PB98-964029
                              EPA541-R98-190
                              May 1999
EPA Superfund
      Record of Decision:
      Savannah River Site (USDOE)
      F-Area Retention Basin (281-3F)
      Aiken, SC
      9/4/1998

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                               Department of Energy
                             Savannah River Operations Office
                                      P.O. Box A
                               Aiken, South Carolina 29802
                                     APR 28 1999
Mr. K. A. Collinsworth, Manager
Federal Facility Agreement Section
Division of Site Assessment and Remediation
Bureau of Land and Waste Management
South Carolina Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201

Mr. J. L. Crane, Manager
SRS Remedial Project
Waste Management Division
United States Environmental Protection Agency, Region IV
61 Forsyth Street, SW
Atlanta, GA 30303

Dear Mr. Collinsworth and Mr. Crane:

SUBJECT:   Submittal of the Record Copy of the Signed Record of Decision for the F-Area
             Retention Basin (281-3F)

Enclosed, please find a signed copy of the F-Area Retention Basin Record of Decision
for your  records.   Savannah River Site (SRS) will make  the  distribution  of the
Administrative Record file(s) and publish the notice of availability.

Please contact me at (803) 725-7032 if you have any questions.
                                       Bnan T. Hennessey
                                       Environmental Restoration Division
                                       SRS Remedial Project Manager

BTH/LHW:ed
OD-99-254
Enclosure
1.  Record of  Decision  for the  F-Area  Retention Basin  (281-3F),  WSRC-RP-97-145,
    Revision. 1.1

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A. B. Gould, DOE-ECD, 703-A
C. V. Anderson, DOE-ERD, 703-A
S. A. Holt, Dynamac*
C. B. Warren, US EPA-IV
K. B. Feely, US EPA-IV
J. K. Lindler, SCDHEC-Columbia
J. T. Litton, SCDHEC-Columbia
M. D. Sherritt, SCDHEC-Columbia
G. K. Taylor, SCDHEC-Columbia
SRS Administrative Record Files (Palmer, 730-2B, 1000)*
*w/enclosure

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                                                             SEP *4

                                                     ^^^^^   ^^^^^^^w^^^^^o'T^
 United States Department of Energy                    ASSESSMENT* ^

 Savannah River Site
Record of Decision
Remedial Alternative Selection for the
F-Area Retention Basin (281-3F) (U)
WSRC-RP-97-145

Revision 1.1

August 1998
Prepared by:
Westinghouse Savannah River Company                            .
Savannah River Site                                           /
Aiken, SC 29808
Prepared for U.S. Department of Energy under Contract No. DE-AC09-9  SAV»NN»M *.*<*

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 Record of Decision for the F-Area Retention Basin (281-3F)             WSRC-RP-97-145
 Savannah River Site                                                       Revision 1.1
 August 1998
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Record of Decision for the F-Area Retention Basin (281-3F)            WSRC-RP-97-145
Savannah River Site                                                     Revision 1.1
August 1998                                 ^^^^^
                                  DISCLAIMER
      This report was prepared by Westinghouse Savannah River Company (WSRC) for
      the  United  States Department  of Energy  under Contract  No.  DE-AC09-
      96SR18500 and is an account of work performed under that contract. Reference
      herein to any specific commercial product, process or service does not necessarily
      constitute or imply endorsement, recommendation, or favoring of same by WSRC
      or by the United States Government or any agency thereof.
                        Printed in the United States of America
                                    Prepared for
                             U. S. Department of Energy
                                        by
                        Westinghouse Savannah River Company
                               Aiken, South Carolina
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  Record of Decision for the F-Area Retention Basin (281-3F)             WSRC-RP-97-145
  Savannah River Site                                                       Revision 1.1
  August 1998
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                RECORD OF DECISION
      REMEDIAL ALTERNATIVE SELECTION (U)
             F-Area Retention Basin (281-3F)
                   WSRC-RP-97-145
                      Revision 1.1
                      August 1998
                  Savannah River Site
                 Aiken, Soutb Carolina
                      Prepared by:

          Westinghouse Savannah River Company
                        for the
U.S. Department of Energy under Contract DE-AC09-96SR18500
             Savannah River Operations Office
                 Aiken, South Carolina

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 Record of Decision for the F-Area Retention Basin (281-3F)            WSRC-RP-97-145
 Savannab River Site                                                      Revision 1.1
 August 1998	

 DECLARATION7 FOR THE RECORD OF DECISION

 Unit Name and Location

 F-Area Retention Basin (SRS Building 281-3F)
 Savannah River Site
 Aiken, South Carolina

 The F-Area Retention Basin (FRB) Operable Unit (OU) is listed as a Resource Conservation and
 Recovery Act (RCRA) 3004 (U) Solid Waste Management Unit/Comprehensive Environmental
 Response, Compensation, and Liability Act (CERCLA)  Unit in Appendix  C of the  Federal
 Facility Agreement (FFA) for the Savannah River Site (SRS). This OU includes the retention
 basin (basin soils),  the former process sewer line (pipeline,  pipeline sediment, and pipeline
 associated soils), and the groundwater associated with the unit.

Statement of Basis and Purpose

 This decision document presents the selected remedial alternatives for the FRB OU located at the
 SRS south of Aiken, South Carolina. The selected alternatives were developed  in accordance
 with CERCLA, as amended by SARA, RCRA, and to the extent practicable, the National  Oil and
 Hazardous Substances Pollution Contingency Plan (NCP).   This  decision is  based  on the
Administrative Record File for this specific RCRA/CERCLA unit.

Assessment of the Site

 Actual  or threatened  releases  of hazardous substances  from this site, if not  addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
                                   Declaration - 1
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 Record of Decision for the F-Area Retention Basin (281-3F)             WSRC-RP-97-145
 Savannah River Site                                                          Revision 1.1
 August 1998	
 Description of the Selected Remedy

 The preferred alternatives  for  the FRB OU  are:   (1)  for  the basin soil; Alternative  S5:
 Institutional  Controls,  Grouting, a Low Permeability Cover, and  Groundwater Monitoring;  (2)
 for the  former process sewer line: Alternative P4: Institutional Controls, Pipeline Grouting, and
 Soil Excavation and Disposition with Basin Soils; and (3) for the  groundwater; Alternative  Gl:
 No Action. The waste unit will be physically maintained and institutional controls will remain in
 place in perpetuity. The field conditions will be evaluated to determine the need to modify the
 program or to identify if further remedial action is appropriate during the five-year ROD review.

 Under Alternative S5, deep basin soil will be grouted from approximately 0.6 m (2 ft) above the
 basin bottom to approximately  4.3 m (14 ft) below grade.  The purpose of grout is to prevent
 leaching of Sr-90, which is the only contaminant migration COC (CMCOC) to the groundwater
 above maximum concentration level 8.0 pCi/L.  Furthermore, grouting the  soil  provides  an
 additional  layer  of protection  by offsetting  the  inherent  uncertainty associated with  the
 mathematical model used to predict contaminant migration.  Grouting will also immobilize other
 deep contaminants  which represent principal threat  source material such  as  Cs-137, Ra-226,
 thallium, arsenic, etc., and  further reduce infiltration  of water through the deeper contaminated
 soils. Grouting of soils is preferred over only capping because it meets the CERCLA preference
 for treatment.   A  cover will be provided  over the stabilized soil to minimize stormwater
 percolation and erosion.  The cover is also very effective in reducing direct radiation exposure
 received from radionuclides in the shallow soil. This alternative  includes institutional controls to
 prevent  exposure of current and future workers  to hazardous constituents in the waste unit and
 direct radiation from the waste unit. Since waste is left in place, the future use of land will  be
 restricted to industrial use to prevent unrestricted residential use of the land.

In situ grouting  reduces air emissions and is relatively simple to  implement.  However,  in situ
 grouting results in a slight increase in waste volume.  The volume of the  basin, when clean soil is
 excavated prior  to  grouting, will be adequate  to accommodate any increase in grouted soil
 volume. The estimated volume of grout/soil mixture is 6,600 mj  (8,100 yd3).

 Implementation of institutional  controls will involve both short- and long-term actions. For the
 short-term action, signs will be posted at the FRB OU indicating that this area was  used for the
 disposal of waste material and contains buried waste. Additionally, existing SRS access controls
 will be used to maintain use of this site for industrial use only. In the  long-term, if the property is
 ever transferred  to  non-Federal ownership,  the U.S.  Government will  take  those  actions

                                     Declaration - 2
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 Record of Decision for the F-Area Retention Basin (281 -3F)             WSRC-RP-97-145
 Savannah River Site                                                       Revision 1.1
 August 1998	
 necessary pursuant to Section 120(h) of CERCLA. These actions will include a deed notification
 disclosing former waste management  and  disposal activities as well as any remedial actions
 taken on the site and any continuing groundwater monitoring commitments. These requirements
 are also consistent with the intent of the RCRA deed notification required at final closure of the
 RCRA  facility if contamination would remain at  the unit.  The deed notification  shall,  in
 perpetuity, notify any potential purchaser that the property has been  used for the management
 and disposal of radioactive materials and hazardous substances. The deed shall also include deed
 restrictions  precluding residential  use of  the property.  However, the  need  for these  deed
 restrictions may be reevaluated at the time of transfer in the event that contamination no longer
 poses an  unacceptable risk under  residential use.  Any revaluation of  the need for  deed
 restrictions would be done  through an amended ROD with the Environmental Protection Agency
 (EPA) and the South Carolina Department of Health and Environmental Control (SCDHEC)
 approval.  In  addition, a  certified  survey  of the area will be prepared by a registered land
 surveyor and will be included in the Post-Construction Report. The survey will be reviewed and
 updated, as necessary, at the time the site is  transferred and will be recorded into the appropriate
 county recording agency. The FRB OU is located in Aiken County.

 Per the EPA-Region IV Land Use Controls  (LUCs) Policy, a Land Use Control Assurance Plan
 (LUCAP) and a  Land Use Control Implementation Plan (LUCIP)  will  be  developed  and
 submitted to the regulators for their approval. The LUCAP will be  submitted under  separate
 cover whereas the LUCIP will be submitted with the Remedial Work Plan/Remedial Design
 Report/Remedial Action Work plan (RFWP/RDR/RAWP) for the FRB OU in accordance with
 the Post-ROD document  schedule  provided in this  ROD.  The LUCAP will include the
 information  requested in the EPA  policy.    The LUCIP  details how SRS  will implement,
 maintain, and monitor the  land use  control elements  of the FRB OU ROD to insure  that the
remedy remains protective of human health.
The LUC objective necessary to ensure the protectiveness of the preferred alternative is:
 •     Prevent unauthorized access/exposure to contaminated grout and basin soil
The institutional  controls required to prevent  unauthorized  exposure to the contaminated grout
 and soil include the following:
 •     Controlled access to the FRB waste unit through existing  SRS security  gates and
      perimeter fences and the site use/site clearance programs
 •     Signs posted in the area to indicate  that contaminated grout and soil are  present in the
      waste unit

                                    Declaration - 3
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Record of Decision for the F-Area Retention Basin (281-3F)              \VSRC-RP-97-l 45
Savannah River Site                                                        Revision 1.1
August 1998	
•      Notification of contaminated  grout  and soil to any future land owner through deed
       notification as required under CERCLA Section 120(h)

Along with the institutional controls identified above for the FRB soils, the preferred alternative
for the process sewer line and associated soils will include pipeline and manholes grouting, and
excavation and disposition of pipeline soils (approximate volume 240m3 or 300 yd 3) with basin
soil. In this alternative, the localized areas of the contaminated soil around the pipeline hot spots
will be excavated.  If necessary, the sections of pipeline associated with the hot spots will also be
excavated. The excavated soil and pipeline will be disposed of at the basin by in situ grouting
along with soil from  the basin. Clean soil from SRS borrow areas will be used to fill excavated
areas  around the pipeline.  This alternative will also include access controls such as installing
warning signs around the pipeline area.

The preferred alternative for the FRB OU groundwater is "No Action". The history of the FRB,
the results of the groundwater modeling, and the current groundwater data reveal that the FRB-
associated groundwater poses no risk to human health  or the environment.  No contaminant
exceeds the maximum contaminant levels (MCLs) stipulated by EPA under the Safe Drinking
Water Act. However, to ensure that the grout monolith, formed by in situ grouting of soils under
Alternatives  S5  and P4,  has accomplished the required  immobility of contamination,  a
groundwater monitoring program will be established under Alternative S5.  The groundwater
will be monitored semi-annually until it is confirmed that the remedial response action for the
FRB OU has achieved the required stabilization of the contaminants.  Groundwater monitoring,
in conjunction with institutional controls, will help prevent ingestion of groundwater; verify that
no upgradient  source of contamination exists; and reduce the uncertainty in the environmental
data collected during  the characterization of the FRB OU.

The post-ROD document, the Corrective Measures Implementation/Remedial Design Work Plan
(CMI/RDWP), will be submitted to the U.S. Environmental Protection Agency (EPA) and the
South Carolina Department of Health  and  Environmental Control (SCDHEC) following the
issuance of the ROD. The CMI/RDWP will contain a summary description of the scope of work
for the remedial action design, detailed implementation/submittal schedule for subsequent post-
ROD documents, and an anticipated field activities start date.  The CMI/RDWP will also include
regulatory review  period,  SRS  revision period,  and final regulatory approval period.  The
regulatory review period, SRS revision period, and final regulatory review  and  approval period
normally are 45 days, 30 days, and 30 days, respectively.
                                    Declaration - 4
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Record of Decision for the F-Area Retention Basin (281-3F)             WSRC-RP-97-145
Savannah River Site                                                         Revision 1.1
August 1998	
The SCDHEC has modified the SRS RCRA permit to incorporate the selected remedy.

Statutory Determinations

Based  on the Remedial  Investigation  Report and  the  Baseline Risk Assessment (RI/BRA
prepared under SRS RFI/RI  Program  Plan), the FRB  OU poses no  significant risk  to  the
environment but poses a significant risk to human health. Therefore, institutional controls, in situ
grouting of the contaminated basin soil and covering the grouted soil with a low permeability
cover,  and confirmatory groundwater monitoring are necessary for the basin soil; institutional
controls, pipeline and manhole grouting, and excavation  and disposition of soil with the basin
soil are necessary for the pipeline and pipeline associated soil. No additional remedial action is
required for the FRB OU groundwater.  However, as a part of remedial action, the groundwater
will be monitored:   (1) to confirm  that the source remediation has  achieved  the required
stabilization of the contaminants; (2) to relieve any uncertainty in the analytical data; and (3) to
verify  that there exists no upgradient source contributing  any  contamination  to the FRB OU
groundwater.  If monitoring detects contamination above  MCLs (or Risk-Based Concentrations
(RBCs) without MCLs) for those constituents attributable to the  FRB OU groundwater (or an
upgradient source)  for two consecutive monitoring  periods, the regulators will  be informed
within  30 days. A plan for evaluating the  data and  developing further action needed will be
submitted within 90 days for regulatory approval.

In situ  grouting of soils and cover will:  (1) result in the protection of unit groundwater through
the stabilization of unit constituents of concern (COCs); and (2) serve to stabilize  the principal
threat source  material.  The grout testing under  actual  field conditions will be performed to
confirm the successful soil stabilization.  The remedial action, therefore, will be protective of on-
unit human and ecological receptors by shielding exposure and preventing the assimilation of
unit COCs. The selected  remedy is  protective of  human health and  the  environment,  and
complies  with Federal  and  state  Applicable or  Relevant and Appropriate Requirements
(ARARs). The selected remedy is cost-effective.  This remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable and satisfies  the statutory
preference for remedies that employ treatments that  reduce toxicity, mobility, or  volume as a
principal element.
                                    Declaration - 5
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 Record of Decision for the F-Area Retention Basin (281-3F)             WSRC-RP-97-145
 Savannah River Site                                                       Revision 1.1
 August 1998	
 Section 300.430 (f)(4)(>i) of the NCP requires that a Five-Year Review of the ROD be performed
 if hazardous substances, pollutants, or contaminants remain in the waste unit.  Since hazardous
 substances will remain on-unit above health-based standards, the United States Department of
 Energy, the United States Environmental Protection Agency, and the South Carolina Department
 of Health and Environmental Control have determined that a Five-Year Review of the ROD for
 the FRB  OU will be  performed to ensure continued protection of  human health  and the
 environment.
                                     Declaration - 6
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Record of Decision for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
                                             WSRC-RP-97-145
                                                   Revision 1-1
Date
 S£P 0 4 1998
T. F. Heenan
Assistant Manager for Environmental Quality
U. S. Department of Energy
Savannah River Operations Office
Date
        fD. Green
 Division Director
 Waste Management Division
 U.S. Environmental Protection Agency
Date
R. Lewis Shaw
Deputy Commissioner
Environmental Quality Control
South Carolina  Department of Health  and  Environmental
Control
                                    Declaration - 7
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                             DECISION SUMMARY
                  REMEDIAL ALTERNATIVE SELECTION (U)
                         F-Area Retention Basin (281-3F)
                               WSRC-RP-97-145
                                  Revision 1.1
                                  August 1998
                              Savannah River Site
                             Aiken, South Carolina
                                  Prepared by:
                      Westinghouse Savannah River Company
                                    for the
             U.S. Department of Energy under Contract DE-AC09-96SR18500
                         Savannah River Operations Office
                              Aiken, South Carolina
10:6«Twp
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  ROD for the F-Area Retention Basin (281-3F)                         WSRC-RP-97-145
  Savannah River Site                                                       Revision 1.1
  August 1998         	                                  Pageiiofvi
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ROD for the F-Area Retention Basin (281-3F)                        WSRC-RP-97-145
Savannah River Site                                                  Revision 1.1
August 1998	Pageiii of vi



                            DECISION SUMMARY

                            TABLE OF CONTENTS


SECTION                                                               PAGE


FIGURES	iv

TABLES	iv

ACRONYMS AND ABBREVIATIONS	v

I.     SAVANNAH RIVER SITE AND OPERABLE UNIT NAME, LOCATION, DESCRIPTION AND
      PROCESS HISTORY.	...	.	.		 1

II.    SITE AND OPERABLE UNIT COMPLIANCE HISTORY			5

ID.    HIGHLIGHTS OF COMMUNITY PARTICIPATION	8

IV.    SCOPE AND ROLE OF THE OPERABLE UNIT WITHIN THE SITE STRATEGY	10

V.    OPERABLE UNIT CHARACTERISTICS	14

VI.    SUMMARY OF OPERABLE UNIT RISKS	21

VH.   REMEDIAL ACTION OBJECTIVES AND DESCRIPTION OF THE CONSIDERED
      ALTERNATIVES FOR THE FRB OPERABLE UNIT	36

VHI.   SUMMARY OF COMPARATIVE ANALYSIS OF THE ALTERNATIVES	58

IX.    THE SELECTED REMEDY	64

X.    STATUTORY DETERMINATIONS	68

XI.    EXPLANATION OF SIGNIFICANT CHANGES	69

XII.   RESPONSIVENESS SUMMARY.-.		......		70

XID.   POST-ROD DOCUMENTS SCHEDULE AND DESCRIPTION		70

XIV.   REFERENCES.......	..	.				73

A i>piri\jT\Y^f A                                                                   i


RESPONSIVENESS SUMMARY		1
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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998	
WSRC-RP-97-145
     Revision 1.1
     Page iv of vi
                                    FIGURES
Figure 1. Location of F Area at the Savannah River Site	2
Figure 2. Topographic Map of the F-Area Retention Basin and Surrounding Area	3
Figure 3. Plan View of the F-Area Retention Basin	4
Figure 4. RCRA/CERCLA Logic and Documentation	12
Figure 5. Revised Conceptual Site Model for the F-Area Retention Basin and Process Sewer
        Line	15
Figure 6. Sampling Locations in and Around the F-Area Retention Basin	16
Figure 7. Distribution of Sr-90 by Depth - FRB Basin Area	30
Figure 8. Distribution of Sr-90 by Depth - FRB Basin Area	31
Figure 9. Distribution of Sr-90 by Depth - FRB Basin Area	32
Figure 10. Distribution of Cs-137 by Depth - FRB Basin Area	33
Figure 11. Distribution of Cs-137 by Depth - FRB Basin Area	34
Figure 12. Distribution of Cs-137 by Depth - FRB Basin Area	35
Figure 13. Low Permeability Cover Cross Section	43
Figure 14. Distribution of Sr-90 by Depth - Depicting the Zone  of High Concentration -
        FRB  Basin  Area  Alternative S5  - Institutional  Controls, Grouting,  Low
        Permeability Cover, and Groundwater Monitoring	47
Figure 15. Distribution of Cs-137 by Depth - Depicting the Zone of High Concentration -
        FRB  Basin  Area  Alternative S5  - Institutional  Controls, Grouting,  Low
        Permeability Cover, and Groundwater Monitoring	48
Figure 16. Backhoe Soil Mixing	50
Figure 17. Jet and Soil Mixing Grouting Techniques	51
Figure 18. Locations of FRB Monitoring Wells and Upgradient Well	53
Figure 19. Location of Potential Trouble Spots	56
Figure 20. FRB Post-ROD Document Schedule	71


