PB95-964015
                             EPA/ROD/R04-95/225
                             April 1995
EPA  Superfund
       Record of Decision:
       Savannah River Site (US DOE)
       (O.U. 9), Aiken, SC
       4/13/1995

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             United States Department of Energy
                     Savannah River Site
              Interim Action Record of Decision
                Remedial Alternative Selection
                             for
           H-Area Groundwater Operable Unit (U)

                Revision.1 April 1995
Prepared by:

Westinghouse Savannah River Company
Savannah River Site
Aiken, SC 29802
            Prepared for the U.S. Department of Energy Under

                   Contract DE-AC09-89SR18035

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
                                            	April 1995
                                                                    t.
                           Interim Action Record of Decision
                                   Table Of Contents
Section                                                                                 Page

Declaration for the Interim Action Record of Decision	1

Site Name and Location	1

Statement of Basis and P -pose	1

Assessment of the Site	1

Description of the Selected Remedy	2

Declaration Statement	2

I. Site and Operable Unit Names, Locations, and Descriptions	3

n. Operable Unit History and Compliance History	3

      Operable Unit History	3

      Compliance History	".	3

HI.  Highlights of Community Participation	4

IV.  Scope and Role of Operable Unit Within the Site Strategy	4

V. Summary of Operable Unit Characteristics and Contaminants	4

VI.  Summary of Operable Unit Risks and Basis for Remedial Action	6

Vn.  Description of Alternatives	6

Vm. Summary of Comparative Analysis of Alternatives..	11

DC.  Selected Remedy	11

X Statutory Determination	15

XI.  Explanation of Significant Changes	,	15

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Interim Action ROD                                                     WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                              Revision 1
•	April 1995
                                                                 c.
Tables

1.     Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance.

2.     Evaluation of Alternative Actions Considered for Remediation of Groundwater Contamination.


Figures

1.     Site Area Map

2.     H-Area Hazardous Waste Management Facility

3.     Contaminant Plumes in Water Table Aquifer, F and H Area Groundwater Operable Units.


Appendices

A.     References for Development of ROD Format

B.     Responsiveness Summary
                                            11

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
              	April 1995

                     Declaration for the Interim Action Record of Decision
Site Name and Location

H-Area Groundwater Operable Unit
Savannah River Site
Aiken County, South Carolina

The H-Area Groundwater Operable-Unit is the groundwater associated with the H-Area Hazardous Waste
Management Facility (HWMF). Both the H-Area Groundwater Operable Unit and the H-Area HWMF are
part of the H-Area Fundamental Study Area.  The H-Area HWMF (Building Numbers 904-41G, 904-45G,
904-46G, and 904-56G) is listed as a Resource Conservation and Recovery Act (RCRA) regulated unit in
Appendix H of the Federal Facility Agreement (FFA) for the Savannah River Site (SRS).  These terms
have been defined in the Interim Action Proposed Plan for the H-Area Groundwater Operable Unit That
document is part of the administrative record for this unit and is the document on which this declaration
and the accompanying Record of Decision are based.

Statement of Basis and Purpose

The purpose of this Interim Action Record of Decision (IROD) is to address the potential concerns at the
H-Area Groundwater Operable Unit under a program that comprehensively and responsively meets the
needs of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and
supports the SRS RCRA Permit as the primary decision-making authority. If the remedy appearing in the
permit is significantly revised, a review of this interim action will be performed to determine whether
requirements for continued protection of human health and the environment  are being met.

This document presents the selected interim corrective action for the H-Area Groundwater Operable Unit
at the SRS, which was developed in accordance with the FFA.  This decision is based on the
Administrative Record File for this specific unit.  The selected interim action under CERCLA is no
further action beyond that required by the corrective action as identified in the SRS RCRA Permit

Assessment of the Site

The H-Area HWMF is a source specific operable unit within the H-Area Fundamental Study Area. The
H-Area HWMF is located in the center of SRS, Southwest of Road E and North of Road 4 approximately
16 miles from the nearest plant boundary. The H-Area HWMF consisted of three unlined earthen basins
that had a combined maximum operating capacity of 26.5 million gallons of  waste water during operation.
The groundwater contamination plume associated with these basins is called  the H-Area Groundwater
Operable Unit and is observed in a zone which extends from the water table surface to approximately  ISO
feet below land surface and covers an area of approximately 200 acres.  The primary contaminants are
tritium, alpha, and beta emitting radionuclides, and hazardous metals.  The potential pathway for
contamination from the H-Area Groundwater Operable Unit is through discharge of contamination into an
onsite stream.

Remedial alternatives were developed for corrective action of the H-Area Groundwater Operable Unit as
part of the SRS RCRA Permit process. Monitoring and investigation of the groundwater operable unit is
being conducted.  DOE is scoping a phased approach to identify the optimal  sequence of activities for
corrective action.

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Grouncfwater Operable Unit                                               Revision 1
	.	April 1995
                                                                    s.
Description of the Selected Remedy

Closure of the H-Area HWMF was conducted under a RCRA closure plan approved by the South Carolina
Department of Health and Environmental Control (SCDHEC). The corrective action of the groundwater
operable unit associated with these basins is being addressed under the SRS RCRA Permit.

The CERCLA selected alternative for the H-Area Groundwater Operable Unit is no further action beyond
that required by the SRS RCRA Permit.  The remedy described in the 1992 SRS RCRA Permit provides
for recovery of contaminated groundwater via extraction wells and treatment of hazardous constituents
and radionuclides (except tritium and nitrates).  The treated water under the conditions of current permit
will be injected into the shallow aquifer at the upgradient extent of the plume. DOE has been proceeding
to implement this action.  On March 1,1995, the renewal of the SRS RCRA Permit was issued as a draft
for public/permittee review and comment.

Declaration Statement

Corrective action for the H-Area Groundwater Operable Unit is specified by the SRS RCRA Permit issued
by the State of South Carolina.  Pursuant to the FFA, the permit addresses all identified constituents
capable of harming human health and the environment. This action has been determined to be protective
of human health and the environment under CERCLA. Therefore, no further remedial action beyond or
in addition to that establis'-  ' 'inder the SRS RCRA Permit is necessary under CERCLA.
         7fr
Date                                          Thomas F. Heenan
                                              Assistant Manager for
                                              Environmental Restoration and Solid Waste
                                              U.S. Department of Energy
Date                                      J^ John H. Hankinson, Jr.
                                              Regional Administrator
                                              U.S. Environmental Protection Agency
                                              Region IV

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
	April 1995
                                                                    £..
L      Site and Operable Unit Names, Locations, and Descriptions

The Savannah River Site (SRS) occupies approximately 300 square miles (800 square km) adjacent to the
Savannah River, principally in Aiken and Barnwell Counties of South Carolina (Figure 1).  SRS is a
secured facility with no permanent residents. The site is approximately 25 miles (40 km) southeast of
Augusta, Georgia, and 20 miles (32 km) south of Aiken, South Carolina. SRS is owned by the United
States Department of Energy (DOE). Westinghouse Savannah River Company (WSRQ is the managing
and operating contractor for DOE.

The original mission of the site was to produce nuclear materials for national defense. Recycling and
reloading of tritium to keep the nation's supply of nuclear weapons ready is a continuing site mission.
Today the Separations Facilities, of which H-Area is a part, are processing existing inventories of
materials for a variety of purposes, including supplying Plutonium-238 for deep space probes and
processing inventoried liquid radioactive materials into solid form for storage and testing.  This activity is
expected to continue for several years.

The H-Area HWMF is a RCRA-regulated unit (Figure 2). As an operable unit, the basins comprising the
H-Area HWMF were stabilized and closed in 1991. The H-Area Groundwater Operable Unit is the
groundwater associated with the H-Area HWMF. Contaminant plumes are shown on Figure 3.

EL     Operable Unit History and Compliance History

Operable Unit History

The H-Area HWMF consists of a series of three hydraulically connected unlined basins (H-l, H-2, and H-
4). Basins H-l, H-2 and H-3 were constructed in 1955.  Basin H-4 was built in 1962 to replace basin
H-3. Since basin H-3 was not used after 1962, it is considered Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) site and was not part of the Resource Conservation and
Recovery Act (RCRA) closure. However, Basin H-3 was filled in and covered as part of the closure of the
other three basins, this action satisfied the CERCLA requirements. Wastewater flow to the basins was
terminated on November 7, 1988 in accordance with the requirements of RCRA. The H-Area HWMF
received waste effluents from H-Area chemical separations facilities such as the nitric acid recovery unit,
waste storage system evaporator overheads, and general purpose overheads. The waste stream contained
hazardous constituents and low levels of radionuclides. Radioactivity released to these basins was due
primarily to tritium.

The basins were closed by dewatering, physically and chemically stabilizing the remaining sludge  on the
bottom of the basins and placing a multi-layer clay/soil cover over them. The cover system reduces
rainwater contact with the stabilized sludge and further contamination of the groundwater.

Compliance History

The entire SRS was placed on the National Priorities List (NPL) in December 1989. Following that date,
RCRA preventive activities at the H-Area HWMF have also been required to meet  CERCLA regulations.
The Federal Facilities Agreement, which became effective in 1993, formalized the integration of RCRA
and CERCLA in remediations on the SRS. Remediation of environmental contamination on the SRS is
directed by a Federal Facility Agreement (FFA), which was signed by EPA Region IV, DOE, and
SCDHEC and became effective August 16, 1993.  The FFA identifies all sites that may require
remediation and establishes an administrative process to set priorities and guide response actions.  The
FFA requires CERCLA Records of Decision for all RCRA decisions.

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Interim Action ROD
H-Area Groundwater Operable Unit
WSRC-RP-94-1163
        Revision 1
        April 1995
Figure 1. Site Area Map

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                               A,   Aoptotlmilt Locdlon ol To»«t H-DJ
                           IAV/MW 0V - Mlllldovt Witltf Mi»« Will* Builll Oioundt
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1
S

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Interim Action ROD                                                     WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                               Revision 1
	April 1995
                                                                  t
Preventive actions at the H-Area HWMF were conducted pursuant to the requirements of RCRA per
Settlement Agreement 87-27-SW between SCDHEC and DOE. In 1988, a RCRA Closure Plan was
submitted to SCDHEC. The closure plan underwent revisions to address SCDHEC comments prior to
approval in 1989. Closure of the H-Area HWMF was begun in 1989, completed in January 1991, and the
unit was certified closed in February 1991. In April 1991, the closure certification was accepted by
SCDHEC as being in compliance with RCRA requirements. Following a review of the SCDHEC RCRA
action, EPA determined that it was protective of human health and the environment and that no additional
actions were necessary. The three parties to the FFA then embodied this decision in a CERCLA Record of
Decision on the closed basins which was signed on September 10,1993.  A RCRA Permit Application for
Postclosure Care of the cover and to address groundwater contamination was submitted in December 1990
and revised in 1992. SCDHEC addressed the H-Area HWMF in the SRS RCRA Permit effective
November 1992.  This permit required submittal of a corrective action phs. for the groundwater associated
with the H-Area HWMF.  The Corrective Action Plan was included in the RCRA Permit Renewal
Application (submitted in October 1993).  On March 1,1995, as part of renewal of the permit, a draft SRS
RCRA Permit was issued for public/permittee review and comment Issuance of the renewed SRS RCRA
Permit is anticipated in the near term.

