those considered, and it sounds good in theory or in words, what
about two or three years hence when these barrels are rusting and
leaking mixed and hazardous waste onto and into the ground and the
air? The K-65 silos were cracked and leaking within a few years,
although they were supposedly desiqned to last 25 years and were
~ade of concrete. Barrels of thorium were found falling apart and
leaking in the mid 1980's after being re-packed in the 1970's.
Is this in compliance with CERCLA? How about NEPA? Are you
permitted to store radionuclides over an aquifer? Even for a so-
called few years?
Health effects:
General Public
Please do not compare it to an average individual in the United
States receiving an annual radiation dose of 300 millireml. Our
natural background in the Fernald area before FEMP was constructed
was two parts per million.
-------
OU3 Decision Summary {Final}
8-21
June 1994
Comment L (Cant.)
Preferred Alternative
Operable unit 3
Page 2
Norma J. Nungester
February 2, 1994
People have to live with natural background, but some of these are
man-made contaminants, and many do not naturally occur in this. area
(thorium comes to mind). Residents would not have come in contact
with them via air, water, or inhalation were it not for the FEMP
facility being located in the Fernald area.
If a person has received a dose year after year after year, from
naturally occurring and manmade radionuclides, your mere 300
millirem may be the cumulative amount that puts him in the high-
risk category.
We, of course, have no way of knowing this since the DOE
to do or disclaimed health effects studies in the past.
refused
Health erfect:
Workers
When the buildings are dismantled, or in the process, where are
these workers to go? Are they expected to be .out of doors for
eight hours a day.
The cleaning and dismantling should be done by experienced Fernald
Atomic Trades Council workers who have worked with these
contaminants throughout the years; not people experienced in only
building and dismantling and cleaning of some hazardous
contaminants.
The contractors should not be allowed to order workers to open
cylinders or drums, as they have done in the recent past, which
endanger their lives. The FEMP safety record must improve. The
demolishing of good equipment such as fire engines to fill scrap
shipments must stop.
I (Fact Sheet for the proposed Plan/Environmental Assessment for
Interim Remedial Action)
-------
OU3 Decision Summary (Final)
8-22
Comment M
COMMENT SHEET
DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed Plan / Environmenral Assessment for Interim Remedial Action of Operable
Unit 3. including the preferred alternative to decontamInate and dismantte the former
production area at the Fernald site. Please use the space provided below to write your
commentS. then fold. staple or tape. and mail this form. We must receive your
comments on or before the close of the public comment period on January 7. 1994. If
you have QueStions aboUt the comment period. please contact Ken Morgan. the DOE
Public Information Officer at Fernald. at (513) 648-3131.
Comment attached.
January 5. 1994
Name: ~OLLY SCHICK. STATE DIRECTOR of the OHIO SBDC
:HIO DEPARTMENT OF DEVELOPMENT
Address:77 S HIGH STREET. 28th FLOOR
City:
Phone:
:"':LUMBUS
: (14) 466-2711
State/Zip: OHIO
or 1-800-848-1300
43266-0101
MAILING LIST ADDITIONS:
Please add my name to the Fernald Mailing List to receive additional information on the
cleanup progress at the Fernald Environmental Management Project:
YES...,L
NO-
June 1994
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-------
OU3 Decision Summary (Final)
8-23
June 1994
Comment M (Cont.)
. [Q.R~!9. ~'~~i~~~~~.SS DEVELOPMENT CENTERS
George V. Voinovich
Governor
Donald E. Jakeway -
Development Director
TO: Ken Morgan, the DOE Public Information Officer at Fernald
January 5. 1994
This comment is in response to DOE's request for public comments regarring the cleanup process
a/tematilles. The following statement serves as a notification to the U.S. Department of Energy that
the Ohio SSDC wishes to participate and assist in the decision-making process for the remedation
ofthe Femald site.
The Ohio Small Business Development Center (SBDC), under the Ohio Department of
Development and in partnership with the Small Business Administration, provides counseling,
training and technical support to Ohio small businesses. The Ohio SSDC also has a well
established government procurement network program called Ohio Procurement Technical
Assistance (OPT A). The OPTA outreach centers provide prime contracting and subcontracting
assistance to Ohio businesses through counseling, training and education, and through various
advocacy iniliBliVes.
The Ohio SSDC office was contacted by a consortium of Ohio based businesses wanting
infonnation on subcontracting opportunities related to the clean up and remediation process at the
DOE Femald Site. Our office has begun to research the potential economic impact associated with
this massive remediation project that DOE oversees.
We wish to take the lead in developing a statewide economic strategy for Ohio small businesses
as it relates to the potential impacts of the DOE environmental management projects within the
state. This initiative would estaJiish a mechanism to coordinate local interests and represent
communities to assist in the following process:
developing a networl< to share infonnation and resources. maximizing local and
statewide opportunities for the enhancement of:
. public awareness
- small business contracting opportunities
- economic impact
- safety education and training
- public/private alliances
- innovative technology and research
- reuse of property, (etc.)
- environmental restoration
as it relates to opportunities at DOE sites within Ohio
addressing the economic impact of potential contracting opportunities for local'
businesses and businesses throughout the State of Ohio
addressing the environmental needs of the immediate areas impacted
~.-
~~". .EE: An Office of the Ohio Deportment of Development
~~'
77 S. High St., P.O. Box 1001. Columbus. Ohio 43266-0101 (614) 466-2711
-------
OU3 Decision Summary (Final)
8-24
Comment M (Cant.)
page 2
The Ohio SSDC recognizes the tremendous magnitude of the problem facing DOE. Ourgosl Is to
create an atmosphere of coopetation, trust and understanding in order to benefit sm811 businesses
and local economies within the state and to assist DOE in reaching its remediation gosIs.
In response to DOE's invitation to comment on the altematives being considered for the cleanup
of Operable Unit 3 at the Fem8id Environment Management Project, the Ohio SBDC wishes to
provide information to the public on the proposed initiBlives and contracting opPortunities at the
Femald site. We want to worlc with the DOE Fem8id office on al88s applicable to IocaJ economc
development. technology reinvestment, worlcforce and community transilionas it teIates to the
phases of remediation process.
The Ohio SSDC intends to worlc with the DOE site personnel for Operable Unit 3 in 8 timely manner
and in accordance with the cle8nup goals and schedule. The Ohio SSDC has been identified by
the DOE Office of Facility Transition and Management, EM-6O as the Ohio contact for economic
development assistance. (see attachments from a 1994 DOE Handbook)
In summary, we wish to assist in making this remediation project a success that benefits Ohio
economically and environmentally; and one that will provide DOE with a national model for fulure
remeditation projects. We look forward to hearing from you and developing a partnership of c0-
. determination for achieving success.
7k~
Holly ,. Schick, State Director
Ohio Small Business Development Center
Ohio Department of Development
-
\
June 1994
"
-------
OU3 Decision Summary (Final)
8-25
Comment M (Cant.)
u.s. Department of Energy
Economic
Development Funding,
Assistcince, and
Points of Contact
FY 1994 Handbook
June 1994
-------
OU3 Decision Summary (Final)
8-26
June 1994
Comment M (Cant.)
PREFACE
This handbook provides infomwion on federal and state economic development funding,
~o:~~nce, and points of conw:t. It is far planning pUIpOses only and is not in~ded as a
Sfllici~rion.
As with any reference guide. revisions will be D-~ry as conditions change or as new
factors came 10 light. Of immediate c:onccm 10 the economic development p1aJmer are
budget appropriation figures which affect economic development funding levels far FY 1994.
These figures should become available by November 1993, and will be included in a revision
to this document at that time.
Updates will be provided to assess programs conlained in the handbook. identify changes as
they occur, and to provide updated information as new contI.CtS, funding, and programs are
established.
This document was prepared by Joseph Pastel and I..ama Prout of ScicDce Applj,",rinn~
International Cmpomion under contraCt with the Department of Em:rgy, in c:ono:nlr..rinn with .
the agencies described in the following IeXL Copies are distributed free of charge to
economic development representatives at DOE sites and smmunding communiUes upon
request.
To obtain additional copies please contact:
Kitty R. Gandee
Office of Facility Transition and Management. EM-60
United States Department of Energy
1000 Independence Ave.. SW
WashingtOn. D.C. 20585
(202) 586-3605
!
-------
OU3 Decision Summary (Final)
Comment M (Cant.)
APPENDIX A:
.fu- po£ 5iTe~ f!!.l
California
Coloraao
Floriaa
laabo
Illinois
Missouri
Nevaaa
:-Iew MeXIco
Ohio
South Carolina
Tennessee
WashingtOn
9/B193-LP-957-01
B-27
June 1994
Federal and Stale Economic Development COnlacu
EDA
Regional Offices
ITPA
Liaison
SBA
Regional Offices
Sta.~
SBDC
IlAftU MGIDIUiLCfRCI MI. --- _II ---
--- -- ..-... ~1__--
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A-I
-------
OU3 Decision Summary (Final)
Comment N
8-28
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COMMENT SHEET
DOE is interested in your comments on the cleanup alternatives being considered in the
Proposed Plan / Environmenral Assessmenr for Interim Remedial Action of Operable
Unit 3. including the preferred alternative to decontaminate and dismantle the former
production area at the Fernald site. Please use the space provided below to write your
comments. then fold, staple or tape, and mail this form. We must receive your
comments on or before the close of the public comment period on January 7. 1994. If
you have Questions about the comment period. please contact Ken Morgan, the DOE
Public Inform~ion ;~er ~rnald' at (5.131 64;;'1 1.
Name:~ J.LL.
~:""~~~ b
Phone:
C9tt-
YSD~/
StatelZip:
MAILING LIST ADDITIONS:
Please add my name to the Fernald Mailing List to receive additional information on the
cleanup progress at the Fernald Environmental Management Project:
YES-
NO-
June 7994
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-------
OU3 Decision Summary (Fina/)
8.29
Comment N (Cont.)
fErnald 1Rtmnit iradts & lahar {umncil
An. CIO 111111 TrIdu AIfIIIatId
~
8
P.O. 8oI12&, lioii, Ohio 45081
Commeats of the Fenaald Atomic Trades and Labor Comu:i1 (FAT&LC)
Febnwy 7, 1994
CoDcemiDg the
EImrolllllent81 AssesSllleat (FA) for Operable UDit 3 (OU-3)
Femald EImrolUllfDhIIl ManagemeDt Project (FEMP)
U.s. DeparbDeII& of Eaergy (DOE)
Femald, Ohio
INTRODUCTORY CbMMENI'S ON OPERABLE UNIT 3. F.NVlRONMENrAL A~crns..~
We support the DOE's effort to obtain the earliest, least cost and safest deamJp
of the Femald site. We support this interim acUon for OU 3 as weD. However, we have
reservations about whether the E.nvironmeDta1 As~ent was properly scoped, whether
risks have been properly assessed. and whether certain mitigating measures have been
taken to reduce avoidable risk. Thus, our COIDJDeDtS are intended to Strengthen the EA
and mitigate certain risks which we believe must be addressed in order for DOE to
permissibly issue a FUKting of No Significant Impact (FONS!). If the risks are properly
~ssed. and the mitigating acUODS we request are. undertaken, a full EIS for this interim
acUon will not be required.
These con'J1'nen~ are also intended to supplement the verbal comments of Robert
Tabor, speaking on behalf ofFAT&LC, that were given at the public hearing on January
S, 1994 at the Plantation in Harrison, Ohio. See tranSCript of hearing, pag~ 122-136.
FAT &LC appreciates DOE's 30 day extension of the comment period. This added
time provided a chance for a Roundtable with FRESH and F AT&LC to address ongoing
concerns regarding NEP A compliance.
.1-
HAs DOE TAKEN A "HARD LooK" AT THE "WORST CAsE". Is THE RIsK AS-
SESSMEm' PREPARED BY A PARTY WITHOUT ANY POs..C:IBLE C..oNFUcr OF
L-.'TEREST. AND IF NOT. WHAT MEASURES HAVE BEEN TAKEN TO MITIGATE
1HEsE RISKS?
The EA lacks the required "worst case" analysis resulting from a catastrophic:
failure or release from the cenual storage facility (CSF). The CSF is a tent which covers
radioactive and other cont2minatcd debris, waste and rubble from the demolition and
decontamination of up to 200 buildings in OU 3. A "worst case" scenario is required when
June 1994
-------
OU3 Decision Summary (Final)
8-30
Comment N (Cant.)
Comments of FAT&LC on EA for OU-3
Page 2
preparing an ElS, pursuant to 40 em 1502.22. A worst case analysis would require a
probability analysis, a dispersion 'model and an environmental impact analysIs. One
credible catastrophic failure is a hurricane or tornado tearing the fabric roof off of the
CSF and spreading contaminAted material around.
The osteDSlble "worst case" postulated in the EA was a ruptured High Efficiency
Particulate Air filter blowing matter for 24 hours. Obviously, if a filter ruptured, the blower
motor switch would be tU1'Ded off! To suggest that a ruptured filter is the "worst case"
scenario trivializes the intent of CEQ regulation under NEP A to examine the impacts of
a worst case scenario, especially where the record contains testimony that a tornado (or
comparable event) has hit near the OU-3 once before (see transcript page 51).
To the extent that there are gaps in relevant information, or scientific uncertainty,
as may be the case here, CEO regulations require the agency to "always make clear that
such information is lacking or that uncertainty exists."
The EA doc:ument fails to identify these risks or the uncertainty associated with
them.
FERMCO and its subcontrac:tors, acting as agents of the Responsible Party, the
U.S. Department of Energy, apparently prepared the risk assessment in the EA. According
to FERMCO, the DOE and the two EPAs (US EPA and Ohio EPA) reviewed the Risk
As~c~'tIents in the EA The assumptions contained in the Risk As~~~"'ent were justified
at the January 5, 1994 hearing by DOE's contrac:tor, FERMCO. rather than DOE.
An arlminietrative agency may not delegate its public duties to private entities, particularly
private entities whose objectivity may be questioned on grounds of conflict of interesL
Sierra Club v Si~er. 695 F2d 957 (1983).
At the January 5, 1994 DOE public hearing, the following exchange between
FERMCO and a citizen illustrates this point:
Citizen:
Would it make sense to solicit comment on that from people here
who are concerned about whether or not the document (EA) is
properly scoped at this time?
FERMCO official:
We are soliciting comments.
Citizen:
No you're not, the DOE is soliciting comments.
(Transcript at 95)
Has DOE taken a hard look at the environmental consequences from a worst case
scenario from the temporary storage of radioactive debris in a fabric covered CSF
compared with the other alternatives? Has DOE taken a hard look at mitigating this risk?
June 1994
"
-------
OU3 Decision Summary (Final)
8-31
Comment N (Cont.)
Comments of FAT&LC on EA for OU-3
Page 3
Cost cffective alternativcs may be readily available, but not yet considered. Has DOE made
a determination that this risk is inconsequcntial or so unlikely that it is Dot worthy of
serious consideration?
The standard of scrutiny for rcviewing this EA is higher when DOE uses a
contractor to prepare documcnts for the agency, and when the contractor is speaking on
behalf of the agency, as it did at the public hearing on January 5, 1994. Indeed, a review
of this EA leaves the distinct impression that most, if not all of the EA was performed
by the contractor working for DOE. While ostcnsibly the DOE was supervising, the
shortage of DOE personnel leads us to question the thoroughness of DOE's review. We
realize that the preparation of the EA was a mammoth task and that DOE roles permit
thc participation of contr8ctors. However, the line between governmental officials making
policy decisions, and that of an interested contractor en~ging in inhercntly governmental
activity bas becn blurred.
~
HIsTORICAL RISK DATA THAT IS USED IN THE EA IS UNR1::T TA'RIJ:.
The historical estimate of radionuclide discharges from thc FEMP are based on
1987 Westinghouse data (referenced on page 0-20 of thc EA) that appear to grossly
undcrstate the we quantity of discharges. New emissions data was released in 1993. This
EA must be updated to reflect the 1993 data on the quantity of uranium and other
radionuclide releases when looking at past risks, as well as data collected in connection
with the dose reconstrUction project.
The annual and total mrem exposures (for skin, whole, eye, extremity and internal)
are not detailed in the EA since environmental restoration work began (1989-1993).
The EA postulates that the average external exposures to workers at the FEMP
was 166 mrem between 1986.tn when operations will still underway. It further states that
the probability of an average exposure as high as 166 mremfyr is low. FERMCO's own
RAD I training manual notes that the US annual average radiation dose is 180 mrem per
person. Thus, this risk profile from d&d activity assumes that worker exposure will be
below the background levels for an average person not employed at the site.
Who bas critically examined this assumption within DOE? If DOE agrees with
that this level is achievable, will it lower the DOE and FERMCO arlmini!:trative conuol
levels at the FEMP correspondingly? If not, why not?
J....
THERE IS No AssURANCE THAT THE CSF WILL NOT By DEFAtn.T BECOME
A LoNG TERM STORAGE FACILITY. THus SAFEGUARDS ARE REOUIRED TO
ASsURE THAT THE "INTERIM AcnON" Is NOT A "FINAL ACTION"
June 1994
-------
OU3 Decision Summary (Final)
8-32
Comment N (Cant.)
Comments ofFAT&LC on EA for OU-3
Page 4
The EA relies on the assumption that a Cenual Storage facility will be constrUcted
to cover radioactive and contaminated soils, wastes and debris. ~3().4(),OOO square
foot StrUctures are effectively little more than a fabric: covered tenL The EA also relies
on the assumption that the CSF is temporary and that permanent disposal will take plac:e
after a final RIfFS and ROD is completed.
There are three major risks associated with the CSF that are not identified in
Appendix E of the EA, and should have been sc:oped before the EA was drafted. They
are:
1. The .temporary (CSF) facilitywill, by default, become a longer term storage
facility (Le. wastes will continue to be stored after the point that the ROD is
finalized in late FY 97) because of budget shortfalls, alternative waste disposal
siting limitations, or technology shortfalls;
2. The CSF will become a permanent storage facility (due to budget or other
reasons) Le. final action will not be in full implementation by FY 2000 (it is DOted
that the design life of the CSF cover is 10 years and can be "repaired or replac:ed
if needed to extend lif~); and
3. The CSF is subject to c:atastrophic: failure due to tornado, hurricane or other
event which will cause the waste and debris to be spread over the site and into
the neighboring areas off site. This risk is not considered in Appendix E.4, and
was not treated seriously at the January 5, 1994 hearing by FERMCO personnel.
The risk from a tornado/hurricane should be compared with the risk of storing
the debris in (decontaminated/locked down) standing buildings. The risk should
also be assessed in terms of the likelihood and severity of such events that could
spread the loose debris. While the likelihood of a tornado hitting the CSF may
be low over 1-3 year period. how will the likelihood increase over 10-15 year
period.
With respect to the three scenarios outlined above, the following questions emerge
and deserve a clear reply:
1.
Please define with precision the time frame covered by the word "interim".
2. By law or rule, what is the longest time period an action can be termed
interim? 10 em 1021.104 does not delimit the time frame. If this term is not defined,
will DOE stipulate to a maximum time period beyond which the action will no longer
remain interim?