                                    TABLES

Table 1. Unit-Specific Constituents Identified for the FRB Source Operable  Unit	19
Table 2. Summary of Risk-Based COPCs, Grouped by Exposure Route	24
Table 3. Contaminants of Concern for  Soil at the FRB Operable Unit with Maximum
        Detected Concentrations and Remedial Goals	27
Table 4. Principal Threat Source Material Contamination at Depth for the  FRB Operable
        Unit with Their Maximum Detected Concentrations	29
TableS. Chemical-Specific Requirements	38
Table 6. Action-Specific Requirements	39
Table 7. Location-Specific Requirements	40
Table 8. Comparative Analysis Summary	60
Table 9. Selected Remedy Cost	66
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ROD for tbe F-Area Retention Basin (281-3F)
Savannah River Site
August 1998         	
WSRC-RP-97-145
     Revision 1.1
      Page v of vi
                      ACRONYMS AND ABBREVIATIONS

ANS        American Nuclear Society
ARAR      Applicable or Relevant and Appropriate Requirement
BRA        Baseline Risk Assessment
CERCLA    Comprehensive Environmental Response, Compensation, and Liability Act
Ci          Curies
COC        Constituent of Concern
COPC      Constituent of Potential Concern
CSM        Conceptual Site Model
DOE        United States Department of Energy
DQO        Data Quality Objectives
EPA        United States Environmental Protection Agency
ERD        Environmental Restoration Department
FFA        Federal Facility Agreement
FRB        F-Area Retention Basin
CMS/FS     Corrective Measures Study/Feasibility Study
ft           foot (feet)
GPR        Ground Penetrating Radar
HI          Hazard Index
HQ         Hazard Quotient
m           meter
MCL        Maximum Contaminant Level
pCi/g        picoCurie per gram
NCP        National Oil and Hazardous Substances Contingency Plan
NEPA       National Environmental Policy Act
NPL        CERCLA National Priorities List
OU         Operable Unit
O&M       Operation and Maintenance
PCR        Post-Construction Report
mCi/g       milHCurie per gram
RAO        Remedial Action Objective
RAWP      Remedial Action Work Plan
RBA        Risk-Based Activity
RBC        Risk-Based Concentration
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 ROD for the F-Area Retention Basin (281-3F)
 Savannah River Site
 August 1998
WSRC-RP-97-145
      Revision 1.1
      Page vi of vi
RCRA       Resource Conservation and Recovery Act
RDR        Remedial Design Report
RDWP      Remedial Design Work Plan
RGO        Remedial Goal Option
RJ          CERCLA Remedial Investigation
RME        Reasonable Maximum Exposure
ROD        Record of Decision
SB/PP       Statement of Basis/Proposed Plan
SCDHEC    South Carolina Department of Health and Environmental Control
SCHWMR   South Carolina Hazardous Waste Management Regulations
SRS         Savannah River  Site
TBC         To-Be-Considered (requirement)
TCLP       Toxicity Characteristic Leaching Procedure
USC         Unit-Specific Constituent
WSRC       Westinghouse Savannah River Company
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 ROD for the F-Area Retention Basin (281-3F)                         WSRC-RP-97-145
 Savannah River Site                                                      Revision 1.1
 August 1998	Page 1 of 74

 I.     SAVANNAH RIVER SITE AND OPERABLE UNIT NAME, LOCATION,
       DESCRIPTION AND PROCESS HISTORY

 Savannah River Site Location, Description, and Process His ton

 The Savannah River Site (SRS) occupies approximately 803 square kilometers (310 square
 miles) of land adjacent to the Savannah River, principally in Aiken and Bamwell counties of
 western South Carolina. SRS is a secured U.S. Government facility with no permanent residents
 and is located approximately 40 kilometers (25 miles) southeast of Augusta, Georgia, and 32
 kilometers (20 miles) south of Aiken, South Carolina (Figure 1).

 SRS is owned by the United States Department of Energy (DOE); Management and operating
 services are currently provided by Westinghouse Savannah River Company (WSRC). SRS has
 historically produced tritium, plutonium, and other special nuclear materials for national  defense
 and the space program. Chemical and radioactive  wastes are by-products of nuclear material
 production processes.

 Operable Unit Name, Location, Description, and Process History

 The Federal  Facility Agreement (WSRC, 1993)  lists the  F-Area Retention Basin (FRB) as a
 Resource  Conservation  and   Recovery  Act/Comprehensive  Environmental   Response,
 Compensation, and Liability Act (RCRA/CERCLA) unit requiring further evaluation using .an
 investigation/assessment process that integrates and combines the RCRA Facility Investigation
(RFI) process with CERCLA Remedial Investigation (RI) to  determine the actual or potential
impact to human health and the environment.

The FRB, designated as Building 281-3F, is located outside and south of the F-Area  perimeter
fence, approximately 1035 m (3397 ft) from Fourmile Branch (Figure 2).  The FRB, with an area
of approximately 0.6 acres (2,400 square meters)  and approximate dimensions of 61 m (200 ft)
 long, 36.6 m (120 ft) wide, and 2.1 m (6.9 ft) deep (Figure 3), was designed and operated as an
unlined, temporary container [capacity approximately 4.68 million liters (1.2 million gallons)]
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ROD for the F-Area Retention Basin (281-3F)
Savannab River Site
August 1998
WSRC-RP-97-145
      Revision 1.1
      Page 2 of 74
Figure 1.   Location of F Area at the Savannah River Site
           SOUTH
          CAROLINA
                     GEORGIA

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 ROD for the F-Area Retention Basin (281-3F)
 Savannah River Site
 August 1998
WSRC-RP-97-145
      Revision 1.1
      Page 3 of 74
 Figure 2.   Topographic Map of the F-Area Retention Basin  and Surrounding
            Area
                                                 SCALE MFST
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                                                                                                                             u
         Area Covered by vegetation


         Areas within F-Area fence

      ** Stream


FET-4D  Existing groundwater monitoring well
                                                           FRB-03
                                                             •   Sample Location
                                                            o    Manhole Location

                                                            	Process Sewer


                                                                 Ground surface elevation and contour
0    100  200   300   400  500

         _:••—
         Scale In feet
                                           > %#

                                          1    §
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                                           »-> w  n
                                           VO EJ" .—

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                                          O  D

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                        Revision 1.1
 August 1998	PageS of 74

 for potentially contaminated  cooling water from the F-Area Canyon Facility and stormwater
 drainage from the F-Area Tank Farm.  Water was conveyed to the basin by a process sewer line
 (approximately 168 m (550 ft) of 61-cm (24-inch) diameter and approximately 212m (700 ft) of
 91 cm (36-inch) diameter that discharged into the north side of the basin. One branch of the line
 conveyed water from the Canyon Facility and the other branch conveyed water from the Tank
 Farm. Cooling water from the Canyon Facility generally had low levels of radioactivity, while
 water from the Tank Farm is believed to have  had only trace quantities of nonradionuclide
 chemicals. The quantities of water released to the retention basin and the  level of various
 constituents contained within the water are unknown.

 The FRB is currently an inactive basin filled with clean soil and covered with grass. The FRB
 and its surrounding  area lies at  an elevation of approximately 275 ft above mean sea level.
 Surface  water runoff drains  southeast to Fourmile Branch via  an unnamed drainage ditch
 (tributary) and overland flow.

 II.    SITE AND OPERABLE UNIT COMPLIANCE HISTORY

 SRS Operational History

The primary mission of SRS was to  produce tritium (3H), plutonium-239 (239Pu),  and other
special nuclear materials for our nation's defense programs. Production of nuclear materials for
the defense programs was discontinued in 1988.  SRS has provided nuclear materials for the
space program,  as  well as for medical,  industrial, and  research  efforts up  to  the present.
Chemical and radioactive wastes are  by-products  of nuclear material  production processes.
These wastes have been treated, stored,  and in some cases, disposed at SRS.  Past disposal
practices have resulted in soil and groundwater contamination.

SRS Compliance History

Waste materials handled at SRS are regulated and managed under RCRA, a comprehensive law
requiring responsible management of hazardous waste.   Certain SRS activities have required
federal operating or post-closure permits under RCRA.  SRS received a hazardous waste permit
from the South Carolina Department of Health and Environmental  Control (SCDHEC). The
permit was most recently renewed on September 5,  1995.  Part TV of the permit mandates that
SRS  establish and implement an RFI Program to fulfill the requirements specified in Section
3004(u) of the federal permit.
I026crwp doc JSB/blb 09/22/91

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 ROD for the F-Area Retention Basin (281-3F)                         WSRC-RP-97-145
 Savannah River Site                                                       Revision 1.1
 August 1998	Page 6 of 74
 On December 21, 1989, SRS was included on the National Priorities List (NPL). This inclusion
 created a  need  to  integrate  the RFI  Program  established  under RCRA  with CERCLA
 requirements to provide for a focused environmental program. In accordance with Section 120 of
 CERCLA, DOE has  negotiated an FFA (1993) with the United States Environmental Protection
 Agency (EPA)  and  the South Carolina Department  of  Health and  Environmental Control
 (SCDHEC) to coordinate remedial activities at SRS with one comprehensive strategy that fulfills
 these dual regulatory requirements.

 Operable Unit History

 The F-Area Retention Basin (FRB) includes the retention basin and the abandoned process sewer
 line associated with  the basin. The history  of the FRB  prior to characterization  activities is
 briefly described.

 F-Area Retention Basin

 The basin  operated  from 1955 until 1972 and was closed  in December 1978. This closure
 included the following activities:
 •      Sampling soil at four locations in the bottom of the retention basin
 •      Excavating approximately 0.6 m (2 ft) of soil from within the basin
 •      Sampling soil from 53 locations from the bottom  excavation and basin berm
 •      Removing and transporting a total of 970 m3 (1267 yd3) of contaminated soil to Burial
       Grounds (Building 643-G) for disposal
 •      Backfilling the basin with clean soil and seeding the area with grass

 Excavation of soil from the bottom of the  basin greatly reduced the level  of radiological
contamination at the  basin. The maximum levels of cesium-137 (Cs-137) and strontium-89/90
(Sr-89/90) detected in basin soils prior to  excavation  were  80,600 picoCuries per gram (pCi/g)
and 1540 pCi/g, respectively. The transferred radionuclide inventory was calculated as 11.5 Ci
of Cs-137  and 0.5 Ci of Sr-89/90.  Following excavation, the maximum  levels of Cs-137
detected in FRB soils were  430  pCi/g in the basin and  1410  pCi/g  in the berm while the
maximum concentrations of Sr-89/90 were 1700 pCi/g in the basin and 1000 pCi/g in the berm.
l026crwp.ikic.JSB/blb OW22/91

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ROD for the F-Area Retention Basin (281-3F)                         WSRC-RP-97-145
Savannah River Site                                                       Revision 1.1
August 1998	Page 7 of 74
Process Sewer Line
A portion of the process sewer line extending north from the basin was aba idoned at the same
time the basin was closed. The branch of the line from the Tank Farm approximately 168 m (550
ft) of 61-cm (24-inch diameter) was sealed off at a point close to manhole P37 (see  Figure 6).
The wastewater coming from the Tank Farm was diverted by installing a sluice box to Building
281-9F. The branch of the line from the Canyon Facility approximately 212m (700 ft) of 91-cm
(36-inch  diameter) was sealed off at manhole P40 (see Figure 6). The abandoned portion of the
process sewer line north of the basin and outlet pipe located south of the basin (total length
approximately 380 m (1250 ft) is a part of this unit. The process sewer line north of manholes
P37 and P40 is still active and is not included in this unit.

The depth to the top of the abandoned process sewer line varies from less than 1 m (3ft) near the
original location of the basin to 4.6m (15 ft) for the segment from P40 to P39.  There are several
access points to the abandoned process sewer line (see Figure 6).  Two of the four access points
(P39 and one unnumbered manhole) are standard manholes constructed of brick.  Access point
P38 is a nonstandard manhole constructed of poured concrete walls and floor.  The final access
point  is a valve/junction box located just downstream from manhole P39.  The purpose of this
junction box was to regulate the amount of liquid released to the retention basin during normal
operation.

Drainage Ditch
The FRB was designed to  discharge its contents through  an  outlet into a ditch  naturally
connected with an unnamed  tributary discharging into Fourmile Branch. However, the remedial
investigations.conducted.4B-jfe5pc«ae,tCuS,RS'  established  cleanup program revealed  that the
outfall ditch  and the unnamed tributary to Fourmile Branch  were not impacted  by FRB
operations; therefore, they are not considered for cleanup operations under this remedial action.

Operable Unit Compliance History

As  previously stated, the FRB OU is listed in the FFA as a RCRA/CERCLA unit  requiring
further evaluation to  determine the actual or potential  impact  to  human  health and the
environment. A Remedial  Investigation (RI)  and Baseline  Risk  Assessment (BRA)  were
conducted for the unit between 1995 and  1997. The results of the RJ and BRA were presented in
the RJ/BRA report (WSRC, 1997b). The RI/BRA report was submitted in accordance with the
FFA-approved implementation  schedule and was  approved by  the  EPA and SCDHEC in

1OJ*er»p doc JSB/blb 09/22/9*

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 ROD for the F-Arca Retention Basin (281-3F)                         WSRC-RP-97-145
 Savannah River Site                                                      Revision 1.1
 August 1998	Page 8 of 74
 October 1997. The Corrective Measures Study/Feasibility Study (CMS/FS) (WSRC, 1997c) and
 Statement of Basis/Proposed Plan (SB/PP) (WSRC,  1997d) were submitted in accordance with
 the FFA-approved implementation schedule and were approved  by EP.\ and  SCDHEC in
 December 1997.

 The post-ROD documents include Corrective Measures Implementation/Remedial  Design Work
 Plan (CMI/RDWP) and Corrective Measures  Implementation/Remedial Design Report/Remedial
 Action Work Plan (CMI/RDR/RAWP). In accordance with the FFA-approved implementation
 schedule, the Rev. 0 CMI/RDWP and Rev. 0, CMI/RDR/RAWP will be submitted to EPA and
 SCDHEC for approval. The Field Start Date for the implementation of the remedial action is
 scheduled for April 4, 1999.

 III.    HIGHLIGHTS OF COMMUNITY  PARTICIPATION

 Both RCRA  and  CERCLA require that the public  be given  an  opportunity to review  and
 comment on the proposed remedial alternative. Public participation requirements are listed in
 South  Carolina Hazardous Waste Management Regulations (SCHWMR) R.61-79.124  and
 Sections  113  and  117  of  CERCLA.  These  requirements  include establishment  of  an
 Administrative Record File that documents the investigation  and  selection of  the remedial
 alternatives for addressing the FRB OU soils and groundwater. The Administrative Record File
 must be established at or near the facility at issue. The SRS Public Involvement Plan (DOE,
 1994a) is designed to facilitate public involvement in the decision-making process for permitting,
closure, and the selection of remedial alternatives. The SRS Public Involvement Plan addresses
the requirements of RCRA, CERCLA and the National Environmental Policy Act, 1969 (NEPA).

The South Carolina Hazardous Waste Management Regulations (SCHWMR) R.61-79.124 and
Section 117(a) of CERCLA, as amended,  requires  the advertisement of the notice  of any
proposed remedial action and mandates that the public be given an opportunity to participate in
the selection of the remedial action. The Statement of Basis/Proposed Plan for the  F-Area
Retention Basin (281-3F) (WSRC, 1997d), which is a part of the Administrative  Record File,
highlights key aspects of the investigation and identifies the preferred action for remediating the
FRBOU.

The FFA Administrative Record File, which contains the information pertaining to the selection
of the response action, is available at the EPA office and at the following locations:
I026crwp docJSB/blb 0902/91

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                       Revision 1.1
 August 1998	Page 9 of 74

 U. S. Department of Energy
 Public Reading Room
 Gregg-Graniteville Library
 University of South Carolina-Aiken
 171 University Parkway
 Aiken, South Carolina 29801
 (803)641-3465

 Thomas Cooper Library
 Government Documents Department
 University of South Carolina
 Columbia, South Carolina 29208
 (803) 777-4866
 Reese Library
 Augusta State University
 2500 Walton Way
 Augusta, Georgia 30910
 (706)737-1744

 Asa H. Gordon Library
 Savannah State College
 Tompkins Road
 Savannah, Georgia 31404
 (912)356-2183


 The  public  was  notified  of the public  comment  period  through mailings  of the SRS

 Environmental Bulletin—a newsletter sent to approximately 3500 citizens in South Carolina and

 Georgia—and through notices in the Aiken Standard, the Allendale Citizen Leader, the Augusta

 Chronicle, the Barn-well People-Sentinel, and the State newspapers. The public comment period
 was also announced on local radio stations.


 The 45-day public comment period began January 20,  1998, and ended on March 5, 1998.  A

public briefing was provided in the CAB subcommittee meeting on February 23,  1998.   In the

meeting, SRS briefed the public regarding the path forward for the remediation of FRB.  At the

meeting, a concern was raised over the need to grout the contaminated soil in addition to capping

 the basin soil. Consequently, an extension for the public comment period was granted, extending

 the period to April 4,  1998. A formal public comment was also received  which questioned the

risk reduction and necessity of soil grouting. CAB recommendation No. 56 (Appendix A) was

also received on March 28, 1998. The SRS response to this concern is provided with this ROD

in the Responsiveness Summary (Appendix A). It will also be available  with the final  RCRA

permit. The response to public comment and CAB recommendation has been  accepted by EPA
 and SCDHEC.
I0]0cn»p doc JSaWb O)HV9t

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ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
Savannah River Site                                                        Revision 1.1
August 1998	Page 10 of 74
IV.    SCOPE AND ROLE OF THE OPERABLE UNIT WITHIN THE SITE
       STRATEGY

RCRA/CERCLA Programs at SRS
RCRA/CERCLA units  (including  the  FRB) at  SRS  are  subject  to a multi-stage remedial
investigation process that integrates the requirements of RCRA and CERCLA as outlined in the
RFI/RI Program Plan (WSRC, 1993b).  The RCRA/CERCLA process summarized in Figure 4
consists of investigation and characterization of potentially impacted environmental media (such
as soil, groundwater, and surface water) comprising the waste unit and surrounding areas; the
evaluation of risk to human health and the local ecological community; the screening of possible
remedial actions to  identify the selected technology which will protect human health and the
environment; implementation of the selected alternative; documentation that the remediation has
been performed competently; and evaluation of the effectiveness of the technology. The steps of
this process are iterative  in nature and  include decision  points which involve concurrence
between the DOE (as owner/manager), the EPA and SCDHEC (as regulatory oversight), and the
public. The RCRA/CERCLA process was used for the characterization of the FRB OU, and for
developing the remedial alternatives and finally selecting the remedial action.

F-Area Retention Basin (281-3F) Remedial Strategy

The FRB OU includes the retention basin (basin soils), the former process server line (pipeline,
pipeline sediment, and pipeline associated soils), and groundwater associated with the unit. The
F-Area Retention Basin is located within the Fourmile Branch Watershed (see Figure 1). Several
source control  and  groundwater operable units  within this watershed will be evaluated  to
determine future impacts, if any, to the associated streams and wetlands.  It is the intent of SRS,
EPA, and SCDHEC  to manage these sources contamination to minimize impact to the watershed.

Presently, based on the characterization and risk assessment  information, the  FRB OU does not
significantly impact  the watershed. The investigation and sampling for the FRB OU considered
all unit specific groundwater. Based on the results of the investigation of the groundwater, the
contamination in the water table aquifer is not attributable to the wastes associated with FRB
OU.   Upon disposition  of all  the source control and groundwater operable units  within this
watershed, a final, comprehensive evaluation of the watershed will  be conducted to determine
whether any additional actions are necessary.
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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah  River Site                                                        Revision 1.1
 August 1998                 	Page 11 of 74
 The preliminary investigation conducted for the FRB  OU identified two primary sources of
 contamination:  (1) the former basin; and (2) the process sewer line leading from the F-Area
 Canyon Facility and the F-Area Tank Farm  to the  FRB.  To characterize the FRB OU  and to
 identify the primary sources  of  contamination and primary contaminated media, numerous
 environmental  investigations  were conducted  at  the  unit  between  1993 and   1997.   The
 Groundwater Sampling Report with Residential Risk Assessment for the F-Area Retention Basin
 (WSRC, 1997a) and the Remedial Investigation with the Baseline Risk Assessment Report for the
 F-Area Retention Basin  (WSRC,  1997b) contain detailed  analytical  data   for   all  the
 environmental media samples taken in the characterization of the FRB OU. These reports are
 part of the  Administrative Record File (see Section III).  The primary media of contamination
 determined included  soils associated with the former basin area primarily the subsurface soils
 (deeper than  1.2 m [4 ft]); the surface [0-0.6 m (0-4 ft)  and subsurface soils associated with
 process sewer line area; and sediment within  the sewer pipeline.  Only human health COCs (i.e.,
 Cs-137, Ra-226, K-40, thallium) were identified in  the surface soil and only one CMCOC (Sr-
 90) was identified  in the subsurface soil.  Radionuclide contaminants in subsurface soil (deep
 soils, 6-14  feet) represent a principal threat source material (i.e., highly  toxic or highly mobile
 contaminants which would present a significant risk to human health or the environment should
 exposure occur). No COCs associated with FRB OU were identified for the groundwater. To
 address the remediation of FRB OU soils, various potential remedial alternatives were developed
 and  evaluated.   After  evaluation, the alternatives  S5 and P4 were selected as the preferred
 remedies for FRB OU soils and sewer pipeline, respectively. For the groundwater, no action was
 selected as  the preferred remedy.  However,  groundwater monitoring is included as an integral
 part  of S5  alternative  to monitor the effectiveness  of the remedial action against any  future
 leaching of Sr-90;  to mitigate any uncertainty in the environmental data collected during the
 investigations; and  to confirm that there are no upgradient sources to the  FRB OU groundwater.
In the  event, monitoring detects contamination above MCLs (or RBCs) for those  constituents
attributable to  the FRB OU or an unknown upgradient source, for two consecutive monitoring
periods, the regulators will be informed  within  30 days.   A plan for evaluating the data  and
developing  further  action will be  submitted within  90 days for regulatory approval. The plan
 will  also include a schedule  for assessing the need for corrective action and  a schedule for
developing  the specifics for that corrective action.