DDL    Highlights  of Community Participation

The public comment period for the H-Area Groundwater  Operable Unit Interim Action Proposed Plan was
from December 14, 1994 to February 15,1995. The comments received on the Interim Action Proposed
Plan are addressed in the Responsiveness Summary found in Appendix B.

IV.    Scope and Role of Operable Unit Within the Site Strategy

The description of the remedy- addressing groundwater contamination at the H-Area Groundwater
Operable Unit, summarized below, is from the SRS RCRA Permit.

As described in the SRS RCRA Permit, the goal of remediation of the H-Area Groundwater Operable Unit
is to lower contaminant concentrations in the groundwater associated with the H-Area HWMF to levels
specified in the RCRA permit and to minimize the discharge of contaminants to the adjacent stream. In
accordance with the  current 1992 SRS RCRA Permit, the remediation program includes groundwater
extraction, treatment, and injection at the upgradient extent of the contamination.  The remediation
follows the closure of the H-Area HWMF, and precedes the investigation of smaller source-specific units
in the H-Area Fundamental Study Area. The smaller source-specific sites will require investigation and
possibly remediation in accordance with the FFA. The groundwater remediation is an interim measure
pending an evaluation of its effectiveness in actual practice. The 1992 RCRA Permit specifies that the
overall corrective action will be implemented in phases and will be periodically reevaluated. The scope of
the Phase I action coupled with possible future actions (i.e., Phase II, Phase III) will serve to provide
protection to human health and the environment

V.      Summary of Operable Unit Characteristics and Contaminants

Waste effluents from H-Area chemical separations facilities including the nitric acid recovery unit, waste
storage system evaporator overheads, and general purpose evaporator overheads were discharged to the H-
Area HWMF.  Significant amounts of nitrate and caustic  were discharged to the basins. Tritium was the
primary radioactive constituent (99%) released to the basins. According to the RCRA Permit the
following constituents have been detected at concentrations above the Groundwater Protection Standard
(GWPS) established in the 1992 SRS RCRA permit:

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Interim Action ROD
H-Area Groundwater Operable Unit
                                  WSRC-RP-94-1163
                                           Revision 1
                                           April 1995
Hazardous Constituents (South Carolina Hazardous Waste Management Regulations 264.94 Table 1)
Arsenic                              Barium
Cadium                              Chromium
Lead                                 Mercury
Selenium                             Silver
Lindane
Hazardous Constituents (SCHWMR 261 Appendix VHI/264 Appendix EX)
Antimony
Bis(2-ethylhexyl) phthalate
Copper
Methylene Chloride
Tetrachloroethylene
Trichloroethylene
Vanadium
Benzene
Cobalt
Cyanide
Nickle
Tin
Trichlorofluoromethane
Zinc
Non-Hazardous Constituent
Nitrate
Specific Radionuclides + Indicators
Gross Alpha
Total Radium (226 + 228)
Americium-241
Cobalt-60
Curium-243/244
Iodine-129
Plutonium-238
Radium-226
Strontium-90
Thorium-228
Uranium-233/234
Uranium-235
Gross Beta (i.e., Nonvolatile Beta)
Tritium
Carbon-14
Curium-242
Curium-246
Nickle-63
Plutonium-239/240
Radium-228
Technetium-99
Thorium-230
Uranium-234
Uranium-238

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Interim Action ROD                                                       WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                 Revision 1
	April 1995
                                                                      s.
VL    Summary of Operable Unit Risks and Basis for Remedial Action

The maximum detected level of several contaminants (e.g., tritium, cadmium, and lead) in the H-Area
ground-water currently exceed the National Primary Drinking Water Standards, and applicable state
standards.  However, potential exposures to the general public are minimized by the distance from the
operable 'unit to the site boundary, by natural attenuation and radionuclide decay, by institutional controls,
and by dilution in receiving streams. In addition, all off-site contaminant concentrations are well below
drinking water and other applicable standards. This corrective action will address the potential ecological
impacts at the seeplines along Fourmile Branch, and will also serve to address the ambient water quality
standards in Fourmile Branch by remediating this operable unit  The remediation of the H-Area
Groundwater Operable Unit will be designed to meet, as far as practicable, the Phase I groundwater
protection standards outlined in the RCRA permit

VIL    Description of Alternatives

Three alternatives were evaluated for remediation of contamination at the H-Area Groundwater Operable
Unit.  Each alternative is described below.

1.    No Remedial Action.

2.    Groundwater Recov   and Hydraulic Control with treatment of mobile hazardous constituents and
      radionuclides (except tritium and nitrates) and discharge of treated water to a surface stream.

3.    Remedy as provided in the SRS RCRA Permit, i.e., groundwater recovery and hydraulic control
      with treatment of mobile hazardous constituents and radionuclides (except tritium and nitrates) by
      treatment and  injection of treated water into the shallow aquifer at the upgradient extent of the
      plume.

All three of the alternatives include groundwater monitoring, engineering and administrative controls to
guard against inadvertent human and ecological exposure to contaminated water.

Alternative 1. No Remedial Action

Under Alternative 1,  no groundwater extraction would be conducted.  Concentrations and activity levels of
the constituents of concern would gradually be reduced with time through natural attenuation processes
such as dispersion and radioactive decay. Groundwater would continue to discharge low levels of
contaminants into surface waters. Institutional controls and long term monitoring of groundwater, surface
water, and ecological conditions would be components of the no remedial action alternative.  These
activities are already  being implemented and associated costs are substantially lower than the other
alternatives. The lower cost is due to the lack of capital expenditures, such as the procurement of a
treatment system and the installation of wells. Potential risks to off-site receptors would be identified
through monitoring and minimized by institutional controls.

Alternative 2. Groundwater Recovery, Treatment, and Discharge to a Surface Stream.

This alternative would consist of recovery of contaminated groundwater via extraction wells and treatment
to remove hazardous  constituents and radionuclides (except tritium and nitrates). The treated water
would be discharged  through an NPDES permitted outfall into a surface stream at SRS.  A practical
technology to remove tritium from the groundwater does not exist. Therefore, tritium would be released
to the surface water.  Hazardous constituents and radionuclides removed from the groundwater would be
immobilized and disposed in permanent disposal vaults at SRS.

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Interim Action ROD                                                         WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                  Revision 1
	April 1995

Discharge of the treated water would shorten the flow path of tritium-contaminated groundwater to
surface streams. This strategy would allow less time for tritium decay before water discharges to surface
waters. In the short term this system could increase specific activities of tritium in the onsite receiving
streams.  However, the impact to the Savannah River would be negligible due to dispersion and dilution.
(The specific activity of a radionuclide is equivalent to the concentration of a chemical).

Institutional and engineering controls, plus long-term monitoring of groundwater and surface water
conditions would be part of Alternative 2, and anticipated to be lower in cost than Alternative 3.

Alternative 3. Groundwater Recovery, Treatment, and Injection

Alternative 3 is th:. remedy provided in the 1992 RCRA permit. It provides three phases for the recovery
of contaminated groundwater via extraction wells and treatment of hazardous constituents and
radionuclides (except tritium and nitrates). The extraction wells would capture the plume as defined by
the 10,000 picoCuries per milliliter (pCi/mL) tritium contour (Figure 3). Groundwater modeling was
used to determine optimal well locations and pumping rates. Unlike Alternative 2, the treated water
would be injected into the shallow aquifer at the upgradient extent of the plume.  Meeting treatment
standards provided in the RCRA permit in the injected water is the remedial goal of Phase 1.

Although tritium will not be removed from the groundwater, injection of the treated water will partially
control the movement of tritium-contaminated water. Upgradient injection will lengthen the tritium flow
path to the seep lines, allowing more time for tritium decay before the plume water discharges to the
receiving stream. This will reduce tritium discharges to the onsite receiving surface stream.

Institutional and engineering controls, plus long-term monitoring of groundwater, surface water, and
ecological conditions would be part of Alternative 3.  This alternative could be operational in accordance
with the schedules in the SRS RCRA Permit, and it would have the highest costs of the three alternatives.

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Interim Action ROD
H-Arca Oroundwatcr Operable Unit
W8RC-RP-94.1163
       Revision 1
       April 1895
                                                                                                                                            Fig. 3.  Contaminant Plumes In Water
                                                                                                                                            Table Aquifer, F- and H-Area
                                                                                                                                            Groundwater Operable Units

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Interim Action ROD
H-Area Gmundwater Operable Unit
WSRC-RP-94-1163
        Revision 1
        April 1995
Table 1. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance
Actions

Requirements

Prerequisites

Federal Citation

South Carolina
Code of Laws
LOCATION - SPECIFIC
Ground water
Remediation








Establish a
Corrective action
program







Measurement of
hazardous
constituents in the
groundwater which
exceed established
concentration
limits. -
Substantive
requirements
applicable
40CFR270.14

40 CFR 264.92-
100






SC-R.61-
79.270.14

SC - R.61-
79.264.92-100
(Implemented by
the SRS RCRA
Permit)


CHEMICAL - SPECIFIC
Protection of the
general public
from all sources of
radiation



Worker Protection

















The general public
must not receive an
effective dose
equivalent dose
equivalent greater
than 100
mrem/year
Maintain worker
exposures to "as
low as reasonably
achievable"
(ALARA).