3. How can DOE and EP A guarantee that the interim action won't become
permanent by default?
June 1994
;
-------
OU3 Decision Summary (Final)
8-33
Comment N (Cant.)
Comments of FAT&LC on EA for OU-3
Page 5
4. Budget crunches are very real. Has the possibility that funding will not be
made available by Congress been factored in when deciding whether to rely on' a fabric
covered storage area instead of a more durable alternative? If so, how?
5. What are the environmental and health risks if the CSFbecomes a long term
or permanent storage facility? How are these risks mitigated in the EA?
6. Since there is no permanent storage facility, and a fabric tent will be used
to cover the loose contaminated rubble, is the material safer in its current form from a
catastrophic weather event (ie in a decontaminate and locked down building), than if it
is turned into rubble?
7. Will contaminated rubble ultimately be put into a solidified form, and if so,
does it make sense to begin treatment and solidification sooner to mitigate against the
risks inherent in having loose rubble stored under a fabric tent?
~
DOE APPARENTLY PREJuDGED THE ADEOUACY OF THE EA TO SUPPORT A
FONSI BEFORE EVER SEEKING PuBuc COMMENT
Under questioning at the January 5, 1994 hearing in Harrison, Ohio, FERMCO
revealed that DOE intends to issues a FONSI. Before the EA was ever opened to public
review and commcnt on December 8, 1993, a draft FONSI had already becn submitted
dated November, 1993.
By drafting a FONSI in November, DOE has at least tentatively determined that
a FONSI was warranted without even holding a public hearing on the EA. Thus, one is
left to wonder whcthcr the hearing process little more than a formality. Why clse write
a draft-FONSI before the EA has cvcn becn announced and released?
Why didn't DOE first announce its intent to issue a FONSI at the same time it
released the EA for public commcnt on December 8, 1993?
In response to concerns that only an EA (and not a full BIS) would be done for
the OU-3 Interim Action, Dave Kozlowski of DOE stated at the January 5 hearing:
"in April (1993) an action description memorandum was written for this
project, which indicated that an environmental assessment would most
likely be documentation that would be needed from NEP A, and that was
submitted for public comment and it appeared in the Federal Register.
(transcript page 93)
An inquiry to DOE's NEP A unit in headquarters (EH-25) informs us that there
was no Federal Register notice on this NEPA action. The only related document DOE
June 1994
-------
OU3 Decision Summary (Final)
8-34
Comment. N (Cant.)
Comments of FAT&LC on EA for OU-3
Page 6
could produce was a letter to the state of Ohio informing them of the intent to produce
a combined EA for OU-3 and the CSF. Perhaps Mr. Kozlowski misspoke, in which case
he should clarify this point of concern for the record. Was there a Federal Register notice,
was there public comment on this notice, and why was the public not notified of an intent
to perform an EA and not an EIS?
The transcript will also reveal that at no time did FAT&LC or Richard Miller
of the Oil, Chemical & Atomic Workers Union ever call for an EIS instead of an EA for
OU-3's interim action.
~
THE OU-3 BAc;EI JNF SUBMITTED BY FER~~:~D~ ~~~~D~:~
REPLACEMENT QFTHE CURRENT HOURLY W -, I
THE EA's AsSUMPTION OF MINIMAL SOClQEOON~~~ I~~~
The EA for OU-3 states that there will be "no change in the number of employ-
ees," and suggests there will be minimAl socioeconomic impact from implementing the
Recommended Alternative (#3). This conclusion is at odds with another FERMCO
document, the FEMP Baseline. FERMCO's current Baseline for the OU-3 c:a1ls for cutting
the OU-3 hourly workforce from 170 down to 23 between FY 94-97 (SR-009, see section
1.1.1.3, spreadsheet dated December 6, 1993). Apparently, the existing hourly workforce
will be replaced by subcontract workers. At the January 5, 1994 DOE hearing, the
question of socioeconomic impact was raised, and the record reflects comments by a
FERMCO official agreeing that a different hourly workforce may be used to perform OU-3
activities.
FAT&LC has subsequently been informed by DOE that the Baseline is not a
decisional document, and efforts are underway t9implemeDt the workforce continuity goals
of Section 3161 of the FY 93 Defense Authorization Act, 42 use 7274h. Until these
workforce issues are resolved, however, the Environmental Assessment, as explained at
the Janwuy 5 hearing, grossly understates the socioeconomic impacts. Such impacts and
any accompanying uncertainties should be identified in the EA.
6. A FINDING OF No SIGNIFICANT IMPACT ~= :~~~~~= :~
PROPOSEDACTIONWILLNOTHAVEASI~ ~;-M;;:;d~;;~~"'R; ~;,~ N-
MEN(. DoE..~ THE EA MRFT THIs TEST OR Is ~ O?
HDOE issues a FONSI, 10 ~ 1021.322(2) requires that a FONSI must contain:
Any commitments to mitigation that are essential to render the impacts
of the proposed action not significant, beyond those mitigation measures
that are integral elements of the proposed action, and a reference to the
Mitigation Action Plan. . .
June 1994
-------
OU3 Decision Summary (Final)
8-35
Comment N (Cant.)
Comments ofFAT&LC on EA for OU-3
Page 7
The EA and the Draft FONSI do not contain any means to mitigate the risks
inherent in using a fabric covered structure to cover loose contaminated debris and waste
from (1) becoming a long term storage facility; (2) becoming a permanent storage facility;
or (3) catastrophic failure due to a tornado or hurricane.
The EA does not explore the conversion of an existing building(s) for interim
storage of contaminated debris, waste and rubble that might mitigate against the dispersal
of contamination in the event that there is a catastrophic event such as a tornado or
hurricane. The EA must address this option.
. We recommend a stipulation betWeen DOE, EPA, Ohio EPA and members of
the public that any FONSI contain the following:
1. A hammer date by wbich contaminated materials placed in the CSF must
begin to be removed from the CSF on an ongoing basis for treatment and final disposal
(estimated date Jamwy 1, 1998);
2. An enforceable agreement among FRESH. DOE and EP A that prohibits
permanent storage of material from OU-3. to be signed by the Assistant Secretary of
Energy for Environmental Restoration;
3. A system of fines/penalties against DOE and the contractor if waste and
debris materials are stored in the CSF on more than an interim basis, including a definition
of interim; and
4. A commitment to minimi7e adverse socioeconomic impacts to the community
by retaining the existing long term hourly workforce to perform environmental restroation
and waste management activity to the maximum extent feasible.
June 7994
-------
OU3 Decision Summary (Final)
Comment 0
8-36
June 1994
CI1iIER\
H-aC11~
State of Ohio Environmmtal Protection A geney
Southwest Dlstrtct Office
40 Soulh Main 51n1e1
DayIOII. Ohio 45402-2086
(513) 28S-QS7
FAX (513) 285.0404
George V. Voinovic:h
Governor
8-011--
January 31, 1994
RE: PUBLIC COMMENTS
O. U . 3 PROPOSED PLAN
Mr. Ken Morqan
Public Relations
U.S. DOE FEKP
P.O. Box 398705
Cincinnati, Ohio
45239-8705
Dear Mr. Morgan:
The purpose of this letter is to provide official comments on the
Operable Unit 3 Proposed Plan:
1.
The OUJ Proposed Plan is the culmination of efforts by Ohio
EPA, U.S. EPA, and DOE to mitigate potential environmental
releases, achieve a faster cleanup, and realize significant
cost savings. The Proposed Plan recoqnizes that current
structures have exceeded their design life and therefore have
no future use other than decontamination and demolition.
This, of course will be a gradual process where buildings that
are not being used to support remediation will be taken down
over the next 15-20 years.
2.
OU3 waste storage - Ohio EPA, as well as the residents around
Fernald, have significant concern with regard to DOE's
historic definition of the term "interim storage". Ohio EPA
concurs that laydown, sorting and interim storage areas are
needed for this Interim Remedial Action. However, we want DOE
assurances that interim storage does not become long term
storage. DOE should address this issue by explicitly defining
the terms and duration of "interim storage" within the Interim
Record of Decision.
3.
Additional storage area - With regard to building additional
interim storage areas, Ohio EPA believes that DOE should make
the maximum effort to utilize the Plant 1 Pad and other
eXlsting buildings and storage areas at Fernald. The Plant 1
Pad is currently undergoing a major removal action to upgrade
the Pad and erect structures to provide interim storage for
r-elDedia tion waste like O. U . J ' s. To successfully util~ze these
ar-eas will require a commitment from DOE to manage and ship
waste residues currently stored on the Plant 1 Pad and other
bUlldings. Ohio EPA expects DOE to make this commitment.
Environmental monitoring data should be collected as buildings
are removed to ensure that engineering controls are effective
in con-crolling environmental releases. This data must be made
4.
-------
OU3 Decision Summary (Final)
8-37
Comment 0 (Cant.)
Mr. Ken Morgan
January 31, 1994
Page #2
available to the public via roundtables, fact sheets, etc..
If you have any questions about these comments please contact Tom
Schneider or me.
Sincerely,
d~~
Graham E. Mitchell
project Manager
GEM/tas
cc:
Lisa crawford, FRESH
Jack Van Kley, Ohio AGO
Tom Schneider, DERR
Jim Saric, u.S. EPA
Ken Alkema, FERMCO
Lisa August, Geotrans
Jean Michaels, PRC
Jenifer Kwasniewski, DERR
Robert Owen, ODH
June 1994
-------
OU3 Decision Summary (Final)
8-38
June 1994
Comment P
IDI'IIIILUIR
0..-.
ITAft OF NEVADA
.
"....... P. COlltU,'.u
..,....
DEPARTMENT OF ADMINISTRATION
C8p8co1 C..pl.. .
eu.... City, N..... 89f10
Fa (701) ..'.111
(701) 617-4061
Februar)< " 1994
Thomas p, Grumbly
Assisranc Secretary for Environmoa&aJ
Restomlon and Waste Management
u.s. Depanmem ofEnOl'l)'
WuhiDgton, DC 20SaS
Rc:: SAt NV #194300068
Project: Operable unit 3, Pmpoaod PIID! EnYirmamentaJ AaellIDCnt for InWim
Rcz=dial Action, Fernald EnvllD1U1'1en1a1 MaDapment Project, Fernald, Ohio
Dear Mr. Grumbly:
. A11aCbed is a commem &om the Nevada Divbion olEnviromnenlAl Protection
cooceming the above rcti=renced project. ThIs comment constitutes the State CleariDgbouse
review of this proposal as per Presidential Executive Order 12372, PJeuc address this commen'
or c:onccms in your final decision.
Sincerely,
I . ..
.'1 . j /. ,,/
I , . . I. '.
'..:,. . I.
.. ~ .
Maud NamJJ
State CICllrinsboue Coordinator
MN\jbw
Enclosures
-------
OU3 Decision Summary {Final}
8-39
June 1994
Comment P (Cant.)
L H. DOIICWN
'~~".A,
STATE OF NEVADA
108 MIU.E8
o..-r
I"t1D co. MQCICO..
, ~
~I.....
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DEPARTMENT OF' Q)N8DVA'I'IOM AND NATURAL aaoulCES
DIVISION OF ENVr'RONMENTAL PROTBCTION
tapIDI Co8I8Iea
:as "" Npc ....
CanoII CItJ....... .mo
February 3. 1994
RECt:ll/t:n
DEP,FEB 04 7994
I. u" ~Ubr
DIREcTOR' 'IW,~ I ..,. 1101.
:s OF(;ICE
NDBP # 94..061
SAJ NY I 94300068
'nTLE: .
U.S. DOll - ~~ PllIIIBA for Inlerim Remedial Action' for Pemald
Environmemal Manlpment Project. NTS
The'Division of Environrnemal Pratection lull rovic:wcd me afoi'cmcmionecl SKare Clearinghouse
itam aad has the following commencs:
There ha.~ been no attempt to evaluate tbe approprillCft88$ of the propoacd interim actions but
our commenrs CUJ'lCem the disposition of wuca generated from any ot' the aUemative actioDl
UT the disposition of the: materials in Storage tbat have now heen determined to he WUIC$.
Page 2-12 Section 2.3.2.1 R.emowl No.9 - JU;mo~1 of Wille In\'eDlOnes
This SCdian addresses the 1 S ,000 ccxuainm 0' thorium maleriaJa that have been declared WIlle
and are propOsed for .hipmcnt to the Nevada Test Site (NTS) tor disposal. TIH:se actionlare
' s&atcd &0 be jn compliance with EPA and DOT regulations and DOE Orders. It i8 not questioned
whether or anI. tbc apecific r=novll acLions mI)' be in compliance with the latter 1CIUWioni
however the propo&ed disposal facUlty on the NTS which would enable this aClion 10 a=Ir is
not in chc ame level formal eompliaftCe.
DOE OJ'der 5S20.2A Requires DOE to perform a detailed PERFORMANCE ASSESSMENT
Gr a dispolal facUlty, Ibis has not been done for any of the dispouJ facilities on the NTS
~fgrc DOE is technically nDt in cDmpliance with ii, own Orden as this document .tatea.
-------
OU3 Decision Summary (Final)
8-40
"June 1994
Comment P (Cant.)
Page 2 . NDEP 94.068 . SAt 94.300068
Page 3-7 under S=aon 3.4 AJtcmauvc 3 - DecamamiDau: and DlsInaDtle (dtis i. the preferred
altemativr) In the aecond paragraph on IIUa pap it is 5tated . At Ihis rime ,NTS if the only
facility for wblch . NBP A review IW beei1 completed that can receive 'nlles fmm FBMP..
FEMP pt0p08 10 Ihip 500.000 cubic f=t af W88 from this action 10 NTS. This doe. 110&
lnolude the thorium mattziats dc:cIarod WID referenced in the prevlauc ~gnph. J believc &he
inlmt of &hil aricement is that ibis NEPA evaluation will oaJy coDSidor lhipmenu to the NTS U
tbal is the 111£ DOB I1u direc:ed d1em 10 ship low level WUIC8 LO. liowever the latter clearly
implies that the diaposaJ facilities at NTS have liready been evaluared UIKIeJ' &be: NEPA procea.
mlS IS NOT TRUE. Although DOB bas deaipated and used !he NTS u . low level di8poll1
(actin)' 1berc baS never bec:n 101 NEPA evaluation of this acdon by DOn and this his bc:cD a
c:ontinual point of aon&endon with the S"t&:. Failure 10 perform NBP A eyalualions for dilpo.l
{acilitles izs 1110 a vial.lion of DOH Order ~820.2A
JJ..,;;1;f: ~
David R. Cowpenhwaite
CleariDabousc Coordinator
Division oC Enviromnc:ntaJ Protection
-------
dU3 Decision Summary (Final)
8-41
Comment Q
122
to work.
There were some people that signed up as
2
they came in who wished to make statements.
I will
3
give their names and call them up.
People who wish
4
to make a statement,
you need to come up to the
5
microphone, state your name clearly so the recorder
6
can easily get your comment.
7
I would like to start with Bob
8
Schwab.
9
'MR. SCHWAB:
Ken, Bob Tabor is going
10 to make that presentation in behalf of the
11 Council.
12 MR. MORGAN: All right, fine.
13 MR. TABOR: I have some comments,
1 4 the Fernald Atomic Trade --
15
MR. MORGAN:
You need to state your
1 6
name.
, 7
MR. TABOR:
Oh,
I'm
I'm sorry,
'8
Robert Tabor,
speaking in behalf of the F~rnald
1 9
AtomlC Trades and Labor Council.
20
The comments of the Fernald Atomic
21
~rades and Labor Council on the environmental
,
22 i assessment for the Fernald Operable Unit 3,
you'll
23
have to bear with me,
I have a relatively lengthy
24
statement here,
I'll try to move this along as fast
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OU3 Decision Summary (Final)
8-42
Comment Q (Cant.)
I as I can.
---
123
January 5th,
1994.
The Fernald
3
Atomic Trades and Labor Council has been the
4
primary representative of the hourly work force at
5
the Fernald site for over four decades.
In the
6
course of this period we have not only performed
7
production work but have performed virtually every
8
kind of environmental cleanup work.
Indeed,
since
9
the shutdown of the site in 1989 our work has
10
focused on the environmental cleanup.
11
In the brief period in which the EA
12
has been publicly available, the FATLC has not been
13
able to undertake the full analysis, including
14
assessing backup documents that is required.
, 5
FATLC, therefore, respectfully requests that the
1 6
record be kept open for the reasonable period of
17
time to permit the FATLC and other stakeholders to
18
provide fuller comments~
two or three weeks or
19
20
whatever the decision was.
However,
information available to the
21
FATLC does raise basic questions which we hope will
22
be addressed by those who prepared the EA.
These
23 . questions go to both the EA's premises and the
24
extent to which relevant facts and law have been
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Comment Q (Cant.)
125
site safety standards and required practices are
2
not adequate.
If the EA's conclusion is to proceed
3
sooner rather than later, is to mitigate risk and
4
not increase it, these issues must be addressed by
5
the EA and solutions buttoned down before the
6
recommendation is approved.
For example,
A, FERMCO
7
and DOE documents record that the site it yet to
8
comply with many basic standards and protocol,
9
including alarm,
rat control,
and OSHA standards.
10
FATLC has previOusly provided such documents to DOE
11
and would be pleased to put them in the record
12
here.
How have these deficiencies, some of which
13
have been commented upon critically by the defense
14
facility's Nuclear Safety Board and others, been
15
factored into the risk assessment?
1 6
B, in September 7th,
1993 memo on the
17
status of the site hazardous communication program
18
for compliance with OSHA,
29 CFR 1910-1200, a DOE
19
consultant reported that,
"The overall site haz com
20
program is not in compliance with the current OSHA
21
standard, 29 CFR 1910-1200, nor the site document
22
chemical hazardous communications program, RN2806."
23
Most of FERMCO's internal time align
24
dates have not been met, nonetheless in a september
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June 1994
Comment Q (Cant.)
...--..--
124
considered.
2
3
In essence, the EA supports the
recommended alternative immediate facility
4
dismantlement and demolition on grounds that quick
5
6
reaction will save costs and reduce needless worker
and community exposure to risk.
In the absence
7
FATLC agrees this sounds plausible.
However, it
8
has recently become clear evidence that present
9
site health and safety rules and practices, work
10
force plans, and by that token cost and safety
"
assumption are inadequate and indeed contrary to
12
law.
Hither to these matters have not been
13
addressed.
By that token it does not appear that
14
they are addressed in the EA.
In raising them at
1 S
this same time, FATLC wants to make clear that it
1 6
hopes to work in good faith with FERMCO and the DOE
'7
and other stakeholders to address these matters.
18
given the limited time available to file
However,
'9
comments and the fact that these ~atters remain to
20
be resolved, FATLC is obliged to raise these
21
matters here.
We also will provide for the record
22
further documentation transmitted to DOE which
23
addresses these questions.
24
Firstly,
it is now clear that the
. Q
.
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OU3 Decision Summary (Fina/)
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Comment a (Cant.)