The preferred remedies meet the remedial action objectives of the remedial actions, as described
 in Section VII of the ROD, for the  former basin area  soil and groundwater as well as the soils
I026cn>p 
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 ROD for the F-Area Retention Basin (281-3F)
 Savannah River Site
 August 1998	^^
          WSRC-RP-97-145
                 Revision 1.1
                Page 12 of 74
 Figure 4.    RCRA/CERCLA Logic and Documentation
SRS RCRA/CERCLA UNIT L
1
r
                       PRELIMINARY EVALUATION

                      •Unit Reconnaissance
                      •Unit Screening
                              RFI/RJ WORK PLAN

                   • Develop Conceptual Site Model CSM
                   • Identify Data Needs
                   • Develop Data Quality Objectives and
                     Decision Logic
                   • Detailed Sampling and Analysis Plan
                                     I
                   UNIT/SITE CHARACTERIZATION

                   • Implement RFI/R1
                   • Data Evaluation Vs. DQOs
                   • Re-Evaluate CSM
                                Characterization
                                  Complete?
  Additional
Characterization
                                                                    Characterization
                                                                      Complete?
1026crwp.doc. JSB/blb 09/tt/Vt

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998      	
             WSRC-RP-97-145
                   Revision 1.1
                  Page 13 of 74
Figure 4. (Cont'd). RCRA/CERCLA Logic and Documentation
       Treatability Studies
         (as necessary)
   RFI/RJ REPORT

Establish  Remedial  Action
Objectives
    NO ACTION REMEDY
  Baseline Risk Assessment

• Determine Unit Risk
• Develop RGs

                                   CMS/FS REPORT

                               Identify Response Actions
                               Identify Technologies
                               Alternatives Development
                               Alternatives Screening
                               Detailed Analysis
                                     SB/PP

                               Preferred Alternative
                               Draft Permit Modification
                               Public Comment

                                RECORD OF DECISION

                                Select Remedy
                                Responsiveness Summary
                                Final Permit Modification
                               CORRECTIVE MEASURE/
                                REMEDIAL ACTION

                             • Unit closure
                             • Post Closure Documentation
                               (Post Construction Report)
     POST ROD
  DOCUMENTATION

• Remedial Design
  Work Plan/Report
• Remedial action
  Work Plan/Report
I026crwp doc:JSB/blb 09/IJ/9*

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ROD for the F-Area Retention Basin (281-3F)                         WSRC-RP-97-145
Savannah River Site                                                      Revision 1.1
August 1998	Page 14 of 74
associated  with the  process sewer line  area and significantly contribute toward  the  overall
protection of the groundwater as a resource.

V.     OPERABLE UNIT CHARACTERISTICS

Media Assessment
The primary sources of contamination associated with the FRB OU are the former basin and
abandoned process sewer line.  A Conceptual Site Model (CSM) (Figure 5) was developed for
both the basin and the process sewer line to identify the primary sources, primary contaminated
media, migration pathways, exposure pathways, and potential receptors for FRB OU.  The
detailed analytical data for all the environmental media samples taken in the characterization of
the FRB OU are contained in two reports: The Remedial Investigation with the Baseline Risk
Assessment Report for  the F-Area Retention  Basin (U) (WSRC  1997a); and Groundwater
Sampling Report with  Residential Risk Assessment for  the F-Area Retention Basin (WSRC
1997a). The documents are available in the Administrative Record File (see Section III).

The primary  data  used for the  RJ/BRA  report  was  collected during the  environmental
investigations  conducted at the unit between 1993 and 1995.  These investigations included a
soil-gas survey, soil sampling,  groundwater sampling, and field measurement of radionuclides.
Also, two horizontal bore holes were drilled and monitored for radionuclides in real-time using
Environmental-Measurement-While-Drilling Gamma Ray Spectrometer System Technology.

Surface and subsurface soil samples  were collected in the area  of the former basin,  in the
adjacent basin overflow area, and in the area along the abandoned process sewer line. Samples
were also collected from residual water and sediments in the  sewer pipeline. Figure 6 shows
sampling locations in and around the F-Area Retention Basin.  All samples  were  analyzed  in
accordance  with  EPA-approved protocols.   Results  of the  environment investigation and
subsequent analysis indicate the following:

•   Groundwater quality has not been adversely affected at this site
102«xrwp doc JSB/blb 09/U/VI

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
VVSRC-RP-97-145
      Revision 1.1
     Page 15 of 74
Figun
? 5. Revised Conceptual Site Model for the F-Area Retention Basin and Process Sewer Line
PRIMARY
PRIMARY RELEASE
SOURCE MKCHANISM


Overtopping
Former A
»""» * F.r«k,n
Area

, "1
i
1
f
Proctii *• Infiltration*
Scner I'mutorlot:
Line
1
1

! i _^
i
i
L 	 _

1 WFNII
SECONDARY
SECONDARY RELEASE PATHWAY
SOURCE MECHANISM (Media)

HI Air
VoblUhalkin !_•. _»_

.
Generation < Participates)
1 	 1
Sulk Direct Contact

EXPOSURE
KOUIE
I'OI KMIAI. HUMAN KECEI'lOR
Ciinsirncllon
Worker
Industrial
Worker
Oii-tlnlf
Resident

KKk
Driver

Inhalation
NA
NA
NA


Inhalation
 Direct Contact
NA
NA
IE-S
Cs-137, K-40

digestion
Dermal Contact
. Kllcrnal Radiation
NA
NA
NA
NA
NA
NA
NA
NA
NA




digestion
Inhalation
Dermal COMJCI
Eilcrnal Radiation
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA





digestion
Inhalation
Dermal Contact
NA
NA
NA
MCI.
> Ucnudlul (iiuU
NA
NA
NA
(VIJ7. ('U-2JW24U



IUIIderwpdocJSfVblh09/18/98

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998                	
WSRC-RP-97-145
      Revision 1.1
     Page 16 of 74
Figure 6.   Sampling Locations in and Around the F-Area Retention Basin
                                                                                        D—UI.O
                                                                                        «tllMUXIl
                                                                                          I/
         tb 0*71/71

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 ROD for the F-Area Retention Basin (281-3F)                           WSRC-RP-97-145
 Savannah River Site                                                         Revision 1.1
 August 1998	Page 17 of 74

 •   Levels of Sr-90 in soil beneath the basin represent a risk that future contaminant migration
    could result in contamination of the groundwater

 •   Levels of contaminants (example Sr-90 and Cs-137) at depth represent principal threat source
    material (i.e., highly toxic or highly mobile contaminants that would present a significant risk
    to human health or the environment should exposure occur).

 •   Levels of the  remaining radioactive and non-radioactive contaminants  in soil beneath the
    basin do  not represent a risk that future contaminant migration could result in contamination
    of the groundwater

 •   Levels of several contaminants (e.g., Cs-137)  in  surface  soil represent a potential risk to
    human health

 •   Levels of contamination in the surface soil and beneath the basin do not represent a risk to
    ecological receptors

 Nature and Extent of Contamination

 The CSM was developed for two primary sources: (1)  the former basin area; and (2) the process
 sewer line area. The CSM also identified primary as well as secondary release mechanisms for
 both sources.

During characterization, primary contamination sources and  release mechanisms were also
 identified using CSM.  The results of the investigations and CSM are summarized below.

 Primary Sources and  Release Mechanisms

The primary  release   mechanisms  for contamination  from  the  former  basin  area  are
infiltration/percolation  of contaminants to groundwater and overflow of the basin. The overflow
of the basin  could result in the discharge of contaminants to  surface soils and to the nearby
drainage  ditch. The sole  primary release  mechanism identified by CSM for  contaminants
associated with the process sewer line area is the escape of contaminants through defects in the
line, followed by percolation of contaminated water to the groundwater.
IOIMn»p doc JSB/blb 0942/91

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                        Revision 1.1
 August 1998	Page 18 of 74
 Secondary Sources and Release Mechanisms

 The CSM identified surface soil and subsurface  soil  (deep soil) in the basin and around  the
 perimeter of the basin as secondary sources for the former basin area.  The surface soil and
 subsurface soil  (deep  soil) along the abandoned process sewer line  were also  identified as
 secondary sources for the abandoned process sewer line. The sediment in the process sewer line
 is an additional secondary source for the process sewer line.

The secondary release mechanisms for the basin surface soil included volatilization, fugitive dust
generation,  biotic  uptake, and runoff.   Leaching  was  identified as the  secondary  release
mechanism for subsurface soils.  The secondary release mechanisms for the process sewer line
included volatilization, fugitive dust generation and biota uptake for surface soil and leaching for
the subsurface soils.  No secondary release mechanism was identified for the sediment in  the
process sewer line.

Unit Specific Constituents

Constituent concentrations found in soil, groundwater, and surface water were compared against
twice the background concentrations. The groundwater concentrations were compared with EPA
primary Drinking Water Standards (i.e., MCLs) or twice the mean background concentrations,
where no MCL exists.  Unit constituents that exceeded twice the background concentration were
considered Unit-Specific Constituents (USCs). These USCs were used to define the nature and
extent of contamination at the unit and were evaluated in detail in the RI/BRA report to reflect
risk to human health or the environment.  Table 1 contains the list of USCs identified for the
FRB source OU.  These include 7 inorganics, 16 organics, and 22 radionuclides.

Former Basin Area

USCs were detected in subsurface soils within the former basin area.   The metals arsenic and
beryllium  and   several   radiological  parameters  exceeded   maximum   screening   level
concentrations. Primarily, Cesium-137 and  Strontium-90 were the radiological parameters with
the  highest detected concentrations.  Their concentrations  exceeded twice the background
concentrations by factors of 38,000 and 2,570, respectively.  Europium-154 also exceeded the
maximum  screening level  concentration  for deep soils.  Beryllium slightly  exceeded  its
maximum screening level in one surface soil sample.  Cesium-137 and Radium-226 (a naturally
occurring isotope) slightly exceeded their maximum screening levels in several surface and
I026«wp doc ISB/Mb 09/22/Vt

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ROD for tbe F-Area Retention Basin (281-3F)
Savannah River Site
August 1998                     	
                                      WSRC-RP-97-145
                                            Revision 1.1
                                           Page 19 of 74
Table 1.    Unit-Specific Constituents Identified for the FRB Source Operable Unit
        Inorganics
       Organics
  Radionurlides
          Arsenic
          Barium
         Beryllium
         Chromium
           Lead
          Nickel
         Thallium
       Acetone
    Carbon disulfide
    2-Chlorophenol
     Dibenzofuran
   1,1-Dichloroethane
   Dichloromethane
  Di-n-butyl phthalate
     Ethylbenzene
  Methyl ethyl ketone
N-Nitrosodiphenylamine
       Styrene
   Tetrachloroethene
       Toluene
   Trichloroethylene
Trichlorofluoromethane
       Xylenes
  Actini'\n-228
  Americium-241
    Carbon-14
   Cesium-137
    Cobalt-57
    Cobalt-60
  Europium-154
  Europium-155
    Lead-212
    Nickel-63
  Plutonium-238
Plutonium-23 9/240
  Potassium-40
 Promethium-147
   Radium-226
   Sodium-22
  Srrontium-90
  Technetium-99
  Thorium-234
Uranium-233/234
  Uranium-235
  Uranium-238
1026crwp doc JSB/Wb M/22/9!

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                        Revision 1.1
 August 1998	Page 20 of 74

 shallow subsurface soil samples taken in the basin area.  USCs were also identified in surface
 soils and shallow subsurface soils within the former basin area. However, 'hese USCs are not
 associated with operation of the basin since the former basin was backfilled in 1978 with clean
 soil. Hence, only USCs identified in subsurface soils could be attributable to past operations.

 USCs  were also detected in  soils  adjacent to the former basin (overflow area).  Beryllium,
 Cesium-137, Thallium, Radium-226, and Plutonium 239/240 were detected and exceeded twice
 the background levels.  These detections, however, closely matched the detected levels in the
 background borings and did not exhibit any discernible pattern of contamination.  Therefore, the
 soils in the basin overflow area  do not appear  to have been adversely impacted  by  basin
 overflow.

Process Sewer Line Area

 USCs  were detected in residual water in the abandoned process  sewer line and manholes.
 Primarily, Cesium-137  and Strontium-90 were the radiological parameters  with  the  highest
detected concentrations. Cesium-137 exceeded its maximum screening level concentration by a
 factor  of 327 while Strontium-90 exceeded its maximum screening  level concentration by a
 factor  of 94.4.  These  were also the largest margins by which the maximum screening level
concentrations were exceeded.

USCs were detected in residual sediments in the abandoned process sewer line. The inorganic
constituents Arsenic and Beryllium exceeded their maximum  screening level  concentrations.
Cesium-137, Strontium-90, and Plutonium-239/240 were the radiological  parameters with the
highest detected concentrations that exceeded their maximum screening level concentrations.

The concentrations exceeded their twice background levels by factors of 24,600, 118, and 86.3,
respectively.

USCs  were detected in soils  adjacent to the abandoned  process  sewer line.  Arsenic  and
Beryllium  were   the  inorganic  constituents  that   exceeded  maximum  screening   level
concentrations.    The   radiological parameters  that  exceeded maximum  screening  level
concentrations were Cesium-137 and Strontium-90.  Their maximum concentrations occurred in
deep samples  and exceeded  their  twice  background levels  by factors  of 368 and 51.9,
respectively.
I026crwp doc. JSBWb 09/22/91

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ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
Savannah  River Site                                                       Revision 1.1
August 1998	Page 21 of 74
Groundwater

The only  contaminant  detected (a single  delect) in groundwater  was trichloroethylene  at
sampling location FRB-2 (see Figure 6), but it was also detected in the background well.  This
could indicate that the trichloroethylene originated from an area hydraulically upgradient from

the site, particularly since a trichloroethylene source was not found in the soil.  Metals other than
common cations were not detected  consistently.   Only one radiological analyte was  detected
above twice background concentrations, and only in one round of sampling. However, based  on
the data collected in January 1997 and February 1997, activities associated with the former basin
do not appear to have impacted the groundwater.

Groundwater Transport Analysis

In response to a recommendation from the Citizens Advisory Board (CAB), transport modeling
was performed for the most prevalent  radioactive constituents (e.g., Sr-90 and Cs-137).  This
analysis was performed using RESRAD modeling for leachability of contaminants.  Results  of
this analysis indicate that only Sr-90 is predicted to reach the groundwater at levels which exceed
relevant  standards.  This analysis supersedes overly conservative calculations  reported in the
RFI/BRA which indicated that  TC-99 and Sr-90 could potentially contaminate groundwater.
However, the remedy to stabilize the Sr-90 will also reduce the mobility of Tc-99 and the other
radioactive contaminants present in the soil.

VI.    SUMMARY OF OPERABLE  UNIT RISKS
As part of  the F-Area Retention Basin RFI/RI process, a baseline risk assessment (BRA) was
prepared to evaluate the potential risk to human health  and the environment from chemical and
radioactive contaminants identified in investigations at the FRB. The following sections outline
the results  of the human health and ecological risk characterizations conducted as  part of the
assessment. A complete discussion of the risk assessment methodology, receptor analysis, risk
characterizations, and uncertainty within the characterizations can be found in the Groundwater
Sampling Report with Residential Risk Assessment for the F-Area Retention Basin  (WSRC,
1997a) and the Remedial Investigation with the Baseline Risk Assessment Report for the F-Area
Retention Basin (WSRC, 1997b).

Unit-specific data from the RFI/RI were used to identify  and screen constituents of potential
concern (COPCs). Exposure point concentrations were calculated and used to estimate potential
l02Mrwp
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 exposures and risks to humans and wildlife. Carcinogenic risks and hazard indices (His), based
 on a combination of exposure scenarios, locations, and receptors identified in the CSM, were
 calculated and then compared to EPA risk guidelines [i.e., 1 x  10"4 to  1 x 10"6 carcinogenic risk,
 HI > 1,  and ecological effects  quotient (EEQ) > 1]. COPCs were screened and identified as
 preliminary COCs (PCOCs) and designated  as  primary  or  secondary COCs, based  on their
 individual contribution to total media risk or hazard.

 Human Health Risk Assessment
 To evaluate the risk to human receptors due to the contamination at the FRB, unit-specific
 analytical data are used to identify  COPCs. Exposure point concentrations are determined  for
 each COPC to estimate the potential exposure  for various receptors and exposure scenarios. The
 current land use scenario is inactive industrial use and an infrequent on-unit visitor (researcher or
 sampler) was postulated but quantitative risks were not determined for this receptor because SRS
 programs and procedures  are  implemented  to  protect  workers from  harmful  exposure to
 contaminants at waste units. Receptors for the future land use exposure scenario identified for the
 former basin area included an on-unit industrial worker and  an  on-unit resident (adult/child).
 Receptors identified  for  future land use at the  process sewer  line area included an on-unit
 industrial worker, an on-unit  resident  (adult/child),  and  an  on-unit  construction  worker
 (Figure 5).

 Following the selection  of human  receptors  for evaluation, the carcinogenic  risks  and the
 noncarcinogenic health hazards were estimated for each COPC and for each pathway/receptor
 combination based on EPA guidance (EPA, 1989b).

 Carcinogenic risk is  defined as  the incremental probability of an individual developing cancer
over a lifetime as a result of pathway-specific exposure to cancer-causing contaminants. The risk
to an individual resulting from exposure to non-radioactive chemical carcinogens is expressed as
 the increased probability of cancer occurring over the course of a 70-year lifetime.  At Superfund
 sites incremental risk from carcinogens is compared to the EPA target risk range of one in ten
 thousand (1 x 10"4) to one in one million (Ix 10"6).

 Noncarcinogenic hazards are also evaluated to identify a level at which there may be concern for
potential noncarcinogenic health effects. The  hazard quotient (HQ), which is the ratio of the
 exposure dose to the  reference dose, is calculated for each contaminant. HQs are summed for
 each exposure pathway to determine the specific HI for each exposure scenario. If the HI  exceeds
 unity (1.0), there is the potential for adverse health hazards.

 I02MTW? doc JSB/blb 09/U/9I

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 ROD for the F-Area Retention Basin (281-3F)                           WSRC-RP-97-145
 Savannah River Site                                                         Revision 1.1
 August 1998	Page 23 of 74
 Former Basin Area

 Future Land Use Carcinogenic Risks

 The future on-unit industrial worker has three exposure routes with carcinogenic risks within the
 target range of 1  x 10^ to 1 x 10"* (Table 2). External radiation exposure to surface soil has a nsk
 of 2 x 10"5 primarily due to Cs-137 and Ra-226. Ingestion of subsurface soil has a risk of 2 x 10 6
 primarily due to arsenic. External radiation  exposure to subsurface soil has a risk of 9 \ 10"
 primarily due to Cs-137 and Ra-226. The risks for the future worker from all other pathways are
 less than the EPA action level (1 x 10'*).

 Several pathways for the future on-unit resident have estimated risks within the target range
 (Table 2). External exposure to radionuclides in surface soil has a risk of 2 x 10"4 primarily due to
 Cs-137, K-40, and Ra-226. Ingestion  of produce grown on  surface soil has a risk of 1 x 105
primarily due to plant uptake of Cs-137 and K-40. Exposure  to subsurface soil has a risk of
 8x 10"6 from ingestion primarily due to arsenic, Pu-239/240,  Ra-226,  and  Cs-137. External
 exposure to radionuclides in subsurface soil  has a risk of 8 x 10"5 primarily due to Cs-137 and
Ra-226. Ingestion of produce grown on  subsurface soil  has a risk of 5 x 10'* primarily due to
plant uptake of Cs-137 and K-40. RESRAD modeling indicates that the MCL for Sr-90 (8 pCi/L)
will be exceeded by leaching from deep soils (>4 feet deep) with the peak concentration of 79
 pCi/L reached in 76 years (E7 Calc Note reference).