Maximum
exposure to
occupational
workers: 5
rem/year
(stochastic); 50
rem/year
(nonstochastic)
effective dose
equivalent
Dose received by
the general public
from all sources of
radiation exposure
at a DOE facility -
TBC guidance

Internal and
external sources of
continuous
exposure to
occupational
workers at a DOE
facility - TBC
Guidance
Internal and
external sources of
continuous
exposure to
occupational
workers at a DOE
facility - TBC
guidance


DOE Order 5400.5






DOE Order
5480.11






DOE Order
5480.11


































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Interim Action ROD
H-Area Groundwater Operable Unit
 WSRC-RP-94-1163
         Revision 1
	April 1995
Table 1. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance (Cont'd)
Actions
Requirements
Prerequisites
Federal Citation
South Carolina
Code of Laws
ACTION- SPECIFIC
Water Treatment
Stormwater
discharge
Erosion Control
Well Construction
Discharge of
treated water to
groundwater
Wastewater
Treatment
Discharge limits
will be established
in the permit
Prepare a Notice of
Intent in
accordance with
NPDES SC
1000000
Develop a plan for
erosion sediment
control
Construction by a
certified driller is
required
Standards for
construction,
maintenance, and
operation of all
wells
Standards for
construction of
injection wells
Injection of any
waters to
groundwaters of
the State by means
of an injection well
is prohibited
except as
authorized by a
Department permit
or rule
State of S.C.
requires a permit
to build and a
wastewater facility
Discharge of
regulated
constituents in
water -
Substantive
requirements
applicable
Land Disturbance
activities over 5
acres -
Applicable
Land disturbing
activities -
Applicable
Drilling water
wells -
Applicable
Drilling Water
weiis -
Applicable
Construction
injection well -
Applicable
Discharge to
injection wells -
Substantive
requirements
applicable
Construction and
operation of
industrial
wastewater
treatment facility -
Substantive
requirements
applicable




40 CFR 144-147



SC-R.61-9
SC Pollution
Control Act Title
48-1-10
SC 72-300
SCR.61-71
SC R.61-71
SC R.61-87.4

S.C. Pollution
Control Act Title
48-1-110

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Interim Action ROD
H-Area Groundwater Operable Unit
 WSRC-RP-94-1163
         Revision 1
	 April 1995
Table 1. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance (Cont'd)
Actions
Wastewater
Treatment (cont'd)
Secondary Waste
Disposal
Requirements
ANESHAP
evaluation to
determine if source
of radionuclide
emission requires
EPA approval
Disposal in a low
level waste
disposal facility
Prerequisites
Radionudides
other than radon
from DOE
facilities (Air
discharge may or
may not be a pan
of the selected
treatment process)
- TBC Substantive
requirements may
be applicable
Generation of Low
Level radioactive
secondary waste -
TBC guidance
Federal Citation
40 CFR 61.96
DOE Order.
5820.2A
South Carolina
Code of Laws


Acronyms used in Table

TBC = to be considered
CFR = Code of Federal Regulations
DOE = Department of Energy
EPA = Environmental Protection Agency1
NPDES = National Pollutant Discharge Elimination System
NESHAP = National Emissions Standards for Hazardous Air Pollutants
UIC = Underground Injection Control
                                           10

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Interim Action ROD                                                       WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                 Revision 1
              	April 1995
                                                                     A.
VUL  Summary of Comparative Analysis of Alternatives

Each of the remedial alternatives was evaluated using nine criteria established by the National
Contingency Plan.  The criteria were derived from the statutory requirements of CERCLA, Section 121.
The results of  the evaluation are presented in Table 2.

Description of Nine Evaluation Criteria

Compliance vnth Applicable or Relevant and Appropriate Requirements (ARARs) - addresses whether a
remedy will meet all of the ARARs of other federal and state environment statutes.

Overall Protection of Human Health and the Environment - addresses whether a remedy provides
adequate protection and describes how risks posed through each pathway are eliminated, reduced or
controlled through treatment, engineering controls or institutional controls.

Long-term Effectiveness and Permanence - refers to the magnitude of residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time once cleanup goals
have been met

Short-term Effectiveness - refers to the speed with which the remedy achieves protection, as well as the
potential for a remedy to create adverse effects on human health and the environment that may result
during the construction and implementation period.

Reduction ofToxicity, Mobility or Volume Through Treatment - assesses reduction of toxicity, mobility, or
volume through treatment, including how treatment is used to address the principal threats posed by a
media-specific operable unit

Implementability - assesses the technical and administrative feasibility of a remedy, including the
availability of materials and services that may be used to implement the chosen solution.

Cost - includes capital and operation and maintenance costs.

State Acceptance - indicates whether the state concurs with, opposes, or has no comment on the preferred
alternative based on its review of the proposed action.

Community Acceptance - will be assessed in the Record of Decision following a review of the public
comments received  on the proposed interim actions.

IX.    Selected  Remedy

The SRS RCRA permit is viewed as the primary decision-making authority. Alternative 3 (groundwater
recovery, treatment and injection) is the corrective action described in the 1992 RCRA permit. This
action has been determined to be protective of human health and the environment under CERCLA, and
therefore, no additional corrective action under Phase I is necessary at this time.
                                              11

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Interim Action ROD
H-Area Groundwater Operable Unit
                                                   WSRC-RP-94-1163
                                                            Revision 1
                                                            April 1995
Table 2. Evaluation of Alternative Actions Considered for Remediation of Groundwater Contamination.
   Evaluation Criteria
     Alternative 1
       No Action
     Alternative 2
 Pump-treat-discharge to
        stream
     Alternative 3
   Pump-treat-inject
    (RCRA permit)
Overall Protection of
Human Health and the
Environment
This alternative is the
least protective of
human health and the
environment. If
groundwater above the
GWPS continues to seep
along Fourmile Branch
uncontrolled, then some
measure of human and
ecological impact may
occur
In the short term, this
alternative will increase
tritium flux to the
Savannah River (levels
will remain below
DWS).
This alternative will
minimize tritium
discharge to the
wetlands, streams, and
ultimately to the
Savannah River. This
alternative is protective
of human health and
environment.
Compliance with
ARARs
This alternative will not
be in compliance with
the Groundwater
Protection Standards as
    aminant
concentrations in the
groundwater and "local
onsite surface water
exceed primary drinking
water standards.
This water treatment
unit will be constructed
in full compliance with
wastewater treatment
regulations. Treated
groundwater will meet
NPDES requirements
and off-gas from the
treatment unit will meet
Clean Air Act
regulations. Cleanup
goals for this alternative
will be based on
drinking water
standards (with the
exception of tritium).
The water treatment
unit will be constructed
in full compliance with
wastewater treatment
regulations.  Treated
groundwater will meet
Underground Injection
Control (UIC) permit
requirements and off-
gas from the treatment
unit will meet Clean Air
Act regulations.  Clean
up goals for this
alternative will meet
RCRA permit levels.
Long-term effectiveness
and permanence
Adequacy of this
alternative will be
assessed by monitoring.
Contaminants (except
tritium and nitrates) will
be removed from the
groundwater and
disposed of in low level
radioactive waste vaults
at SRS. Residual risk is
expected to be minimal.
Adequacy of this
remediation will be
assessed by monitoring.
Contaminants (except
tritium and nitrates) will
be removed from the
groundwater and
disposed of in low level
radioactive waste vaults
at SRS. Tritium
discharge to surface
water will be
minimized. Residual
risk is expected to be
minimal. Adequacy of
this remediation will be
assessed by monitoring.
                                              12

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                                                    WSRC-RP-94-1163
                                                             Revision 1
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Table 2. Evaluation of Alternative Actions Considered for Remediation of Groundwater Contamination.
         (cont't)
  Evaluation Criteria
     Alternative 1
      No Action
     Alternative 2
Pump-treat-discharge to
        stream
     Alternative 3
   Pump-treat-inject
    (RCRA permit)
Reduction of toxicity,
mobility, or volume
through treatment
None
Water treatment process
will remove
contaminants (except
tritium and nitrates)
from the groundwater,
reducing toxicity.
Tritium release to
surface water may be
increased; however,
tritium levels in the
Savannah River will
remain well below
drinking water
standards.
Water treatment process
will remove
contaminants (except
tritium and nitrates)
from the groundwater,
reducing toxicity.
Tritium release to
surface water will be
reduced by allowing a
longer time for
radioactive decay of
tritium before it
discharges to surface
water.
Short-term effectiveness
This alternative does not
provide a short-term
remedy for preventing
discharges of
contaminated
groundwater to
wetlands, surface
streams and ultimately
the Savannah River.
Groundwater recovery
and treatment will
immediately reduce the
amount of contaminants
(except tritium and
nitrates) from
discharging to wetlands
and streams. Tritium
release to surface water
will be increased;
however, tritium levels
in the Savannah River
will  remain well below
drinking water
standards.

Since risks to the offsite
population are minimal,
no measures to protect
the community will be
required during
remediation and during
the time period before
remedial goals are met.
Protection of workers
will be required to
eliminate risks
associated with
handling and treatment
of radioactive materials.
Groundwater recovery
and treatment will
immediately reduce the
amount of contaminants
from discharging to
wetlands and streams.
Tritium release to
surface water will
immediately be reduced
by allowing a longer
time for radioactive
decay of tritium before it
discharges to surface
water.

Since risks to the offsite
population are minimal,
no measures to protect
the community will be
required during
remediation and during
the time period before
remedial goals are met
Protection of workers
will be required to
eliminate risks
associated with
handling and treatment
of radioactive materials.
                                               13

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         Revision 1
	April 1995
Table 2.  Evaluation of Alternative Actions Considered for Remediation of Groundwater Contamination.
         (cont't)
Evaluation Criteria
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1 No Action
This alternative is
already in place.
Capital Cost = None
Maintenance &
Operation =
Groundwater
Monitoring and
Reporting Costs
During negotiations
with regulators, it was
indicated that this
alternative would not be
acceptable to SCDHEC.
This criterion will be
completed following
public review.
Alternative 2
Pump-treat-discharge to
stream
Water treatment
processes to remove
contaminants of concern
(except tritium and
nitrates) are
commercially available.
Capital Cost =
approximately $16
million.
Maintenance &
Operation are probably
less than the preferred
alternative because
surface discharge is less
expensive to operate
than an injection field.
During negotiations
with regulators, it was
indicated that this
alternative would not be
acceptable to SCDHEC
because it would not
minimize tritium
discharge to surface
waters.
This criterion will be
completed following
public review.
Alternatives
Pump-treat-inject
(RCRA permit)
Water treat processes to
remove contaminants of
concern (except tritium
and nitrates) are
commercially available.
Technology to inject
treated water into an
aquifer exists; however,
there may be operational
problems with such a
system. Some
development may be
required before the
injection system design
can be finalized.
Capital Cost =
approximately $16
million.
Maintenance &
Operation = estimated
to be between $2 and S3
million per year.
This alternative has
been accepted by
SCDHEC. A RCRA
permit requiring a
corrective action plan
for pump-treat-inject to
remediate groundwater
contamination has been
issued.
This criterion will be
completed following
public review.
                                           14

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	:	April 1995
                                                                      a..
X.     Statutory Determination

The National Contingency Plan (40 CFR 300.430(e)(9)) sets forth nine evaluation criteria that provide the
basis for evaluating alternatives and subsequent selection of a remedy. The selected alternative,
Alternative 3, was evaluated with respect to the five statutory findings, as required for interim actions
under CERCLA. The results of the evaluation are as follows:

Protection of Human Health and the Environment.  Alternative 3 will mitigate risks of exposure to
contaminated surface water by minimizing discharge of contaminated ground-water to the adjacent
wetlands and stream. In addition, removal of hazardous constituents and radionuclides (except tritium
and nitrates) will reduce the future risk of exposure to contaminated ground-water by ingestion.