126
1
30th,
1993 road map of the site, FERHCO stated that
2
it is in compliance with 29 CFR 1910 Occupational
3
Safety and Health standards.
The FERHCO prepared
4
road map was forwarded by DOE Fernald to
5
headquarters, evidently for public distribution.
6
Is FERHCO in compliance with OSHA?
Has anyone
7
checked?
What does the EIS
assume?
What effect
8
would noncompliance have if work is speeded up?
9
C, in a November 30th,
1993 letter to
1 0
FERMCO, DOE informed FERMCO of basic deficiencies
11
in the FERMCO health and safety plan.
In
12
particular, DOE stated the'plan lacked basic worker
1 3
empowerment provisions which DOE stated are
14
essential to assuring health and safety.
What does
, S
the EIS assume about the adequacy of the basie site
1 6
health and safety plan?
What effect would speedup
17
have in light of an inadequate plan?
18
D, the EA concludes that there is
19
relatively little risk of radioactive release from
20
the site.
Once again,
it is not clear whether this
21
assumption is founded on full knowledge of the site
22
activities.
For example, FATLC has recently
23
brought to DOE and Congressional attention a
24
release of uranium hexafluoride that to FATLC's
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Comment Q (Cant.)
._-~-----
127
understanding was not reported as required.
DOE
2
has been on-site investigating this release and
3
related issues of nuclear safety.
Are those who
4
prepared the EA aware of this episode and the
5
practices that underlie it?
Has such an episode
6
been factored into the risk assessment?
7
E, documents confirm that FERMCO has
8
at least until extremely recently displayed what
9
has been called an insensitivity to health and
, 0
safety issues.
For example, as discussed at recent
1 1
Congressional hearings, FERMCO's safety manual
1 2
1 3
actually counseled FERMCO employees not to provide
information on potential safety violations to
14
government compliance inspectors.
Similarly,
1 5
FERMCO documents show that FERMCO ES&H staff
16
compared the cost of complying with health and
1 7
safety rules against the penalties for
18
noncompliance.
1 9
In the most recent past DOE and
20
FERMCO have stated a commitment to address basic
21
health and safety issues and deficiencies in
22
ongoing programs.
FATLC looks forward to working
23
with them and all others
in
this process.
24
Nonetheless, the timing and extent to which they
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OU3 Decision Summary (Final)
8-47
June 1994
Comment Q (Cant.)
128
will be addressed
remains
to be seen.
2
In addition to the specific questions
3
noted above,
examples such as those above raise
4
more basic questions,
including:
5
One, did those who -- let me see
6
here -- did those who reviewed the EA at the EPA
7
and the Ohio EPA question health and safety
B
assumptions provided by FERMCO and DOE?
Two, did the EA examine and/or
9
10
contemplate the health and safety deficiencies that
"
have recently surfaced?
If not, how does their
1 2
presence affect the presumption that workers in the
13
community will be benefited by speedy action?
14
Three, what actions will be taken in
1 5
revising the EA to bring to bear critical analysis
'6
on the deficiencies that have surfaced and on the
17
remedies that must be provided before action can
18
proceed?
19
Secondly, FERMCO has planned to
20
replace the FATLC work force which has long
21
performed cleanup tasks with a new work force, much
22
likely with less experience at the
site and, for
23
all anyone knows, maybe less experience with
24
nuclear materials.
This work force is to be
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OU3 Decision Summary (Final)
8-48
June 1994
Comment a (Cant.)
2
3
4
5
6
7
B
9
10
1 1
12
13
14
B
16
1 7
1 B
19 by a
I
20 I w1th
I
21 I
I
22 :
129
employed under a document called Project Labor
Agreement.
Workers hired under this agreement will
be governed by the very FERMCO health and safety
plan which the DOE has just found deficient.
In
contrast, FATLC,
the negotiators of the Project
Labor Agreement,
failed to insist on the worker
empowerment provisions which the DOE has confirmed
are essential for Fernald site health and safety.
FERMCO'S design to replace the long-term work force
is made plain by the baseline document which FERMCO
has recently provided to DOE.
This document in
essence lays out the plans for the site,
and DOE
must approve the document.
The baseline volumes
for Operable Unit 3 show that virtually all work
will be 8ubeontraeted out under the Project Labor
Agreement.
That is even though FATLC worker has
long performed cleanup at the site,
the FERMCO plan
shows he or she will likely be fired to be replaced
new worker hired under a subcontract,
perhaps
no site experience, who will perform the same
or similar work and probably at higher pay.
The replacement of a worker with
24
23 I nuclear cleanup experience is contrary to common
In the case of nuclear
sense as well as equity.
.
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OU3 Decision Summary (Final)
8-49
June 1994
Comment Q (Cant.)
130
sites there is a special premium on maintaining
2
those who have dealt with nuclear waste and no
3
particulars of the site.
This experience is
4
essential because,
as has been repeatedly found and
5
as DOE has acknowledged, traditional oversight
6
agencies such as OSHA, DOE, and environmental
7
agencies have lacked staff and other resources
8
needed to follow site work in the detail needed.
9
In this case the planned replacement
10
of the existing work force is without evident
11
regard for statutory and DOE policy to maintain, to
12
the extent practicable, the long-term work force as
13
cleanup proceeds.
For example, see Section 31 of
14
the fiscal year 1993 Defense Authorization Act in
1 5
the DOE Five-Year Plan.
1 6
In addition to jeopardizing safe and
17
efficient cleanup, the replacement of the long-term
18
work force will obviously have impact on the
19 . communi ties in which they live.
We emphasize this
20
is not a case where workers will become unemployed
21
because there is no work to be done, rather it is a
22
case where experienced workers will be replaced for
23
the same or similar work with no apparent economic
24
or health and safety logic.
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OU3 Decision Summary (Final)
8-50
June 1994
Comment a (Cant.)
131
In light of the above, FATLC requests
2
that the revision of the EA address the following
3
4
questions:
One,
did those preparing the EA
consider Section 3161 and the work force continuity
5
6
policies expressed in the DOE Five-Year Plan?
not, these must be considered.
If
7
Two,
what assumptions does the EA
8
make about work force to be used in the cleanup of
9
OU-3?
For example, does theEA assume that
10
whatever is stated in FERMCO's baseline will
11
govern?
If not, what is assumed?
12
Three, if the EA made no assumptions
13
or accepted FERMCO's, what consideration was given
14
to the costs and health and safety effects of the
'5
planned replacement of the Fernald Atomic Trade and
16
Labor Council work force as indicated in the FERMCO
1 7
OU-3 baseline?
For example,
in deposition
18
testimony FERMCO's president stated that in
19
determining to employ subcontract workers and
20
replace FATLC on cleanup work, FERMCO does not make
21
cost comparisons.
That is, FERMCO would
22
subcontract work out even if it costs taxpayers
23
Does the EA's cost analysis and conclusions
more.
24
contemplate this logic?
Have those performing the
~
.'
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8-51
June 1994
Comment a (Cant.)
132
EA performed their own cost analysis of the way in
2
which FERMCO proposed to do the work?
3
As stated above, the Project Labor
4
Agreement lacks health and safety provisions which
5
6
DOE has recently told FERMCO are essential to
worker protection.
Does the EA's recommendation to
7
press on with the work contemplate the use of a
8
work force that failed to insist upon protections
9
required by workers and the community?
If so, what
10
consideration has been given to the effect on
11
worker and community safety?
12
~he introduction of hundreds of new
13
workers to replace the FATLC work force will
14
require extensive training.
However, at the same
1 5
time FERMCO would fire workers in whom taxpayers
1 6
have invested many thousands of dollars in training
17
and experience.
Does the EA consider the cost and
18
safety consequences of this waste of scarce
19
taxpayer dollars?
20
Thirdly, if work is to proceed
21
expeditiously, then safe and efficient performance
22
requires an assured supply of trained personnel.
23
On the other hand, FERMCO has proposed to fire the
24
experienced FATLC work force.
And on the other
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OU3 Decision Summary (Final)
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June 1994
Comment Q (Cont.)
133
hand, it admittedly does not have the plans and/or
2
resources to train needed workers.
For example,
3
the November 30th,
1993 FERMCO baseline document
4
records that FERMCO is or has terminated contracts
5
who have been providing radiation worker protection
6
classes.
This says FERMCO will reduce the number
,
of qualified RAD Worker II personnel by
approximately 50 percent weekly.
6
9
Additionally, development of other
10
DOE mandated training will be delayed because of
1 1
insufficient personnel to develop identified
12
training.
13
Have those preparing and reviewing
14
the EA considered the adequacy of the training
15
programs and related resources which underlie the
16
recommended alternative?
If so,
where is the
l'
analysis?
If not,
such analysis is essential to
'8
any recommendation for quick action.
19
Fourthly, have those preparing the EA
20
considered the impact on community dislocation of a
21
plan which would rapidly remove a long-standing and
community based work force and replace it with an
22
23
alternative work force, one which may have far less
24
roots in the Fernald communities?
If so, where is
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OU3 Decision Summary (Final)
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June 1994
Comment Q (Cant.)
134
the analysis?
While community impacts may be hard
2
to quantify, they will nonetheless be real.
3
FATLC notes that whatever rules may
govern the triggering of the EA/EIS where one is
4
5
prepared, it is axiomatic that related sociological
6
impacts must be considered.
in this
Moreover,
7
situation the need to consider community impacts is
B
independently mandated by Section 3161 and DOE's
9
own policies.,
including order 47.1 as well as the
'0
Five-Year Plan.
The EA states that there will be
"
no change in employment levels.
'2
Fifthly, the EA proceeds on the
, 3
premise that the proposed actions can be considered
14
interim and,
therefore,
analysis of permanent
1 S
actions is not required at this time.
18 the
16
Fernald Atomic Trades and Labor Council understands
17
it, however,
the OU-3 work includes shipping waste
1 B
off-site for permanent disposal elsewhere.
This
19
would seem to be an action which could not be
20
characterized as interim.
21
Thank you for this opportunity.
We
22
look forward to your response to our comments and
23
the opportunity to submit supplementary comments.
24
And I have here an additional document that I would
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Comment R
8-54
June 1994
135
like to submit for the records.
2
MR. MORGAN:
Thank you.
3
MR. TABOR:
Thank you.
4
MR. MORGAN:
Jerry Monahan.
5
MR. MONAHAR:
Jerry Monahan, Greater
6
Cincinnati Building Trades.
I would like to make
7
just some brief remarks, mostly in response to Mr.
8
Tabor's remarks, but what I believe is inaccurate
9
description of the Project Labor Agreement.
'0
The Project Labor Agreement that we
, ,
negotiated with the FERMCO Company in a traditional
12
fashion that is usually implemented at sites of
13
this type includes provisions for training of all
of our employees who previously "might not have had
14
'5
training.
We have had employees at this site from
'6
its inception; in fact, we were there before FATLC,
'7
we built it before FATLC entered the picture.
Our
18
workers currently attend training through grants of
, 9
the United States Government through our various
20
internationals, and in fact many of the FATLC
21
employees went to those same schools that we have
22
attended.
Our record of safety has been
23
outstanding, and in fact the most recent accidents
24
have involved the FATLC Council and not the
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Comment R (Cont.)
136
Building Trades Council.
2
1.8 far a8 the
issue
of local, all of
3
our locals are in the Cincinnati area.
I represent
4
approximatelY 13,000 employees who have worked at
this site whenever there was a need for
5
6
construction activities.
7
I a150 would like to bring up the
that FATLC people did not normally
8
economics,
9
perform functions of construction, and to retrain
10
workers who had previously performed duties that
were in the plant and then to educate them and
11
12
brin~ their skill level up to the construction
13
i4
trade would be very cost prohibitive.
We're
sympathetic to the idea that the employment in the
15
pa8t or whatever contribution the FATLC people
16
might have made.
We are also aware of the laws
17
that govern it.
As we understand it, many of these
18
decisions that had been made on the work or all of
19
them that have been made up to this time on the
20
work, are under provisions of law, the Davis Bacon
21
Law or the Service Contract Act.
That has been the
22
guiding principle.
That is separate from the
23
project Labor Agreement.
24
Again,
our workers will always be
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Comment R (Cant.)
137
1
safe and they will be productive, and they are
2
trained.
It's a misconception that they are not
3
trained or they're not aware of the dangers of
4
radiation or construction activities.
5
We have a~so attempted to resolve
6
these issues in separate fashion whenever requested
7
by the Department of Energy, by the FERMCO Company,
8
9
or any third-party politicians.
We'll continue to
be cooperative.
We intend to protect our
10
traditional work, which is construction activities,
1 1
and we have no intent of performing duties that
12
rightfully belong to FATLC.
Thank you.
13
MR. MORGAN:
Thank you.
virginia
14
Least.
'5
Virginia Least.
16
Lisa Crawford.
17
MS. CRAWFORD:
I defer my time, I
18
will hand my comments in in written fashion.
19
MR. MORGAN:
Thank you.
Edwa Yocum.
20
MS. YOCUM:
I defer my time and I
21
will hand my comments in in written fashion.
22
MR. MORGAN:
Thank you.
Are there
23
any others who would like to speak?
Vicki.
24
MS. DASTILLUNG:
Vicki Dastillung.
spangler Reporting Services
PHONE (513) 381-3330
FAX (513) 381-3342
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OU3 Decision Summary (Fina/)
8-57
June 1994
Comment S
SPIEGEL & McDIARMID
.350 NEw VORK AvENUE N W
N.S"'''C;~O'' 0 C 20005-471;18
-~-~"-O"'t 202' 8751.4000
-~~~c:)..,t'" "2C2: 3513-2966
December 13. 1993
Yia Hand Deliverv
The Honorable Hazel R O'Leary
Secretary of Energy
U.S Deparanent of Energy
1000 Independence Avenue. S.W.
Washington. D.C. 20585
Re: Fernald. Ohio Site: Health and Safety Plans
and Practices
Dear Secretary O'Leary:
On behalf of the Fernald Atomic J'rades &. Labor Council ("FAT &.LC') this
letter is to welcome the critical attention wbich DOE is briDging to bear on health and
safetV at the Fernald. Ohio site. as evidenced bv the Denaranent's November 30 con-
firm8tion that the health and safety plan maim8ined by the prime contractor. Fernald
EnviroDplental Restoration management Corp. ("FERMCO"), evidently has deficiencies
which require prompt correction.
In its November 30 lener to FERMCO. DOE indicated. as it has stated
elsewhere. that its review of the FERMCO plan constitutes only a ponion of ongoing
DOE review of health and safety concerns at the site. FAT &LC welcomes this oversighL
FAT &LC requests the opportunity to provide continued assistance. as may be appro-
priate. This lener is to note that there are several further issues which lend themselves
to immediate anention. These include:
ARE CONTRACtOR AND DOE REPRESENTATIONS
OF HEALTH AND SAFE1Y COMPLIANCE RELIABLE?
First. there are questions about the accuracy of health and safety materials
prepared by FERMCO and put out to the public under DOE imprimatUr. For example,
in a September 7. 1993 memorandum on a review of the Fernald Hazard Communication
Program ior Compliance with OSHA Rules (29 CFR 1910.1200). a DOE contraCtor
(Modern Technologies) recorded that: "{t]he overall site HAZCOM Program is not in
compliance with the current OSHA standard (29 CFR 1910.1200). nor the site document
-------
OU3 Decision Summary (Final) .
8-58
Comment S (Cant.)
The Honorable Hazel R. O'Leary
.December 13, 1993
Page 2
Chemical Hazard Communication Program (RM-2086). Most of FERMCO's internal
time line dates have not been met." 1
We have not learned of any subsequent document which attests to cor-
rection of the deficiencies found. and compliance with the OSHA HAZCOM rules.:
However. on September 30, 1993, FERMCO submitted a "ROADMAP"' for the site which
states that it is "in compliance" with 29 CFR 1910jOccupational Safety and Health Stan-
dards (Attachment 2).
The ROADMAP is a "state of the site" document for the Fernald Environ-
mental Management Project ("FEMP"). It serves as basic reference for officials and the
community. On October 20, 1993 DOE Fernald transmined FERMCO's draft to Head-
quaners and to the BDM ROADMAP coordinator for distribution in headquaners, with
no indication that the document h2.d been reviewed or evaluated and no statement on
OSHA compliance (Attachment 2). .
1. A copy of the document is attached (Attachment 1). Among other things, the
findings raise questions about whether all chemicals coming onto the Fernald Site have
Material Safety Data Sheets rMSDS"). For example, the "main points" of the review
included: .
If m [Industrial Hygiene] can not obtain MSDSs from the
vendor, neither IH. nor any other group, are currently writing
MSDSs for the site. Therefore, ch~micals are on site without
MSDSs. and there is no system for developing these if they
can not be obtained from the vendor.
We note that the FERMCO contract provides. among other things, that the
"Contractor agrees to submit a Material Safety Data Sheet. . . 5 days before the delivery
of the material." See Section D.3 (FAR 52.223-3 Hazardous Material Identification and
Material Safety Data (Nov. 1989). Has FERMCO been in compliance with this provi-
sion?
2. Indeed, FERMCO's own self-assessment for the period ending September 30,
1993 identifies under "Weaknesses" (at page 28):
1. Safety...
c. Hazard Communication needs improvement. Audits of
work areas still find chemicals that are not listed in
MSDS notebooks. Systems are being developed to
identify chemicals, update MSDSs. and train em-
ployees.
June 1994
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OU3 Decision Summary (Final)
8-59
Comment S (Cant.)
The Honorable Hazel R. O'Leary
December 13, 1993
Page 3
Can DOE assure the public that the ROAD MAP's statementS of regulatory
compliance, wben made, and today, are correct. in the face of near-contemporaneous
documentation whicb raises questions? Or bas DOE rubber stamped a parachute with
boles in it?
CAN DOE ASSURE THAT THOSE WHO QUESTION
FERMCO HEALTH AND SAFm DIRECTION AND
PROTEcrJON WILL BE PROTECTED AGAlN31' RETALIA110N?
. Second. there is the question of the adequacy of FERMCO supervisory
direction. and the pro~ction of those who question health and safety activities.
For example. FAT &LC brought to DOE anention evidence of a potentially
serious episode involvmg uranium hCxafl.uoride. On December 2 and 3 DOE officials
visited the Fernald site to talk with FAT&LC members and others. We understand this
investigation is continuing. In addition. FAT&LC offic:ials have testified to their under-
s~andin~ regarding further questionable safety practices at the site.
FAT&LC is ready and willing to cooperate with DOE (and other appropri-
ate official groups) in order to get to the bonom of questions that have becn raised.
However, the prospect of retaliation (against FAT&LC and any others) is a very live
reality. What has been termed a "critical lack of sensitivity towards the important mission
of bealth and safc~ appears to be indistinguishable from a design to retaliate against
those who raise health and safety principles.
First. the FERMCO Comprebensive Environmental Occupational Safety and
Health Program ("CEOSHP") expressly enjoins FERMCO employees irom informing
official Compliance Officers of health and safety violations. ~
3. See December 1, 1993 statement of John Dingell. Chainnan. Subcomminee on
Oversl~t and Investigations. Comminee on Energy and Commerce. U.S. House of
Representatives.