Nonbarcinogenic Hazards

The BRA shows that potential adverse noncarcinogenic health effects are not likely to occur for
the future on-unit worker because the sum of His for all pathways evaluated is less than the value
of 1.0 (Table 2).

The His for hypothetical future resident exposures equal or exceed  1.0 for the ingestion of
surface soil (0-1  foot) and  subsurface  soil (0-4 feet) (Table 2).  The HI for ingestion  of  surface
soil equals 1 and is primarily the result of thallium. The HI for ingestion of subsurface soil equals
2 and is primarily the result of thallium and arsenic.
I026crwp doc JSB/blb 09/22/91

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ROD for the F-Area Retention Basin (281-3F)
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August 1998                      	
WSRC-RP-97-145
      Revision  1.1
     Page 24 of 74
Table 2.     Summary of Risk-Based COPCs, Grouped by Exposure Route
Receptor *
Former Basin Area
Hypothetical Future
Worker
Hypothetical Future
Resident
Process Sewer Line
Area
Hypothetical Future
Worker
Hypothetical Future
Construction Worker
Hypothetical Future
Resident
Exposure Route/Medium
External Radiation /
Surface Soil
External Radiation /
Subsurface Soil
Ingestion / Subsurface Soil
External Radiation /
Surface Soil
Ingestion / Surface Soil
Ingestion / Produce Grown
on Surface Soil
External Radiation /
Subsurface Soil
Ingestion / Subsurface Soil
Ingestion / Produce Grown
on Subsurface Soil
Ingestion / Deep Soil
Leaching to Groundwater
External Radiation /
Surface Soil
External Radiation /
Subsurface Soil
External Radiation /
Surface Soil
External Radiation /
Subsurface Soil
Ingestion / Sediments within
Pipeline & Manholes
External Radiation /
Surface Soil
Ingestion / Surface Soil
Engestion / Produce Grown
on Surface Soil
External Radiation /
Subsurface Soil
Ingestion / Subsurface Soil
Ingestion / Produce Grown
on Subsurface Soil
Preliminary COCs
Cs-137. Ra-226
Cs-137. Ra-226
As
Cs-137, K-40. Ra-226
Tl
Cs-137, K-JO
Cs-137, Ra-226
As, Tl, Pu-239/240, Ra-226, Cs-137
Cs-137, K-40
Sr-90
Cs-137, Ra-226, Ac-228
Cs-137, Ra-226. Ac-228
Cs-137, Ra-226
Cs-137, Ra-226
As. Cs-137, Pu-239/240
Cs-137. Ra-226. Ac-228
AS
Cs-137. K-40
Cs-137. Ra-226. Ac-228
As. Ra-226. Sr-90
Cs-137, K-40
Carcinogenic
Risks
2x 10'5
9x 10-"
2x JO"6
2x 10"

Ix 1(T
8x 10'5
8x lO'5
5x 1CT
Exceedance
of MCL
1 x 10'5
9x 10"*
4x ID'6
4 x 106
8 x lO'6
IX ID"4
3 x 10'6
5x lO'6
Ix 10"
5x 10'6
5 x 10'6
Hazard
Index




1


2













o Ecological Receptors were identified as being impacted by UisLs.
        As •» arsenic              K-40 - Potassium-40
        Tl = Thallium        •     Pu-239/240«Plutonium-239/240
        Cs-137-Cesium-137       Ac-228 • Actinium-228
        Ra-226 = Radium-226       Sr-90 - Strontium-90
lOJtwiwp doc JSB/Wb 09/22/91

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 August 1998	Page 25 of 74

 Total Pathway Risks and Hazard Indices

 Carcinogenic risks  and noncarcinogenic  hazards  associated  with  the  individual  exposure
 pathways for surface soil (0-1 ft) and subsurface soil (0-4 ft) have been summed to obtain total
 pathway risks and His for each receptor (worker and resident).

 The total pathway risk values for the hypothetical future on-unit worker and hypothetical future
 on-unit resident  are 3 x 10"5  and 3x10"*, respectively. The risk values that exceeded the EPA
 point of departure (1 x 10"*)  for the future receptors  are a result of exposure to constituents in
 soil. Additionally, leaching of Sr-90 from deep soil to the groundwater will exceed the MCL by
 almost 10-fold in 76 years.

 Total pathway His exceeded  1.0 for the future on-unit resident. These  His were 1 [for pathways
 excluding subsurface soil (0-4 ft)]  and 2 [for pathways excluding surface soil (0-1  ft)]. The
 noncarcinogenic hazards for  the future on-unit resident were a result of exposure to metals in
 surface and subsurface soil.

 Process Sewer Line Area

 Future Land Use Carcinogenic Risks

 The future on-unit industrial worker has two exposure routes with carcinogenic risks within the
 target range of 1  x 10"* to 1 x  10'6 (Table 2). External radiation exposure to surface soil has a risk
 of  1  x 10"5  primarily due to Ra-226,  Cs-137,  and Ac-228.  External radiation  exposure to
 subsurface soil has a  risk of 9 x 10"6 primarily due to Ra-226, Cs-137, and Ac-228. The risks for
 the future worker from all other pathways are less  than the EPA action level (1 x 10'").

The future on-unit construction worker has two exposure routes with  carcinogenic risks within
the target range of 1 x 10"4 to  1 x 10"6 (Table 2). External radiation exposure to surface soil has a
 risk of 4 x 10"* primarily due to Ra-226 and Cs-137.  External radiation exposure to subsurface
 soil has a risk of 4 x  10"6 primarily due to Ra-226 and Cs-137. Ingestion of sediments contained
within the pipeline and manholes has a risk of 8 x 10" primarily due to arsenic, Cs-137, and Pu-
 239/240. The risks for the future worker from all  other pathways are less than the EPA point of
 departure (1 x 10"6).
I026«wp doc JSB/blb 04/22/91

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
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 August 1998	 Page 26 of 74.
 Several pathways for the future on-unit resident have estimated risks within the target range
 (Table 2). Ingestion of surface soil has a risk  of 3 x  10"" primarily due to arsenic.  External
 exposure  to radionuclides in surface soil has a risk of 1 x 10"1 primarily due to Cs-137, Ac-228,
 and Ra-226. Ingestion of produce grown on surface soil has a risk of 5 x  10"6 primarily due to
 plant uptake of Cs-137  and K-40. Exposure to subsurface soil has a  risk  of 5  x 10'6  from
 ingestion  primarily due to arsenic, Ra-226, and Sr-90. External exposure to radionuclides in
 subsurface soil has a risk of 1 x 10"* primarily due to Ac-228, Cs-137, and Ra-226. Ingestion of
 produce grown on subsurface soil has a risk of 5 x 10~6 primarily due to plant uptake of Cs-137
 and K-40.

 Non carcin ogenic Hazards

 The BRA shows that potential adverse noncarcinogenic health effects are not likely to occur for
 the future on-unit worker, construction worker, and resident because the sum of His for all
pathways  evaluated is less than the value of 1.0 (Table 2).

 Total Pathway Risks and Hazard Indices

 Carcinogenic  risks and  noncarcinogenic  hazards  associated  with the individual exposure
pathways  for surface  soil (0-1  ft), subsurface soil (0-4 ft), and sediment in the  pipeline and
manholes  have been summed to obtain total pathway risks and His for each receptor (worker and
resident).

The total  pathway risk values for the hypothetical future on-unit worker, future construction
worker, and hypothetical  future on-unit resident are 1 x 10"5, 3 x 10"2 and 5 x 10"4, respectively.
The risk values that exceeded the EPA point of departure (1  x 10"*) for the future receptors are a
result of exposure to constituents in soil.
Total pathway His did not exceed the threshold of 1.0 for any of the exposure pathways.
I026*rwp fec.JSB/Mb 09/UAI

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ROD for the F-Area Retention Basin (281-3F)
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August 1998
WSRC-RP-97-145
      Revision 1.1
     Page 27 of 74
Table 3.    Contaminants of Concern for Soil at the FRB Operable Unit with Maximum
           Detected Concentrations and Remedial Goals
Former Basin Area
Medium
Surface Soil
(0-1 foot)
Subsurface Soil
(0-4 foot)
Groundwater
(current)
Leachability to
Groundwater
from FRB Soil
Analyte
Cesium-137
Potassium-40
Radium-226
Thallium*
Arsenic
Cesium-137*
Potassium-40
Radium-226
Thallium*
None
Strontium-90
Maximum Detect
0.29 pCi/g
2.49 pCi/g
0.931 pCi/g
6.12 mg/kg
7.13mg/kg
10.9pCi/g
3.04 pCi/g
0.931 pCi/g
6.93 mg/kg
N/A
79 pCi/L @ 76 yrs
(modeled level)
KG for soil
0.74 pCi/g
2.53 pCi/g
0.226 pCi/g
25.9 mg/kg
11.1 mg/kg
0.74 pCi/g
2.53 pCi/g
0.226 pCi/g
25.9 mg/kg
N/A
109pCi/g**
Process Sewer Line Area
Medium
Surface Soil
(0-1 foot)
Subsurface Soil
(0-4 foot)
Groundwater
(current)
Sediment within
the Pipeline &
Manholes
Analyte
Arsenic*
Actinium-228
Cesium-137
Lead-212*
Potassium-40
Radium-226
Arsenic*
Actinium-228
Cesium-137
Lead-212*
Potassium-40
Radium-226
Strontium-90
None
Arsenic*
Cesium-137*
Plutonium-239/240*
Maximum Detect
20.8 mg/kg
1.57pCi/g
2.69 pCi/g
1.65pCi/g
2.42 pCi/g
1.21 pCi/g
17. 7 mg/kg
2.51 pCi/g
21.3pCi/g
2.44 pCi/g
1.49pCi/g
2.60 pCi/g
21.8pCi/g
None
16.3 mg/kg
2040 pCi/g
32.2 pCi/g
KG for soil
11.1 mg/kg
0.202 pCi/g
0.74 pCi/g
2.19pCi/g
2.53 pCi/g
0.226 pCi/g
11.1 mg/kg
0.202 pCi/g
0.74 pCi/g
2.19pCi/g
2.53 pCi/g
0.226 pCi/g
233 pCi/g
N/A
63.9 mg/kg
l.lpCi/g
26.3 pCi/g
  Secondary COCs
** RG is the level of leachable contaminants from FRB soil that will not exceed the MCL in the
future. The RG is derived from the RESRAD modeling for leachability (K-CLC-F-00030). The
MCL for Strontium-90 is 8.0 pCi/L (CFR 1991).
I0:t>rr»p due JSU/Mb tw:s OS

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August 1998	       Page 28 of 74

Ecological Risk Assessment

The BRA also addressed the ecological risk associated with the former basin area and the process
sewer line area. Risks from both nonradionuclide and radionuclide constituents were evaluated.

Quantitative risk estimations were based on a comparison of estimated intake to a predetermined
toxicity reference value, expressed as a HQ. The assessment concluded that no ecological  risk is
associated with FRB OU.

Constituents of Concern

COCs were selected for the FRB because they exceed ARARs, because they exceed risk-based
criteria  in the  BRA,  or because they are  projected to have the potential to leach to  the
groundwater at levels  exceeding a  maximum contaminant level (MCL). Primary  COCs  are
defined  in the human health risk assessment as constituents that contribute a chemical-specific
risk of more than 1 x 10'6 or an HQ of greater than 0.1 to any media risk estimate that exceeds a
1 x 10"*  risk  or an HI of 3. COCs projected to exceed an MCL  due to soil leachability are also
considered primary COCs. Secondary COCs are defined as those  constituents in each  medium
contributing  a chemical-specific risk greater than 1  x 10'6 or a HQ of at least 0.1 to a media with
a risk greater than 1 x 10~6, but not more than 1x10^, or a HI of one or greater, but not more than
three. Final COCs are listed in Table 3.  A pictorial representation of the distribution of Sr-90
where the soil concentration exceeds the  leachability limit of 109 pCi/g (that would exceed the
MCL of 8.0  pCi/L) is included in Figure 7. Figures 8 and 9 show  that the Sr-90 concentrations
outside of the basin area are below levels of concern.

Principal Threat Source Material

Evaluated levels of radioactive contaminants in the FRB  OU soils at depth meet the definition of
principal threat source material.  Principal threat source materials are those contaminants that are
highly toxic or highly  mobile and  would  represent a significant  risk to  human health or  the
environment should exposure occur.  Cs-137, Ra-226, thallium, arsenic, and Sr-90 are present in
the FRB OU soils at depth with Cs-137 and Sr-90 representing the highest levels. Distribution of
Sr-90 by depth is shown in Figures 7, 8, and 9.  Figures 10 through 12 present the distribution of
Cs-137 by depth. Principal threat source material at depth are shown in Table 4.
I0:ecn»p Jot JSU-blIM

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 ROD for the F-Area Retention Basin (281-3F)
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 August 1998
                                      VVSRC-RP-97-145
                                            Revision 1.1
                                           Page 29 of 74
Table 4.    Principal Threat Source Material Contamination at Depth for the FRB
           Operable Unit with Their Maximum Detected Concentrations
          Medium
                  Former Basin Area
Subsurface Soil at Depth
Cs-137

Sr-90

Ra-226
2200 pCi/g

1080pCi/g

1.37pCi/g
I020tn,f0ac J SB/bib 09/21/91

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998	
                                                               WSRC-RP-97-145
                                                                      Revision 1.1
                                                                     Page 30 of 74
Figure 7. Distribution of Sr-90 by Depth-FRB Basin Area
                       rae-12
                        o
                FRB-13
                   o
                  FBB-14
FHB-11
e
FHB-OB
e
1
i

FBB.07^_ _
FRB-10
e
FRB-OS
FHB-19 ?
— • *" "~ ""^- i
.— -" ' \ :
F^.0.
                                                                            lr.*: P p«
                                                        O FRB-i:
                                   Sr-90 Distribution by Depth    oa.,r5,0nosc*e
   £l«vation
   ibov* MSL
Surlio
Elevation:
                        (-HB-O8
                                                                       FHB-OO
                        269.9U
                                        271.90
     276 T
     275
     274
                                                            0.346
     273
     272
           Ground Surface
                                            -0.27
                                                                            2.61
     271
     270
     268
     267
     266
 J   Basm  '
 ,  Bottom  '
 1    at   f
 • 264 ft MSL i
                         2.24
5.25
5.25
                             1.75
                1.43
                1.43
                                                                           0.0713
0.0713
     265
     264
    •263"
     262
            •air
             23.2
                91.3
                                                           0.571
                                                           0.571
                                                               9.99
     261
     260
     259
     258
             102
             102
             13.8
             13.8
                13.4
                13.4
     257
     256
             8.35
             8.35
                8.7
                8.7
     255
     254
                             1.62
                             1.62
     253
     252
     251
     250
     249
     248
     247
     246
     245
     244
     243
     242
     241
     240
           |E»cndi RESRAD Soil LMclublllty l«va) el 109 pCi;g that would ticMd lh« MCL ol 8.0 pCI/L.
101 Idenvp doc:JSB/blb 09/18/98

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ROD for the F-Area Retention Basin (281-3F)
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August 1998              	
                                               \VSRC-RP-97-l 45
                                                      Revision 1.1
                                                     Page 31 of 74
Figure 8.     Distribution of Sr-90 by Depth - FRB Basin Area
    FRB-12
      O

   FRB-13
    O
    FRB-14
                     FRB-11
                                    FRB-10
                                      e
 FRB-08
.  O
 FRB-07
   O
     FRB-05
FRB-19  O
                                                          FRB-06
                                                                   inlet Prpe
                                                                       •09
                                        	O-TRB-15
                       Sr-90 Distribution by Depth    Drawing nol to ^
Elevation
abov. MSL
ZfB ^
277
276
275
274
273
272
271
270
ZD3
268
267
266
265
264
	 763 	
262
261
260
259
258
257
256
255
254
233
252
251
250
249
248
Surtac*
Elevation:
irrto*T» fKD-io rno-us»
tOU.IU H4..l\i £.1 I .~\\) j

/
/
/
/

' G rbund"S uiTa'ce 'I .

_x'
r rfasm
! Bottom
' at 	
I 264 (t MSL
- JL_.







-O.4ZO
-0.321
•0.321






-u.24a
-0.248
-O.621
-0.621









p ' -2.14- -
3.42
3A1
2.08
2.08




3.28
3. 28
2.37
Z.Jf

/








"-0.27" '
-0.407
-0.407





4.46
4.46
-0.198
-0.198





IOIterwp.doc:JSB/MI> (MI/M

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ROD for the F-Area Retention Basin (281-3F)
Savannah  River Site
August 1998                    	
    WSRC-RP-97-145
          Revision 1.1
         Page 32 of 74
Figure 9.     Distribution of Sr-90 by Depth - FRB Basin Area
            FRB-12
                          FRS-11
                                               FRB-10
        FRB-H
                      FRM»
                        e
                       FRB-C7
                        o
    fas-tit
FRB-1*    O
 e

    FRB-M
        e
                                                            IrvMPioe
 e
FRB-Ot
                                            O FRB-13
                               Sr-90 Distribution by Depth
                                                            Drawing not to scaif
tltvauon
•t>av* MSL
J 'J
272 ^
271
270
269
268
267
266
265
264
763 	 "
262
260
Z3V
258
257
256
255
254
253
252
251
250
24B
248
sunac*
El«v»aon:



T" &£n
' Bonom
-I it —
1 264 II MSL
j_











foy.iu



•U.4JB

•0.321
•0.321






-0.248
•41.621
•0.621





1

•«^»














^09. uw

srouna sunac*


•^T62"
•0.711
•O.711





•1.05
-1.D5
-0.064
. 4.064




1

















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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998	
                                     WSRC-RP-97-145
                                            Revision 1.1
                                    	Page 33 of 74
Figure 10. Distribution of Cs-137 by Depth-FRB Basin Area
                      FRB-12
                       e
                                  FRB-ll
                          FRB-10
                            e
               FRB-13
                  e
                  FRB-14
FRB-08
 e
    FRB-OS

FRB-19  9
                                RB-07^
                                                   e
                                                 FRB-1S
                                Cs-137 Distribution by Depth
            EiCMdslntfustriilWorkw RQO(a74pCI/g@ IE-tna I«M|)
!OI Iderw-p.doc:JSB/blh 09/lg/'J8

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998	
                                             WSRC-RP-97-145
                                                   Revision 1.1
                                                  Page 34 of 74
Figure 11.  Distribution of Cs-137 by Depth-FRB Basin Area
   FRB-12
     O

  FRB-13
   O
  FRB-14
    O-.-J
                     FRB-11
                                                      FRB-10
FRB-08
  O
 FRB-07
   e
FRB-05
                                                       FRB-19
                                                         O
FRB-06
                                                    Iniet Pipe
           RB-09
                                             —o -
                                             FRB-15
                      Cs-137 Distribution by Depth
Elevation
above MSL
278 v
277
276
275
274
273
272
271
270
269
268
267
266
265
264
263
262
261
260
259
258
257
256
255
254
253
252
251
250
249
248
Surface
Elevation:
FRB-14 FRB-15 FRB-09 |
269.70 272.70 277.10 |


/ ^^

| Ground Surface |

X
X "










0.41
0.04
0.04






0.00
0.00
0.00
0.00









/
b7o'7~
0.02
0.02
0.00
0.00




0.00
0.00
0.01
0.01

'













0.02
0.02
-0.01
-0.01





lOl lderwp.doc.JSB/blb W/I8/98

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
                                             WSRC-RP-97-145
                                                   Revision 1.1
                                                  Page 35 of 74
Figure 12.    Distribution of Cs-137 by Depth - FRB Basin Area
            FRB-12
                         FRB-11
                                                FRB-10
     FRB-11
        FRB-14
FRB-OI
 e
                       FRB-07
                        e
    FRB-05
FRB-11    O
 e

    FRB-N
        e
                                          O
                                        FRB-OI
                                           FR8-1S
                              Cs-137 Distribution by Depth
titvauon
»bov»M3U
2/3
272 w
Z71
270
261
268
267
266
265
264
263
262
261
260
259
258
257
256
255
254
253
252
251
250
248
248
gurnet
Umtton:
[ mo*i4 mD'iii rno*i^ rKO*ii mo*iu I
 »W7I/*I

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ROD for the F-Area Retention Basin (281-3F)                         \VSRC-RP-97-145
Savannah River Site                                                        Revision 1.1
August 1998	Page 36 of 74

VII.   REMEDIAL ACTION OBJECTIVES AND DESCRIPTION OF THE
       CONSIDERED ALTERNATIVES FOR THE FRB OPERABLE UNIT

Remedial Action Objectives
Remedial Action  Objectives  (RAOs) specify COCs, media  of concern, potential  exposure
pathways, and  remediation  goals.  The  RAOs  are  based  on  the  nature  and  extent  of
contamination, threatened resources, and the potential for human and environmental exposure.
RAOs are developed based upon ARARs or other information from the RJ/BRA report. ARARs
are those cleanup standards, standards  of control, and other substantive requirements, criteria, or
limitations promulgated under  federal,  state, or local environmental laws that specifically address
a hazardous substance, pollutant, contaminant, remedial action, location or other circumstance at
a CERCLA site. Initially, remedial technologies are selected based on the RAOs. However, with
additional information, the preferred treatment technologies are modified to achieve the goals.