Attainment ofARARs.  All ARARs, as identified in Table 1, pertaining to the treatment and disposal of
contaminated groundwater and injection of treated water will be met by the proposed alternative.

Cost Effectiveness.  Alternative 3 has significantly higher operating and maintenance costs than the other
alternatives, because the injection system is expected to be a long-term and high maintenance operation.
However, operation of any treatment facility which will handle radioactive materials will be costly.

Use of Treatment Technologies and Permanent Solutions to the Maximum Extent Practicable.  The
chemical water treatment process represents utilization of treatment technologies to the maximum extent
practicable. No practicle treatment is available for tritium.

Reduction of Mobility, Toxicity, and Volume.  The selected alternative utilizes extraction and treatment of
contaminated groundwater in a way that minimizes migration of contaminants to surface waters and
reduces the mass of contaminants in the plume. Hazardous constituents and radionuclides removed from
the groundwater will be immobilized and deposed in permanent disposal vaults at SRS.  The system will
be designed to ensure that the secondary waste sludge will not be a hazardous waste.

XI.    Explanation of Significant Changes

There were no significant  changes.
                                              15

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Interim Action ROD                                                   WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                              Revision 1
	April 1995
                                                                 c,
                                    APPENDIX A


                     References for Development of ROD Format
EPA, 1991. "Guide to Developing Superfund No Action, Interim Action, and Contingency Remedy
RODs," OSWER Publication 9355.3-02FS-3, U.S. Environmental Protection Agency, Washington, D.C.,
April 1991.

Weeks, "Victor, 1993. "Regarding Records of Decision, H-Area and H-Area, Savannah River Site, Aiken,
South Carolina", Letter to Goidell (DOE), Savannah River Site, Aiken, SC, April 14,1993.

WSRC, 1992. "Draft RCRA Facility Investigation/Remedial Investigation Program Plan," WSRC-RP-89-
994, Rev. 1, Chapter 15, Westinghouse Savannah River Company, Aiken, South Carolina, May 1992.
                                          A-l

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
             	April 1995
                                                                     £..
                                      APPENDIX B


                            RESPONSIVENESS SUMMARY
During the 34 day public comment period, a request for a public meeting was received. The public
meeting was held on January 9,1995, in the North Augusta Community Center, North Augusta, South
Carolina. The public comment period was extended an additional 30 days so that comments could be
submitted

DOE has received comments regarding the F&H Areas Groundwater Operable Units and they have been
addressed in this Responsiveness Summary.  These comments are available for review in the
Administrative Record.

During the public comment period, several letters were submitted from individuals and groups regarding
the proposed interim action.  This Responsiveness Summary addresses the general comments and
concerns from the public meeting and specifically addresses the written comments received. The
summary is divided into three sections:  1) general responses to specific comments and questions raised
during the public meeting, 2) responses to written comments received on questionnaires at the public
meeting, and 3) specific responses to written comments received during the public comment period.
Please note that some of the specific comments are addressed in the general response section due to
common questions and concerns.

Many of the comments that DOE has received relating to this type of project  question the soundness of the
planned remediation. DOE is required to continue the groundwater remediation project under the terms
of the Resource Conservation and Recovery Act (RCRA) Hazardous Waste Permit that is issued by the
State of South Carolina in conjunction with the United States Environmental Protection Agency (EPA).
This permit sets forth all the requirements with which DOE is obligated to comply.  Prior to issuance of
the permit, the South Carolina Department of Health and Environmental Control (SCDHEC) issues a
draft permit that is made available to the public and the DOE for a 45 day comment period. Any
interested party can request a public hearing to discuss concerns regarding the conditions set forth in the
draft permit. SCDHEC will evaluate these concerns prior to issuing a final hazardous waste permit.
Many of the comments received are in regards to the appropriateness of this corrective action. These
comments will be addressed through the SCDHEC RCRA renewal permitting process during the 45 day
public comment period

The following questions were extracted from the public meeting transcript and are numbered sequentially
for ease of reference as they appeared in the transcript.

1.     How does the cost effectiveness of this program relate to Crumbly's six goals?
      Response: Grumbly's six goals are:
      •    Eliminate and manage the urgent risks in our system
      •    Emphasize health and safety for our workers and the public
      •    Establish a system that is managerially and financially in control
      •    Demonstrate tangible results
      •    Focus technology development efforts on identifying and overcoming obstacles to progress
      •    Establish a stronger partnership between the DOE and its stakeholders

      These six Crumbly goals are Department of Energy programmatic goals.  In terms of these goals
      the F- and H-Area projects do not rate highly in terms of managing urgent risks. However, SRS
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                                                                        £,
       must work within the framework of exising laws and regulations in making decisions regarding the
       cleanup of F- and H-Area Groundwater Operable Units.

 2.     Provide scientific justification?
       Response: As part of the development of the Corrective Action Program contained in the RCRA
       Part B HWMF Permit, 12/3/90,  SRS evaluated several potential ground water remediation
       technologies for implementation at the F&H Seepage Basins. Based on a thorough evaluation of
       various treatment alternatives, which included evaluation of Treatment Effectiveness, Constituents
       Treated, Treatment of Seep Area, Regulatory Requirements, Implementation Schedule, Capital
       Cost, etc., SRS selected the ground water removal with the surface treatment remediation
       alternative. Further studies were performed to evaluate the potential surface treatment
       technologies, and potential treated effluent discharge alternatives.  A request for proposal has bee .
       sent out for bid 12/28/94. A commercially available water treatment unit will be selected based on
       technical evaluation of the vendor bids, cost, and the ability of the unit to meet or exceed the clean
       up levels.

       Alternate remedial technologies have been evaluated as part of technology selection for the RCRA
       corrective action plan. Evaluation criteria included treatment effectiveness, feasibility, ability to
       satisfy regulatory requirements,  and capital cost Pump and treat was chosen largely because it is a
       developed technology for groundwater remediation.  A demonstrated technology can be
       implemented morw   ddy (and usually more inexpensively) than an innovative technology which
       would  require extensive laboratory and field testing prior to implementation.

       Potentially applicable technologies which have been considered include immobilization techniques
       such as deep soil mixing and in-situ vitrification.  Other potentially applicable technologies are
       those which remove or immobilize contaminants in-situ (such as electrokinetic migration and
       magnetic separation.) Introduction of chemicals into the subsurface which would cause
       precipitation of contaminants or mobilize them for faster removal have also been considered.  All of
       these were eliminated from consideration because  of the expense involved in development and
       testing of these technologies, and because of the uncertainty of their effectiveness.

3.      How long will the process take?
       Response:  The duration of the entire remedial process has not yet been determined. The RCRA
       Part B  permit application calls for remediation to be accomplished in phases. Phase 1 is expected
       to operate for five years.  The effectiveness of the corrective action will be evaluated at the
       conclusion of Phase 1. At that time, a decision will be made whether to discontinue operation of
       the remedial system, to continue operation without modification, or to modify the system to
       enhance its performance in the next phase.

4.      What kind of a standard are you cleaning up to? Residential or Industrial? Are you cleaning up to
       a residential standard? If this is being cleaned up  to an industrial standard, would this even have to
       be done? So the reason to do this is to reduce the levels in the GW and at the seepline to get it to a
       residential standard? And if we were talking about an Industrial standard,  it would strictly be for
       the tritium contamination, is that right? Discussion on land use including if industrial use, a
       different standard should be applied. Is that land use policy before you go in and spend money?
       Response:  The clean up levels,  Groundwater Protection  Standards (GWPS) are based on drinking
       water standards and background levels. These values are mandated by the RCRA permit and do
       not reflect either an industrial or residential standard as defined by EPA Risk Assessment Guidance
       for Superfund sites (RAG's). Residential standards are considerably more stringent than the
       GWPS for some constituents and less restrictive for others. Industrial standards as defined by EPA
       guidance are more restrictive than the GWPS for some constituents and less restrictive for others.
                                              B-2

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Interim Action ROD                                                         WSRC-RP-94-1163
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	April 1995
                                                                        z.
      RCRA does not recognize any difference between residential and industrial scenarios.  RCRA is a
      regulation that was developed to address mainly active, industrial sites—so there was not a need to
      make distinctions between residential and industrial for the regulated units under the RCRA
      permit

5.    Ability to Capture Contaminants?  (referring to which COC's, ie. metals and radionuclides, will be
      cleaned up)
      Response:  The remedial system is being designed to extract contaminated water from the ground,
      treat it to remove hazardous constituents and radionuclides (except tritium and nitrates), and inject
      the treated water back into the shallow aquifers. In order to achieve clean up goals, the
      contaminants must be captured by the extraction well network. Any contaminants which  are in the
      water and are mobile are expected to be captured and treated by the pump and treat system.

      Radionuclides and hazardous metals generally adsorb onto soil particles, which can inhibit their
      capture by a pump and treat system.  However, during operation, solutions with very low pH were
      placed in the basins.  The low pH facilitated the movement of hazardous metals and radionuclides
      into the groundwater. Hazardous metals and radionuclides are present in the groundwater
      downgradient of the basins, and in surface water at the seepline (wetlands), indicating that these
      constituents are in the water and are mobile.  Therefore, these constituents are expected to be
      captured and treated by the proposed corrective action while the pH remains low in portions of the
      plume. However, the pH is expected to rise as the system begins to operate which will reduce the
      mobility of many of the metals and radionuclides.

      Evaluation of the corrective action will take place at the conclusion of Phase 1.  Modification of the
      system to enhance capture of any contaminants which remain in the groundwater will be
      considered  at that time.

6.    There is essentially no difference in the metals between the Four Mile Creek and the Savannah
      River?
      Response: The levels of hazardous metals are below primary drinking water standards in  the
      Savannah River. Cadmium  has been measured above the primary drinking water standard in Four
      Mile Creek. Lead, cadmium and zinc exceed ambient water quality standards in Four Mile Creek.

7.    When tritiated water is injected upgradient, how long will it take to reach the surface water and at
      what rate will it be decaying? To what degree will the tritiated water reinjected upgradient decay?
      Do we have a model as to what degree the tritium will decay by the time it gets to the surface
      water? Can you supply how much tritium will ultimately go into the creek?
      Response:  The pump-treat-inject system takes advantage of the short half life of tritium to
      minimize the migration of tritium from the F and H Area seepage basin plumes to surface water
      and ultimately the Savannah River.  The half life of tritium is 12.3 years. This means that every
      12.3 years half of the tritium has decayed. Groundwater extracted at the downgradient edge of the
      plume will be treated to remove hazardous constituents and radionuclides except tritium and
      nitrates. The treated water will be injected into the shallow aquifer upgradient of the plume. Based
      on groundwater modeling contained in the 1992 Part B Permit Application, It is estimated that it
      will take 3-5 years for injected water to travel back to the extraction network and be recaptured and
      reinjected for another 3-5 year cycle.
      This system will provide a measure of hydraulic control which will minimize tritium discharge to
      adjacent wetlands, steams, and ultimately the  Savannah River. The total estimated reduction in
      tritium discharged to surface water due to implementation of the proposed Phase I corrective action
      based on groundwater modeling is approximately 3000 curies.  The total estimated tritium release
                                              B-3

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                                                                      e.
      from F&H Areas to Founnile Creek between the years of 1997 to 2027 is estimated to be 16,690
      curies.