4
It states that wben Compliance Officers come on site:
Courteous treatment of the CO [Compliance Officerj is
expected at all times and the following principles must be
followed during the walk-around phase.
Do not agree that any alleged violation existS.
Do not point out any possible/probable violations.
( continued._)
June 1994
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OU3 Decision Summary (Final)
8-60
Comment S (Cant.)
The Honorable Hazel R. O'Leary
December 13. 1993
Page 4
Second. on November 29. 1993 FERMCO evidently initiated a "business
ethics and conduct policy" which subjec:t5 employees to di..missaJ if they fail to disclose
"circumstances, investments, interests or affiliations which could reasonably be expeCted
to. . . (e) reflect poorly on the Company or its clients, and (f) have the effect of dimin-
ishing the trUSt and confidence of the public. the government, our clients or other
employees in the Company: We do not know if this policy was intended to chill
employees from raising questions about FERMCO's performance or conduct to DOE or
the U.s. Congress. but its effect can only serve to diminish the willingness of employees
to become whistleblowers and retain their privacy. It has not escaped our attention that
this policy surfaced 2 days before the December 1. 1993 hearing before the U.S House
of Representatives Energy and Commerce Comminee. and shortly following U.S. District
Court invitation that the Department review FERMCO's health and safety plan.
Third. in mid-1993. when FAT&LC expressed concern about the failure to
provide work breaks for those wearing protective equipment during hot days, FERMCO
told FAT &LC that "any future work for the FAT &LC will depend on their aQility to
perform without grievances, without abuse of non-productive time. and with efficiency...s
Since then, FERMCO has steadfastly sought to gut the (Article IV) health
and safety protections (including the right to refuse work and right to repon violations
to the media or authorities) which FAT&LC won through hard fought bargaining years
ago.
FERMCO's September 1993 "beSt and final" contract proposal deleted these
extraordinary bealth and safetyjwhistleblower protections. On September 27. U.S. Dis-
trict Court Judge Spiegel ordered FERMCO to continue to honor the Article IV. In
subsequent Court filings. however. FER.\fCO (with the suppon oithe Greater Cincinnati
(...continued)
Do not indicate that you have been or are aware of any
alleged violations.
Do not argue with the CO whether a violation or prob-
lem exists.
Do not volunteer any information or make any admis-
sions.
See EAPR 3-6: Revision O. page 3 of 7.
4.
5. See Affidavit of FAT&LC President Roben Schwab (Attachment 3 at para-
graphs 9 and 10), and FERMCO Industrial Relations memorandum on the July 15.1993
Joint Labor-Management Comminee Meeting (Anachment 4).
June 1994
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OU3 Decision Summary (Final)
8-61
Comment S (Cant.)
o
The Honorable Hazel R. O'leary
December 13. 1993
Page 5
Building and ConstrUction Trades Council) continued to contend that the FERMCO
CEOSHP is adequate to protect worker safety. By lener of November 30. of course.
DOE confirmed that. in itS judgment. the CEOSHP is deficient.
On December 2. however. a FERMCO public relations memorandum
sought to dismiss the problems identified by DOE and Congress as "misinformation" from
FAT &LC. On December 3. FERMCO delivered a "best and final" contract proposal to
FAT&LC. Remarkably, FERMCO proposed to substitute itS CEOSHP. which has just
been found deficient. for the worker protection provisions FAT &LC successfully fought
for long ago.'
What assurance is there that under color of "collective bargaining negotia-
tions." FERMCO will not be permined to destroy the fabric of worker health and safety
protection that it took years to weave?
How WIU. TIlE PuBLIc KNow THAT HEALm
AND SAFE'IY COST CtTrnNG MEAsuREs
Do Nm COMPROMISE HEALTH AND SAFETY?
Fourth. there are the questions raised by FERMCO's evident propensity to
balance health and safety measures against costS. At the December 1 Congressional
Hearing. for example. FERMCO confirmed that FERMCO ESH (environment safety and
health) staff engage in calculation of the costS and benefitS of complying with OSHA.
Moreover. in August 1993 FERMCO proposed to DOE that costS could be cut by. among
other things. making workers pay for their own safety equipment and reducing the fre-
quency oi testing for radiation exposures. FER.\1CO noted that the former would require
DOE to "relax interpretation of regulatory guidelines." and that "[o]nly portions" of the
laner could be implemented without violating OSHA 29 crn 1910 (Attachment 5 at
pages 15 and 17).
Will DOE assure that FERMCO's proposals to relax health and safety rules
and cut health and safety coStS be supponed by analyses that are accessible to the stake-
holders whom the rules are to protect?
6. FERMCO's memorandum transmitting the "best and final" offer accused
FAT &LC President Schwab of "staying away" from contract negotiations on the morning
of December 3. FERMCO was well aware that Mr. Schwab was in anendance at a
meeting(s) with DOE investigators to consider the uranium hexafluoride maner. On
. December 9 FERMCO withdrew the December 3 "best and final" proposal.
June 1994
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OU3 Decision Summary (Final)
8-62
Comment S (Cont.)
The Honorable Hazel R. O'Leary
December 13. 1993
Page 6
How WILL THE PuBuc KNow THAT
FERMCO ENVIRONMENTAL COST-CtJTnNG
DOES NOT COMPROMISE HEALTH AND SAFE1V!
Fifth, FERMCO COSt cutting proposals involve reducing environmental. 1I.s
well as health and safety obligations. For example, PERMCO proposes to use "Interim
Actions (IA) whenever possible to expedite cleanup activities." FERMCO explains that
"savings result from avoidable and/or reduced NEPA. RIffS costS. site's fac:ility charac-
terization COStS and D&D ac:c:cleratioD." PERMCO noted that "EP A or the State of Ohio
may ultimately place a limit on the use of Interim Actions" (Attachment 5 at page 21).
Will Stakeholders and the public have access to analyses needed to assure them
that FERMCO proposals do not unduly cut regulatory comers. and have been carefully
reviewed and approved by D9E (and other appropriate agencies)?
CAN DOE ASSURE THAT SAFE1Y TlWNING
Wn.L PROTECT WORD:RS AND BE DONE EmclEN1t..Y?
FiDally. there are questions about the efficiency of health and safety train-
ing. FERMCO intends to rely heavily on training provided by the Greater Cincinnati
Building and ConstrUction Trades Council ("GCBCTC"), under itS Project Labor Agree-
ment ("PIA") with PERMCO.
However. the primary health and safety protection vehicle bargained for in
the PLA is the CEOSHP. DOE's November 30 letter coniirms that the CEOSHP appar-
ently "lac:les lack[s] the prOvisions which adequately integrate and empower workers in the
development and implementation of a comprehensive health and safety program." The
DOE letter further noted that. in DOE's experience. the "'human factors'~ aspects of a
comprehensive management program are as. or more. impOrtant than itS "technical and
programmatic aspects." In Federal court. however. GCBCTC as well as FERMCO,
aCtively supponed the adequacy of the FERMCO CEOSHP.
What actions will DOE take to assure that those who do Fernald-related
worke~ traming are sufficiently attuned to worker protection and empowerment
requlTementS. and can communicate them with requisite vigor, notwithstanding potential
contr:1Ctor o?position?
June 1994
-------
OU3 Decision Summary (Final)
8-63
Comment 5 (Cant.)
u
The Honorable Hazel R. O'Leary
December 13. 1993
Page 7
FERMCO has told DOE that the PiA will save monev because the
GCBCTC will provide training at union expense.' But much of this "savings" presumably
will be paid for by taxpayers, as these training programs are largely funded through
DOE's environmental restoration budget. a 10 this time of budget CUtS. does DOE have
confidence in FERMCO's assertion of training-related savings? Moreover, PERMCO
has been laying off workers in whom many thousands of taxpayer training dollars have
been invested. Does DOE know whether the claimed savings may be offset by previous
training expenditures that will be lost?
10 conclusion, FAT &LC realizes the matters addressed here are sensitive
and complex. As you and your staff have recognized. however. the public interest de-
mands that health and safety questions be addressed directly. and up front.
FAT &LC respectfully requests the opportunity to review and comment on
FERMCO's response to the November 30 letter. prior to any approval by the Depart-
ment. FAT &LC has been the primary representative of workers at the Fernald site for
four decades. FAT&LC previously fought and bargained for the worker protec:tioDS
which. DOE's November 30 lener confirms, appear to be lacking in the FERMCO plan.
FAT&LC further believes it would be of value if other Stakeholders. including com-
munity groups and other worker representatives, are also invited to comment on
PERMCO's response.
7. The PiA "results in significant COSt savings (e.g.. 40 hour Hazardous Materials
training for craft personnel at no expense to DOE). The overall estimated COSt savings
are S15-20 million." Self Assessment. at page 6; item p.
8. Section 3131 of the FY 92 Defense Authorization Act provided S10 million for
hazardous waste worker training grants to unions and universities, and the FY 94 Defense
Authorization Act authorized an added $11 million. These training funds are atimini~-
tered through an interagency agreement betWeen DOE and the National Institutes of
Environmental Health Sciences ("NIEHS").
June 1994
-------
OU3 Decision Summary (Final)
8-64
Comment S (Cant.)
lbe Honorable Hazel R. O'Leary
December 13, 1993
Page 8
In any event, FAT&LC remains available to provide funher information
regarding the above, and such assistance as may be appropriate on these critical maners.
Verv nuly yours,
a;
Dan Guttman
Attorney for .
Fernald Atomic Trades & Labor Council
DG/kah
AttachmentS .
cc (with attachmentS):
Tom Grumbly, Assistant Secretary .
Roben Nordhaus. Esq.. General Counsel
Tara O'Toole, Assistant Secretary
Dan Reicher, Esq.. Deputy Chief of Staff
Scott Van Leme, Esq., DOE Counsel. Fernald
Bob Schwab (President, FAT&LC)
Melvin HutSOn. Esq.
Richard Resnick. Esq.
June 1994
-------
OU3 Decision Summary (Fina/)
8-65
June 1994
Comment S (Cant.)
"
Am~ment 1
c,
-~.>~~~
---
MTC/FES-S3-305
'-=-=
w-
.- . '':
..: .... - ..11 --
MEMORANDUM
DATE:
September 7, 19.93
FROM:
W. J. Quaider. DOE-FN
J. C. Simak. DOE-FN
D. N. Harper, DOE.FN
M. B. Jones ~
STATUS OF SITE HAZARD COMMUNICATION
COMPUANCE WITH OSHA 29 CFR 1910.12001
PROGRAM (FOR
TO:
SUBJECT:
In oreer to provide continued fOllow-up on Industrial Hygiene UHI program areas on-
site. I met with Debbie Grant. FERMCO. IH Section. to determine the progress of
FEJ:tMCO's Hazard Communication (HAZCOM) Program since mv last status report on
May 13. 1993. Attached are copies ot the latest FEMP Hazard Communication
Program Analysis and HAZCOM Check and Action Worksheet. which give FERMCO's
timeline for completion of various portions of this program. (These have not been
updated since the May report. 1
In my discussion with Debbie Grant. several other groups were identified as important
to contact in the overall program assessment. Additionally, I contacted 1) Receiving,.
to determine their policy and procedures for handling chemicals that arrive withoUt a
Material Safety Data Sheet (MSDS); 2) Training. for an update on the site HAZCOM
training program; and 31 ESH, for a copy ot a recent assessment report.
The following summarizes the main points of these discussions arid reports. Topics
are nm listed in order of importance to tne program.
, .
All MSDS stations have been visitea and an inventory of chemicals in the area
taken .by IH, except tor the laboratory area and G3. The laboratory is
conduCting their own inventory. and it is moving very slowly. (FERMCO due
date was 5/1/93.1
2.
IH wrote up a HAZCOM training program for the porters. which was presented
to them by their supervisors.
3.
The following is the breakdown of MSDSs on-site:
4258 Chemicals in the MSDS database
787 No MSDSs as yet
,," :: aJ MllIIem
LJ.U ~ Technolollies
-------
OU3 Decision Summary (Final)
8-66
Comment S (Cant.)
MTC/FES-93-305
Page 2
Of these 787 chemicals. 343 simpiy do not have MSDSs as yet, 444 mayor
may not be chemicals still on-site. IH is inquiring with the department
supervisors to see if they really have these chemicals. So far, they have found
only 20 on-site.
4.
(FERMCO due date to have MSDSs from vendors was 6- 1 -93.)
Debbie Grant receives a purchase order for every chemical that comes on-site.
but does not really have time to review these against the current MSDS
database.
5.
IH is looking into the Haz-Track System, which would bar code chemicals in and
out of buildings to show the movement of chemicals throughOut the site. One
of the problems is that once chemicals are received. they do not necessarily stay
with the same group that purchased them. MSDSs do not always accompany
the chemicals when they move.
6.
IH is looking into ordering some additional training videos. but money will not
allow them to purchase anything at this tinie. (FERMCD due date to develop or
buy videos was 6/1/93.)
7.
The written HAZCOM Program has not been upaated as yet. (FERMCO due
date was 8/1193.)
8.
Annual general training varies per department or organization.
consistent at this time. (FERMCO due date 7;1193.1
It is not
9.
If departments call in for a safety meeting tocic in August. HAZCOM will be
suggested. IH wiil have to develoc information for eacn group on the chemicals
they are handling. HAZCOM safety meetings are !JQI mandatory at this time.
(FERMCO due date was 6/1/93. A lener was to be wrinen by this date
requiring one safety meeting per year to be devoted to HAZCOM.)
10.
IH also indicated they currently had no system for tracking emctoyees who had
been trained.
11.
If IH can not obtain MSDSs from the vendor. neither IH. nor any other group. are
currently writing MSDSs for the site. Therefore. chemicals are on site without
MSDSs. and there is no system for developing tnese if they can not be obtained
from tne vendor.
12.
IH would like to get rid of the chemicais no longer being used on site. but there
is no program in place to do this at the present time. (FERMCO due date was
5/1193.)
June 1994
u
-------
OU3 Decision Summary (Final)
8-67
Comment S (Cont.)
MTC/FES-93-305
Page 3
13.
No system has been set up to revise MSDSs on a regular schedule nor a system
set up to assure maintenance of the MSDS binders. (FERMCO's due date for
both was 6/1/93.1
14. There is no system developed to write MSDSs for chemicals generated on-site.
Even though employees have been exposed to fly ash during boiler plant
operations. no MSDS exists for fly ash at this time.
15.
FERMCO's training deoartment is developing a "boiler plate" Task-Specific Job
Briefing training program for 22 different areas on-site. These will include the
MSDSs for each different area. The "boiler plate" program will include some
specific training on the various sections of an MSDS and is expected to be
completed for all 22 areas by the end of September 1993. A '"draft'" copy of
the "boiler plate" program is attached. I understand a section on chemical
families and storage compatibilities will be aaded before it is finalized. (FERMCO
due date 7/1/93.1
It is anticipated that Daryl Miller will issue a letter reQuiring annual HAZCOM
training when the 22 area programs are completed. The training will be given
by the supervisor using the "boiler plate" . program and the employees asked to
sign an attendance roster for tracking purposed. (FERMCO due date 6/1/93.1
16.
Attached is a portion of the recent ESH report on the site HAZCOM Program.
It gives additional details of findings at several MSDS stations. MSDS availability
to contractor. the potential OSHA penalty for non-compliance. etc.
SUMMARY AND RECOMMENDATIONS
The overall site HAZCOM Program is not in compliance with the current OSHA
.Stanoard (29 CFR 1910.12001. nor the site document Chemical Hazard
Communication Program (RM-20861. Most of FERMCO's internal timeline dates have
not been met.
1.
Updating of the MSDSs at the individual stations. as is currently done. will
always be a very labor-intensive operation. A site-wide computer system for
accessing MSDSs should be investigated.
2.
A system/program should be developed to remove unknown/unlabeled chemicals
and no longer used chemicais from the site in a scneduled time frame.
3.
IH needs to review all POs to assure chemicals coming into the site have
MSDSs.
June 1994
-------
OU3 Decision Summary (Final)
8-68
Comment S (Cant.)
MTC/FES-93-305
Page 4
4.
The Receiving Department needs to have a written procedure on how they
handle chemicals that arrive with no MSDS. and what paperwork is necessary
to send chemicals back to a suppiier.
5.
The training .programs need to be developed to specifically give adequate
information on the terminology and use of the various sections of the MSDS.
. In a recent survey. OSHA identified that. even when MSDSs were available to
employees, they did not understand the information presented on the sheetS.
This training must be documented.
6.
If the supervisors will be providing the HAZCOM instruction. then they should
be given separate training on the OSHA HAZCOM Standard and on the contents
of the MSDS.
7.
The laboratory inventory and MSDS Stations should be completed promptly.
8.
The WEMCO document on HAZCOM (RM-2086) needs to be updated by
FERMCO.
9.
An on-site chemical tracking system is needed to fulfill the "cradle to grave"
tracking requirement and determine the chemical movement between areas.
(Modern Technologies has developed a system which is currently used at
Wright-Panerson Air Force Base, whiCh will be inStalled at 84 Air Force Bases
around the country. FERMCO may wish to investigate this program.)
10.
A better system for documenting and obtaining MSDSs from vendors should be
developed. If a MSDS can not be obtained. the chemical needs to be disposed
of or a MSDS develoDed by FERMCO.
11.
A documented procedure should be instituted that assures contractors receive
HAZCOM training and MSDSs for tne hazardous chemicals they are working
with.
I understand that Debbie Grant took a voluntary RtF in the last FERMCO staff
reduction. Walt Mengel will be assuming resDonsibiiitV for tne site HAZCOM Program.
Don Fleming indicated that he and Walt Mengel will be reviewing the entire program
in the next few weeks. .
Attachment
c:
MTC-FES Program File
June 1994
u
-------
OU3 Decision Summary (final) .
8-69
June 1994
Comment S (Cant.)
Attachment 2
- . ~r::
United States Government
memorandum
C.pa~entofEn.~
Fernald FI8Id Orfic:8
:)ATE.
OCT 2 0 1993
ooE-OI01-94
IIE"- Y TO
ATntOf':
FN:Youngmeyer
FISCAL YEAR 1994 ROADM'
SUIl4CT:
TO:
Lenora J. Lewis, EM-lO, FORS
Attached 1s the revised FY 1994 Roadmap submission for the Fernald
Environmental Management Project (FEMP). This revision includes the Human
Resource Projections and the Logic Diagrams, which were incomplete when
the Roadmap Plan was submitted on October I, 1993. A copy of this
revision has been sent directly to the SOH Federal Roadmap Coordinator for
distribution in Headquarters.
If you have any questions, please call
Harley Youngmeyer at 513-648-3162.
t4t~
J. Phil Hamric ~
Manager
Attachment: As Stated
c:c wIatt:
R. P. Whitfield, EH-40, FORS
J. J. Fiore, EH-42 , TREY
K. A. Chaney, EH-424 , TREY
H. C. Kaufman, FERHCO
...,.-_.-
* Recycled GIld RecyciDble-:;~
-------
OU3 Decision Summary (Final)
8-70
Comment S (Cant.)