There  are three types of ARARs:   action-specific, chemical-specific,  and  location-specific.
Action-specific  ARARs   set  controls on  the  design,  performance,  and other aspects  of
implementation of specific remedial activities.  Chemical-specific ARARs are media-specific
and health-based concentration limits developed for site-specific levels of constituents in specific
media. Location-specific  ARARs consider federal, state,  and local requirements that reflect the
physiographical and environmental characteristics of the unit for the immediate area. The action-
specific,  chemical-specific , or location-specific ARARs (requirements) and to-be-considered
requirements relevant to  establishing remedial action objectives  for the FRB OU  identified  is
shown in Tables 5 through 7.

The RI/BRA report (WSRC, 1997b) has indicated that the secondary sources (i.e., surface soils
contaminated with radionuclides) associated with the former basin and process sewer line pose
significant carcinogenic risks (approximately 2 x 10") to  human health by external exposure to
radiation.  Since threatened, endangered, or sensitive species are not found at the unit and since it
does not offer attractive or unique cover or forage opportunities for wildlife,  ecological receptors
are not at  significant risk  from  the unit. Although limited risk is associated with the pipeline and
manhole  sediment (approximately 8 x 10'6), radioactivity detected inside the pipeline sediment
does pose potential future risks associated with this source. The RI/BRA report further indicates
that presently  there  is no contamination  in the  water table aquifer attributable  to the unit.
Groundwater modeling indicates there exists a future potential  for Sr-90 to leach out and enter
the groundwater above MCL.  Hence, based on the RI/BRA report conclusions, the feasibility
I02frrrwp doc JSB/blb 09/22/91

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ROD for the F-Area Retention Basin (281-3F)                           WSRC-RP-97-145
Savannah River Site                                                         Revision 1.1
August 1998	Page 37 of 74
study (FS) was  conducted to consider actions that could reduce the risks associated with the
former basin area soils, process sewer line area soils, pipeline sediment, and reduce the potential
for the COCs to leach out, and enter the groundwater.

Based on the risks  posed by the radionuclides in the soils and  pipeline sediment, the general
remedial action objectives for the FRB  OU are as follows:
•      Reduce risks to human health associated with COCs through
    -  external exposure to radiological constituents by direct contact with the former basin area
       soil, surface water, and sewer line area soil,
    -  ingestion of former basin area and sewer pipeline area soils and pipeline sediment  or
       produce grown in soils with radiological constituents, and
•      Prevent or mitigate exposure to highly toxic or highly mobile contaminants that represent
       principal threat source material.
•      Prevent or mitigate the leaching and migration of Sr-90 to unit  groundwater.  MCL for
       Sr-90 is 8.0 pCi/L.

Since groundwater data  collected in January 1997 and February  1997 reflected no present risk
from groundwater associated  with this unit, no RAO was developed for the groundwater.

Summary of the risks associated with FRB OU (see Table 2) indicates that one exposure scenario
for the former basin area equals or exceeds an excess carcinogenic risk of one in ten thousand (1
x 10"4). This scenario, which is addressed by the RAOs, is external radiation from surface soils
(on-unit resident). The risk is 2 x 10"* and COCs contribution to this risk include Cs-137, K-40,
and Ra-226. Scenarios for which risk is within the one in ten thousand to one in one a million (1
x lO^to 1 x 10"6) range are soil ingestion (industrial worker and  on-unit resident), dermal contact
with sediment and  surface  water (on-unit resident), biota ingestion  (on-unit resident),  and
external radiation from surface soils (industrial worker).

The scenario for the process sewer line area (pipeline sediment and soils) that equals or exceeds a
risk of 1  x  10"4 for excess cancer is external radiation  from surface soils (on-unit resident).  The
risk is 1 x 10"* and COCs contributing to this risk  include Cs-137, Ra-226, and Ac-228.
Scenarios for which risks are within the 1 x  10'6 to 1 x 1CT4 range are surface soil ingestion (on-
unit resident),  sediment ingestion (construction worker), external  radiation from surface  soil
(industrial worker), and soil and sediment ingestion (on-unit construction worker).
I OJtxrvp doc JSB/blb 0MJ/9J

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 ROD for the F-Area Retention Basin (281-3F)
 Savannah River Site
 August 1998
WSRC-RP-97-145
      Revision 1.1
     Page 38 of 74
Table 5.    Chemical-Specific Requirements
tTTATioMS)
4UCJ-K3U.6
40 OK IV2.12
5L R 01-
58.5(B)(2) and 40
CFR 141.62
SC R 01-
58.5(B)(2) and 40
CFR 141.62
SC K 01-
58.5(B)(2) and 40
CFR 141.62
SC R 01-
58.5(B)(2) and 40
CFR 141.62
SU R 01-
58.5(B)(2) and 40
CFR 141.62
it; K 01-
58.5(B)(2) and 40
CFR 141.62
sc; K 01-
58.5(B)(2) and 40
CFR 141.62
SC K 01-
58.5(B)(2) and 40
CFR 141.62
STATUS
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant ana"
Appropriate
Relevant and
Approphate
REQUIREMENT
SUMMARY
The concentration ot paniculate
matter (PM,0) in ambient air shall
not exceed SO ng/mj (annual
arithmetic mean) or 150 ug/m3
(24-hour average concentration).
ine concentration ot radium-226
in land averaged over any area of
ICO square meters shall not exceed
the background level by more than
(1)5 pCi/g, averaged over the first
15 cm (5.9) of soil below the
surface, and (2) 1 5 pCi/g, averaged
over 15-cm (5.9-in) thick layers of
soil more than 15 cm (5.9 in)
below the surface.
Hie proposed M(_'L tor thallium is
1 mg/L
Ihe M(_L tor arsenic is U.U5 mg/L.
Ihe MC-L tor cesium- 13 / is 2W
pCi/L.
1 he proposed MCL tor potassium-
40 is 300 pCi/L.
1 he proposed MCL tor radium-ZZO
is 14.7pCi/L.
The MCL lor strontium-90 is S.U
pCi/L.
Ine proposed ML'L tor plutonium
239/240 is 62. 1 pCi/L.
I he MCL tor actimum-ZZS is 3Z /u
pCi/L.
RtASONTOR
INCLUSION
tanh-movmg activities
will generate airborne
dust thai will have the
potential to exceed the
levels specified. Dust
suppression will likely be
required to minimize
dust emissions.
Radium-220 has been
identified as a COC for
soil.
l hallium has been
identified as a COC for
soil and may leach into
the groundwater.
Arsenic has been
identified as a COC for
soil and may leach into
the groundwater.
Lesium-137 has been
identified as COC for
soil and may leach into
the groundwater.
Potassium-4U has been
identified as a COC for
soil and may leach into
the groundwater.
Kadium-ZZO has been
identified as a COC for
soil and may leach into
the groundwater.
Mrontium-yy has been
identified as a COC for
soil and the RERRAD
shows that it can leach
out and enter the
groundwater.
Plutonium Z3W24U has
been identified as a COC
for soil and may leach
into the groundwater.
Actimum-ZZB has been
identified as a COC for
soil and may leach out
into the groundwater.
Ai;itRNAlIVL(S)
S3. S-l. P.J
SI. S3. S-*. Pi. H-.
SI. S3, S4. Pi. P-. Ul.
G2
SI, S3, S4. PI, P4, Ul.
G2
M
SI. S3. S-4. PI. P4. UIM
G2 ^
SI, S3, S4, PI, P4. Ul.
G2
SI, S3, S4. PI, P4. Ul,
G2
SI, 53, S4. PI, P4. Ul,
G2
SI, S3, S4. PI. P4. Ul.
G2
SI, S3, 54. PI. P4. Ul,
G2
I026cn>pdoc JSB/blb 09/11/98

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998                     	
\VSRC-RP-97-145
      Revision 1.1
     Page 39 of 74
Table 6.    Action-Specific Requirements
IT1'AT1UIN(&)
4ULJ-K 264. JIU
SC R 61.02.0,
Section 111
UUt Order
5820.2A, Chapter
111
5IA1US
Relevant and
Appropriate
Applicable
1H(_
Kty UlKLIVLtrS I
SUMMARY
Cap (or cover) must have
permeability less than or equal
to the bottom liner systems.
Paniculate matter must be
controlled in such a manner
and to the degree that it does
not create an undesirable level
of air pollution.
Low-level radioactive waste
must be managed in a manner
that protects public health and
safety, assures that external
exposure to the waste does not
exceed 25 mrem/yr to any
member of the public, and
protects groundwater resources.
RLASUIN tUK
INCLUSION
ioil and sediment addressed bv
this removal action is not RCRA
hazardous waste. This
requirement is identified as
relevant and appropriate for the
low permeability cover. The
hydraulic conductivity of the
cover will be less than or equal
to the soils at the bottom of the
basin or underneath the former
process sewer line.
banh-movmg activities have the
potential to generate airborne
paniculate matter.
Contaminated soil generated
during this remedial action will
likely be considered low-level
radioactive waste.
AL1LKNAI IN t(isl
S3. b?
i»3. J>4. bx P-J. P5A
51, i>j, i>4. bX PI. P4.
P5A
lOiftcrwp 
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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
WSRC-RP-97-145
      Revision 1.1
     Page 40 of 74
Table 7.    Location-Specific Requirements
CIl'AllUiN(M)
I6USL bJI
l6Ub'L6fcl
bt- K ji.02.0.
Section III
UUt Order
5820.2A, Chapter
III
MAI US
Applicable
Applicable
Applicable
Applicable
KtyillKtlVLKM
SUMMARY
I he remedial action must be
conducted in a manner to
conserve endangered or
threatened species.
I he remedial action must be
conducted in a manner to protect
fish or wildlife.
I he remedial action must be
conducted in a manner that
minimizes impacts to migratory
birds and their habitats.
I he remedial action must
minimize the destruction, loss,
or degradation of wetlands.
KLASUiN fOK IJNC'LUSlOrs
I here are threatened and
endangered species at the SRS;
however, as stated in the FRfl
RJ/BRA. this action will not
affect these species.
Ihis remedial action has the
potential to affect wildlife in the
vicinity of the FRB and former
process sewer line. This action
will not affect fish located at the
SRS or in nearby bodies of water.
Migratory bird populations may
be presented in the vicinity of
SRS.
wetlands may be located in the
vicinity of the FRB and former
process sewer line; however, they
will be unaffected by this action.
ALItKJNAl l\ L(i»l ,
61. bJ. b-«. bx Cj !. (_!-.
PI, P4. P5A
i>i. b.\ b-». bi. ui. UJ.
PI. P4.P5A
bl, 53. i>4. bX Ui, UJ.
P1.P4.P5 A
bl, bJ. b-4, bX Cil. CJJ,
P1.P4, P5A
lOiterwp doc JSB/blb 09/72/91

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 ROD for the F-Area Retention Basin (281-3F)                           WSRC-RP-97-145
 Savannah River Site                                                         Revision 1.1
 August 1998	Page 41 of 74

 Description  of the Considered Alternatives for FRB Operable Unit

 As part of the investigation/assessment process for the FRB OU, a CMS/FS was performed using
 data generated during the assessment phase. The CMS/FS evaluated various  treatment processes
 and technologies .that can be used to remediate the contaminated  soil attributed to the FRB OU
 and groundwater. Detailed information regarding the development and evaluation of remedial
 alternatives can be found in the Corrective Measures/Feasibility Study for the F-Area Retention
 Basin (U) (WSRC, 1997c).

 After screening a number of treatment processes and technologies, various treatment alternatives
 were  developed.  Fifteen potential remedial alternatives were identified initially  to address  the
 remediation at the former basin area  and the process sewer line area. After initial screening, nine
 alternatives were considered for detailed analysis. Since primary and  secondary  COCs for  the
 former basin  area soil and process sewer line area soil are radionuclides  and metals with very
 similar physical and chemical properties, the remedial alternatives identified  in the FS report  are
 applicable to  all unit primary and secondary COCs.

 Considered Alternatives for Soils

 Four  alternatives were evaluated  for remedial action  of the soil.  Each  alternative is briefly
 described  below. For additional information regarding  the description  of the alternatives, their
 cost estimates and their analyses, see the Corrective Measures/Feasibility Study for the F-Area
 Retention Basin (281-3F) (U), (WSRC, 1997c).

Alternative SI - No Action

Under this alternative, no action will  be taken for the soil, which means leaving the FRB OU soil
in its current condition  with no additional controls. EPA policy and regulations  require the
consideration of  a  No  Action alternative  to  serve as  a baseline against which the other
alternatives can be compared.

There is no reduction of risk with this alternative.  The only reduction in risks resulting from the
No Action alternative are due to natural decay of radionuclides, primarily Cs-137 and  Ra-226.
The half-lives of Cs-137 and Ra-226  are 30 years and  1600 years, respectively.  Therefore,
natural decay of Cs-137 and Ra-226 will not reduce the external radiation risk significantly from
a No Action alternative  for  the  next 30  years.   Sr-90 could also leach  out and enter the
I036cr»p doc JSB/blb 09/22/91

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ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
Savannah River Site                                                         Revision 1.1
August 1998	Page 42 of 74
groundwater in 30 years with  concentrations above MCL (8.0 pCi/L).  The Remedial Action
Objective for principal threat source material would not be addressed under this alternative.

No costs are associated with this alternative.  However, the total present worth cost for the five-
year ROD reviews for 30 years (for cost estimating purpose only; actual five-year ROD reviews
will be required in perpetuity), is approximately 59,600.

Alternative S3 - Institutional Controls and Low Permeability Cover

This alternative will include institutional controls and a low permeability cover placed over the
basin. The cover is designed to minimize stormwater percolation. Stormwater percolation is
further minimized by mounding the cover and diverting stormwater by constructing a runoff
control system around the cover. A vegetative cover is placed over the low permeability cover to
minimize erosion (see Figure 13 for illustration).  Under institutional controls, deed restrictions
and/or notifications will be provided if the government sells the property. Five-year CERCLA
ROD reviews will also be performed for this alternative for 30 years. The 30-year period is for
cost estimating purposes only; actual five-year ROD reviews will be required in perpetuity.

The institutional controls will involve both short-term and long-term actions.  For the short-term
action, signs will be posted at the FRB OU indicating that this area was used for the disposal of
waste material and contains buried waste.  Additionally, existing SRS access controls will be
used to  maintain use of this site for industrial use only.  In the long-term, if property  is ever
transferred to non-Federal ownership,  the U.S. Government will  take those actions necessary
pursuant to Section  120(h)  of CERCLA.   These actions will  include  a deed notification
disclosing former  waste management  and  disposal activities as well  as any remedial actions
taken on the site and any continuing groundwater monitoring commitments. These requirements
are also consistent with the intent of the RCRA deed notification required at final closure of the
RCRA facility  if contamination would  remain at  the unit.  The  deed notification shall, in
perpetuity, notify any potential purchaser that the property has  been used  for the  management
and disposal of radioactive materials and hazardous substances. The deed shall also include deed
restrictions  precluding residential  use of the  property.  However, the need for these  deed
restrictions may be reevaluated  at the time of transfer in the event that contamination no longer
poses an  unacceptable  risk under residential  use.  Any  reevaluation  of the need  for  deed
restrictions would be done through an amended ROD with the Environmental Protection Agency
(EPA) and the  South Carolina Department of Health  and Environmental  Control (SCDHEC)
approval.  In addition, if the site is ever transferred to non-Federal ownership, a survey plat of the
1026CTWp O«/22/9«

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                                                                                                                            TO

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COYER COMPOSITION
VEGETATION
      TOPSOIL (0.5')
      CLAY (l.O'l
    R IS MOUNDED TO MINIMIZE
STORHVATER PERCOLATION
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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                       Revision 1.1
 August 1998	Page 44 of 74

 area will be prepared.  The plat will be certified by a professional land surveyor, and recorded
 with the appropriate county recording agency.

 Per the EPA-Region IV Land Use Controls (LUCs) Policy, a Land Use Control Assurance Plan
 (LUCAP)  and a Land Use  Control  Implementation Plan (LUCIP) will be developed  and
 submitted to the regulators for approval.  The LUCAP will be submitted under separate cover
 whereas the LUCIP will be submitted with the post-ROD documents for the FRB OU.

 The LUCIP will clearly identify the objectives of the land use controls for the FRB  OU.  The
 land use control objectives for the FRB OU are to:  reduce risks to human health from direct
 exposure to radiological COCs by direct contact with basin soil, surface water, sewer line soil,
 and ingestion of soils  and/or produce grown in  FRB  OU soils; and prevent leaching  and
 migration of Sr-90 to  groundwater.  The specific manner of achieving the  land use  control
 objectives will be included in the LUCEP as part of the post-ROD documents.  The LUCIP will
 also specify the assumptions made concerning current and expected future land  use and exposure
 scenarios.  The land use scenarios used in the risk assessment as well as the DOE  policy on
 current and future land use projections are discussed in Section VI.

Under the current land use scenarios, the most reasonable receptor for the FRB  OU considered is
 a visitor who is exposed to the FRB OU area on an infrequent or occasional basis.  Under future
 land use scenarios, the receptor  and exposure pathways   considered included:   an  industrial
 worker  exposed to surface soils, redistributed deep soils,  and groundwater;  a future resident
 exposed to surface and  excavated deep soils, air, groundwater, homegrown produce and external
radiation; and  a construction worker exposed to surface and subsurface soils,  groundwater and
 sediment  within  the sewer pipeline.  For  a construction  worker and future  resident,  both
carcinogenic risks  and  non-carcinogenic  hazards  also  considered  exposure  to  modeled
concentrations in groundwater due to  leachability of soil contaminants.  All  the assumptions
made concerning current and expected future land use scenarios used in the risk assessment will
 also be included in the LUCIP as part of the post-ROD documents. The LUCIP will also specify
those  exposure scenarios, which may not be protective of the human health and the environment
 under less restrictive land uses.

A low permeability engineered cover will be sufficient to minimize infiltration, intrusion, and
 surface  erosion.  The  cover design  will be  approved by the EPA and  SCDHEC prior to
 construction. The low permeability cover will encompass an area of approximately 4,000 square
1026crwp doc JSB/Mb OW72/9I

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meters (1.0 acre) and will be maintained for 30 years. The 30-year period is for cost estimating
only; actually the cover will be maintained in perpetuity. Based on the known half-lives of the
predominant  radiological  risk drivers (i.e., Cs-137 and Ra-226), only Cs-.37 will have gone
through approximately one half-life.  In addition, institutional controls will remain in place as
long as the waste remains a threat to human health or the environment.

A properly engineered cover will function as a physical barrier to prevent direct human exposure
to soil-borne contamination and thus will be protective of human health and the environment. A
low permeability cover is a performance-based engineering approach since it does not reduce the
total mass of COCs.  The  soil cover will be adequate to reduce the annual effective dose
associated with  continuous  exposure to Cs-137 and  Ra-226 to within regulatory limits. In
addition, a properly maintained cover will minimize  infiltration and  subsequent  leaching of
contamination from unsaturated soil to the groundwater.

Under this remedial alternative, two remedial action objectives are satisfied  by:   (1) limiting
infiltration into the area, thereby reducing the leaching of primary and secondary COCs to unit
groundwater; and (2) preventing human or ecological access, thereby  reducing risks to human
health and the environment.  The  third  remedial  action objective to prevent or mitigate  the
potential exposure to highly toxic or highly mobile contaminants (the principal threat source
material) would not be met.

The  total present value estimate for this alternative is approximately $286,000.  These  costs
include  estimated capital costs approximately  5267,000 and operation and maintenance costs,
approximately $19,000, for the cover for 30 years and review, of the remedy every five years for
30 years, as required by the NCP. The 30-year period is for cost estimating purposes only; actual
five-year reviews will be required in perpetuity.

Alternative S4 - Institutional Controls and Grouting

This alternative  consists  of institutional  controls  and grouting the  soils in situ to  reduce
contaminant mobility and stabilize principal threat  source material. A vegetative cover will be
installed over the  stabilized soil  to minimize  erosion. The estimated depth  range of in situ
grouting is approximately  1.8 to 4.3 m (6 to 14 ft).  The depth range, 6 to 14 ft has been selected
for two reasons:  (1) Cs-137 and Sr-90 is mostly distributed in the deep soil beneath the former
basin in  the depth range  of 6 to  14 ft as is  apparent from Figures  14 and  15; and (2) the
permeability of  the grouted mass  will be no greater than 1 x  10"* cm/s,  thereby preventing
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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                        Revision 1.1
 August 1998	Page 46 of 74
 infiltration to the soils beyond the  14 ft depth.  Therefore, Sr-90 and any other contaminants
 present in the soil beyond 14 ft depth will have less potential for migrating to the groundwater.