8.    Describe the treatment system that takes place at the surface? Have you specified a particular
      treatment technology?
      Response: The actual treatment process has not been determined A commercially available water
      treatment unit will be used.  A particular treatment technology has not been specified Selection of
      the actual unit will be based on a technical evaluation of vendor bids and cost considerations.
      Technical evaluation will be based on the ability of the unit to meet or exceed clean up levels.
      Performance specifications will require that any secondary waste generated will be non-hazardous.
      However, it will ultimately be up to the supplier to provide a commercial treatment technology that
      will meet the water clean up standards and the requirements of the specification.  SRS has
      performed an evaluation of various treatment technologies, which included evaporation, reverse
      osmosis, ion exchange, chelation, and chemical precipitation.

9.    Has the RFP gone out for bid?
      Response: The RFP went out for bid on December 28, 1994.

10.   "Found tritium 1500 feet down in wells in Georgia."
      Response: The results of the tritium underflow study indicate that there is not any tritium
      migrating from the SRS to Georgia under the Savannah River. The tritium in the wells in Georgia
      was found to come from rainwater. The rainwater contained small amounts of tritium from
      atmospheric releases of tritium.

11.   Will the drawdown and reinjection increase the migration? If so, how much? What effect will
      drawdown and migration have on migration of radionuclides and other chemicals in the soil? Will
      drawdown (and reinjection) increase the flow of nuclides more so than if you had left it the way it
      is? Will drawdown increase rate of migration? soil effects? radionuclides?
      Response: The extraction / injection system is designed to change the flow path and increase the
      migration rate of contaminated plume water. Flow towards the extraction wells will be increased
      by pumping and drawdown.  This will enhance delivery of the contaminants to the treatment unit.
      It is not expected to increase migration of contamination towards surface water or any
      environmental receptors.

      The effect of pumping and drawdown on migration of radionuclides and chemicals in the soils is
      expected to be minimal.  In the saturated zone, the greatest fraction of contamination is thought to
      exist in the groundwater and is not expected to be adsorbed onto saturated sediments. Any
      contamination which is bound to sludge and soils in the unsaturated zone at the waste sites has
      been isolated from the groundwater by source control measures.  Low permeability caps provide
      source control by deflecting rainwater from infiltrating into the closed waste site and thus
      protecting against transportation of contaminants into the groundwater. Pumping and drawdown
      will have no direct effect on  the unsaturated zone.

12.   "...this IAPP position is very negative and very technically oriented and very difficult for the
     . common person who does not work on the site to understand." "Why was Rev 1 (IAPP) so negative
      and difficult to read when Rev 0 was much easier?"
      Response: SRS will attempt to make these type of documents easier to read in the future.  It can be
      a difficult balance to insert the appropriate amount of technical discussion for the regulators and
      reviewers, and at the same time summarize the proposed action in clear and concise manner. The
      Rev 1 document incorporated DOE-HQ, EPA and SCDHEC comments. Some of the comments
      requested incorporation of more technical discussion.

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                   	April1995
13.    "...public can influence the decision-making process.."
      Response:  EPA, SCDHEC and DOE encourage and support public participation in the
      environmental restoration process. Both RCRA and CERCLA require public review of the
      remediation decisions.  These Proposed Plans document that the RCRA remedy chosen to
      remediate contaminated groundwater at F&H-Areas is protective of human health and the
      environment and meets the requirements of CERCLA.  The RCRA decision had already been
      subject to the public review process and had been deemed acceptable. The public will be allowed
      another opportunity to provide comment in the RCRA process in the near future when the draft
      permit renewal is issued for public comment

14.    "Why does the Bulletin indicate that our lOinds are made up for the selected alternative when the
      LAPP says the public will be given the opportunity to participate in the selection of the remedial
      action."
      Response:  The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) are the
      regulations implementing CERCLA. The NCP gives specific requirements for selecting a remedy
      for a site. After identifying the alternative that best meets the requirements, the lead agency
      presents the alternative to the public. The proposed plan describes the remedial alternatives
      analyzed by the lead agency, presents a preferred remedial action alternative and summarizes the
      information relied upon to select the preferred alternative. The proposed plan is then made
      available to the public for review.

      After review by the public the proposed plans are then re-evaluated to see if the preferred
      alternative provides the best balance of trade-offs, factoring in any new information  or public
      perspective. The Bulletin identified the preferred remedy in the Proposed Plan and gave
      information about the public comment period.

15.    "...the only action is the one done under RCRA 2 years  ago or do we have a right to  say which
      alternative we wish to have brought up before you folks.."
      "...What makes me think that my opinion in the selection of the alternatives counts? Has anyone
      listened to what DOE is saying.?"
      Response:  The Proposed Plans for the F&H Groundwater Operable Unit state that no additional
      actions are  necessary under CERCLA to address the contaminated groundwater. The RCRA
      actions are  independent and required by other permits.  There were no additional remedial actions
      proposed for the F&H-Area Groundwater Operable Unit at the public meeting.

16.    How was SRS scored for placement on the National Priority List?
      Response:  The SRS was placed on the NPL December 21,1989.  SRS commented on the proposed
      listing to EPA during the allowable comment period. Specific comments regarding  how the site
      was ranked are not specifically  relevant to these Proposed Plans. However, this information can be
      obtained from Region IV EPA.

17.    The H-3 Basin does not fall under RCRA and it is also the primary source for the release of
      mercury, and this has not been addressed?
      Response:  Basin H-3 was not considered a  regulated unit under RCRA. However, the NCP gave
      EPA broad authority to determine how best to use its authorities under CERCLA, RCRA, or both to
      accomplish appropriate cleanup action at a site, even where the site is listed on the NPL. When the
      site is an active, RCRA-permitted facility, EPA may consider whether the use of RCRA or
      CERCLA authorities (or both) is most appropriate for the accomplishment of cleanup at the site.
      The cleanup plan would be discussed in the  InterAgency Agreement, or the Federal  Facility
                                            B-5

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•     	April 1995
                                                                       &
      Agreement (FFA) at the SRS. The DOE, EPA and SGDHEC agreed that cleanup would be best
      accomplished by integrating it into the existing RCRA action. This not only accomplished it fester
      and cheaper, but allowed the entire complex to be closed and monitored as one unit

18.   The National Academy of Sciences finds pump and treat an incomplete remedial activity?  What
      would it recommend as an alternative?
      Response:  The National Academy of Sciences (NAS) performed an extensive review of
      alternatives for groundwater cleanup, which included a review of pump and treat systems.  The
      NAS stated that based on a review of these systems, that the effectiveness of the pump and treat
      technology to restore contaminated aquifers seems quite limited and subsequently, this has led to a
      widely held view that pump and treat systems should not be used for groundwater remediation.
      The conclusions of this report are based on a review by the NAS of only 77 sites utilizing the pump
      and treat technology.  The NAS has indicated that there are greater than 3000 pump and treat units
      currently in operation. Based on a review of the 77 listed sites and their associated hazardous
      wastes, only 3 sites were identified to contain metals, and the remainder all contained primarily
      organic  hazardous wastes. Consequently, the results reported certainly do not represent the overall
      effectiveness of the pump and treat technology for all hazardous waste streams. Although the pump
      and treat technology appears to be limited, the NAS identifies several factors to be considered in
      utilizing pump and treat as a possible remediation method. The key technical reasons for the
      difficulty of cleanup include the following:
      «   Physical heterogeneity:  The subsurface environment is highly variable in its composition and
          contaminant migration pathways are often extremely difficult to predict.
      •   Presence of nonaqueous-phase liquids (NAPL's): This includes many common contaminants
          like oils, gasolines, etc., that do not dissolve readily in water.
      •   Migration of contamination to inaccessible regions:  Contaminants migrate to inaccessible
          areas of the flowing groundwater.
      •   Sorption of contaminants to subsurface materials:  Contaminants adhere to solid  materials in
          the  subsurface.
      »   Difficulties in characterizing the subsurface: The subsurface cannot be viewed in its entirety
          and is usually only viewed through a small number of drilled holes.

      Based on a review of the above technical difficulties and the 77 sites reviewed by the NAS, which
      all contained primarily organic waste streams,  it is apparent that the effectiveness of the pump and
      treat technology is very site specific. The difficulties noted above are not of major concern at the
      F&H Groundwater Operable Units, ie., the subsurface environment and contaminated pathways
      have been extensively characterized, groundwater monitoring indicates no presence of NAPLs, the
      plumes exist in shallow easily accessible aquifer units, and studies indicate that sorption of
      contaminants to subsurface materials in minimal.  Finally, the NAS  provides several alternative
      technologies or "enhanced pump and treat systems", i.e. soil vapor extraction, bioremediation, air
      sparging, etc., and states that these methods, show promise, but they are in the development stage,
      and their long term effectiveness has not yet been determined:  These techniques are applicable to
      remediation of volatile organics (ie. TCE, PCE), but are not effective for cleaning up metals and
      radionuclides such as those that exist at F&H seepage basins.

19.   How much will the proposed  remediation cost? S270 million? Have any alternatives to reduce the
      operating cost by reducing the life cycle primarily been investigated  as part of this? What
      technologies for reducing operating costs were looked at, if any, and at what point in the future
      operating scheme or phases is that expected to be done?
      Response:  Table 2 in each of the interim Action Proposed Plans for F&H Areas addresses the
      estimated costs for each of the alternatives. Alternative 3 (pump and treat system) capital costs are
      estimated at $16 million per area ($32 million combined) and the annual operating costs are
      estimated at $2 million to $3 million per area ($4 million to $6 million combined). Phase I will
                                              B-6

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Interim Action ROD                                                        WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                  Revision 1
             	April 1995
                                                                     £.
      operate for 5 years. Capital costs and operation of Phase I are estimated at approximately 45
      million dollars. Future phases may incur additional costs. Total life cycle costs are dependent
      upon further evaluation of subsurface conditions and evaluations of the effects of pump and treat
      once the system is operational. Studies are underway across the DOE complex to identify and
      develop technologies which will enhance remediation and reduce life cycle costs.

20.   "Did you purposely plan the public comment period over Christmas?  Why was this meeting so
      hurriedly called?"
      Response: The public comment period is always scheduled as soon as possible after concurrence of
      the Proposed Plans by the three agencies. The comment period is usually only 30 days and it was
      extended because of the holidays.