Fernald
Environmental
Management
Project
Fiscal Year 1994
"ROAD MAP
Septe~er30, 1993
Prepared For The Department Of Energy By
Fematd Environmental Restoration Management Company
03607
June 1994
£.)
"
-------
OU3 Decision Summary (Final)
Comment S (Cant.)
8-71
June 1994
Regulation:
Regulaung Authority:
Description:
Status:
FY 1994 Roadmap
Regulatory Drivers
40 CFR Part 61/National Emission Stanaaras tar Hazaraous Pollut-
ants (NESHAP)
US EPA
1.
In general. NESHAP limits the emission of polJUtamS into the air. The
requirements of 40 CFR Part 61 indude the following:
Umit emissions of radionuctides (other than radon) to an effective
dose of less than 10 mrenvyr to off-site residentS.
Maintain continuous emission monitoring on any source (stack or
vent) with a POtential to emit more tnan 0.1 mrenvyr.
Receive approvai tor construaion or modification of any facility with
potentia! to emit more than 0.1 mrenvyr. Consuuction or madificalicn
conducted withaUt appraval an facilities that emit less than 0.' nnm
must be identified in annual repen in the year it is compteted.
Submit annual compliance demonstration repan to the US EPA by
June 30.
Umit the radon flux from any building, StrUCtUre. pile. ete. used tor
internal S1Drage or disposal of waste material containing radium to 20
pCi1m2s. .
The flux standard does not apply during acIive remediation.
2-
3.
4.
5.
6.
In compliance
. Regulation:
Regutattng Authority:
Descnptlon:
Status :
29 CFR 1910/Occupauonal Safety & Health StanaardS
Depanmem of LaDer
29 CRF 1910 ensures the satBty and health of worKers. It sets
standards to prevent illness and injury. regutates employee expo-
sure. and mandates that employees be informed of the dangers
associaUld with any hazardous mat8riats.
29 CFR 1910.120 also regulates safety and health training tor
employees at hazardous waste sites being deaneduD under CeRCLA.
in addition hazarciDus waste tr'8aunent. storage. and dil;)osai opera-
tions conductea unaer RCRA. Training content and hour require-
ments are specified in the rule.
In compliance
13
03620
-------
OU3 Decision Summary (Final)
8-72
Comment 5 (Cant.)
Attachment 3
.~Avrr
1. My name is Raben Schwab. 1 am President of die FmWd JUomic Trades aad
Ubot Council ("FAT &LC8). I haw workcci at the FcmaJd site siDce May of 1968.
2. I haw wOltcd II the IiIe as a DIiI1wrigb1. The wOlt I haw performed inl'!h'
-------
OU3 Decision Summary (Final)
8.73
Comment S (Cant.)
heavy suits M:re Dot permiacd 10 get oUt of me: suits 10 uke: rest breW pr'CMdcci for by
swuiard pracUcc.
c) I have 1camcd = the Compmy (FRMCO), in a dcpanurc: from lcmg-st.mdiDg
pr2CIicc, ceased informmg workcn of bomb Ibn:aIa. ( I 1camc:ci of this when a repana'
coma=ci us for COIDIDCIIII on a tbre:at. wbid1 we had DOt bccD sM:n D01icc: of).
10. DuriDg 1hc: PlaDI 1 silo incidc:m FAT&:LC members ~M dial me:
su.bcoDncfDr (MJrtcch) wana:d FAT 4LC mc:mbc:n 10 remain ill dIcir saiD, bccauIe
subc:amracf,or cmpiay=s M:re doias so. FAT &:LC souFt to ciiacusa procedures II a joim
labor mmagcmcm IDCCIing wish FERMCO. I cbaiRci tbia m=iag for Iabar. Mr.
Wc:aIbarcd of FERMCO c:baired Ihc mcaiDg for ...-.--' AlIhc ~ Mr.
Wc:aIbcrrcd aid Ibat FATALC 11'''''''''''' weft IakiDg too Ioas brcaka. He raid U8 dial he
WII gcaiDg tired of picvm:cs. md told as if we ~ to file ~ we waaId aat
be cbcrc: co do Ib.c: wcD-it wouI.d be ~ 'Ibis -- is rdb:ct.cd in c=
miDuD:a of1bc ~
11. In tapaIII' to F ATllJ.J:s ezpraaiaD of _.u~."mt Ibar me ~
paiicy bad bec:D airInd. FERMCO promised, dmiag me ---, tbat it would provide 111
wiI:h . new proc:edure. B has not yet done 10.
FUR.THE1l AFFIANT SYE'IH NOT.
~~
SubIcribcci met swam 10 bc:forc me
tbia~ dayo~1993
-cI b~-''''~
NOlII)' Public
My W"". "..u-. apirea:
YICTaR.A L ~
NOTAItY P I' . r.--
~v C-'II' uo IC! SUt.o'CIItf.
. 1l1l'i .''''"1 "'rett Z'
. 'Its
June 1994
-------
OU3 Decision Summary (Final)
8-74
Comment S (Cont.)
June 1994
Att...hwnent 4
ADMINISTRATION DIVISION
INDUSTRIAL REALTIONS DEPARTMENT
WEElCL Y SIGNIFICANT ITEMS
WEEK ENDING July 21, 1993
SIGNIFICANT .ITEMS
The Fernald Atomic Trades and Labor Council (FATlC) alleges that FERMCO management is
not abiding by a 1991 arbitration decision. The decision States who is authorized to drive a
rental truCk used by groundwater sampling. IR maintains that the ruling has not been violated.
Joint Labor-Management Committee met on July 1 S to discuss various issues which inctuded:
Plant 1 silo, Plant 7 project, Smoking Policy, CRU3 Sampling, Applied Environmental
Remediation Training, Work Time (Stan/quit, breaks, Junch), chemical un~ employwes
operating "Standup. fork lifts, chemical unit employees performing remediation of Streets, and
welder Qualifications. Representatives from Construction were also present at the meeting.
FEftMCO management conveyed their concerns OYer the percePtion of the Fernald Atomic
Trades and Labor Council's (FATlC) paSt and present performance and Stressed
management's concem that any future work for theFATlC will depend on their ability to
perfo!m without grievances, without aDuse of non-prOductive time, and with efficiency.
Met with Security to discuss the computerization of the procedure used to report off by the
re;r;::e!n~d workforce. Cunent/y, when a represented employee reportS off, they call the
Communications Center who log the call as .well a. complete a form in triolicate that is
distriDuted to intereSted parties. The computerization of this Dt0C8dure will eliminate the form
and cut down the communication time of the employee's absence. This will represent a cost
savings, which is being. calculated, for both Security and Industrial Relations.
OTHER IMPORTANT ISSUES
Coordinated a tour for senior execUtives of Indianapolis based Hubert. Hunt & Nichols
ConstructIon. a leading ConstrUCtion firm in the United States. They are considering bidding
on uCC:Jmrng packages at the FEMP. 1ft met with these reoresentative to address Questions
regarDing various asoects of the EftMC mission.
Conducted a trlnsition meeting with employees of Rust Construction and it's successor
cOmr'aCtor: wise. IR is malang every effort to assiSt both Wise and RUSt during the transition
in ora.r to msure minimum diSlUpUon. 1ft has arranged a meeting between Wise Construction
ana tn. Greater Cincinnati Building and Consuuction Trades Council (GCSCTC) to facilitate
a smoom tTansmon of the Union work force to the new Labor Broker.
rTEMS AWArTlNG DOE RESPONSE
rTEMS DOE HAS RESPONDED ON
J
"
0-
d
023:
-------
OU3 Decision Summary (Fina/)
8-75
June 1994
Comment S (Cant.)
Attachment S
o~ ~nvrrOtll7)e
"ell' "'0/
. ~--5~ 08
'=~L.
--
llesrotaraOn Management <:cmoranan
P.O. Box 398704 Cincinnati. Ohio 45239-'8704 - (513) 738-c
August 23, 1993
U. S. Department of Energy
Fernald Environmental Management Project
Letter No. C:OP:93-1242
Mr. Raymond J. Hansen, Acting Manager
DOE Field Office, Fernald
P. O. Box 398705
Cincinnati, Ohio 45239-8705
Dear Mr. Hansen:
CONTRACT DE-ACOS-920R21972, COST SAVINGS SUGG£STIONS
Reference:
00E-2750-93 (17AUG93)
Attached in accordance with the referenced request are 20 cost savings/avoidance
suggestions. These are provided for your use in responding to Assistant
Secretary Grumbly's Task Force on Cost Reductions. ~ copy of the Word Perfect
file has been forwarded to Harley Youngmeyer by EMAIl :n acccraance w1th the DOE
Headquarters request.
;~.;~
(N. C. Kaurr
President
NCK:ccl
Attachment
c:
Robert Mendelsohn, DOE Contract Specialist
J. A . Ras i 1 e
J. W. Thiesing
C. C. Little
S. C. Cosse 1
N. P. Reeves
File Record Storage Copy 102.1
o
-------
OU3 Decision Summary (Final)
8-76
June 1994
Comment S (Cant.).
F.'ERNAED:ENVIRONMENTALJ\ifANAGEMENT..PROJECT"".(FEl\iIP)
:~ --.......," '.... """--"''''-'''''''''''.'''''.'.'.".'.........-.,.'.'....................,---~",,,,"'....--.......
omCE OF ENVIRONML"ITAL RESTORATION AND WASTE MANAGEMENT
COST SAVINGS INmA TIVE
PROPOSED COST SA VTNGS TNTTTA TTVE:
Ua-layer supportsenices subcontracts, which will provide for direct charging of aU
work. -
ANTTCIPA TED COST SA VTNGS:
s.s-~s million per year
JUSTYFTCA TlON FOR ANTTCIPA TED COST SA VTNGS:
Flimin!llte5 duplication of work and multipUcation of overhead.
.
Allows FERMCO to take direct control of work being done, minimizing layered
management
STEPS NECESSARY TO ACRTEVE ANTTCIPA TED COST SA VTNGS:
Evaluate aU subcontractS. developing the "hierarchy" with respect to l:1yering.
Evaluate efficacy of self-perfonn or consolid:1tion of existing subcontr:acts.
Renegotiate or close existing subcontracts and issue new ones only where uft:1void:1ble.
POssmLE HINDRANCES TO ACHTEVTNG ANTICIPATED COST SA VTNGS:
"
Insufficient specific C3P:1bllity in-house.
Insufficient control of new subcontracts.
-------
OU3 Decision Summary (Final)
8-77
June 1994
Comment S (Cant.)
FERNALILENVIRONMENTALJ\'IANAGEl\ilENT PROJECT"(FEMP)
.. 'II~' ' . "It .,' ., _..._~..........'b'.~'N''''''','''''''J ..n...""""'"''''''''''''''"''"''''"''''''''''' ... . ..' ',.' ""." .........-..-. ...c.,>,....... .......
omCE OFENV1RONMENTAL RESTORATION AND WASTE MANAGEL\-[ENT
COST SA VINGS INITIATIVE
PROPOSED COST SA VINGS TNmA TTVE:
1i'Ii...in!S"; ~..m.....o- in DOE Order 4700.1 aDd EP A requirements. iDdudiag integr21ioD
or 4'7OO.1JCERCLAJRCRAJNEPA
AN"I1CYPATrn COST SAVINGS:
Oftr S5M1year lor r"e yeus oC Conc:epaml Design Reports alone
Others in the progress or being deoteIoped.
nJSTIFICATlON FOR ANTICIPATED COST SAVtNGS:
Based oa just ODe CERCLAIRCRA Uait. (CRU1), savinCS to e1iminatiag the CDRs in
p""..ning in S3.5M.
~ NECFSSARY TO AcmEVE ANTICIPATED COST SAVtNGS:
Eftluate all pnlpDlS Cor duplications (e.g.. CDR reports and IU/FS)
Deftiop ftoW....n~nMtiODS based on purpose or Mund!lnt activities
ObtaiD approfti for c:IwIps
NOTE: The results or this .efTort can be applied to DOE nationwide.
POSSTBLE HINDRANCES TO AcmEVTNG ANTICIPATED COST SAVlNGS:
Determining wbo bas authority in DOE to approve changes.
Obtaining DOE Approfti
-------
OU3 Decision Summary (Final)
8-78
June 1994
Comment S (Cont.)
FERNALD,ENVIRONl\'I&"IT.AL..Nr~~AG~mNT PROJECT ~rP)
"""""~""'~"""""'''''''''';''''''''''''''''''''''.'-''''''''''''''-_h.............-,.. ""'....,',. ".. "".n........ ..
ornCE OF E.WmONME.'lTAL RESTORATION AND WASTE: MANAGE1\iE:.'lT
COST SA VINCiS INmA TIVE -
PROPOSED COST SA VTNGS:
ReductioD in sampling and analytical costs :1SSoci:ited with oper:uion of the VOC
wastewater tnalment system.
ANTrCTPA TED COST SA VTNGS:
$11 Million
JUSTTFTCA TION FOR ANTrCTPA TED COST SA VTNGS:
Cost of each sampling and analytical activity, and the number of samples and analyses
eliminated
STEPS NEC'£SSARY TO ACHIEVE ANTTCTP,\Trn COST SA VTNGS:
US EPA and Ohio EPA Approval (obtained)
Detennining those activities that can be eliminated
Revising procedures
POSSIBLE HTNDRANCES TO ACHTEVTNG ANTTCTPA TED COST SA VNGS:
~one identified.
\J
-------
OU3 Decision Summary (Finall
8-79
June 1994
Comment S (Cant.)
~ALD:ENVIRO~~ l\~~~A~.~tENr'P'ROJECT (FEl\11',)
OFFICE: OF ENVIRONMENTAL RESTORATION AND W ASTt MANAGEMENT
COST SAVINGS INITIATIVE
PROPOsrn COST SA VTNGS:
Mlcr'DpurgiDc as a new ~nd water sampiing technique. Under cenain conditions, this
t-"lIique c:m caUec:t sam- much more economically th:an pre\'ious methods.
AN"MnPA.Trn COSTSAVTNGS:
5300,000 per year
rt~CATTON mR ANTTCtPATrn COST SAVTNGS:
Cast aring fram tri:l1 existing wells outfitted with Micropurging equipment.
~OTE: This technique CID be applied nationwide to DOE
~ ~~SARYTO A~ ANTTCTP4.Trn COSTSAVTNGS:
EY81uaIe caadit1aas at acb well to determine ,,,here the technique is viable.
Init"-t- tedtnique
POSST1U..~JnNDRAN~TO A~G ANTTC'TFA.Trn COSTS"VTNGS:
~ODe idemified
u
-------
OU3 Decision Summary (Final)
8-80
June 1994
,.,omment S (Cont.)
~AI:D~~ONMENT~ht~.~q~~~~~9~~~..:.~
OrnCE OF ENVIRONMENTAL RESTORATION AND WASTE MANAGEMENT
COST SAVINGS JNITtA TIVE
PROPOSED COST SA VTNGS:
Using Stand:mi analytial methods in the Sitewide CERCLA Quality Assurance Project Plan
(SCQ).
ANTICTPATD) COST SAVINGS:
$7 Million per year
mSTJF1CATION FOR ANTICIPATED COST SAVTNGS:
Cost of non-Standard methods compared to standard methods
Number oC analyses
F.Jimin~tion of one round oC competitive bidding using standard methods.
NOTE: this is the first instance where the US EPA has sanctioned performance-based
methods Cor CERCLA work. These radioc:hemic:al mindards bave set precedent and could
be adopted DOE-wide.
!ITEPS NECESSARY TO AnnEVE A NTICIP " TED COST SA VTNGS:
DOE Approval (Obtained )
Put into contr:ict5 (partially complete)
POSSIBLE H1NDRANCES TO ACHIEVTNG AvrTCJPATrn COST C::AVTNGS:
None identified.
<)
-------
OU3 Decision Summary (Final)
8-81
June 1994
Comment S (Cant.)
~ALD'.'~~.Q~~~NT.AL. i\JA~AGE:'vrENT PROJECT iFr:\[P1
omCE OF ENVIRONMENTAL RESTORATION AND WASTE :\IA:'-;AGDIr:',"r
. COST SA VINeS INITIATIVE
PROPOSED COST SAVINGS:
EJiminate unnecessary analyses, based on a reeYaluati~n oC monitoring requircml'lIl:' 1,lr
surfa~ water at the Great Miami Riyer and Paddy's Run. water :11 manholes. .1:lu III::
general sump.
ANTlCTP4Trn COST SAVTNGS:
535,000 per year
JUST1'FJCA TION FOR ANTTCIPA TED COST SA VTNGS:
Eliminate 3,600 analyses
Using laboratory resources more efficiently
Redu~d waste
STEPS NECESSARY TO ACHIEVE ANTTCTPATrn COST SAVINGS:
Complete analysis
Obtain approval
Revise sampling plans
POssmLE HINDRANCES TO ACHIEVING ANTICIPATED COST SA V~GS:
None identified.
-------
OU3 Decision Summary (Final)
8-82
June 1994
Comment S (Cant.)
FF;RNALD:ENVIRq~!~~"I~" ~"~~~-\GE;YIEl'." PROJECT CFE!'r1P)
omCE OF :ENVIRONM£L'lT AL RESTORATION AND WASTE MANAG£L'\iENT
COST SA VINGS INITIATIVE
PROPOSED COST SA VTNGS:
RedeveJop Site Access and Compiiance Training Program at F'EMP. Training to be
ac:c:ompJisbed in halt the time and feature perfonnance-based examination which is more
effective than the aid method of open book/open note testing".
ANTICIPATED COST SA VTNGS:
ApproximateJy 1,000 workers per year equates to an average of ::I.bout S2.5 :\liJlion per
year.
TUSTTFTCATTON FOR ANTICIPATED COST SA VTNGS:
52000 per genera! site worker. S2.640 per limited site worker. :lnd 53.440 per
administrative workers.
STEPS m:CESSARY TO ACHIEVE ~NTTCrPATED COST SA VTNGS:
Revise training
Implement new training program.
POssmu: HINDRANCES TO ACHTEVTNG ANTICIPATED COST SA VINes:
~one identified.
-------
OU3 Decision Summary (Final)
8-83
June 1994
Comment S (Cant.)
EERNALDO:ENVIRONMEm"ALOj\IANAGEMENTPROJECr (FEMP)
...... .......................................... .. ......... ",.,."".'''',,,,,,, ". .......... ".""
omCE OF ENVIRONMENTAL RESTORATION AND W ASTE MANAG~'\IENT
COST SAVINGS INITIATIVE
PROPOSED COST SA VTNGS:
Use wastewater exclusion to reclassify three water treatment surface impoundments from
Hazardous Waste Management Units CHWMtJ) to Solid Waste Management Units (SWMU).
ANTTCIPATrn COST SA VTNeS:
UDder evaluatioD
TUSTYFTCA "ON FOR ANTTCIPA TED COST SA VTNGS:
Costs associ:1ted with HWMUs versus costs oC SWMUs.