 Deed restrictions and/or notifications will be provided if the government chooses to sell the
 property.  Five-year CERCLA ROD reviews will be performed for 30 years. The 30-year period
 is for cost estimating only; the actual reviews will be required in perpetuity.

 This alternative will involve excavating the basin to remove the nominal eight  feet of clean soil
 that was placed in the basin when the basin was closed, cleaned and backfilled in 1978;  grouting,
 or solidification/stabilization (S/S) of the soil in the bottom of the basin down to a 1.8 m (6 feet)
 depth (4.3 m or 14 feet depth from the present surface of the basin, with an approximate volume
 of 6,600 m3 or 8,100 yd3); backfilling the basin with clean soil; and grading the top surface of the
 basin. Institutional  controls  will be  same as identified in  Alternative S3.  In  situ S/S  involves
 mixing  the S/S reagents into the waste by a mechanical means such as a jet-grouting system or a
 long-reach backhoe fitted with a grouting device  (see Figures 16 and 17 for illustration).  A
 treatability study  has been conducted on L-Area Oil and Chemical Basin (LAOCB) soils, which
 has  characteristics almost   identical  to F-Area  Retention  Basin soil (Laboratory-Scale
Immobilization Study Report for L-Area Oil and Chemical Basin) (WSRC, 1996). This study has
 determined that S/S agents can immobilize unit-specific contaminants; specifically, a mixture of
Portland  cement,  bentonite,  and  sodium  silicate  was found  to effectively  immobilize
 contaminants, primarily radionuclides such as Cs-137 and Co-60.

In situ S/S does not reduce the  total mass or toxicity of the COCs.  However, it is a proven
performance-based engineering approach that reduces the mobility of the primary and secondary
COCs.  Based on the results of a literature search and a treatability study performed on  LAOCB
soils, the  in situ  S/S  reagents are  considered  effective  at reducing  the leachability of
contaminants. Specifically, the various S/S reagent samples (with LAOCB soil) were subjected
to the toxicity  characteristic leaching  procedure (TCLP)  and  the extended American Nuclear
Society (ANS)  16.1 procedure to simulate leaching of contaminants over time.  Analysis of the
two leaching tests performed on LAOCB soil samples mixed with S/S reagents demonstrated that
all of the samples released 0.41% and 1.61% or less of gross alpha and gross beta, respectively.

Alternative S4 meets remedial action objectives by: (1) preventing infiltration into the basin area
through immobilizing contaminants present in the basin, thereby preventing migration of primary
and  secondary COCs  to groundwater;  (2) preventing human or ecological  access,  thereby
reducing risks to human health and the  environment; and (3) preventing or mitigating the
lOZttcrwp doc. JSB/blb 09/22/91

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ROD for the F-Area Retention Basin (281-3F)
Savannah RJver Site
August 1998                    	
                                  WSRC-RP-97-145
                                         Revision 1.1
                                        Page 47 of 74
Figure 14.  Distribution of Sr-90 by Depth - Depicting the Zone of High
            Concentration-FRB Basin Area Alternative S5-Institutional Controls,
            Grouting, Low Permeability Cover, and Grounchvater Monitoring
                     FHB-12
                      e
FRB-11
 O
FBB-10
  e
                 FHB-14
FflB-08
• FRB"U

FBB.07 __._•—• ~~
FRB4S
< T
\ '
FHBJ06
                                    iniei P pe
                                    ^^••••^^B
                                     e
                                    FRB-09
                                                   O FRB-1S
                                     Sr-90 Grout Zone
                                                               Drawing noi to scai«
          lEiCMd* RESflAD SeH LuctwbHIty Lent ol 10* pCVfl lh«1 would ne«*d lh« MCL of 8.0 pCI/L.
           IQraul Zon* beginning 21«* *bo>« th« biun bottom ind extending lo 6 twl btlow the b««in ballom.
           |Bj«in bottom it tt 2M tMt abon mwn M« l«v«l (MSL).
101 lder^vp.doc:JSB^Ib 09/18/98

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
                                    WSRC-RP-97-145
                                          Revision 1.1
                                         Page 48 of 74
Figure 15. Distribution of Cs-137 by Depth - Depicting the Zone of High
           Concentration -FRB Basin Area Alternative S5- Institutional Controls,
           Grouting, Low Permeability Cover, and Groundwater Monitoring
                    FRB-12
                     e
                                FRB-11
                                                      FRB-10
              FRB-U
                 e-
                FRB-14
FRB-08
 e
                              FRB-07 _ . — •
                                                           FRB-OS
 RB-07 __
                                                                 Inie: P:B«
                                               FRB-IS

                              Cs-137 Distribution by Depth
            UMd* Indunriil Werlur RCO (0.74 pCi/g © l£-t riiJi I*M!)
 CI!!I!."I!!I3 Grow Zoo.
IOIIderwp.doc:JSB^Ib 09/18/98

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 ROD for the F-Area Retention Basin (281-3F)                           WSRC-RP-97-145
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 August 1998	       Page 49 of 74

 potential exposure to highly toxic or highly mobile contaminants, i.e., the principal threat source
 material.
 The short-  and long-term institutional controls and LUC information described under Alternative
 S3 would also be applicable under Alternative S4.

 The total present value estimate for this alternative is approximately 51,228,000.  These costs
 include estimated capital costs approximately $1,209,000 and operation and maintenance costs
 approximately 519,000  for the grouted monolith  for 30 years and review of the remedy every
 five years  for 30 years,  as required by the NCP.  The 30-year period is  for  cost estimating
 purposes only; the actual five-year ROD reviews will be required in perpetuity.

Alternative S5 - Institutional Controls, Grouting, Low Permeability Cover, and Groundwater
Monitoring

Alternative S5 is a combination of alternatives S3 and  S4 and consists of grouting the soils in
situ  to reduce contaminant mobility and providing a low  permeability cover over the grouted
soils. A vegetative cover is placed over the low permeability cover to minimize erosion.

This alternative like S3 will be  effective  in  preventing contact  with  and  ingestion  of
contaminated soil.   Like Alternative S4,  it will  also be  very  effective in  reducing  potential
leaching  of contaminants from soil to  groundwater.  Additionally,  deed restrictions  and/or
notification will be provided if the government sells the property.  Five-year ROD reviews will
also be performed for this alternative.

Under this  alternative, contamination in the basin soil  will  be  immobilized and covered with
clean soil and a low permeability cover as discussed under Alternative S3. These actions would
meet all the three remedial action objectives by:

•  preventing infiltration into the soil through cover and immobilizing contaminants present in
   the basin via in situ  S/S, thereby preventing migration of primary and secondary COCs  to
   groundwater;

•  preventing human or ecological access, thereby  reducing risks to human  health and the
   environment;
I0:<*rwj> dec JSB/blb 09/2WI

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M
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ROD for the F-Area Retention Basin (281-3F)
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August 1998
WSRC-RP-97-145
      Revision 1.1
     Page 51 of 74
Figure 17.  Jet and Soil Mixing Grouting Techniques
                           TVack Mounted Jet-Grout Drilling
                                                           PKvioudjr Grouted A/cu
                     Crane Mounted Soil/Grout Mixing System

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 August 1998	Page52 of 74

 •   preventing or mitigating potential exposure to highly mobile or toxic contaminants which
    represent the principal threat source material; and

 •   reducing the radioactive dose (direct radiation exposure) received from Cs-137 and Ra-226
    by nearly 100%, assuming an approximate cover thickness of four feet.

 This alternative also includes groundwater monitoring to confirm that the source remediation has
 achieved  the required stabilization of  the contaminants; to relieve  any uncertainty  in the
 analytical  data;  and to verify that there exists  no  upgradient  source  contributing  any
 contamination to the FRB OU groundwater.  The existing monitoring wells (FRB-01, -02, -03,
 and  -04) will  be used  to collect groundwater samples semi-annually (see  Figure  18  for
 monitoring well locations, groundwater flow direction, and location for the upgradient well).

 The analytes monitored will include Cs-137, Sr-90, TCE, and other COCs  and normal field
 measurements specified  in the  post-ROD document  work  plans.  If monitoring  dejects
 contamination above MCLs (or RBCs without MCLs) for those constituents attributable to the
 FRB  OU or an  unknown  upgradient  source,  for two  consecutive monitoring periods, the
 regulators will be informed within 30 days. A plan for evaluating the data and developing further
 action will be submitted within 90 days for regulatory approval.  The results of the monitoring
 will be reported annually; however, no raw data will be provided.

 The short-term and  long-term institutional controls  and LUC information described  under
 Alternative S3 would also be applicable under Alternative S5.

 The total present value estimate  for this  alternative is  approximately $1,461,000 with total
 estimated capital costs approximately $1,442,000 and O&M costs approximately $19,000.

This estimate includes costs for groundwater monitoring, operation and maintenance of the cover
 for 30 years, and review of the remedy every five years for 30 years as required by the NCP. The
 30-year period is for cost estimating purposes only; actual five-year reviews will be required in
perpetuity.

 Considered Alternatives for Groundwater

 Since no impact to the groundwater from the operation of the basin was discovered, only two
 alternatives  were  evaluated  for  groundwater.   The   alternatives  are  described  below.
102MT»p doc JSB/bIb 09/22*1

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ROD for the F-Area Retention Basin (28I-3F)
Savannah River Site
August 1998	
Figure 18. Locations of FRB Monitoring Wells and Upgradient Well
WSRC-RP-97-145
      Revision I.I
     Page 53 of 74
   553000      EiROO      E SJ400      t SJIOO      I 53800	E 44000	fMJOO      E 54400      E 44«00      E 54»00
                                                                                               —  N 16000
                                                                                                             LEGEND
                                                                                                         «M» tONTC'U* U
                                                                                                              f,C»lf IN (f f I
IUIldcnvp.doc:JSB/blb09/lg/9K

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 Alternative Gl - No Action

 This alternative  involves leaving the  groundwater associated  with FRB OU  in  its current
 condition with no additional controls. EPA policy and regulations require the consideration of a
 No Action alternative to serve as a baseline against which the other alternatives can be compared.

 Because no further action is taken at the unit, the groundwater remains  in its present condition.
 No costs are associated with this alternative.

Alternative G2 - Groundwater Monitoring

 This alternative involves maintaining control of the basin area and monitoring the groundwater
 annually until it is confirmed that the remedial response action for the FRB OU has achieved the
 required stabilization of the  contaminants.  This alternative alone  will  not  be effective in
 preventing future ingestion of shallow aquifer groundwater. No monitoring is required  based on
 no basin impact.  However, groundwater monitoring was considered as an element  of the soil
 remedy.

 However, groundwater monitoring when performed in conjunction with institutional controls
will be  effective  in preventing the ingestion  of groundwater and thereby reducing the risks to
human health. If contamination is detected above the maximum contamination level, then further
 groundwater response actions will  be  necessary.  If monitoring  conditions change, SRS  will
 request alteration or termination of the monitoring program.

The short-term  and long-term institutional  controls  and LUC  information described  under
 Alternative S3 would also be applicable  under Alternative G2.

 There are no capital costs associated with this alternative; however, total estimated O&M costs
 are approximately $114,000.  Therefore,  the  total  present worth  cost for this alternative is
 approximately $114,000. These costs include a five-year ROD review for 30 years. The 30-year
 period  is for cost estimating purposes  only;  actual five-year  reviews will  be required in
 perpetuity.

 Considered Alternatives for Process Sewer  Line

 Three  alternatives were evaluated  for remediation  of the process sewer line  and  pipeline-
 associated soils.  The alternatives are described below.
10}6cn»p doc JSO/blb 09/1:2/91

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Alternative PI - No Action

This alternative involves leaving the process sewer line, like the basin, in its current condition
with no additional controls.  EPA policy and regulations require the consideration of a No Action
alternative to serve as a baseline against which the other alternatives can be compared. Because
no further action is taken at the unit, the process sewer line along with the basin soil remains in
its present condition. There  is no reduction in the risk posed by the radionuclides present in the
soil, which include Ac-228,  Cs-137, K-40, Ra-226, and Sr-90.

No costs are associated with this alternative. However, the total present worth cost for five-year
ROD reviews for 30 years is approximately $9,600.  The 30-year period is for cost estimating
purposes only; actual five-year reviews will be required in perpetuity.
Alternative P4 - Institutional Controls, Pipeline Grouting, Soil Excavation, and Disposal of
Soil with Basin Soil

This alternative includes pumping grout into the pipeline and manholes to  stabilize contaminants,
thereby restricting access to the  contaminants  inside the pipeline. This alternative also involves
excavating localized areas of contaminated soil (areas around the trouble spots determined by
robotics investigation  and soil sampling)  (Figure 19) around the pipeline area using standard
earth-moving equipment. The volume of contaminated soil will be determined by comparing the
existing sampling data against the acceptance criteria (concentration  levels not to  exceed 20
pCi/g for alpha and  50 pCi/g for beta and gamma  emitters). The material  (unacceptable
contaminated soil with an  estimated  volume  of approximately 240  m3 or 300 yd3) is then
transported to the basin for disposal  along with the  basin  soils.  Deed  restrictions and/or
notifications would  be provided if the government were to sell  the property. Five-year ROD
reviews are also included in  this alternative.

The short-term and  long-term  institutional  controls and LUC  information described  under
Alternative S3 would also be applicable to  P4.

Because the source of contamination  is  removed  under this alternative, the  remedial action
objectives are met.  The sewer line soil hot spots and, if necessary, associated sections of pipeline
are excavated and combined with the basin grout mass, thereby reducing  the risk from the most
contaminated areas of the sewer line soils.
I026en»p dac.JSB/Mb V>r.Wt

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  Savannah River Site
  August 1998
WSRC-RP-97-145
      Revision 1.1
     Page 56 of 74
  Figure 19.  Location of Potential Trouble Spots
                          Horn TV* Fern
                         P37
                                           Fron Canyon
                       P38
>- -I 	 ">«
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 August 1998	Page 57 of 74

 The total present worth cost for this alternative is approximately 5320,000 with total estimated
 capital costs approximately $310,000 and estimated O&M costs 596,000.  These costs include
 five-year ROD reviews for 30 years.  The 30-year period is for cost estimating purposes only;
 actual five-year reviews will be required in perpetuity.

Alternative PSA - Excavation and Off-Unit Disposal (SRS Disposal)

This alternative involves excavating and removing the pipeline and associated contaminated soil
and using clean backfill from an SRS source to return the area to natural grade.  Topsoil will also
be used to support a vegetative layer.

Concrete debris (estimated volume of 45  m3  [58 yd3]) generated during removal of the pipeline
will be transported  to E-Area Low Level Radioactive Disposal Facility for disposal. Assuming a
150% bulking factor for the concrete pipe, the volume of pipeline that will be broken and sized
into small pieces will be approximately 68mJ (87 yd3). Contaminated soil (estimated volume of
approximately 240  m3 [300 yd1]) will be dispositioned with basin soils.

This alternative meets ARARs.  Residual  concentrations of Ra-226 in soil will meet the relevant
ARAR. Excavation of contaminated material (pipeline and soil) can be performed in a manner
that  meets  air emission ARARs;  that  is, using  conventional  earth-moving equipment and
standard dust suppression techniques. Current access restrictions prevent inadvertent  intrusion
into the area.   Risks to  remediation workers from operating heavy earth-moving equipment and
handling  contaminated soil and sediment can be  managed by following  the project-specific
health and safety plan.   Equipment and materials required for this remedial action are readily
obtained by SRS.

Implementation of this alternative will be difficult as a large amount of soil (2728 m3 [3567 yd3])
must be excavated and managed while removing the pipeline.   There  will also be difficulties
associated with removing the 0.6 m (2 ft) and 0.9 m (3 ft) diameter pipeline from the ground due
to its size and weight.   Another process  line (unrelated  to this unit and  not addressed by this
alternative) runs close to the former process sewer line. Therefore, excavation activities must be
carefully planned and conducted to avoid disturbing this other process line. Disposal capacity at
SRS for the disposal of low-level  radioactive waste is  also limited.  Because the source of
contamination will  be removed under this alternative, remedial action objectives will be met by
eliminating any risk to groundwater, human health, and the environment.
I026er»p doc JSB/blb 09/22/9*

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 The cost of this alternative is approximately 5410,000 (total present value cost).   There are no
 O&M costs  for this alternative and  these costs also do not include costs for five-year  ROD
 reviews since no ROD review will be  required for this alternative.

 VIII.   SUMMARY OF COMPARATIVE ANALYSIS OF THE ALTERNATIVES

 Evaluation Criteria
 Each remedial alternative was evaluated using the nine criteria established by the National Oil
 and Hazardous Substances Contingency Plan. The criteria were  derived  from  the statutory
 requirements of CERCLA Section 121 and are listed below:
 •      Overall protection of human health and the environment
 •      Compliance with applicable or relevant and appropriate requirements (ARARs)
 •      Long-term effectiveness  and permanence
 •      Reduction of toxicity, mobility, or volume through treatment
 •      Short-term effectiveness
 •      Implementability
 •      Cost
 •      State acceptance
 •      Community acceptance

 In selecting the preferred alternative,  these nine criteria were used  to evaluate the alternatives
 developed in  the Corrective Measure  Study/Feasibility Study for the FRB (U)  (WSRC, 1997c).
First seven of the criteria are used to evaluate all the alternatives.  The preferred  alternative is
 further evaluated based on the final two criteria, state acceptance and the community acceptance.
The first two criteria (overall  protection of human health and the environment, and compliance
with ARARs) are also categorized as threshold criteria.  The next five criteria are categorized as
primary balancing criteria.  The last two criteria (state acceptance and community acceptance)
 are categorized as modifying criteria.

 Detailed Evaluation

The remedial action alternatives discussed in Section VII were evaluated using the nine criteria.
 A detailed evaluation of the alternatives is provided in the Feasibility Study (WSRC, 1997c).
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 Comparative Analyses

 This section discusses how well each alternative addresses the CERCLA evaluation criteria. The
 alternatives are discussed in relative order of performance with respect to the particular criterion.
 Table 8 provides a summary of the comparative analyses.

 Overall Protection of Human Health and the Environment

 For  soil  remedial alternatives, Alternative  S5 is the most  protective  because it involves
 stabilizing the waste and providing a cover to minimize stormwater percolation. Alternative S4
 is the second most protective because it involves stabilizing the waste source only. Alternative
 S3 offers the next best level of protection. Alternative SI, the No Action alternative, offers the
 least protection.

 For groundwater, both alternatives, Alternative Gl  and Alternative G2 are  equally protective of
 human health and the environment.

 For the process sewer line area, Alternative PSA is the most protective of human health and the
 environment followed by Alternatives P4 and PI.

 Compliance with ARARs

Alternatives SI, S3, S4, S5, PI, P4, and PSA comply with ARARs for soil.   Alternative  G2
complies with groundwater ARARs.

Long-Term Effectiveness

Of the soil alternatives, Alternative S5 offers the most long-term effectiveness.  The second most
effective is Alternative S4, followed by S2, and then Alternative SI (No Action).

Both groundwater alternatives, Alternative Gl and Alternative G2, are equally effective over the
long term for groundwater.

Alternative PSA offers the most protection over the long term  for the process  sewer  line area,
followed by Alternatives P4 and then PI (No Action).