21.   "Now that weVe had the request for 90 days, I'm sure the comment period will be extended."
      Response: The public comment period was extended through February 15,1995.

22.   What amounts of heavy metals & nuclides are reaching the surface waters and how much, what
      sort of level?
      Response: In the report titled "Semi-Annual Sampling of Fourmile Branch and Its Seeplines in the
      F and H Areas of SRS: February 1993, July 1993, and April 1994," results from these sampling
      events suggest that the seeplines in both F and H Areas and FMB continue to be influenced by
      contaminants migrating from the F and H Area Seepage Basins. The anaiytes exceeding
      groundwater protection standards or maximum concentration limits as indicated in this report are
      shown below,
      Analvte          FMB           F-Seep          H-Seep         Standard       Units
Gross Alpha
Non-Vol. Beta
Tritium
Sr-90
Ra-226
1-129
Cadmium
Lead
Iron
Aluminum
Manganese
Nitrate
Zinc
3
28
1070
10
5
2
6
3
668
109
41
2000
21
20
614
2030
227
14
2
15
3
28,300
5650
2760
50,000
184
16
426
4470
80
32
9
16
3
7570
90,000
891
31,000
222
15
50
20
8
20
1
5
15
300
50
50
10000
5000
pci/1
pci/1
pci/ml
pci/1
pci/1
pci/1
ug/1
ug/1
ug/1
ug/1
Jlg/I
Kg/1
Wg/1
23.   What contaminants exceed the ambient water quality standards that effect ecological issues?
      Response: All anaiytes listed in the response to question #22 are also listed as ecological
      chemicals of concern. The metals that have exceeded the Ambient Water Quality Criteria (AWQC)
      for these locations are Cadmium, Lead, and Zinc. The radionuclides listed do not have a
      corresponding AWQC standard.

24.   Does water in the wetlands (seepline) exceed drinking water standards?
      Response: See response to question #34.
      Levels of radionuclides and hazardous metals have been measured above primary drinking water
      standards at the seepline in both F and H Areas.
                                             B-7

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Interim Action ROD                                                        WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                 Revision 1
                                                                                    April 1995
25.   Explain gross alpha and gross beta measurements? p.70.
      Response:  The gross alpha measurement is representative of alpha emitting radionuclides (ie.
      Uranium, Plutonium), and the nonvolatile beta measurement is representative of the beta emitting
      radionuclides (ie. Strontium, Cesium). The EPA has set drinking water standards for these
      measurements, which are  15 pci/1 for gross alpha and 4 mrem (approximately 50 pCi/1) for
      nonvolatile beta.

26.   "Considering that treatment for this site has already progressed to the point where there's
      procurement underway, under the RCRA decision, what in reality does this process under
      CERCLA have to do with the ultimate treatment of the site?"
      Response:  To fulnll the requirements under the CERCLA process, the proposed plans state that no
      further action under CERCLA is required to protect the human health and the environment

27.   How come the six treatment alternatives weren't presented to the regulators? How come they are
      not in the public document?
      Response:  The six treatment alternatives were presented to EPA and SCDHEC in the Proposed
      Plans for F&H Areas Groundwater Operable Units, Revision 0. During comment review and
      negotiations with the Regulators, it was determined that the alternatives that had been previously
      rejected should be r*- ived.

28.   "Are you familiar with the 11/8/94 Federal Register? Is it true that EPA is proposing to remove the
      current requirement for postclosure permits?'1
      Response:  The proposed provisions actually expands the authority of EPA to mandate post-closure
      care requirements.  The proposal would allow EPA or an authorized State to use any other available
      legal authority as an alternative to the post-closure permit, as long as that authority provides the
      same level of protection and public participation as does the post-closure permit. The EPA and
      States had found that for closed or closing facilities they had very little incentive to submit the post-
      closure care permit applications.  They did not want or need a permit to operate. The proposed rule
      would allow EPA and authorized states to bring an uncooperative facility into compliance through
      an enforcement action.  Facilities that need an operating permit such as SRS, would still have to
      obtain post-closure care permits for their closed RCRA facilities.  This proposal does not change
      the requirements for corrective action.

29.   Haven't you heard lately ihat everybody's budgets are being cut?  Haven't you heard that DOE's
      budget and that  Secretary O'Leary as well as Mr. Crumbly are saying we want prioritization?
      What is the worst risk?
      Response:  We acknowledge budgets across the DOE complex will be reduced in the near term.
      SRS is no exception to the mandate from the Administration and Congress to use fiscal
      responsibility in planning  its work.  As such, SRS is evaluating its programs from a total risk
      standpoint, rather than risk posed to human health and the environment as a sole consideration.
      The parameters being used to determine total risk include: 1) public  health and safety, 2)
      environmental protection,  3) worker health and safety, 4) compliance with standards, 5) clean-up
      mission and business efficiency, 6) safeguards and security, 7) public and community relations,
      and 8)  cost efficiency.

30.   What about the GAO report (which criticized the progress of the DOE's cleanup programs and
      calls for consideration of alternatives such as creating a separate government cleanup commission)?
      Response:  The GAO Report, entitled Superfund, Status, Cost, and Timeliness of Hazardous Waste
      Cleanups and dated September 1994 was a general report evaluating the Superfund program across
      the nation (including federal and private cleanups). This report noted that expenditures for the
                                             B-8

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
	April1995
                                                                     &.
      Superfund program are higher than expected and that the actual number of sites deleted from the
      NPL remains small. Additionally, federal facility cleanup is slower than nonfederal facility
      cleanup. No reference could be found regarding creation/formation of a separate cleanup
      commission.

      Another GAO report (GAO/RCED-95-66, Coordinating Activities Under RCRA and CERCLA,
      December 12, 1994), examined how DOE coordinated cleanup activities under RCRA and
      CERCLA and outlines some problems encountered to date with those coordination efforts. The
      report notes that DOE intends to issue guidance in the spring of 1995 to facilitate this coordination
      and develop, with EPA and state involvement, model interagency agreement language. Again, no
      reference regarding the creation/formation of a separate government cleanup commission was
      found in this report

31.   SCDHEC and EPA, are you aware of any time that you granted SRS authority to pump tritium into
      the streams at levels that exceed 10,000 pCi?  How about ETF?  Isn't that (32K Ci) significantly
      higher than  the 10,000 we are supposedly treating? Tritium is the primary radionuclide in the
      effluent at the ETF and can not be separated and is currently being discharged to surface streams.
      What's the difference?
      Response: In its implementing regulations (40 CFR 122 in particular), EPA refined the definition
      of "pollutant" to exclude radioactive materials regulated under the Atomic Energy Act of 1954
      (AEA). Currently all discharges of tritium into sitewide SRS steams are regulated by the
      Department of Energy in accordance with the ALARA program. This information is provided to
      EPA and SCDHEC in an annual Environmental Report as well as in National Pollutant Discharge
      Elimination System (NPDES) permit applications. The levels of tritium discharged from the F/H
      Effluent Treatment Facility into Upper Three Runs Creek are 1-5% of the maximum allowable
      levels (ie. 20 pci/ml), well within the safe levels for maintaining all applicable stream uses.

32.   "Are we going to have another one of these meetings after you respond to the comments."
      Response: Another meeting on the lAPP's is not currently planned.
                                            B-9

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
	April 1995
                                                                    s.
Written comment received on questionnaire from the F&H Gronndwater Public Meeting.

"There must be a better -way to get public involvement than this kind of meeting."

Response:  As part of the CERCLA process it is required to involve the public in selection, review, and
comment of a proposed remedial action. This type of public meeting allows the public the opportunity to
openly communicate their concerns, comments, and to go on record with any specific questions.
Additionally, the public is given the opportunity to review and provide written comments on a proposed
remedial action such as that contained in the F&H Groundwater Interim Action Proposed Plan documents.
SRS would welcome any suggestions from the public on how to possibly improve the Public Involvement
Program. Please submit any suggestions to:

Mrs. Mary A. Flora
WSRC
1995 Centennial Avenue
Aiken, SC 29803


Written comment received on questionnaire from the F&H Groundwater Public Meeting.

"What is the impact off site if no action is taken? Quantify impacts if any against federal criteria and
actual risk to public compared to other industries along river.  Does the risk justify cost? "

Response: Environmental monitoring and risk assessment work indicate that there is minimal risk to the
public if no corrective action is taken.
                                            B-10

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Interim Action ROD                                                 WSRC-RP-94-1163
H~Area Groundwater Operable Unit                                .            Revision 1
	.    	April 1995
                                                              •c.
Letter #1 from Mr. Philip Brandt to the EPA
                                       B-ll

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3325 Berkshire  Circle
Johnson City, TN 37604
January 16,  1995

U.S. EPA Region IV
Attn: Jeff Crane
345 Courtland Street
Atlanta, Georgia 30365


Dear Mr. Crane:

A 'public  meeting  was held at  North Augusta, South  Carolina on
January 9, 1995 on the Savannah River Site F&E Groundwater Proposed
Plans.  At that time I submitted written comments, however, due to
time constraints those comments were incomplete.  Attached please
find a complete set of comments.   Please disregard the original
comments.

I am in the process of obtaining additional technical information
relevant to  the - -oposed  alternative and request an extension of
public comments ...or 90 days due to the time required  to obtain
information  through  the   Freedom  of  Information  process.    In
addition, I  am  requesting that  a  second public meeting  be held
after a formal response to all commentors have been completed.

If you need to  speak with me directly you can call me at work (615)  \
734-9141 ext 1316 or home  (615) 282-5239.
Sincerely,
Philip Brandt

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                         COMMENTS
                            ON
                      F&H GRODNDWATER
                      PROPOSED PLANS


My name is Philip Brandt.   I  have a BS in Wildlife and Fisheries
Science and three years of graduate study training in zoology and
terrestrial  ecology.    I  have  over 15  years experience  in  the
regulatory and environmental field including six years at the SRS.
Three of  those years  was  spent  working for a consultant under
contract  to  the  DOE.   During  that  ti»e  2  provided  expert
environmental regulatory support to the DOE.  My last three years
at SRS,  I was  employed by  the DOE  as Senior Waste  Management
Specialist and as Acting Branch Chief, Environmental Restoration.
During my  tenure there I  was  responsible  for the  RCRA Interim
Status closure of the F and E Area Seepage basins and 58 acres of
the mixed waste  burial ground.   Since leaving DOE and  the SRS I
have continued my environmental career in the commercial sector and
have  continued  to work  with   both  hazardous  and  radioactive
contaminants.  Most recently,  1  managed a removal action involving
radioactive and hrsardous waste  which resulted in a release of the
property with no restrictions by the regulating agency.   My areas
of expertise include both RCRA and CERCLA.