STn'S NECESSARY TO ACHTEVE ANTICIPATED COST SAVTNGS:
Complete sampling and analyses
Answer unresolved characterization issues.
Obtain recbssific:ation CODcurrence Crom EPA.
.
POSSIBLE HTNDRANCES TO ACHTEVTNG ANTICIPATED COST SAVTNGS:
Negative answer to unresolved characteriz:ltion issues. EPA may not concur with the
process.
-------
OU3 Decision Summary (Final)
8-84
June 7994
Comment S (Cont.)
1:}~;KNALD~ENVIRO~~~::..~~~~.gE~.PJl9JECT .~IPJ
OmCE OF ENVIRONMENTAL RESTORA nON AND WASTE MANAGEMENT
COST SAVINGS INITIATIVE
PROPOSED COST SA VTNGS:
Decrease the Dumber oC inspections Cor dnammed low-level waste th:u does not comaia
RCRA hazardous waae.
ANTTCTPATED COST SA VTNGS:
Approximately $21.000 Annually
.JUSTTFTCATJON FOR ANTICIPATED COST SAVINGS:
.
Reduction in inspections Cram cbily to bi-weekly
Cost for inspection personnel
STEPS NECESSARY TO ACHIEVE ANTICIPATED COST SA VtNGS:
Identify with certainty the non-RCRA hazardous waste dnams
Revise procedures.
POssmLE HINDRANCES TO ACHTEVTNG ANTICIPATED COST SA VTNGS:
None identified.
<1
-------
OU3 Decision Summary (Final)
8-85
June 1994
Comment S (Cant.)
o
£ERNALl}:ENVIRONl\1ENTAL::.~~~AG~~!'IT~1':R9J.!!f;T. ~~
oma OF ENVIRONMENTAL RESTORATION AND WASTE MANAGEMENT
. COST SAVINGS IN1TIA TIVE
PRoposrn COST SA VTNGS:
Establish an audit management program to manage au~ Crom the planning Stage through
the closure, indudiDg coordinated scheduling oC DOE-HQ audit visits, audit report
coasolidaUoas, improYed protacals, and coordination with ather audit agencies.
ANTICTPA"IrD COST SAVTNGS:
Under eYUluation
.TmTmCATTON 1='OR ANTrCTPATED COST SAVTNGS:
Probably the best area oC opportunity Cor oversight Cunctions, since there appears to
agreement between auditiDg organizations to try to improve audit management.
~ NECESSARY TO ACHIEVE ANTtC1PA TED COST SA VTNGS:
Complete prototype program (in progress)
Obtain DOE :approftl
Implement program
POSSIBLE mNDRANCES TO ACHTEVTNG ANTTCTPA Trn COST SA VTNGS:
Decide wbo c::mIwiU approve recommendations Cor prototype.
DO~HQ org:uuzations (turf battles).
Obbining support of
-------
OU3 Decision Summary (Final)
8-86
June 7994
Comment S (Cant.)
EERNALD":ENVIROm~AL:~1\f~~~.~N"r:t:'~.9JECT(1i"E1\IP)
OFFICE OF ENVIRONMENTAL RESTORATION AND WASTE MANAGEMENT
COST SA VINGS INITIATIVE
PROPOSED COST SAVTNGS TN1TTATTVE:
The proposed cast saviDgs is to reduce lease costs an~ facility operating expenses while
enh!tnl'ing productivity by CODSoudating the majority of FERMCO's work Corce in a siDgle
ocr site office facility to be constructed using capital Crom II non-DOE source and leased
back for the liCe of the project. The proposed facility would be constnJcted to FERMCO's
requirements by a deYeloper who will lease back to FERMCO for a 10 year period during
wiUch he win recoup his investment.
ANTICIPATED COST SAVTNGS:
51.000.000 over the life of the project.
JUSTTFTCA TJON FOR ANTTCTPA TED COST SA VINeS:
A detailed engineering analyses has been conducted evaluating facility requirements for the
proposed ocr site facility as well as the costs for maintaining and operating the existing
facilities including. ..-ry uppoades for 10Dg term use. An inquiry package was
assembled and deYeiopers were solicited for interest. Based on responses and projected liCe
cycle costs (excluding cost benefit of improYed productivity), the projected cost savings
appear to be yiable. Cost to upgnade and maintain 30040 year facilities scheduled for
demoUtioD greatly exceed the costs of constnlcting and leasing newer facilities in rhe vicinity
of Fernald.
STEPS NECESSARY TO ACHTEVE ANTTCTPA'ITD COST SA VINGS:
DOE real estate function mUSt be willing to give the deyeloper cenain freedom in
coDStruction of the facility which will make it commercially :ntractive when DOE :1nd
FERMCO no longer require use of the offices. Additionally DOE and FER1\ICO must be
willing to sign a long term lease which proYides the deyeloper security in his inyestment and
a reasonable return for use DC the deyejopers capital.
POSSTBLE HINDRANCES TO ACHIEVING ANTICIPATED COST SAVTNGS:
Current government regulations are oyerly restrictiye for long term leases and rental of
facilities. Developers bave DO incentive to construct DOE facilities for low returns, shon
leases and wbich are not commercially viable for future users. DOE's rea! estate function
needs to be more liberal in interpreting current regulations goyerning rea! estate
transactions and Cunding, or seek changes in rhe law.
')
-------
OU3 Decision Summary (Final)
8-87
June 1994
Comment S (Cant.)
v
l'.~~ Ln:~'pNMENTAL.l\ IA.'lAGE1\.IENT PROJECT' (m.1P)
OrnCE OF ~WIRONM~vr AL RESTORATION AND WASTE: MANAGE.'\tENT
COST SA VINGS INITIATIVE
PROPOsrn COST SA VTNGS TNTTT A TTVE:
The proposed cost savings is to immediately :and fully depreciate :aU Fernald facilities. spare
pans, equipment and mac:binery, feedstock and remaining productlby product facilitating
disposal through excess, surplus :and outright sales procedures.
ANTICTPA TED COST SA VTNGS:
51,000,000
mSTTFTCATTON FOR ANTTCTPATI:D COST SAVINGS:
Declaring aU material as excess or SCr:lp with no value aUows relna.tion of maintemnce.
tracking inventory casu :and cOStS for plant upgrades necessary to keep value-less items
oper:1uonal or :at a minimum. protected from funher degr:adation under :a contr:act which
holds us accountable for loss in value of current assets. In:a plant ultimately intended for
demolition and disposal. it makes little sense to expend these costs when they only add to
the ultimate disposal costs. This approach also provides the potential for waste
maaagement and recycle contr:actors to reduce their cost for dispositioning the site
equipment if there is a possibility of decontamination and subsequent recycle or resale thus
providing tbe possibility the contractor on profit if he on cost effectively recycle items.
Adequate surveillance oC :111 contaminated and hazardous propeny would be maintained.
STEPS NECESSARY TO ACHIEVE ANTICIPATED COST SA VTNGS:
Systems to aUow market based pricing of :1SSets nt sites scheduled for cleanup needs to be
developed.
PossmLE HlNDRANCES TO ACHIEVTNG AVT"TCTPA TED COST SA VTNGS:
Current propeny management syStems nre somewhnt cumbersome in dealing with prompt
disposal of contaminated sites. Waivers for NPL sites would help expedite the disposal
process.
-------
OU3 Decision Summary (Final)
8-88
June 1994
Comment S (Cont.)
FERNALD..:ENVIRONl\-IEl-t"TAL ~rA.1\[AGEL\IE~"- PROJECT ~IP)
""'~~~"'''':'''';~''-''''''''...................,.......... d"''', ..... .. . .... ... '. . . .
ornCE OF E.LWIRONMENT AL RESTORATION AND WASTE MANAGEMENT
COST SA VINGS INITIATIVE
PROPOSED COST SA VTNGS TNITT A TTVE:
Flimi'1!1te the aunual requirement for preparation of t~e Energy Management Plan.
ANTTCTPA TED COST SA VTNqS:
550 to 100 thousand annually
JUSTTFTCA TJON FOR ANTTCTPA TED COST SA VTNGS:
Prep2r:1tion of an ener:y management plan is a carryover from a period associated with
limited spini:ung resenes at many utilities coupled with national concern that conservation
of electric and gas resenes was essential to the future survival of the US and its "cheap"
- ener:y economy. Concern that oil and gas reserves will disappear have greatly diminished
:1£ the same time that energy use at many of the DOE's facilities has dropped exponentially
as processes are shut down with no intent to restan operations. Preparation of a plan
which will have Jjttle or no impact on the costs of operating a fast decUning facility senes
no real benefit while requiring valuable human and financial resources to prepare plans
wbich worry about power use by computers and light bulbs at a time wben very inefficient
Steam plants are being operated to maintain obsolete facilities. The resources necessary to
prep:lre the :uanual plan and monitor its implementation would no longer be required if the
need for the plan is eliminated - it is tqe cost of this labor and repon production which
wiu be saved.
STEPS NECESSARY TO ACHIEVE ANTTCIPATrn COST SA VTNCS:
The DOE Order for this requirement should be elimimned or clarified to not apply to sites
primarily involved in site remediation and shut down. FERMCO needs to justify the
e:"emption for FEMP and obtain DOE approval to eliminate the plan and its requirements.
POSSTBLE HTNDRANCES TO ACHIEVING ANTICTPATED COST SAVTNGS:
"
Although energy use is a fraction of what it \Vas when aU facilities were fully operating, it
is politically expedient to appear to be concerned with energy usage which is a popular
theme with- environmentalists who believe consenation is the solution to our problems.
This societ:1l perspective makes it difficult for DOE to focus on the more appropriate use
for this money - that of c:1eaning up the spreading contamination before it further invades
our soils and water supplies. DOE mUSt move beyond the less relevant societal pressures
associated with the issue of energy use to the gre:uer issue of mixed waste contamination
and our stated intent to dean it up as soon as possible.
-------
OU3 Decision Summary (Final)
8-89
June 1994
Comment S (Cant.)
FERNALD':~O~'TAL]\ifANAGEl\tIENTPROJECT. (FDr1P)
........--......""""'" ... ,_.......,.........................,.~...................'.-.......",",'.. ......". ... .
omCE OF ENVIRoNMENTAL RESTORA nON AND W ASTE MANAGE:I.~
COST SAVINGS INmA TIVE
PROPOSED COST SA VTNGS TNTTIA TTVE:
Relax re:strictiODS on disposal of DOE generated wastes at commercial Cac:ilities at such sites
as EDTirocare in Utah. 'Ibis would allow immediate disPosition oC materials for which there
is no CUl'ftDt DOE site Cor disposal oC mixed and other special wastes as well as allow
increases in disposal oC existing low level wastes beyond the limited quantities currendy
I:oing to the NTS.
. It would also allow Cor the efficient handling, transportation, and disposal of millioDS oC
cubic yards oC LLW resuiting from remediation oC DOE sites like Fernald.
Commercial disposal costS are competitive with the REAL cost oC disposal at DOE sites
wheD an costs of disposal are considered as opposed to the anifici:lIly low rates charged by
NTS to DOE generators.
ANTICIPATED COST SAVTNGS:
Teas of miWODS depeadiag upon relid granted and liability protection provided to shippers
such as Fenm1dIFERMCO. Additional hundreds oC mUlioDS for Fernald alone in cost
savings Cor remediation waste disposal.
TUSTTFICA nON FOR ANTTCIPA TED COST SA VTNes:
SigDificaD1 costs are incurred daily for inspection and storage of mixed waste and other
materials not suitable for NTS. Delays in shipping these wastes results in funher
degradation of dnJms resulting in inereased surveillance, overpacks and ultimately an
inereased potential Cor leaks into the environment.
Disposal of future remediation wastes at licensed commerci:lI facilities offers substantial
savings in transportation and materials handling costs.
STEPS NECESSARY TO ACHTEVE ANTICIPATED COST SA VYNGS:
DOE should immediately act to indemnify FERMCO and other site operators and approve
shipment to commercial disposal fac:ilities willing to accept DOE wastes.
POSSIBLE HTNDRANCES TO ACHIEVTNG ANTICIPATED. COST SA VTNGS:
State politics, conc:erned environmentalists and others will immediately redirect their
energies to closing the existing commercial facilities and otherwise block shipments to
commen:.i:LI sites for the same reasons they have tried to block shipments to other DOE
Cac:ilities such as NTS and INEL. Commercial rates could increase exponentially iC DO E
does not retain its ability to dispose at its own sites. Without indemnification. site
operators and 'FERMCO may continue to use government facilities because of the reduced
risks of down stream liability Cor consequential damages in the event oC disposal site failure.
-------
OU3 Decision Summary (Final)
8-90
June 1994
Comment 5 (Cant.)
"
FERNALD'ENVIRONM:E.L'ITAL.!\tANAGEMENr PROJEcr"CFEl\IP)
.......' '---""""""--""""-""_'-"'~"""""''''''''-'''----'''''''''''''''''''''''''''''''''''' . .. .... "..... ,'........-............................. ....,...,
omCE OF £NVmONMENTAL RESTORATION AND WASTE MANAGE£\iENT
COST SAVINGS INmA TIVE
PROPOSED COST SA VINGS TNtTTA TTVE:
Reduce cycle time (e.g. monthly to quanerly) Cor testing oC dosimetry (film) badges
consistent with risk in various faciUties. Reduce urinalyses and other physical testing
consistent with worker risk. Reduce reponing requirementS of worker exposure based on
risk factors.
ANTrCTPA Trn COST SA VTNGS:
$25-50 thousand per year fOI" all testS at Fernald.
,TUSTTFJCA TION FOR ANTlCTPA TED COST SA VTNGS:
Casts oC these programs are well documented and easily managed by controlling the
performance oC uDDecessary tests. Not only are the tests themselves expensive but the cOStS
of record keeping, protection of employee privacy and notification are reduced as well when
cycle times are extended.
STEPS NECESSARY TO ACHTEVE ANTICIPATED COST SA VTNGS:
Relax interpretation of regulatory guidelines and, if appropriate. revise regulations and/or
the FERMCO Rad Manual based on reduced risk factor oC a non-operating Cacility. DOE
approval of proposed redUctiODS may be necessary in some cases. FERMCO needs to
evaluate the cost and risk factors oC the alternatives, develop a proposal to DOE seeking
their npprovaJ aDd revise the procedures prior to implementation.
POSSIBLE HINDRANCES TO ACHTEVTNG ANTICIPATED COST SAVTNGS:
The appearance oC indirrerence to worker expOsures and public perception.
Need for regulatory acceptance oC cycle time based on risk.
"
()
"
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OU3 Decision Summary (Final)
8-91
June 1994
Comment S (Cant.)
FERNALD.]~NVIRONMEJ.'ITAL.,l\'rANi\GEMENT PROJECT' (FEl\IP)
~. .". ._A ... . """,,,,,,,,'-.,. -.......... .-...-......, ..... .. ...""--."..'" ...... ....
ornCE OF ENV1RONMENTAL R£STORA TION AND WASTE MANAGEMENT
COST SA VD'lGS INITIATIVE
PROPOSED COST SA VTNGS TNITTATTVE::
Encourage craft work force to obtain required ~CO site training as pan of their
prerequisite traiDing prior to their being considered for future employment :at the F£MP.
In this approach, FERMCO does not incur labor cOStS of new-hire craft workers while they
are being trained.
ANTICIPATED COST SA VTNGS:
$10.5-2.0 MDlion per year
)us I It I CATION FOR ANTICIPATED COST SAVTNGS:
By considering only workers from the bnrgaining units which are pre-tr:1ined, FERMCO
avoids the 1-2 weeks of lost productivity experienced under previous appronches every time
a new craft worker CUDe on site. This can indude OSHA, GET, respirator and radworker
n training which would require in excess of 40 hours of tr:1ining.
~ NECESSARY TO ACHIEVE ,\NTTCIPATED COST SAVTNGS:
This program has been implemented at the FEMP and will result in the out-year savings
listed. Actual savings will depend on the turnover of craft workers and the hiring of new
workers to replace those which depan.
POSSIBLE HTNDRANCES TO ACHIEVTNG ANTICIPATED COST SA VTNGS:
This can become :an issue at any time during contrilct negotiations which are currently in
progress.
-------
OU3 Decision Summary (Final)
8-92
June 1994
Comment S (Cant.)
"
<.>
FERNALD:m;vmONl\1ENTAL:MANAGEl\IENT.PRomCf (F.EMP)
...'1 '.~~...~.;"d-_._......,...,............................:......'.-,.. ..-.....................~.._.........__..
omCE OF ENVIRONMENTAL RESTORATION AND WASTE MANAGEMENT ..
COST SAVINGS INITIATIVE .
PROPOSED COST SA VlNGS INITTA TTVE:
Require aU workers (or alteratively just subcontractors) to provide their own safety
equipment (shoes only) and sweat prmenu and undergarments for wearing under the ptant
COYeraIIs. At the present time these items are provided for a11 employees free of charge.
ANTJCTPATrn COST SAVINGS:
For subcontractors alone the cost. s:avings :1SSociated with tbis proposal will be
approximately 5500.000.
JUS11FTCA TTON FOR ANTTCTPA TED COST SA VTNGS:
Although it is common practice to provide this equipment on many government sites. it is
not necessarily common practice on private sector constnlction projections. In particular,
subconU2ctors are almost always required to provide all of their own safety equipment and
personal clothing. FERMCO would saye origilml clothing costs. replacement casts. laundry
costs and losses due to theft and abuse of company owned boots and clothinl.
ST£PS NE~SARY TO ACHTE~ ANTICIPATED COST SAVTNGS:
Changes to union agreements may be required but otherwise this is a simple philosophic
change in management by FERMCO and could be implem~nted immediately. As of 8193
FE:R.\tCO will no longer issue safety shoes, glasses or hard hats to subcontractors.
Undef'l:!rments may also be discontinued this fall.
POSSTBU: HTNDRANCES TO ACHIEVTNG ANTICIPATED COST SAVTNGS:
This could create a problem with the unions and could be perceived by the workers as a
decrased emphasis on safety resulting in morale problems and a worseniD~ of our current
OUtSIaDd.iDC safety record. Only portions of this proposal could be implemented at Fernald
without yiolating OSHA 29 cm 1910. Additionally, the risk of needing to nbuyu
employees clothes which become contaminated may increase under this proposal.
(,
-------
OU3 Decision Summary (Final)
Comment T
8-93
June 1994
137
1
safe and they will be productive, and they are
2
3
trained.
It's a misconception that they are not
trained or they're not aware of the dangers of
4
radiation or construction activities.
5
We have a180 attempted to resolve
6
these issues in separate fashion whenever requested
7
by the Department of Energy, by the FERMCO Company,
8
9
or any third-party politicians.
We'll continue to
be cooperative.
We intend to protect our
10
traditional work, which is construction activities,
11
and we have no intent of performing duties that
12
rightfully belong to FATLC.
Thank you.
13
MR. MORGAN:
Thank you.
Virginia
14
Least.
15
16
Virginia Least.
Lisa Crawford.
17
MS. CRAWFORD:
I defer my time, I
18
will hand my comments in in written fashion.