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                                   Table 8.    Comparative Analysis Summary
Alternative
SI: No Action
S3: Institutional Controls
and Low Permeability
Cover
S4: Institutional Controls,
and Grouting,
S5: Institutional Controls,
Grouting, and Low
Permeability Cover
(J 1 : No Action
G2: Uroundwater
Monitoring
PI: No Action
P4: Institutional Controls,
Pipeline Grouting, and
Soil Excavation and
Disposition with FRB
Soils
P5A:Excavalion and Ull-
Unil Disposal (SRS
Disposal)
CbkcLA Criterion
Overall Protection or Human
Health of (he Environment
Least1 protective soil alternative
Protective, but not lo (he extent or
S4 or SS
Second most protective soil
alternative
Most protective soil alternative
Equally protective groundwater
alternative
Equally protective groundwater
alternative
Least protective pipeline
alternative
Second most protective pipeline
alternative
Most protective pipeline
alternative
Compliance with ARAKs
Complies with AKAKs
Complies with AKAKs
Complies with AKAKs
Complies with AKAKs
Compliance with
groundwater ARARS can not
be demonstrated
. Complies with groundwater
ARARs
Complies with soil AKAKs
Complies with soil AKAKs
Complies with Soil AKAKs
Long- 1 erm Effectiveness
and Permanence
Least effective soil
alternative In the long term
Effective in the long term,
but not as effective as S4
Second most effective soil
alternative In (he long (erm
Most effective soil
alternative In the long term
Equally effective
groundwater alternative in
the long term
Equally effective
groundwater alternative in
the long term
Least effective pipeline
alternative In the long term
Second most effective
pipeline alternative In the
long term
Most effective pipeline
alternative In the long term
Reduction ol loxicity,
Mobility, or Volume
through Treatment
Does not reduce loiicity,
mobility, or volume
Reduces contaminant
mobility, but not lo (he
extent of S4
Second most effective in
reducing contaminant
mobility for soil •ll:rnallves
Most ellective in reducing
contaminant mobility for
soil alternatives
Does not reduce loxicity,
mobility, or volume
Docs noi reduce loxicity,
mobility, or volume
Does not reduce loxicily,
mobility, or volume
Second most effective in
reducing contaminant
loxicity, mobility, or volume
for pipeline alternatives
Most effective in reducing
contaminant toxlcily,
mobility, or volume for
pipeline alternatives
IOJI
         W/72/91

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
WSRC-RP-97-145
     Revision 1.1
     Page 61 of 74
                          Table 8. (Cont'd).  Comparative Analysis Summary

Alternative
SI: No Action
S3: Institutional Controls and Low
Permeability Cover
S4: Institutional Controls, and
Grouting
55: Institutional Controls,
Grouting, and Low
Permeability Cover,
Groundwater Monitoring
Gl: No Action
UZ: Uroundwaler Monitoring
PI: No Action
P4: Institutional Controls, Pipeline
Grouting, and Soil Excavation
and Disposition with FRB
Soils
P5A:bxcavalion and Oil-Unit
Disposal (SRS Disposal)
CtRCLA Criterion
Short-Term Effectiveness
Iviost effective soil alternative in ike
short term
Equally effective as S4 and S5 in
the short term
Equally elleclive as S3 and $5 In
the short term
Equally elleclive as S3 and S4 in
(he short term
Equally elTeclive groundwaler
alternative in the short term
Equally effective groundwaler
alternative in the short term
Most effective pipeline alternative
in the short term
Second least effective pipeline
alternative in the short term
Least elfeclive pipeline alternative
in the short term
Implementability
Easiest soil alternative to
implement
Keadily implemented; less
difficult than S4
Second most difficult soil
alternative to implement
Most difficult soil
alternative to Implement
Easiest groundwater
alternative to implement
Easily implemented;
however, more difficult than
Gl
Easiest pipeline alternative
to Implement
Second most difficult
pipeline alternative to
implement
Most difficult pipeline
alternative to implement
Cost
il^,$78
5285,132
SI ,227,694
SI, 460.929
No Cost
511.3,331
19,578
1319,265
$409,134
IOI6nvp dot ISB/Mtl OT'llAII

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                         Revision  1.1
 August 1998	Page 62 of 74

 Reduction of Toxicity. Mobility, or Volume

 No alternative completely reduces toxicity, mobility, and volume at the waste unit.  Alternative
 S5 ranks the highest in this category for the soil  alternatives because it achieves the greatest
 reduction in contaminant mobility.  Alternatives S4  and S3 also reduce contaminant mobility, but
 to  a  lesser extent than Alternative S5.  Alternative SI  (No Action) does not affect toxicity.
 mobility, or volume.

 Alternatives Gl and G2 have no effect on toxicity, mobility or volume.

 Alternative PSA, which removes contaminated material  from the waste unit, ranks first in this
 category for process sewer line area alternatives.  Alternative P4 ranks second because it reduces
 contaminant mobility. Alternative PI  (No Action) has no effect on toxicity, mobility, or volume.

 Short-Term Effectiveness

 Alternative SI  offers  the most short-term effectiveness of the soil alternatives. Alternatives S3,
 S4, and S5 rank equally in this category as they all  provide the same degree of worker exposure
 during implementation.

 Both  groundwater alternatives, Alternative Gl  and Alternative G2  are equally effective in the
 short  term.

 Alternative PI  is most effective in  the short term  for the process sewer line area alternatives.
 Alternative P4 is moderately effective due to limited remedial worker exposure to contaminants.
 Alternative  PSA is  the  least  effective  alternative  due  to  potential  worker  exposure  to
 contaminated material. None of the alternatives should affect the community during remediation.
 The site-specific health and  safety  plan addresses remedial worker risks from equipment
 operation for alternatives involving physical activities.

 Implementability

 Alternatives SI, S3, S4, and  S5 are  readily implemented; Alternatives  S4 and  S5 are more
difficult because they will require testing to determine the appropriate grout mixtures.

Alternative Gl is the easiest to implement for groundwater, followed  by Alternative G2.
IOJ&CTWP  09/12/91

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-1 45
 Savannah River Site                                                          Revision 1.1
 August 1998 _ Page 63 of 74
 Alternative PI is the easiest pipeline alternative to implement,  followed by Alternative P4.
 Alternative PSA is the most difficult to implement.
 The No Action alternative, SI, is the least expensive of the soil alternatives (total present worth
 cost, $9,578;  capital  cost  $0, and  O&M costs,  $9,578), followed by  Alternatives  S3  (total
 present worth cost $285,132; capital costs, $266,908;  and  O&M costs, 5118,224),  S4 ( total
 present worth cost $1,227,644; capital cost, $1,209470; and O&M costs, $18,224), and S5 (total
 present work costs, $1,460,929; capital costs, $1,441,705; and O&M costs, $18,224).

 The least expensive groundwater alternative is No Action, Gl (no cost), followed by Alternative
 G2 (total present worth cost $1 13,331; capital costs $0; O&M costs, $1 13,331).

 The No Action alternative for the  process sewer line  and  pipeline  soil,  PI,  is also the  least
 expensive in its category ($9,578).  Alternative PI is followed by Alternatives  P4 (total present
 worth cost, 5319,265;  capital costs, 5309,687; O&M costs, 59,578) and PSA (total present worth
 cost, $409,134; capital costs, $409,134; O&M costs $0).

 State and community Acceptance

 Alternative SI does not provide short and long-term protectiveness of human health and the
 environment and consequently, has not met state and Federal regulatory acceptance. Alternatives
 S3  and S4 do provide for reduced containment  mobility, however, these alternatives do  not
provide a permanent  reduction in contaminant mobility and  have not  met state and  Federal
regulatory acceptance. The state and Federal regulatory agencies have accepted and approved
Alternative S5 because it is the least expensive in the long term that provides  a most-effective
permanent reduction in contaminant mobility and poses minimal risk to remedial workers and
community. In addition, the Alternative S5 has met the community acceptance.

Both Alternatives  Gl  and  G2 are equally protective of groundwater since no impact  to  the
groundwater from the  operation of the F-Area Basin has been discovered. However, alternative
Gl, in conjunction with institutional controls, will be protective of human health by preventing
the ingestion of groundwater at less cost.  Also, groundwater monitoring, which forms an integral
part of the  Alternative S5,  when implemented in conjunction with Alternative S5, will ensure
that no contaminant leaches out and  enter the groundwater after the contaminated soil is grouted
I026cr»pdac JSB*lbO»aj/9»

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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                         Revision 1.1
 August 1998	Page 64 of 74
 and thereby, will protect the remedial workers as well as the community. The state and Federal
 regulatory agencies have accepted  Alternative Gl.  In addition, this alternative has met with
 community acceptance.

 Alternative PI does not provide short and long-term protectiveness of human  health and  the
 environment and consequently, has not met state and Federal regulatory acceptance. Alternative
 PSA does provide for the protection of human health by permanent reduction in the contaminant
 mobility;  however, this alternative is most difficult to implement since this alternative involves
 significant waste handling and transport. Consequently, Alternative PSA has not met state ar.d
 Federal acceptance or community acceptance.

 The state and Federal regulatory agencies have accepted  and approved Alternative P4.  This
 alternative when implemented in conjunction with Alternative S5, will provide  a permanent
 reduction  in  contaminant  mobility,  pose minimal  risk  to  the  remedial  workers  and  the
 community,  and is the least  expensive alternative.   In addition, the alternative  has met  the
 community acceptance.

 IX.    THE SELECTED REMEDY

 The selected remedies  for the FRB OU are: (1) for the basin soils:  Alternative S5: Institutional
 Controls, Grouting, a Low Permeability Cover, and Groundwater Monitoring; (2) for the former
process sewer line: Alternative P4:  Institutional Controls, Pipeline Grouting, Soil Excavation
 and Disposition in the Basin Soils, and; (3) for the groundwater: Alternative Gl: No Action. The
waste unit will be physically maintained  and institutional controls will  remain in place in
perpetuity.  Field conditions will be evaluated to determine the need for modifying the control
program or to identify if further remedial action is appropriate during the five-year ROD review.

 Since each remedy requires institutional controls, these controls are discussed here instead in the
 more detailed  description of  each  selected  remedies provided below.   Implementation  of
 institutional controls will involve both short- and long-term actions. For the short-term action,
 signs will be posted at the FRB OU indicating that this area was used for the disposal of waste
 material and contains buried waste. Additionally, existing SRS access controls will be used to
 maintain use of this site  for industrial use only.   In the long-term, if the property is ever
 transferred to non-Federal ownership, the U.S. Government will take those actions necessary
pursuant to  Section  120(h) of CERCLA.   These actions will include a  deed notification
 disclosing  former waste management and  disposal activities  as  well as any remedial actions
1026crvp doc JSB/blta M/72^l

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ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
Savannah River Site                                                       Revision 1.1
August 1998	Page 65 of 74
taken on the site and any continuing groundwater monitoring commitments.  These requirements
are also consistent with the intent of the RCRA deed notification required at final closure of the
RCRA  facility if contamination  would remain at the unit.  The  deed notification shall,  in
perpetuity, notify any  potential purchaser that the property has been used for the management
and disposal of radioactive materials and hazardous substances. The deed shall also include deed
restrictions precluding residential use of the  property.  However, the  need for  these deed
restrictions may be reevaluated at the time of transfer in the event that contamination no longer
poses an unacceptable risk under  residential  use.   Any  revaluation  of  the  need  for deed
restrictions would be done through an amended ROD with the Environmental Protection Agency
(EPA) and the South  Carolina Department of Health and  Environmental Control  (SCDHEC)
approval.  In  addition, a certified  survey of the  area will be prepared by a registered land
surveyor and will be included in  the post-ROD documents.  The survey will  be reviewed and
updated, as necessary,  at the time the site is transferred and will be recorded with the appropriate
county recording agency.  The FRB OU is located in Aiken County.

Per the EPA-Region IV Land Use Controls (LUCs) Policy,  a Land Use Control Assurance Plan
(LUCAP) and a  Land Use Control  Implementation Plan (LUCIP) will  be developed and
submitted to the regulators for their approval.  The LUCAP will be submitted under separate
cover whereas the LUCIP will be submitted with  the Remedial  Work Plan/Remedial Design
Report/Remedial Action Work Plan (RDWP/RDR/RAWP) for the FRB OU  in accordance with
the post-ROD document  schedule is  provided in Figure 16.  The LUCAP  will  include the
information  requested in the  EPA policy.  The LUCIP  details how  SRS  will   implement,
maintain, and monitor the land use control elements of the FRB OU ROD to insure  that the
remedy remains protective of human health.

The LUC objective necessary to ensure the protectiveness of the preferred alternative is:

Prevent unauthorized access/exposure to contaminated grout  and basin soil

The institutional controls  required to prevent unauthorized  exposure to the contaminated grout
and soil include the following:
•  Controlled access to the FRB waste unit through existing SRS security gates and perimeter fences
   and the site use/site clearance programs

•  Signs posted  in the area to  indicate that contaminated grout and soil are present in the waste
   unit
I026crwpdoc JSB/blb 09/12/91

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ROD for the F-Area Retention Basin (281-3F)
Savannah River Site
August 1998
WSRC-RP-97-145
      Revision 1.1
     Page 66 of 74
•   Notification of  contaminated  grout  and  soil to  any  future  landowner through  deed
    notification, as required under CERCLA Section 120(h)

The present worth, capital,  and Operation and Maintenance  (O&M) costs for each selected
remedy is provided Table 9.
Table 9.    Selected Remedy Cost
Remedy
Alternative J^* (Soils)
Alternative P4 (Process
Sewer)
Alternative Ul*
(Groundwater)
Total Cost
Present worth
Cost
$1,461,000
$320,000
No Cost
$1,781,000
Capital Cost
i 1,442,000
S3 10,000
No Cost
$1,752,000
U&M Cost
iiy.ooo
510,000
No Cost
$2y,ooo
* Alternative S5 includes the costs for groundwater monitoring.

The selected remedy will meet all of the RAOs by eliminating the potential for direct radiation,
exposure, ingestion of soils,  and  eliminating future impacts to groundwater.  The  selected
remedies  comply  with all   applicable  or  relevant  and  appropriate  Federal  and  state
requirements/regulations.

The SCDHEC has modified the SRS RCRA permit to incorporate the selected remedies.
Soils

Under the selected remedy (Alternative S5), deep basin soil will be grouted from approximately
0.6 m (2 ft) above the basin bottom to approximately 1.8 m (6 ft) below the basin bottom or
approximately 4.3m (14 ft.) below grade.  The purpose of the grout is to prevent leaching of Sr-
90, which is  the  only contaminant migration  COC (CMCOC), to the  groundwater above the
MCL of 8.0 pCi/L.  Furthermore, grouting the soil provides an additional layer of protection by
offsetting the inherent uncertainty associated with the mathematical  model used to predict
contaminant migration. Grouting will also immobilize other deep contaminants which represent
principal threat source material such as Cs-137, Ra-226, thallium, arsenic., etc and further reduce
infiltration of water through the deeper contaminated soils. Tc-99 was originally identified in the
RFI/RI/BRA as a CMCOC. Subsequent evaluation with the RESRAD model eliminated it as a
concern.  However, as is the case with other  radioactive/non-radioactive contaminants, the
selected remedy will also immobilize Tc-99.  Grouting of the soils is preferred over only  capping
because it meets  the CERCLA preference for treatment.  A cover will be provided over the
I026crwp doc JSB/Mb 09/22/91

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ROD for the F-Area Retention Basin (281-3F)                           WSRC-RP-97-145
Savannah  River Site                                                  .        Revision 1.1
August 1998	Page 67 of 74
stabilized soil to minimize storm water percolation and erosion.  The cover is also very effective
in reducing direct radiation exposure received  from radionuclides in  the shallow soil.  This
alternative  includes institutional controls (discussed above) to prevent exposure of current and
future workers to all the Human Health COCs in the waste unit and direct  radiation from  the
waste unit.  Since waste is left in place, the future use of land will be restricted to industrial use
to prevent unrestricted residential use of the land.

In situ grouting reduces air emissions and is relatively simple to implement.  However, in situ
grouting results in a slight increase in waste volume.  The volume of the basin, when clean soil is
excavated prior  to  grouting,  will be adequate to accommodate any increase in grouted soil
volume. The estimate volume of grout/soil mixture is 6,600 m3 (8,100 yd3)..

Process Sewer Line

The  selected remedy for the process  sewer  line and associated  soils will include pipeline and
manhole grouting, and excavation and disposition of pipeline soils (approximate volume 240 m3
or 300 yd 3) into the basin and institutional controls.  In this alternative, the localized areas of the
contaminated soil around the pipeline hot spots will be excavated.  If necessary, the sections of
pipeline associated with the hot spots will also be excavated. The excavated soil and pipeline
will  be treated in the basin by in situ grouting along with soil from the basin.  Clean soil from
SRS borrow areas will be used to fill excavated areas around the pipeline.  Completion of this
remedial action  will  meet  all  applicable   or  relevant  and  appropriate  Federal  and  state
requirements/regulations, and all the remedial action  objectives by reducing risk associated with
the process sewer line  to acceptable  levels.   This alternative includes  institutional controls
(discussed above) to prevent exposure of current and future workers to all  the Human Health
COCs in the waste unit and direct radiation from the waste unit.  Since waste is left in place, the
future use of land will be restricted to industrial use to prevent unrestricted residential use of the
land.

Groundwater

The selected remedy for the FRB OU groundwater is "No Action".  The history of the FRB, the
results of the groundwater modeling, and the current groundwater data  prove that the  FRB-
associated groundwater poses no risk to human health or the environment.  Through computer
modeling and sampling it has been shown the FRB OU has not contributed to contamination in
the groundwater.  However, to ensure that the grout-waste mixture has accomplished the required
immobility  of contamination,  a groundwater-monitoring program will be established under the

l02
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ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
Savannah River Site                                                         Revision 1.1
August 1998	Page 68 of 74
selected  remedy for basin soils  (Alternative S5).  The groundwater will be monitored semi-
annually until it is confirmed that the remedial response action for the FRB OU has achieved the
required stabilization of the contaminants.

Since waste  is left in place in the FRB  waste unit, the future use  of land will be restricted to
industrial use to prevent unrestricted residential use of the land and five-year ROD reviews will
be required.

X.     STATUTORY DETERMINATIONS

Based on the RI/BRA report, the FRB OU poses future risks and hazards to the on-unit resident,
construction  worker, and industrial worker.  The  future risks are associated with:   external
exposure to COC  radionuclides by direct contact into the  FRB OU soils; potential exposure to
principal threat source material; ingestion of FRB OU soils and pipeline sediment and/or produce
grown  in soils contaminated with radionuclides; and ingestion of groundwater containing Sr-90
(which can leach out and migrate to groundwater) with concentrations above MCL. Therefore,
institutional controls, in situ grouting of soils, and installation of a low permeability cover over
the grouted soils in the basin are necessary  for the former basin area soils. Institutional controls,
pipeline grouting,  excavation, and disposal  of pipeline associated soils with basin area soils  are
necessary for the process sewer line area. No action is required for the groundwater;  however,
groundwater shall be monitored to confirm that the source remediation has achieved the required
stabilization of contaminants.  The grouting (using S/S treatment) will reduce the mobility of the
radionuclides (the  principal  threat  source  material),   thereby  preventing  migration  of
radionuclides to the groundwater.  The  soil cover provided over the grouted soil will  shield
radiation exposure from the  radionuclides  contained in the grouted soil in  the basin and also
prevent ingestion of soil and/or produce grown in FRB OU soils.

The selected remedy is protective of human health and the environment, complies with federal
and state ARARs, and is cost-effective.  The ARARs are met by minimizing the potential  for
contaminant  migration  into the groundwater by stabilizing the soil into a nonleachable form.
(The size and location of the waste unit radioactive contaminants preclude a remedy  in which
contaminants could be excavated and treated effectively).   For cost comparison among the
considered alternatives and to determine  the most cost-effective  alternatives, cost estimates
prepared for  the alternatives were based on a variety of cost estimations data, including generic
unit costs, vendor information, and prior similar estimates prepared for other SRS sites with
almost identical characteristics. Cost estimates were prepared for capital costs, O&M costs, and

I026
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 ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
 Savannah River Site                                                        Revision 1.1
 August 1998	Page 69 of 74
 present worth costs. Finally, for selecting the cost-effective.remedial action for the FRB OU. an
 analysis was performed by considering the following factors:
 •      the effective life of the remedial action
 •      the uncertainty regarding some of the  COCs, especially radionuclides that could stay
       absorbed in the contaminated soil for over 1,000 years and could pose a future long-term
       unacceptable risk even beyond 100 to 200 years
 •      the preference for treatment versus containment per CERCLA requirements, and
 •      long-term versus short-term in situ management of radioactive wastes

 Based on the analysis, the selected remedial action was determined as a cost-effective measure
 that  would  provide  a permanent  reduction  of contaminant  mobility,  meet the  statutory
 requirements of CERCLA, ensure future compliance with ARARs (MCLs or RBCs), and present
 a reasonable value for the protection of human health and the environment.

 Contaminated soils represent principal threat source material and will be stabilized to prevent or
 mitigate exposure to highly toxic contaminants and  permanently reduce mobility  of highly
 mobile contaminants at depth.  The selected remedy utilizes long-term permanent solutions and
 treatment technology  to the maximum  extent  practicable  and  satisfies the preference  for
 treatment.

 Since soil and pipeline sediment is grouted below grade, long-term weathering and the potential
 for leaching of contaminants are minimized. Worker and public safety is ensured by minimizing
contact with contaminated media.

Section 300.430 (f) (4) (ii) of the NCP requires that a five-year review of the ROD be performed
if hazardous substances, pollutants, or contamination remain in the waste unit.  The three parties
(DOE, SCDHEC, and EPA) have determined that a five-year review of the ROD for the FRB OU
will be performed to ensure continued protection of human health and the environment.

XI.    EXPLANATION OF SIGNIFICANT CHANGES
A public comment and CAB recommendation were received on the Statement of Basis/Proposed
Plan; raising a concern regarding the need to grout the soil in addition to capping the basin soil.
A  response to the concern is included in  the Responsiveness Summary (Appendix  A of this
I026ciwp doc JSattb OWU/91

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ROD for the F-Area Retention Basin (281-3F)                        WSRC-RP-97-145
Savannah River Site                                                    Revision 1.1
August 1998	Page 70 of 74
document).  No significant changes were made as a result of public comment.  The selected
alternatives from the Statement of Basis/Proposed Plan remain the selected remedial action.

XII.   RESPONSIVENESS SUMMARY

The Responsiveness Summary is provided as Appendix A of this document.