Over the Christmas holidays I became aware of this public meeting
and have driven over five hours  to be  here to present my comments.
The direction the regulatory process has taken and how the public
is kept  informed and involved, or more importantly not informed, is
of a great concern to me.

First I want  to  provide  comments  on .±be  environmental  facts
concerning the Savannah River  Site, the F and H area seepage basins
and the proposed environmental  remedy,  facts  which have not been
properly identified or communicated to the public by the  DOE or the
regulatory  agencies.    At   issue  is whether  the  contaminated
groundwater from the seepage basins pose a threat to human health
and the  environment.  This threat is examined  from the perspective
of (1) impact on the Savannah River which is a  recreation source in
the area and a drinking water source for Beaufort, South Carolina
and Savannah, Georgia,  (2)  impact to Four Mile Creek on the SRS
reservation  into which contaminated  groundwater from the basins
seep, (3)  impact on wildlife and vegetation along the area between
Four Mile Creek and where contaminated water seeps onto the land,
and (4)  impacts on the groundwater and its affects to both onsite
and offsite users.

Facts on F and H Area Seepage Basj.n Operations

Wastewater flows from the F and  H Area Separations to the F and H-
Area Seepage Basins ceased  on November 7,  1988.   'Liquid effluent
that was discharged into the seepage basins is now processed at the
H-Area  Effluent Treatment  Facility.   Tritium  is the primary.

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radionuclide  in the ETF effluent.  Because tritium is a hydrogen
atom it cannot be separated from a water molecule which is made up
of  two hydrogen  atoms and  an oxygen atom.   There  is  no known
practical method for treating tritium contaminated water whether
its  ground water or  surface water.   Consequently,  tritium is
discharged along with the treated effluent into O£per Three Runs
Creek  under  an NPDES  permit.  In  1989,  the first year of full
operation for the treatment facility, over 2,000 Curies of tritium
were discharged to UpperThree Runs Creek (1).    FACT:   There is
absolutely no difference  in the health «n<3 environmental impacts
from the tritium that is  discharged from the permitted treatment
facility and  the tritium that seeps  into the  Four  Kile Creek.
Unlike  other  radionuclides,  tritium  dots  not  bioaccumulate  in
animal or plant tissues or in the ecosystem. • Ther* is absolutely
BO documentation or research that tritiated water -onait* has harmed
or ever will harm land and aquatic plants and animals.  The concern
over tritium is the potential dos*  to people -when tritiated water
is used as a drinking water  source.

Facts on Regulatory Authority Over  BasJLnClosure and Ground Water
Cleanup                        •        .

Regulatory authority over the closure- of  the- basins is  fairly
complex and is w _vided between the State of South Carolina and the
EPA under  two major laws, RCRA  and CERCLA.  -The state  enforces
portions of  RCRA and  includes  the  regulation  of  contaminated
groundwater from hazardous contaminants such  as metals and organic
chemicals.     However,  RCRA  does  not  regulate  radionuclides.
Authority to  regulate radionuclides comes under CERCLA  which is
administered by EPA. Basin H-3, which last received waste in 1962,
is also regulated under CERCLA. RCRA was not enacted then and its
rules cannot be  applied retroactively.  Consequently, any decisions
made on groundwater cleanup actions  for Basin H-3 fall under CERCLA
regulations.   Section 121 (a)  of CERCLA "requires EPA to make, certain
remediation solutions  are cost effective.   The  total life cycle
costs for this project exceed $270 million and will be demonstrated
not  to  be cost  effective  (5).    The  State  regulates  other
groundwater contaminants not  included under RCRA such as nitrates
(sane as fertilizer)  and  sodium (same as salt).   The State also
sets and regulates  water  quality standards  for surface  streams.
streams on the SRS have the same water  quality designation as does
the Savannah River,  Class B  (7).   This dual regulatory authority
and who was going to be the lead agency was a  source of problems in
negotiating closure and post basin closure activities  with  the
State and EPA  when I was there five years ago. state's rights were
a big  issue  and  sometimes  during negotiations I  thought  we  had
traveled back  in time 134 years to Fort Sumter in Charlston, South
Carolina.

After waste water discharges ceased in 1988,  a formal permit under
RCRA was agreed  upon by all parties and physical  closure activities
begun.  After  inspection by an independent engineer, the State and
EPA agreed and  confirmed  in  1991  that the basins had been closed
based  on the  conditions  of  the RCRA  permit.    EPA reviewed  the

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closures and formally determined that the closures were protective
of human health and the environment (10). How the ground water was
to be  treated was decided in  a separate permit action  from the
closure action.

F and H Area Basin Ground WaterFactsf7^8S9>

Simplified, there are three aquifers in the F and H seepage basin
area.  The shallow water table  is characterized by low flow and is
not  used  onsite  or  offsite  for  drinking  water  or  irrigation
purposes.   Some of the  monitoring  wells are located  in perched
aquifers which cannot provide a sustained yield of water.  In other
words, they would not support the water needs  for a hose.   For
example, the  Federal  home loan programs require that you  have a
well that provides a sustained yield of six  gallons per minute.  If
you don't have a well that yields the iBJTiiirom amount you will not
get  the  loan.   Water from  the water  table or shallow aquifer
discharges into Four Kile Creek through a seep line near the creek.
There is an aquitard that separates the shallow water table aquifer
from  the  middle  aquifer,  however,  it  is not  complete  and
contaminated groundwater also moves from the shallow aquifer into
the middle aquifer.  Groundwater from the middle aquifer discharges
several  miles away into  Upper Three Runs  Creek  which  is also on
the  SRS.   A second,  more complete aquitard, exists between the
nicidle and lower  aquifer.   This  aquitard  provides  significant
protection from the contaminated  groundwater  in the middle aquifer
from entering the  lowest aquifer. In addition, this lowest aquifer
is under higher hydraulic pressure due to geologic conditions than
the middle aquifer.   This means  that if the aquitard is breached
the  ground water  will flow up towards the surface .and  not down.
Ground water from the deepest aquifer discharges into the Savannah
River.  FACT:  Geologically, water from the contaminated aquifers
have not migrated into the groundwater beyond the site's boundary
nor  can it ever contaminate  offsite  grbuz&water  aquifers because
they all discharge into on site streams*

The   primary  ground  water   contaminants  are   radionuclides
(principally tritium), nitrates,  metals (principally cadmium in F-
Area and mercury  in  H-Area), and sodium.  Tritium  ,  sodium, and
nitrates are very mobile contaminants whereas metals will not move
as   fast   through the  ground  water.     For   example,  sodium
concentrations  exceeding  200,000  ug/L   are   found.     Other
contaminants such as plutonium move very little,  if at all.

With the closure of the basins, two major positive impacts to the
ground water occurred: (1) a  waste source comprising many millions
of gallons of waste water was eliminated and (2)  further movement
of contaminants from the basins into the groundwater were virtually
eliminated due to the clay cap constructed  over the basins (the
clay cap isolates  the  waste from coming into contact with rainwater
that would have  infiltrated the soil above the waste).   FACT:
Groundwater sampling froa over 240 monitoring veils has confirmed
that the water quality from the contaminated  aquifers has improved
dramatically  and  will  continue  to  improve without any further

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action regarding ground vater •treatment.

        Water Facts/7. 8.
Contaminated  ground water from  the F and H area seepage basins
discharge  into Four Mile Creek along a  eeep line.   In 1993, the
only  radionuclides detected in Four Kile  Creek were tritium and
strontium.  Estimated values have been reported for  iodine 129 but
I am personally aware that the source document used  to develop the
iodine inventory was of poor quality.  The field work that resulted
in quantifying the iodine inventory was superficial at best.  In
addition, there was a calculation error  in the reported inventory
which results in an over estimate of the iodine 129 inventory.
Strontium concentrations have been declining -every year since 1988
and decreased by  23% from 1992 to 1993 in the F area (194 mCi to
150 mCi)  and  17*  in  the E area (78 mCi to €5 mCi).   Based on
measured  inventory, tritium  is the  largest contributor to the
creek.  There is no known environmental  impact to the environment
that tritium at the existing concentrations can cause (for example,
it has  had no impact  on plant or animal  species diversity or
abundance) .   Tritium migration or flux from  the basins have also
decreased dramatically  since  closure and capping.   From 1992 to
1993 there has been a 49* decrease in the Curies of tritium seeping
from the F basins.  For the same time period there has been a 31%
decrease from the H basins. This trend of improving water quality
will continue without any additional action such as  pump and treat
with reinjection.   In  1993 an estimated 2,180 Curies  of tritium
seeped from the F basins and 1,020 Curies from the H basins (1,2,
and  3 only) .   Due to plume  mingling it  is  not possible  to-
differentiate tritium from H-4 and the nearby radioactive burial
ground, 64 3G  (a CERCLA site).  However,  it is projected that from
1994 on that  4,500  Curies of tritium, which represents two thirds
of the tritium flux that seeps into Four Kile  Creek,  will come from
the old  burial ground  and not  the seepage  basins.   By way of
comparison, there were 11,300  Curies of tritium released in liquid
form from all sources.  Releases from the  F  and H seepage basins
accounts for  only  3,200 Curies or only 28% of the total.   liquid
releases are completely dwarfed by air releases.   In 1993, 191,000
curies of  tritium was  released to the  atmosphere which  is  sixty
times  greater  than the  release from  the  F and  H basins  and
seventeen times  greater than  all  liquid releases.   Most of the
tritium released to the  atmosphere combines with water molecules in
the air and returns to the surrounding areas both on  and offsite in
the form  of  rain  or  snow.   This phenomenon has been  confirmed
through the drilling and testing of groundwater wells and shallow
springs on the Georgia side of the Savannah River where well water
concentrations  of 2,000 pCi/L have been found and onsite  where
rainwater with tritium has been found in concentrations exceeding
42,000 pCi/L  (over two times  current  drinking water standards).
This tritiated rainwater either runs off to surface streams such as
Four Mile  Creek or becomes part of the groundwater on  site, or
under  goes   evapotranspiration.    This is  why ' you  can  find
detectable, but acceptable,  levels of tritium in drinking water
supplies for  cities such as Aiken, North Augusta,  New Ellenton,