19
MR. MORGAN:
Thank you.
Edwa Yocum.
20
MS. YOCOM:
I defer my time and I
21
will hand my comments in in written fashion.
22
MR. MORGAN:
Thank you.
Are there
23
any others who would like to speak?
Vicki.
24
MS. DAST~LLONG:
Vicki Dastillung.
Spangler Reporting Services
.. .P.RONE (51 3) 381 - 3 330
FAX (513) 381-3342
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OU3 Decision Summary (Final)
8-94
Comment U, V, W
138
I won't wish to make any formal comments at this
2
3
time, but I do seem to feel that we do need the
3D-day extension to the comment period, and I would
4
like to formally request that DOE provide us with a
5
Round Table or workshop on the EIS and NEPA process
6
as it relates to the OU-3 and the RIfFS process and
7
perhaps discuss with the public whether they would
8
9
need a Round Table or workshop of more detail on
the OU proposed plan.
I would also like to ask
10
that the US EPA and Ohio EPA be included in those
1 1
Thank you.
meetings.
12
Thank you.
MR. MORGAN:
Yes, sir.
13
MR. RICHARDSON:
My name is Robert
14
Richardson, with Labor's Local Union 265.
I didn't
15
16
sign up to speak, but I want to just for the
record,
I want to submit a written statement.
17
Thank you.
Anyone
MR. MORGAN:
18
else?
19
I want to ditto what
MS. DUNN:
20
Vicki said,
and I will submit written comments.
21
Thank you.
MR. MORGAN:
22
MS. CRAWFORD:
FRESH dittos what
23
Vicki said.
24
MR. MORGAN:
Thank you.
Anyone
spangler Reporting Services
PHONE (513) 381-3330
FAX (513) 381-3342
June 1994
G
-------
OU3 Decision Summary (Final)
8-95
June 1994
Comment X
~~(O 15 &~Set(~ )~~5; 0,
~ 1911: fccuJ- rpcluc ~ /1/L...MG..;1 f TP1~
~ /ird- [dO t> ':J!J)(- s.LJ-u' ~ .~ m c.
tlMm ~ur~--1; Sf'~Ce M d(~il12~/
t"CJO +0 20 l(j1JrG( Iw-C'krs-
-- __-lk5~fLe2W ~ -ro-S}~9-
._---~6J u,L 3-J;~~~.~ML:~' ~LSe ), ;K--
- -.. ._.. .
------------ ....-.-.-..
. - .._._-
--'-----
. ._- --.... .. -
--_... .-.
---." - - -- -_.
.. - -- ..---.-.-. -_.-- -
----- - .---.
------_.. --- .---
-.-... -..-.-----. .
.- _.. --...---
._--_._-----
-- -."-'"
.-----
- . -_.. . --
'-'.---'
--. ... .. . -.-. - -. -.-
- - -- - .-.--
. -.-----. ---.
_. --- --- . --...
- . ---- -_.
- ------..
. -.----.--
_-'_0...-
-----
-..-...-.-.--
-------
OU3 Decision Summary (Final)
Comment Y
8-96
1 3 ~
else?
2
MR. MILLER:
My name is Richard
3
Miller.
I would like to know whether there's going
4
to be a public hearing on the finding of no
5
significant impact for the public to be able to
6
comment on that?
I would like to know whether the
7
environmental assessment is beinq performed
8
separate from the environmental impact statement
9
and why, and I ~ould like to know why the finding
1 0
of no significant impact was not incorporated in
1 1
the discussion in the environmental assessment.
12
13
other words, why you're bifurcating the discussions
they are clearly interrelated.
Thank you.
since
14
Thank you.
Anyone
MR. MORGAN:
15
else?
Going once, going twice, three times.
Thank
16
If anyone has any questions informally, we
you.
17
will remain here.
18
19
MEETING CONCLUDED AT 9:50 P.M.
20
21
22
23
24
spangler Reportinq Services
PHONE (513) 381-3330
FAX (513) 381-3342
June 1994
()
,)
In
c
<>
-------
OU3 Decision Summary (Final)
(,'
C-1
June 1994
APPENDIX C
ADMINISTRATIVE RECORD INDEX
-------
OU3 Decision Summary (Final)
C-2
June 1994
Page left intentionally blank.
-------
OU3 Decision Summary (Final)
C-3
June 1994
APPENDIX C
ADMINISTRATIVE RECORD INDEX
d
This appendix contains the listing of the documents and letters used to support the Operable
Unit 3 Record of Decision for Interim Remedial Action. This listing represents the
Administrative Record used in developing the selected remedy for OU3 interim remedial
action. The documents detailed below are listed alphabetically.
1993 ANNUAL PROCEDURE UPDATES FOR REMOVAL ACTION NUMBERS 9, 12, AND 26
Index #: R-022-204.1, R-020-204.12, R-030-204.4
Document Date: 06/29/93
From: DOE-FN
To: EPA
# of Pages: 2
1993 ANNUAL UPDATE OF PROCEDURAL DOCUMENTATION SUPPORTING FERNALD
ENVIRONMENTAL MANAGEMENT PROJECT ASBESTOS REMOVALS (ASBESTOS PROGRAM)
JUNE 1993
Index #: R-030-204.5
Document Date: 06/29/93
From: DOE-FN
To: EPA
# of Pages: 300
ADDENDUM TO FMPC-2082 HISTORY OF FMPC RADIONUCLIDE DISCHARGES
1989
Index #: G-000-1 01 .7
Document Date: 03/31/89
From: WMCO
To: DOE
# of Pages: 22
MARCH
ADDENDUM TO THE IMPROVED STORAGE OF SOIL & DEBRIS REMOVAL ACTION (RA) 17
WORK PLAN, REV. NO.2
Index #: R-028-204.6
Document Date: 04/21/93
From: DOE-FN
To: EPA
# of Pages: 20
C'
ANNUAL ENVIRONMENTAL REPORT FOR CALENDAR YEAR 1991
Index #: G-000-106.55
Document Date: 1991
From: WEMCO
To: DOE-FN
# of Pages: 250
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OU3 Decision Summary (Final)
C-4
June 1994
ANNUAL WORK PROCEDURES UPDATE FERNALD ENVIRONMENTAL MANAGEMENT
PROJECT SAFE SHUTDOWN REMOVAL ACTION NUMBER 12 JUNE, 1992
Index #: R-022-202.4
Document Date: 06/01/92
From:
To:
# of Pages: 200
'J
APPLICATION TO SHIP WASTE TO THE NEVADA TEST SITE
Index #: R-020-1 04. 1
Document Date: 11/01/92
From: WEMCO
To: DOE-FN
# of Pages: 70
APPROVAL OF EE/CA FOR REMOVAL ACTION 27
Index #: R-036-207. 1
Document Date: 01/14/93
From: USEPA
To: DOE-FN
# of Pages: 2
APPROVAL OF FEMP ASBESTOS ABATEMENT REMOVAL ACTION
Index #: R-030-207.3
Document Date: 09/02/92
From: OEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF IMPROVED SOIL AND DEBRIS REMOVAL ACTION WORK PLAN (#17)
Index #: R-028-207.5
Document Date: 12/23/92
From: OEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF PHASE IV REMOVAL ACTIONS
Index #: G-000-708.57
Document Date: 02/16/93
From: OEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REMOVAL ACTION 9 - REMOVAL OF WASTE INVENTORIES
Index #: R-020-207.4
Document Date: 10/01/92
From: USEPA
To: DOE-FN
# of Pages: 1
-------
OU3 Decision Summary (Final)
C-5
June 1994
d
APPROVAL OF REMOVAL ACTION 12 - SAFE SHUTDOWN PROGRAM
Index #: R-022-207.3
Document Date: 10/01/92
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REMOVAL ACTION 13- PLANT 1 ORE SILOS WORK PLAN
Index #: R-O 19-207.4
Document Date: 05/15/92
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REMOVAL ACTION 15 SCRAP METALS PILE PROJECT PLAN
Index #: R-026-207.3
Document Date: 12/29/92
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REMOVAL ACTION 17 - IMPROVED STORAGE OF SOIL AND DEBRIS
Index #: R-028-207.3
Document Date: 09/30/92
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REMOVAL ACTION 24 PILOT PLANT SUMP WORK PLAN
Index #: R-031-207.4
Document Date: 11/19/92
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REMOVAL ACTION 25: NITRIC ACID TANK CAR WORK PLAN
Index #: R-035-207.5
Document Date: 03/04/93
From: USEPA
To: DOE-FN
# of Pages: 1
l,
APPROVAL OF REMOVAL ACTION 26 - REVISED COMPILATION
DOCUMENTATION SUPPORTING ASBESTOS ABATEMENT
Index #: R-030-207.4
Document Date: 09/25/92
From: USEPA
To: DOE-FN
# of Pages: 1
OF EXISTING
-------
OU3 Decision Summary (Final)
C-6
June 1994
APPROVAL OF REMOVAL ACTION 28 WORK PLAN
Index #: R-032-207.2
Document Date: 08/05/93
From: USEPA
To: DOE-FN
# of Pages: 3
APPROVAL OF REVISED OU #3 RIIFS WORK PLAN RTC
Index #: U-005-305.12
Document Date: 04/14/93
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF REVISED REMOVAL ACTION 17 - WORK PLAN AND ADDENDUM
Index #: U-028-207.8
Document Date: 06/10/93
From: USEPA
To: DOE-FN
# of Pages: 2
APPROVAL OF REVISED REMOVAL ACTION 1 9 WORK PLAN
Index #: R-037-207.4
Document Date: 07/29/93
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF THE EE/CA FOR
CONTAMINATED STRUCTURES
Index #: R-036-207.2
Document Date: 01/19/93
From: OEPA
To: DOE-FN
# of Pages: 2
REMOVAL ACTION #17 - MANAGEMENT OF
APPROVAL OF THE FINAL O.U.3 RIIFS WORK PLAN ADDENDUM
Index #: U-005-305. 14
Document Date: 06/08/93
From: OEPA
To: DOE-FN
# of Pages: 1
APPROVAL OF THE NITRIC ACID TANK CAR REMOVAL ACTION WORK PLAN
Index #: R-035-207.5
Document Date: OS/26/93
From: OEPA
To: DOE-FN
# of Pages: 1
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OU3 Decision Summary (Final)
C-7
June 1994
"
APPROVAL OF THE SITE-WIDE CHARACTERIZATION REPORT
Index #: G-000-105.53
Document Date: OS/28/93
From: USEPA
To: DOE-FN
# of Pages: 1
APPROVAL PLANT 1 ORE SILO R.A.W.P.
Index #: R-019-207.6
Document Date: 08/10/92
From: OEPA
To: DOE-FN
# of Pages: 1
APPROVAL WORK PLAN R.A. #14
Index #: R-O 15- 207.6
Document Date: 07/29/92
From: OEPA
To: DOE-FN
# of Pages: 1
ASBESTOS SURVEY & ASSESSMENT FOR THE FERNALD ENVIRONMENTAL MANAGEMENT
PROJECT
Index #: R-030-101.1
Document Date: 02/28/92
From: DIAGNOSTIC ENGINEERING
To: WEMCO
# of Pages: 500
ASSESSMENT OF RADIATION DOSE AND CANCER RISK FOR EMISSIONS FROM 1951
THROUGH 1984
Index #: G-000-101.23
Document Date: 08/01/89
From:
To:
# of Pages: 350
c.
BIOLOGICAL AND ECOLOGICAL SITE CHARACTERIZATION OF THE FEED MATERIALS
PRODUCTION CENTER JANUARY 1990
Index #: G-000-105.16
Document Date: 01/02/90
From: MIAMI UNIVERSITY
To: DOE-FMPC
# of Pages: 543
-------
OU3 Decision Summary (Final)
C-8
. June 1994
BIOLOGICAL SAMPLING ANALYSIS AND RESOURCES REPORT
Index #: G-000-302.5
Document Date: 03/01/90
From:
To:
# of Pages: 150
MARCH 1990
CATEGORICAL EXCLUSION DETERMINATION ASBESTOS ABATEMENT FOR CALENDAR
YEARS 1992 AND 1993 NEPA DOC. NO. 362
Index #: R-030-1 08.1
Document Date: 11/12/91
From: DOE-FN
To: DOE-HO
# of Pages: 4
CATEGORICAL EXCLUSION (CX) DETERMINATION PLANT 1 ORE SILOS REMOVAL ACTION,
NEPA DOC. NO. 363
Index #: R-019-108.1
Document Date: 01/22/92
From: DOE-FN
. To: DOE-HO
# of Pages: 5
CATEGORICAL EXCLUSION DETERMINATION PLANT 2/3 URANYL NITRATE HEXAHYDRATE
REMOVAL ACTION NEPA DOC NO. 358
Index #: U-005-108.1
Document Date: 01/15/92
From: DOE-FN
To: DOE-HO
# of Pages: 4
CATEGORICAL EXCLUSION DETERMINATION -PLANT7 DISMANTLING, REMOVAL ACTION
NO. 19, NEPA DOC. NO. 421
Index #: R-037-108.1
Document Date: 08/23/93
From: DOE-FN
To: DOE-HO
# of Pages: 5
CATEGORICAL EXCLUSION DETERMINATION - REMOVAL ACTION NO. 25 - NITRIC ACID
TANK CAR AND AREA NEPA DOC. NO. 403
Index #: R-03S- 1 08
Document Date: 07/19/93
From: DOE-FN
To: DOE-HO
# of Pages: 6
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OU3 Decision Summary (Final)
C-9
June 1994
CATEGORICAL EXCLUSION DETERMINATION - REMOVAL ACTION NO. 28 - FIRE TRAINING
FACILITY, NEPA DOC. NO. 397
Index #: R-032-108.1
Document Date: 07/22/93
From: DOE-FN
To: DOE-HO
# of Pages: 5
CATEGORICAL EXCLUSION DETERMINATION SAFE SHUTDOWN ACTIVITIES, CY 1993
NEPA DOCUMENT NO. 427
Index #: R-022-108.1
Document Date: 05/10/93
From: DOE-FN
To: DOE-HO
# of Pages: 5
COMMUNITY RELATIONS PLAN VOLUME III OF
INVESTIGATION/FEASIBILITY STUDY WORK PLAN AUGUST 1992
Index #: G-000-1 002.11
Document Date: 08/01/92
From: DOE-FN
To: WEMCO
# of Pages: 250
THE
REMEDIAL
CONDITIONAL APPROVAL OF THE ADDENDUM TO THE SOIL AND DEBRIS REMOVAL
ACTION 17 WORK PLAN
Index #: R-028-207.7
Document Date: OS/25/93
From: OEPA
To: DOE-FN
# of Pages: 2
CONSENT AGREEMENT UNDER CERCLA SECTION 120 AND 106(a)
Index #: G-000-71 0.1
Document Date: 04/09/90
From: USEPA
To: DOE-FMPC
# of Pages: 66
u
. CONSENT AGREEMENT AS AMENDED UNDER CERCLA SECTIONS 120 AND 106(a)
SEPTEMBER 1991
Index #: G-000-71 O. 14
Document Date: 09/01/91
From:
To:
# of Pages: 98
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OU3 Decision Summary (Final)
C-10
June 1994
CONSENT DECREE
Index #: G-000-704.1
Document Date: 12/02/88
From: STATE OF OHIO
To: DOE-FMPC
# of Pages: 31
CONTAMINATED SOILS ADJACENT TO THE SEWAGE TREATMENT PLANT INCINERATOR
REMOVAL ACTION 14 WORK PLAN ADDENDUM REVISION 2 JULY 1993
Index #: R-015-204.10
Document Date: 07/93
From: DOE-FN
To: EPA
# of Pages: 75
CONTAMINATION AT THE FIRE TRAINING FACILITY REMOVAL ACTION WORK PLAN AND
CLOSURE PLAN INFORMATION AND DATA PACKAGE DRAFT JUNE 1993
Index #: R-032-204.2
Document Date: 06/29/93
From: DOE-FN
To: EPA
# of Pages: 350
DECONTAMINATION AND DISMANTLEMENT OF BUILDINGS AND STRUCTURES AT
FERNALD FACT SHEET FOR THE PROPOSED PLAN/ENVIRONMENTAL ASSESSMENT FOR
INTERIM REMEDIAL ACTION DECEMBER 1993
Index #: U-005-1006.3
Document Date: 12/93
From: DOE
To: PUBLIC
# of Pages: 12
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
ASBESTOS ABATEMENT REMOVAL ACTION REMOVAL ACTION NO. 26 ASBESTOS
PROGRAM PROCEDURES
Index #: R:.030-204.1
Document Date: 05/19/92
From: DOE-FN .
To: EPA
# of Pages: 500
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
REMOVAL OF WASTE INVENTORIES LOW LEVEL RADIOACTIVE WASTE AND THORIUM
MANAGEMENT
Index #: R-020-204.8
Document Date: 06/01/92
From: DOE-FN
To: EPA
# of Pages: 700
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OU3 Decision Summary (Final)
C-11
June 1994
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
REMOVAL OF WASTE INVENTORIES LOW LEVEL RADIOACTIVE WASTE AND THORIUM
MANAGEMENT
Index #: R-020-204.13
Document Date: 06/29/93
From: DOE-FN
To: EPA
# of Pages: 550
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
REMOVAL OF WASTE INVENTORIES REMOVAL ACTION NO.9
Index #: R-020-202.4
Document Date:
From: DOE-FO
To: USEPA
# of Pages: 500
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
REMOVAL OF WASTE INVENTORIES THORIUM MANAGEMENT PROCEDURES "TO BE
OVERPACKED"
Index #: R-020-204.6
Document Date:
From:
To:
# of Pages: 20
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
REMOVAL OF WASTE INVENTORIES THORIUM MANAGEMENT PROCEDURES "TO BE
OVERPACKED" REMOVAL ACTION
Index #: R-020-204.1
Document Date: 09/26/91
From: DOE-FN
To: EPA
# of Pages: 500
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
SAFE SHUTDOWN REMOVAL ACTION NUMBER 1 2 PART ONE
Index #: R-022-202.2
Document Date: 10/29/91
From: DOE-FSO
To: EPA
# of Pages: 399
c.
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
SAFE SHUTDOWN REMOVAL ACTION NUMBER 12 PART TWO
Index #: R-022-202.3
Document Date: 10/29/91
From: DOE-FSO
To: EPA
# of Pages: 476
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OU3 Decision Summary (Final)
C-12
June 1994
DOCUMENTATION SUPPORTING FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
SAFE SHUTDOWN REMOVAL ACTION NUMBER 12 JUNE 1993
Index #: R-022-204.2 .
Document Date: .06/29/93
From: DOE-FN
To: EPA
# of Pages: 650
{)
DOE ENVIRONMENTAL ASSESSMENT OF THE PROPOSED LOW-LEVEL WASTE PROCESSING
AND SHIPMENT SYSTEM
Index #: G-000-107.6
Document Date: 05/01/85
From:
To: DOE-HQ
# of Pages: 25
DOSE AND RISK ASSESSMENTS IN SUPPORT OF THE OPERABLE UNIT 3 PROPOSED PLAN
FOR INTERIM REMEDIAL ACTION (ENVIRONMENTAL DIMENSIONS INC - ED!)