XIII.  POST-ROD DOCUMENTS SCHEDULE AND DESCRIPTION

       1.   The Post-ROD documents schedule is listed below and is illustrated in Figure 20.

       2.   Corrective Measures Implementation/Remedial Design Work Plan (CMI/RDWP),
          Revision 0, for the FRB OU will be  submitted for EPA and SCDHEC review 2
          calendar days after issuance of the ROD.

       3.   SRS revision of the CM/RDWP will be completed 30 calendar days after receipt of
          all regulatory comments.

       4.   Corrective Measures  Implementation/Remedial  Design Report/Remedial  Action
          Work Plan (CMI/RDR/RAWP), Revision 0, will be submitted 75 calendar days after
          issuance of the ROD.

       5.   SRS revision of the CMI/RDR/RAWP will  be completed 45 calendar days after
          receipt of all regulatory comments.

       6.   Remedial Action Start on the soils will  begin following  EPA and SCDHEC approval
          of the CMI/RDR/RAWP.

       7.   Post-Construction Report (PCR), Revision 0, will be submitted to EPA and SCDHEC
          after completion of the remedial action.
Post-ROD Document Description

A  brief  description  of the  post-ROD  documents  is  provided.  Corrective  Measures
Implementation/Remedial Design Work plan (CMI/RDWP)
I02
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ROD for the F-Area Retention Basin (28I-3F)
Savannah River Site
August 1998
WSRC-RP-97-145
     Revision 1.1
    Page 71 of 74
Figure 20.   FRB Post-ROD Document Schedule
ACTIVITY

EARI.V EARLY ORIO
START FINISH OUR
RECORD OF DECISION
EPA/SCPHKC ROD ISSUANCE

2RSF.P9S 0
CORRECTIVE MEASURE /REMEDIAL DESIGN WORKPLAN
DEVELOP CM/RD MORKPLAM

SRS SURHITTAL or RFV. 0 CH/RDWP
EPA/SCDHEC REVtEM REV 0 ROMP
SRS INCORPORATE EPA/SCDHEC COMMENTS
SRS ggSMITTAL RCV. 1 CM/RDMP
EPA/SCDHEC PIHAL REVIEW REV
. t CM/RDMP
EPA/SCOHEC APPROVAL REV. 1 CH/MDMt*
22APR9* 30SRP9B ID
3OKF.P9H 0
IOCT98 1CWTV9R 47
17NOV9I 16nEC9» 10
16DEC98 0
17CfC9l ISJAN99 10
IUAN99 0
REMEDIAL DESIGN REPORT/ REMEDIAL ACTION WORKPLAN
DEVELOP CM/RDR/RA HOAKPLAH

SRI SUBM1TTAL OP REV. '0 CM/RDR/AAMP
EPA/SCDMCC HBVXEM OF REV. 0
RCR/RAWP
SAft INCORPORATE EPA/SCDIIEC COMMENTS
SRS nUSMITTAL OF REV. 1 ADA/RAMP
EPA/SCDMBC PINAL REVIEW RXV
EPA/SCRHRC APPROVAL Or RCV.
R A START
R A STA^T
. 1 ROM /RAMP
1 RDR/RAMP


7AU09R 200CT9S 5J
200CT9S 0
210CT9I IBJAH99 90
1>.1AN99 2HAR99 «1
2MAR99 0
1HAR99 1APR9* 30
1APR9* 0

4APB99 0
CONSTRUCTION ACTIVITIES
CONSTRUCTION START COVER/GWMl
4APN99 0
CONSTRUCTION 4APR99 22JULOO 47«
CONSTRUCTION COMPLETE
POST CONSTRUCTION

24JULOO 0
REPORT/FINAL REMEDIATION PLAN
DEVELOP POST CONSTRUCTION REPORT
SRS SUBH1TTAL OP REV.O POST
EPA/SCmiFC, (ICVIEM
CONSTRUCTION REPORT

SRS INCORPORATE EPA/SCHDEC COMMZHTS
SRI CUBMITTAL Of REV.l POST
CONSTRUCTION REPORT
EP8/SCHDBC PIMAL REVIEM 1 APPROVAL
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ROD for the F-Area Retention Basin (281-3F)                          WSRC-RP-97-145
Savannah River Site                                                        Revision 1.1
August 1998	Page 72 of 74

Based on the data and information contained in the previous documents pertaining to FRB OU
(including  RI/BRA  Report, Corrective  Measures  Study/Feasibility  Study,  Statement  of
Basis/Proposed Plan, and Record of Decision), CMI/RDWP will provide a description of the
remedial action design for the FRB OU.

The remedial action design discussed in CMI/RDWP would include a basic scope description of
the following tasks that will be performed during the remedial design:
•  Topographic survey and preparation of site drawings
•  Preparation of erosion control plan

•  Development of acceptance  criteria  for the S/S process, and  preparation of construction
   specifications for S/S activities

•  Preparation of statement of work for final soil matrix design
   •  Design of the soil cover system
   •  Determination of institutional controls for the basin and process sewer line
   •  Schedule for developing the  LUCIP under EPA Region IV policy on Land use Controls
      at Federal Facilities
   •  Preparation of groundwater monitoring plan
   •  Preparation of health and safety and cover system maintenance plans

Corrective Measures  Implementation/Remedial Design Report/Remedial Action  Work  Plan
(CMI/RDR/RAWP)

This  document will combine the contents and purposes of the two post-ROD documents:  the
Corrective Measures Implementation/Remedial Design Report (CMI/RDR) and the Corrective
Measures Implementation/Remedial  Action Work Plan (CMI/RAWP).  This combined document
will primarily outline and describe the remedial design and remedial action planned for the FRB
OU and  will  address:

1.  a remedial design summary highlighting the  critical  design inputs  and  outputs that are
   consistent with the remedial action objectives stated in the ROD; and
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 2.  construction strategy summary highlighting  the  critical  components  of the  construction
    phase, including the remedial action schedule, a design change procedure, requirements of
    health and safety aspects driving the construction phase and project closeout.  The current
    schedule for completing post-ROD documents and RA start may require a phased approach
    to the completion  of this document (e.g., validation of soil solidification mix design  not
    completed until after RA start). This document will also  include a brief discussion on the
    contents of the post-construction report. The CMI/RDR/RAWP will primarily include:
    •  Site drawings showing the boundaries of the basin and locations of process sewer lines
       and manholes, etc.
    •  Design Criteria including performance criteria and acceptance activities for S/S remedial
       action
    •  Design plans and specifications
    •  Permitting requirements
    •  Post-documentation identification and schedule to accommodate phased RA approach
    •  Erosion control plan
    •  Groundwater monitoring well maintenance plan
    •  Land Use Controls Implementation Plan (LUCIP)
    •  Remedial action schedule and remedial design change control
    •  Waste management plan, including decontamination requirements
    • Health and safety plan
    • Maintenance plan, including institutional control requirements
    • Requirement for project closeout
    • Post-construction report description

XIV. REFERENCES

CFR 1991 Reference:  Code of Federal Regulations. National Primary Drinking Water
Regulations, 40 CFR, Part 141, pp. 578-715. Washington, DC.
EPA, 1988.  Guidance for conducting Remedial Investigations and Feasibility Studies under
CERCLA, EPA/S40/G-89/004, Washington, DC (1988).
EPA, 1989a.   Risk Assessment Guidance for Superfund (RAGS). Volume I: Human Health
Evaluation  Manual (Part  A), Office of Emergency and  Remedial Response, USEPA/540/1-
89/002, Washington, DC (1989).

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EPA, 1989b.  Risk Assessment Guidance for Superfund (RAGS).  Volume II: Environmental
Evaluation  Manual,  Office  of Emergency  and  Remedial  Response,  USEPA/540/1-89/001.
Washington, DC (1989).

EPA, 1998, Assessing Land Use Controls at Federal Facilities, a memorandum issued  by EPA
Federal Facilities Branch, 4WD-FFB, dated April 21,1998.

FFA, 1993,  Federal Facility Agreement for the Savannah River Site, Administrative Docket
Number 89-05-FF, Effective Date: August 16, 1993, WSRC-05-94-42

WSRC, 1993b.  RCRA Facility Investigation/Remedial Investigation Program Plan, Revision 1,
WSRC-RP-89-994, Savannah River Site, Aiken, SC (1993).

DOE,  1994a. Public  Involvement.  A  Plan for  the Savannah  River  Site, Savannah  River
Operations Office, Aiken, SC (1994).

WSRC, 1994b.   Phase II Remedial  Investigation Work  Plan for the F-Area Retention  Basin
(281-3F) (U), WSRC RP-94-498, Savannah River Site, Aiken, SC (May 1994).

WSRC, 1994c.  Report on the Robotics Investigation of the F-Area Retention Basin (281-3F)
Process Sewer Pipeline (U). Revision 0, WSRC-RP-94-1105, Savannah River Site, Aiken,  SC
(September 1994).

EPA, 1995.  Region IV. Supplemental Guidance to RAGS: Region IVBulletins. Ecological Risk
Assessment (November 1995).

WSRC, 1996. Laboratory-Scale Immobilization Study Report for the L-Area Oil and Chemical
Basin, WSRC-RP-95-15, Rev. 0, Savannah River Site, Aiken, SC

WSRC, 1997a.  Ground-water Sampling Report with Residential Risk Assessment for the F-Area
Retention Basin (28I-3F) (U),  WSRC-RP-96-00905, Revision 0, March  1997.Savannah  River
Site, Aiken, SC

WSRC, 1997b.  Remedial Investigation with the Baseline Risk Assessment Report for the F-Area
Retention Basin (281-3F) (U),  WSRC-RP-96-356, Revision  1.2,  Savannah River Site, Aiken,
SC.

WSRC, 1997c.  Corrective Measures Study/Feasibility Study for the F-Area Retention Basin
(281-3F) (U). WSRC-RP-96-00906, Revision  1.2, Savannah River Site, Aiken, SC (November
1997).

WSRC, 1997d.  Statement of Basis/Proposed Plan for the F-Area Retention Basin (28J-3F) (U).
WSRC-RP-97-00128, Revision 1.2, Savannah R:ver Site, Aiken, SC (November 1997).
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                                  APPENDIX A


                         RESPONSIVENESS SUMMARY
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                             Responsiveness Summary
The 45-day public comment period for the Statement of Basis/Proposed Plan (SB/PP) for the F-
Area Retention Basin (281-3F) began on January 20, 1998, and ended on March 5,  1998. SRS
briefed the public on the path forward for the remediation of the basin in a Citizens Advisory
Board (CAB) subcommittee meeting held on February 23, 1998. At the meeting, a concern was
raised over the need to grout the soil  in addition to providing a low permeability cap over the
basin area. Subsequently, an extension for the public comment period was granted extending the
public comment period to April 4,1998. A formal public comment (made by Todd V. Crawford)
was received which questioned the risk reduction and necessity of the soil grouting. A formal
CAB recommendation  (see attached  Recommendation No. 56) was also received  on March
28,1998. A response to these concerns is provided below.  The public and CAB comments are
italicized and the response is bolded.

Public Comment:

The Remedial Action Objectives are stated as:

     Prevent future ingestion of shallow aquifer groundwater

     Prevent direct contact with and ingestion of soils

     Prevent direct contact with and ingestion of sediments from the abandoned process sewer
     line

     Prevent the transport of contaminants from subsurface soils to groundwater

The first  three of the above are met now and  would  be met in the  future considering that
institutional  controls  are part of all  alternatives and land use plans clearly  put the F-Area
Retention Basin and associated pipelines in an industrial area.

The first of the Remedial Action Objectives above removes the concern about the last one. On
top of that there is other contamination in the shallow groundwater in the vicinity which would
negate interest in drinking the water.
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 The scenarios upon which the risk numbers are based are not stated in enough detail to evaluate.
 They must have been based on direct exposure to the contaminated soils, which are  nou under
 about 10  feet of clean dirt.  Such direct exposure could not happen unless institutional controls
 were lost  for the 200-Area plateau. If this happens the F-Area Retention Basin would  be a minor
 problem compared to other  locations in the 200-Area.  If loss  ^f institutional controls  was
 assumed,  the risk numbers would sure be misleading to the public.

 Contaminates of concern include Arsenic. It is not clear if this came from the F-Area processes
 or is a result of early cotton farming. Or is the  Arsenic and the Radium-226 from coal  pile
 runoff?  Is the K-40 from the  processes or  is it the  naturally occurring K-40?  Additionally,
 evaluation of the risk reduction as a function of the various alternatives for remedial action is not
 included.  It appears that the main justification for the grouting of the basin soil under Alternative
 S5 is to reduce leaching but perhaps a cap on top of  the current clean fill would be sufficient.
 The  primary  contaminate of concern for leaching is Sr-90 with a 28.6 year half life so caps may
 well make significant difference in  concentrations  reaching the groundwater.  How  much
 remediation is justified when nobody will be drinking the water?

 CAB Recommendation:

 Because the F-Area Retention Basin and associated pipelines are in the nuclear industrial area
 and  will be under institutional controls followed by deed restrictions,  and because this site has
 been buried for 20 years with no identified contaminant migration, the SRS Citizens Advisory-
 Board believes that the Remedial Action  Objectives can be met with less  extensive remediation.
 CAB recommends a low-permeability cap for the basin, continued groundwater monitoring and
grouting the  inside of the pipeline. These changes should reduce the total remediation costs by
 about $1 million.

 Response:

 A risk  assessment for the F-Area Retention Basin  Source Operable  Unit  (FRB  OU) was
 performed in accordance with CERCLA guidance. The relative risk values for the FRB OU
 indicate that remediation  is required per  the statutory requirements of CERCLA.   Both the
 former basin and process sewer line areas represent a risk to a future on-unit resident as well as
 to a  future industrial worker.  Radionuclides including cesium-137, radium-226, actinium-228,
 and  strontium-90 are the primary risk  drivers for the direct radiation pathways and represent over
 90 percent of the risk. These contaminants also present a future  long-term groundwater risk
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 resulting  from their leaching out from the soil and entering the groundwater at levels above
 applicable state regulations(i.e., MCLs).

 Since the FRB OU poses unacceptable risk and a remedial action is appropriate, a Corrective
 Measures Study/Feasibility Study (CMS/FS)  was performed to identify appropriate  remedial
 alternatives.  The alternatives were selected and screened in accordance with CERCLA  guidance
 and a detailed analysis of the selected alternatives  was performed using the nine evaluation
 criteria  as required by  the  NCP.   Alternative  S5:  Institutional Controls, Grouting, Low
 Permeability Cover, and Groundwater Monitoring was  selected because it  would provide  a
 permanent reduction in contaminants (radionuclides) mobility and prevent  contact with and
 ingestion  of contaminated  soil.  To ensure the effectiveness of this  alternative, groundwater
 monitoring downgradient of the grouted mass is also included in this alternative. This alternative
 is also very effective in reducing potential direct radiation exposure received from radionuclides
 and grouting the  soil also provides an additional layer of protection by offsetting the inherent
 uncertainty associated with the mathematical model used to predict contaminant migration. EPA
 and SCDHEC approved both  the CMS/FS and the SB/PP documents that justified the selected
 remedy. The selected remedy provides the best alternative because it meets EPA  preference for
 treatment  versus  containment per CERCLA requirements and provides an additional  layer of
 protection.

 The quantifiable reduction of baseline risk is an essential consideration  in remedy  selection. All
 remedial alternative  evaluations  analyze the risk  remaining after remediation.   This is done
 through the setting of risk-based  remediation goal options  (RGOs). Not all cleanup objectives,
 however, are risk-based.  The National Contingency Plan includes a preference for treatment of
principal threat wastes.  Therefore, to determine the future  risk posed by the  radionuclides
(principal  threat wastes) the risk-based modeling was performed during the development of the
Remedial  Investigation/Baseline  Risk Assessment (RI/BRA) report for the FRB OU.  It was
determined that some of the contaminants of concern (COCs), especially radionuclides, could
 stay absorbed in the contaminated soil for over 1000 years and could pose a future long-term
 unacceptable risk even beyond  100 to 200  years.  The selected remedy  (Alternative  S5)
 incorporates  this preference  as  a key  element  of the  prudent  long-term  management  of
radioactive waste  in situ.

The soil cover provided over the former basin area and contaminated soil associated  with the
process sewer line area, without grouting the soil, could provide a permanent long-term solution
by  simply containing  the contaminants if well maintained for an extended period  of time.
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However, in terms of total remediation cost, the soil cover would cost less initially but would
likely need redesign/reconstruction two or three times during the entire remediation cycle, which
could go beyond 100/200 years.  In the long term, the cost of the soil cover would approximate
the cost of the selected remedy. Hence, in situ grouting coupled with a low permeability cover
was determined to be the best alternative that would provide permanent reduction of contaminant
mobility, meet the statutory requirements of CERCLA, and also ensure future compliance with
applicable state regulations (i.e., MCLs).
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                      Savannah River Site Citizens Advisory Board
                                 Recommendation No. 56
                                     March 24,1998
                         Remediation of F-Area Retention Basin

 Background:

 The F-Area Retention Basin  is  an  unlined basin 120  by 200 feet, which collected  lightly
 contaminated cooling water from the F-Area Canyon Facility as  well as stormwater drainage
 from the F-Area Tank Farm.  The basin was used from 1955 to 1972.  In 1978, its soil was
 sampled and analyzed, contaminated soil removed, and the basin closed.  Closure consisted of
 filling the basin with about 7 to 10 feet of clean dirt and seeding the surface with grass.

 Numerous  environmental  investigations  were  completed on the  retention  basin  and  the
 connecting process sewer line  between 1993 and 1997.  Extensive sampling data and analyses
 were published along with pathway and risk calculations.1  The most significant contaminates are
 Arsenic and Cesium-137.  Also, fate  and transport analyses have indicated that levels of certain
 radionuclides  (e.g.,  lechnetium,  strontium) could exceed acceptable  concentrations  in  the
 groundwater under the basin. The risk analyses, under conservative assumptions, indicate a risk
 above  the  CERCLA  guidelines  only   for an  onsite  resident  exposed to  the  remaining
 contaminated soils in the basin.   However,  there is currently no risk to onsite workers or the
 offsite public.  Further, this site is located in an industrial cleanup zone (see Motion 2).

 Remedial  Action Objectives  for  an onsite resident have  been  identified  and remediation
 alternative  have been evaluated.2  These  Remedial Action  Objectives are:   prevent  future
 ingestion of shallow  aquifer groundwater; prevent direct contact with  and ingestion of soils
(basin and pipeline); prevent direct contact with and ingestion of sediments from the abandoned
process sewer line;  and prevent the transport  of  contaminants  from  subsurface  soils  to
 groundwater (basin and  pipeline).   Remedial  alternatives  were evaluated for basin soils  (4
 alternatives), for  groundwater (2  alternatives)  and process  sewer line and pipeline soils  (3
 alternatives). <2J)  All alternatives require institutional control and the recording of basin and
pipeline locations as deed restrictions before releasing the land to the public.   The preferred
1 Remedial Investigation Report with the Baseline Risk Assessment for the F-Area Retention Basin (281-3F), final,
WSRC-RP-96-356, Rev. 1.2, July 1997
1 Corrective Measures  Study/Feasibility Study for the F-Area  Retention Basin (281-3F),  Final, WSRC-RP-96-
00906, Rev. 1.2, November 1997
J Statement of Basis/Proposed Plan for the F-Area Retention Basin (281-3F). Final, WSRC-RP-97-00128, Rev. 1.2,
November 1997
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alternatives are:  for the basin soils - institutional controls, grouting and low permeability cover
(51,460,929); for groundwater - no action (S9.578); and for the process sewer line and pipeline
soils - institutional controls, pipeline grouting and soil excavation and disposition with the basin
soils  (5319,265).   The reduction in  risk was not evaluated quantitatively  for  any of these
alternatives; however, the relative risk reductions were evaluated qualitatively.

Recommendation:

Because the F-Area Retention Basin and associated pipelines are in the nuclear industrial area
and will be under institutional controls followed by deed restrictions, and because this site has
been buried for 20 years with no identified contaminant migration, the SRS Citizens Advisory
Board believes  that the Remedial Action Objectives can be met with less extensive remediation.
We recommend a low-permeability cap for the  basin, continued groundwater monitoring and
grouting the inside of the pipeline.  These changes should reduce the total remediation costs by
about $1 million.

Because the  amount of risk reduction for different  remediation alternatives is critical  in the
selection of cost effective remediation strategies, the SRS Citizens Advisory Board recommends
that in the future that all SRS remediation studies  include analyses of the risk remaining after
remediation  for the most  likely  alternative and  the most probable pathway and exposure
scenarios.

Furthermore, the  extensive analyses and  documentation  for the F-Area Retention  Basin and
associated pipeline probably cost as much  or more than the planned remediation. This leads us
to make the more general recommendation that the three agencies (DOE, EPA  and  SCDHEC)
expeditiously implement the Plug-In-ROD  approach to reduce future paperwork costs.
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