Index #:
Document Date: 1993
From:
To:
# of Pages:
ECOREGIONS OF THE UNITED STATES
Index #: U-006-307.22
Document Date: 1976
From:
To:
# of Pages: 1
ENGINEERING EVALUATION/COST ANALYSIS-FOR REMOVAL ACTION
MANAGEMENT OF CONTAMINATED STRUCTURES DECEMBER 1992
Index #: R-036-203.2
Document Date: 12/15/92
From: DOE-FN
To: EPA
# of Pages: 200
NO.
27
ENGINEERING EVALUATION/COST ANALYSIS-FOR REMOVAL ACTION NO.
MANAGEMENT OF CONTAMINATED STRUCTURES VOLUME 11- BACKUP DATA
Index #: R-036-203.3
Document Date: 12/15/92
From: DOE-FN
To: EPA
# of Pages: 200
27
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OU3 Decision Summary (Final)
C-13
June 1994
ENGINEERING EVALUATION/COST ANALYSIS, K-65 SILOS REMOVAL ACTION
Index #: R-008-203.3
Document Date: 1990
From: BNI
To: DOE
# of Pages: 135
o
EXPEDITED CLEANUP OF THE FORMER PRODUCTION AREA, OR OPERABLE UNIT (OU) 3
Index #: U-005-708.1
Document Date: 12/08/92
From: USEPA
To: DOE-FN
# of Pages: 3
FEDERAL REGISTER PART II - ENVIRONMENTAL PROTECTION AGENCY 40 CFR PART
300 NATIONAL PRIORITIES LIST OF UNCONTROLLED HAZARDOUS WASTE SITES; FINAL
RULE
Index #: G-000-101.52
Document Date: 11/21/89
From: FED REG
To:
# of Pages: 7
FEED MATERIALS PRODUCTION CENTER RifFS OPERABLE UNIT 3 SCOPE OF WORK
REVISED APRIL 16, 1990
Index #: U-005-101.2
Document Date: 04/16/90
From: ASI
To: DOE-FMPC
# of Pages: 7
FINAL REPORT: ELECTRO FISHING SURVEY OF THE GREAT MIAMI RIVER
Index #:
Document Date: 1989
From:
To:
# of Pages:
u
FY-94 COST ESTIMATE FOR THE OU3 PROPOSED PLAN/ENVIRONMENTAL ASSESSMENT
DRAFT
Index #:
Document Date:
From: FERMCO
To: DOE-FN
# of Pages:
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OU3 Decision Summary (Final)
C-14
June 1994
HISTORY OF FMPC RADIONUCLIDE DISCHARGES, FMPC-2082, (TABLES 52 - 87)
Index #: G-000-1 01 .4
Document Date: 1987
From: WMCO
To: DOE-ORO
# of Pages: 211
~,
IMPROVED STORAGE OF SOIL AND
FEBRUARY 1993 REVISION NO.2
Index #: R-028-204.7
Document Date: 04/21/93
From: DOE-FN
To: EPA
# of Pages: 1 25
DEBRIS REMOVAL ACTION 17 WORK PLAN
LOW LEVEL RADIOACTIVE WASTE SHIPPING DOCUMENTATION TO NEVADA TEST SITE
REMOVAL OF WASTE INVENTORIES REMOVAL ACTION NUMBER -9 JANUARY 1992 - JUNE
1992 VOLUME 1
Index #: R-020-712.1
Document Date:
From: WEMCO
To:
# of Pages: 300
LOW LEVEL RADIOACTIVE WASTE SHIPPING DOCUMENTATION TO NEVADA TEST SITE
REMOVAL OF WASTE INVENTORIES REMOVAL ACTION NUMBER 9 JANUARY 1992 - JUNE
1992 VOLUME 2
Index #: R-020-712.2
Document Date:
From: WEMCO
To:
# of Pages: 280
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) DETERMINATION - LOW LEVEL WASTE
SHIPMENTS TO NEVADA TEST SITE (NTS) - FEED MATERIALS PRODUCTION CENTER
(FMPC)
Index #: G-OOO-1 01 .34, G-OOO~ 101.35
Document Date: 08/1 2/87
From: DOE-ORO
To:
# of Pages: 1
NEVADA TEST SITE ANNUAL ENVIRONMENTAL REPORT - 1990
Index #:
Document Date: 1992
From:
To:
# of Pages:
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OU3 Decision Summary (Final)
C-15
NEW NPDES PERMIT EVALUATION DECEMBER, 1 990
Index #: G-000-104.6
Document Date: 12/01/90
From: WMCO
To: DOE-FSO
# of Pages: 75
June 1994
NITRIC ACID TANK CAR AND AREA REMOVAL ACTION WORK PLAN AND CLOSURE PLAN
INFORMATION AND DATA PACKAGE FINAL MARCH 1993
Index #: R-035-204.6
Document Date: 04/16/93
From: DOE-FN
To: EPA
# of Pages: 150
v
NPDES BEST MANAGEMENT PRACTICES PLAN
Index #: G-000-1106.3
Document Date: 01/25/88
From: WESTON
To: WMCO
# of Pages: 144
OPERABLE UNIT 3 PROPOSED PLAN/ENVIRONMENTAL ASSESSMENT
REMEDIAL ACTION COMMENT RESPONSE PACKAGE NOVEMBER 1993
Index #: U-005-408.8
Document Date: 11/93
From: DOE-FN
To: EPA
# of Pages: 100
OPERABLE UNIT 3 PROPOSED PLAN/ENVIRONMENTAL
REMEDIAL ACTION DECEMBER 1993 FINAL
Index #: U-005-405.6
Document Date: 12/93
From: DOE-FN
To: EPA
# of Pages: 250
"
o
OPERABLE UNIT 3 WORK PLAN ADDENDUM
A-C MAY 1993 REVISION 3 FINAL
Index #: U-005-303.17
Document Date: 05/14/93
From: DOE-FN
To: EPA
# of Pages: 300
FOR INTERIM
ASSESSMENT FOR INTERIM
VOLUME 1 OF 2 SECTION 1-7 APPENDICES
lJ
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r
OU3 Decision Summary (Final)
C-16
June 1994
OPERABLE UNIT 3 WORK PLAN ADDENDUM VOLUME 2 OF 2 APPENDIX D - SAMPLING
AND ANALYSIS PLAN MAY 1993 REVISION 3 FINAL
Index #: U-005-303.18
Document Date: 05/14/93
From: DOE-FN
To: EPA
# of Pages: 400
PILOT PLANT SUMP REMOVAL ACTION NO. 24
PLANT) FINAL REPORT DECEMBER 1993
Index #: R-031-209.2
Document Date: 12/93
From: DOE-FN
To: WEMCO
# of Pages: 25
(ABANDONED SUMP WEST OF PILOT
PLANT 1 ORE SILOS REMOVAL ACTION NUMBER 13 WORK PLAN
Index #: R-O 19-204.7
Document Date: 07/01/92
From: DOE-FN
To:. EPA
# of Pages: 150
JULY 1992
PLANT 1 PAD CONTINUING RELEASE REMOVAL ACTION WORK PLAN
Index #: R-012-204.4
Document Date: 06/01/91
From:
To:
# of Pages: 400
JUNE 1991
PLANT 7 DISMANTLING REMOVAL ACTION 19 WORK PLAN
Index #: R-037-204.3
Document Date: 06/29/93
From: DOE-FN
To: EPA
. # of Pages: 300
JUNE 1993 REVISION 1
PRESENT WORTH ANALYSIS FOR THE OU3 PROPOSED PLAN
Index #:
Document Date:
From: FERMCO
To: DOE-FN
# of Pages:
DRAFT
1
i "
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OU3 Decision Summary (Final)
C-17
June 1994
~
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RifFS) RISK ASSESSMENT WORK PLAN
ADDENDUM
Index #: G-000-303.42
Document Date: 06/19/92
From: DOE-FN
To: EPA
# of Pages: 2
v
REMOVAL #8, OU #3 PLANT 1 PAD WORKPLAN APPROVAL U.S. DOE FERNALD
Index #: R-012-207.7
Document Date: 08/19/91
From: USEPA
To: DOE-FSO
# of Pages: 1
REMOVAL ACTION 14 CONTAMINATED SOILS ADJACENT TO THE SEWAGE TREATMENT
PLANT INCINERATOR FINAL WORKPLAN ADDENDUM .
Index #: R-015-207 .13.
Document Date: 08/24/93
From: USEPA
To: DOE-FN
# of Pages: 1
REMOVAL ACTION PROJECT PLAN (RAPP) FOR PHASE I OF RA#15 PROCESSING AND
DISPOSAL OF AN ESTIMATED 2,210 TONS OF NON-RCRA SCRAP METAL FROM THE
FERNALD ENVIRONMENTAL
Index #: R-026-204.6 .
Document Date: 11/23/92
From: DOE-FN
To: EP A
# of Pages: 150
REPORT ON FISH POPULATION AND ENVIRONMENTAL CONDITIONS IN PADDYS RUN AND
THE GREAT MIAMI RIVER IN THE VICINITY OF THE FERNALD PLANT OF THE A. E. C. JULY
28, 1952
Index #: G-000-1 01 .45
Document Date: 07/28/52
From:
To:
# of Pages: 21
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OU3 Decision Summary (Final)
C-18
June 1994
REVISED DRAFT REMOVAL ACTION WORK PLAN FOR REMOVAL ACTION 25 - NITRIC ACID
TANK CAR AND AREA
Index #: R-035-204.2
Document Date: 01 /27/93
From: DOE-FN
To: EPA
# of Pages: 2
,;
REVISED OPERABLE UNIT 3 REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK PLAN
ADDENDUM
Index #: U-005-303.16
Document Date: 05/14/93
From: DOE-FN
To: EPA
# of Pages: 2
REVISED OU #3 RI/FS WORK PLAN
Index #: U-005-305.15
Document Date: 06/1 0/93
From: USEPA
To: DOE-FN
# of Pages: 4
REVISED OU #3 RI/FS WORK PLAN RESPONSES TO COMMENTS
Index #: U-005-305. 1 6
Document Date: 08/04/93
From: USEPA
To: DOE-FN
# of Pages: 1
REVISED REMOVAL ACTION 13 - PLANT 1 ORE SILOS WORK PLAN
Index #: R-019-204.6
Document Date: 07/14/92
From: DOE-FN
To: EPA
# of Pages: 2
REVISED REMOVAL ACTION WORK PLAN FOR THE PLANT 1 PAD CONTINUING RELEASE
Index #: R-012-204.3
Document Date: 06/14/91
From: DOE-FSO
To: EPA
# of Pages: 2
REVISED SCRAP METAL PILES R.A.W.P.
Index #: R-026-207.4
Document Date: 06/01/92
From: OEPA
To: DOE-FN
# of Pages: 2
.
I
.
(
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OU3 Decision Summary (Final)
C-19
June 1994
RISK ASSESSMENT WORK PLAN ADDENDUM
Index #: G-000-303.43
Document Date: 06/01/92
From: DOE-FN
To: EPA
# of Pages: 150
JUNE 1992
SCRAP METAL PILES REMOVAL ACTION NUMBER 15 WORK PLAN FERNALD SITE OFFICE.
FERNALD, OHIO JANUARY 1992
Index #: R-026-204.1
Document Date: 01/01/92
From:
To:
# of Pages: 1 6
SCRAP METAL PILES REMOVAL ACTION W.P.
Index #: R-026-207.1
Document Date: 02/20/92
From: OEPA
To: DOE-FO
# of Pages: 1
SCREENING LEVEL ECOLOGICAL.: RISK ASSESSMENT FOR THE SITEWIDE ECOLOGICAL RISK
ASSESSMENT AUGUST 1993 DRAFT
Index #: U-007-304.3
Document Date: 08/23/93.
From: DOE-FN
To: EP A
# of Pages: 223
SITE ENVIRONMENTAL REPORT 1992 FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
Index #: G-000-105.5
Document Date: 08/01/92
From: DOE-FN
To:
# of Pages: 250
SITE ENVIRONMENTAL REPORT 1992 FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
Index #: G-000-106.56
Document Date: 06/01/93
From: DOE-FN
To:
# of Pages: 258
;,
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f
OU3 Decision Summary (Final)
C-20
June 1994
SITEWIDE CERCLA QUALITY ASSURANCE PROJECT PLAN
THROUGH 16 SEPTEMBER 22, 1992
Index #: G-000-303.49
Document Date: 09/22/92
From: DOE-FN
To: EP A
# of Pages: 250
VOLUME 1
SECTIONS 1
SITEWIDE CERCLA QUALITY ASSURANCE PROJECT PLAN VOLUME"
THROUGH K SEPTEMBER 22, 1992
Index #: G-000-303.50
Document Date: 09/22/92
From: DOE-FN
To: EPA
# of Pages: 450
APPENDICES A
SITEWIDE CERCLA QUALITY ASSURANCE PROJECT PLAN VOLUME '" ATTACHMENT I -
FEMP LABORATORY ANALYTICAL METHODS MANUAL SEPTEMBER 22, 1992
Index #: G-000-303.51
Document Date: 09/22/92
From: DOE-FN
To: EPA
# of Pages: 450
SITEWIDE CERCLA QUALITY ASSURANCE PROJECT PLAN VOLUME IV ATTACHMENT I -
FEMP LABORATORY ANALYTICAL METHODS MANUAL (CONT.) SEPTEMBER 22,1992
Index #: G-000-303.52
Document Date: 09/22/92
From: DOE-FN
To: EPA
# of Pages: 150
SITEWIDE CERCLA QUALITY ASSURANCE PROJECT PLAN VOLUME V ATTACHMENT 1-
FEMP LABORATORY ANALYTICAL METHODS MANUAL (CONT.) SEPTEMBER 22,1992
Index #: G-000-303.53
Document Date: 09/22/92
From: DOE-FN
To: EPA
# of Pages: 200
SITE-WIDE CERCLA QUALITY ASSURANCE PROJECT PLAN CHANGE PAGES FOR VOLUMES
I AND II
Index #: G-000-303.63
Document Date: 06/28/93
From: DOE-FN
To: EPA
# of Pages: 65
!
I.
r
l
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OU3 Decision Summary (Final)
C-21
June 1994
MARCH 1993
SITE-WIDE CHARACTERIZATION REPORT VOLUME 1 OF 5 PART I
Index #: G-000-105.43
Document Date: 03/31/93
From: DOE-FN
To: EP A
# of Pages: 400
l.,
SITE-WIDE CHARACTERIZATION REPORT
Index #: G-000-105.44
Document Date: 03/31/93
From: DOE-FN
To: EPA
# of Pages: 400
SITE-WIDE CHARACTERIZATION REPORT
1993
Index #: G-000-1 05.45
Document Date: 03/31/93
From: DOE-FN
To: EPA
# of Pages: 600
SITE-WIDE CHARACTERIZATION REPORT
1993
Index #: G-000-105.46
Document Date: 03/31/93
From: DOE-FN
To: EPA
# of Pages: 600
SITE-WIDE CHARACTERIZATION REPORT
1993
Index #: G-000-105.47
Document Date: 03/31/93
From: DOE-FN
To: EP A
# of Pages: 700
VOLUME 2 OF 5 PART I (CONT.) MARCH 1993
VOLUME 3 OF 5 PART II, PART III
MARCH
VOLUME 4 OF 5 APPENDICES A - M MARCH
VOLUME 5 OF 5 APPENDICES N - U MARCH
SITE WIDE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND
LIABILITY ACT (CERCLA) QUALITY ASSURANCE PROJECT PLAN (SCQ)
Index #: G-000-306.35
Document Date: 12/09/92
From: DOE-FN
To: EPA
# of Pages: 6
v
(;
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OU3 Decision Summary (Final)
C-22
June 1994
SITE-WIDE QUALITY ASSURANCE PROJECT PLAN
Index #: G-000-305.56
Document Date: 02/12/93
From: USEPA
To: DOE-FN
# of Pages: 4
SITE-WIDE QUALITY ASSURANCE PROJECT PLAN FINAL APPROVAL
Index #: G-000-303.62
Document Date: '06/08/93
From: USEPA
To: DOE-FN
# of Pages: 1
SOIL SURVEY OF BUTLER COUNTY, OHIO
Index #: U-006-307. 10
Document Date: 01/01/80
From: USAG
To:
# of Pages: 259
SOIL SURVEY OF HAMILTON COUNTY, OHIO
Index #: U-006-307. 1 2
Document Date: 08/01/82
From: USAG
To:
# of Pages: 258
STIPULATED AMENDMENT OF CONSENT DECREE ENTERED DECEMBER 2, 198"8, AS
AMENDED ON JANUARY 22, 1993.
Index #: G-000-704.40
Document Date: 01/20/93
From: U.S. DISTRICT COURT
To: USDOE & OHIO
# of Pages: 75
SUBMITTAL OF CHANGE PAGES FOR SITE-WIDE CERCLA QUALITY ASSURANCE PROJECT
PLAN
Index #: G-000-303.54
Document Date: 01/29/93
From: DOE-FN
To: EPA
# of Pages: 1 8
t
I'
f
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OU3 Decision Summary (Final)
C-23
June 1994
THORIUM MANAGEMENT PROCEDURES FOR CONTAINERS ftTO BE
REMOVAL ACTION NO.9 AUGUST 1991 (REVISED NOVEMBER 1991)
Index #: R-020-204.5 .
Document Date: 11 /01 /91
From:
To:
# of Pages: 17
OVERPACKEDft
U.S. DOE PUBLIC MEETING ON THE OPERABLE UNIT 3 PROPOSED PLAN JANUARY 5, 1994
Index #: U-005-1004.2
Document Date: 1994
From: DOE-FN
To:
# of Pages: 140
U.S. DOE REQUEST FOR EXTENSION FOR OU 2 MILESTONES AND ADDITIONAL WORK IN
OU 3
Index #: G-000-71 O. 1 6
Document Date: 02/05/93
From: USEPA
To: DOE-FN
# of Pages: 1
U.S. DOE REQUEST FOR EXTENSION FOR OU 2 MILESTONES AND ADDITIONAL WORK IN
OU 3
Index #: G-000-71 0.17
Document Date: 02/09/93
From: USEPA
To: DOE-FN
# of Pages: 5
. VOLUME III OF THE WORK PLAN COMMUNITY RELATIONS PLAN REMEDIAL
INVESTIGATION/FEASIBILITY STUDY AND REMOVAL ACTIONS A TTHE U.S. DEPARTMENT
OF ENERGY FERNALD
Index #: G-000-1 002.7
Document Date: 01/01/92
From:
To:
# of Pages: 69
u
WETLANDS DELINEATION REPORT OF THE FERNALD ENVIRONMENTAL MANAGEMENT
PROJECT BUTLER AND HAMILTON COUNTIES, OHIO JUNE 1993
Index #: U-007-107.2
Document Date: 07/22/93
From: DOE-FN
To: EPA
# of Pages: 154
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C-24
June 1994
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