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Jackson, and Augusta,

Water samples from Pour Mile Creek, other surface streams on SRS,
and the Savannah River are routinely collected and analyzed.  The
Savannah River  is  an important recreational  source and drinking
water source for Beaufort,  South  Carolina and Savannah, Georgia.
Radiological contaminant concentrations including such parameters
as gross alpha and nonvolatile beta are  the same above and below
the  SRS with two  exceptions:  (1)  tritium, and (2)  cesium 137.
Cesium is not released from the seepage basins.  Tritium, some of
which originates from the F and H area basins,  is well below EPA
established health based standards.  If the tritium that originates
from the F and H Area basins could be eliminated completely (they
can't)  there  would  be an  insignificant change  in  the tritium
concentration  in the  drinking  water systems  in Beaufort  and
Savannah.   This is  due to the ETF  discharges  (2,000  Curies in
1989), discharge from other seepage basins and the burial ground,
and  down washing of  tritiated rainwater  from the  over 190,000
curies  per year of  tritium  released to the  atmosphere.   The
prestigious  Academy   of Natural   Sciences  of  Philadelphia  has
monitored water quality on the Savannah River  since  1951 and in
1990 conducted a special study on plant and animal life including
sensitive indicator species*  There was  no difference in species
richness or abundance due  to SRS activities and  no detectable
difference  in water  quality factors  due to  SRS  activities that
could   affect   the  species  . richness  and  abundance.     This
documentation of no  impact to the Savannah River  over the past
forty  years is  in  spite  of the fact  that  the discharge  of
radionuclides and other contaminants were much higher  in the past.
In fact,  the  amount  of  tritium released to  the river  has been
higher by a factor of ten (approximately 150,000 Curies) in 1963.
If the river or human health was being  negatively impacted a marked
improvement would have been observed  due to the  continuous and
intensive monitoring  by the Academy of Natural Sciences.  The fact
is no environmental impact has been observed because there has been
no impact.  Over thirty parameters affecting stream water quality
are routinely sampled on Four Mile Creek  including organics, gross
alpha/beta, nitrates,  sodium,  and heavy  metals.    There  is no
difference  in water  -quality for  these parameters  (samples taken
from Road A and A7) when compared  to the  Savannah River except for
tritium.  The only measurable radionuclides discharging from the
seep area  are  tritium and  strontium.  FACT:   Tritium and other
contaminants released from the F and Z Area seepage basins have no
impact on human health or the  environment in the Savannah River or
to sources  down stream  that use the Savannah River as a drinking
water source.

Environmental and Health Risks from the F and  H  Area Seepage Basin
Groundvater Facts (1. 8. &9)

The EPA sets the drinking water standards for  communities.  Limits
prescribed are conservatively derived i.e.  they err on the side of
over protecting individuals.  For  radioactivity in drinking water,
EPA has  determined that concentrations that  provide  a dose of 4

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'nrem  per year is protective of human health and the  environment.
The  maximum  dose received by  the public  from drinking tritium
contaminated water is 0.04 mrem (1% of the allowable dose) and 0*05
mrem  per year  (1.25%  of the allowable  dose}  at Beaufort,  South
Carolina and Port Wentworth, Georgia.  This is in contrast to water
wells in Georgia that  have tritium concentrations that are  10% of
the allowable limits (the source of which tritium released from air
emission sources on the site which are  in •turn over sixty times
greater than that released from the F and H area seepage basins.
These doses measurements are based on a tritium limit of  20,000
pCi/I* and will  decrease  by a factor of  three when the proposed
limits of 60,900 pCi/L are implemented by EPA.   Cesium, which does
not originate from the F and B basins, is found in the  water  system
but it too  is also well below allowable drinking water standards.
In summary,  there is no unacceptable human health or environmental
risk  to the Savannah River as a drinking water supply.  If  the F
and K area seepage basin radionuclide  contribution to  the Savannah
River was completely removed there would be an insignificant  change
in  the radiounuclide due to  other  regulated   emissions, and
discharges  from  the SRS.  There is no  unacceptable human  health or
environmental risk  to  the onsite workers.  Over 20,000 personnel
work  onsite on  a regular basis.   There  are twenty seven  onsite
drinking water s^ ;ems, some of which have been in operation since
plant startup.    Over 1,400  samples  for chemical  analysis .were
performed in 1993 and all systems met EPA's primary health based
standards.  In other words,  the personnel onsite use  drinking water
taken from  the same  aquifers onsite that supposedly are  in  danger
of being contaminated  and have  done so for over forty years while
meeting all drinking water standards established by EPA and SCDHEC. •
Even under worst case conditions, where a theoretical **Bubbaw spent
most:  of his time living  on the site boundary  swimming,   water
skiing,  hunting  and fishing,  drinking  water  from the Savannah
River,  eating contaminated fish and wildlife, could only receive an -
estimated 0.25 mrem per year dose. If someone would  pay me to live -
this  life style  I'll do it.  This way the site could  collect real
data  and I  could then justify why I wear white socks.  This 0.25
mrem per year dose compares to an  average dose of 300 mrem per year
froro  natural causes.   In  other  words,   if  the SRS  could  cease
emitting all radioactivity (it can't) people would still be exposed
to  over 99.92%  of  the radiation that they are  currently  being
exposed to.  A  measure of the risk 0.25  mrem/year  presents is
provided through the loss  of  life expectancy  (LLE)  calculation.
LLE is the  average amount  by which one's life  is shortened  by the
risk  under  consideration.   For example,  being overweight reduces
your  life expectancy one month for each pound you are  over weight.
Unless I lose weight I have shortened my  life by over  three  years.
Being poor and/or unskilled reduces your life expectancy from semi-
skilled, clerical/sales people  by 2.4 years and an  additional 1.5
years when  compared to professional/managerial  personnel. The LLE
for a person in Harrisburg,  Pennsylvania from the Three Mile  Island
nuclear power reactor was 1.5 minutes. The T-TrF for  0.25  mrem/year
is functionally equivalent to a regular smoker smoking  one extra
cigarette every  fifteen years or an over weight person like  myself
increasing  my weight by  eight tenths of an ounce, about half a

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candy bar.                               • .
                                            • £. - *
Environmental damage is typically determined through a decline in
the number plant/animal species and the abundance or total numbers
of plants  and  animals.   The only  environmental damage noted has
been some very minor vegetative stress along the seep line between
where the  basins  seep into Four Kile Creek.   The  source of the
vegetation stress is not known. However, it is  highly likely that
the  stress  is due  to elevated   soil/water   concentrations  of
aluminum/  sodium,  and  nitrates and  not radionuclides  or heavy
metals.   What is important is that since the basins were closed the
vegetation has begun to recover and continues to recover.  It is
also important to note that the plant and animal populations along
Four Mile Creek are not unique and do not  support any threatened or
endangered species.   Kith  the exception of  very -localized areas
described above, the plant and animal species  and populations along
Four Mile Creek, are both diverse and abundant which is indicative
of a healthy ecosystem.

FACT:  There has beea  no - significant impact to  the  environment in
the vicinity of the F  and H seepage basins.  What damage that has
been noted is  recovering naturally.  Water quality in Four Kile
Creek continues t=  improve.    There is no difference  in species
richness or abundance above  and below the seep areas  or in Four
Kile Creek.
Proposed Mitigation fPump/Treat/jReiTneet) Facts f5, 10)

The SCDKEC and the EPA are requiring  the DOE install a series of
interceptor groundwater wells,  pump down the  aquifer,  treat the
water,  and  reinject the  treated groundwfiter  upgradient  to the
basins.   SCDHEC  requires  that  reinjected groundwater  meeting
drinking water standards before it  is reinject.   They both admit
that tritium cannot be removed from  the treated water, therefor it
cannot  meet drinking water  standards,  but  will  be reinjected
anyway.  Nitrates, which also exceed drinking water standards, will
also  be  reinjected  without  treatment  even  though  treatment
technology exists for nitrates.

Normally under RCRA, regulated contaminants must be cleaned up to
drinking water standards.   Under specified conditions, a variance
is allowed  called  an Alternate Concentration Limit.   ACL's are
allowed when the hazardous constituents (not radionuclides-they're
regulated under CERCLA) are not capable  of  posing a substantial
threat  currently or a potential  hazard  to human  health  and the
environment  in the future.   DOE pursued this approach  and was
prepared to evaluate in the field  some innovative technologies but
was denied the ACL.  Consequently,  DOE was required to implement
ground water cleanup.  One of the treatment options rejected was to
install the  pumping wells,  pump  to a collection/treatment tank,
adjust the pH,  and  discharge the water to the Savannah River under

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a NPDES  permit..   This approach meets all regulatory requirements
under RCRA for treatment and discharge.  However, SCDHEC and the
EPA required that a more expensive treatment system be implemented
and the  water  reinjected.  The purpose for the reinjection is to
allow for  the  natural decay of tritium.  However, as  pointed out
before there is no health or environmental risk for discharging the
tritiated  water or for allowing it to  continue to  seep out.   Jn
fact,  a  technical  evaluation (5) conducted  by DOE's  Office  of
Environmental  Restoration (EM-40)  concluded that after 2005 (ten
years) there would be no difference in the off  site tritium flux to
the Savannah River whether the corrective action was implemented or
not (see previously discussed facts).   DOE estimates (1993) that
$12.6  million  has  already been  spent on  this  project with  an
estimated  $24 million budgeted for 1994/1995 and an estimated life
cycle cost of  $270 million.

The proposed ground water treatment  may in fact cause additional
problems.   In response  to questions  at  the public meeting  on
January S, 1994, Ms. Kathy Lewis indicated they will  not  be able to
intercept  or control  the  contaminant plumes in their entirety nor
can they guarantee that relatively immobile contaminants that don't
presently  show up  in Four Mile Creek,  such as plutonium, will be
mobilized.

FACT:  Re injection to control tritium flux is a fallacious argument
by SCDHEC and EPA.    Tritium ground vater contamination  in  the
contaminated aquifers  has improved dramatically over the past six
years and  vill continue to  improve.  Tritium/  because of its half
life of 12.3 years,  vill continue to be removed permanently through
decay.   In 24.6  years 75% of the existing tritium inventory vill
permanently  "go away" through radioactive decay.   Offsite  and
onsite drinking vater quality are already protected with no further
action,  that   is,  without having  to .spend over  a  quarter of  a
billion  dollars.

The proposed action has & high probability of  failure and does not
address one of  dominant ground water contaminants,  nitrates.  Under
the proposed remedy,  the major  contaminants  (tritium,  nitrates)
will  not  be treated.   Minor contaminants such  as mercury  and
cadmium  are in  most  cases  just  slightly above drinking water
standards.  The National  Academy of Science has recently reviewed
pump  and  treat  technology   (1).    Their  conclusion  is  that
remediation by pump and  treat is a slow process which can easily
take tens, hundreds, or thousands of years.and that the ability to
restore  contaminated groundwater to drinking water standards  is
uncertain  at many  sites.   According  to the HAS,  geologic factors
and the  contaminants may  make restoring contaminated ground water
to drinking water standards technically infeasible.   In addition,
in  public  documents  EPA  has  acknowledged  "some  ground  vater
contaminants cannot be completely eliminated, no matter how long we
pump and treat".  As of 1990, based upon research performed by the
Oak Ridge  National Laboratory (3), there  has been  no documented
case where a single aquifer in the United States has been confirmed
to have  been successfully restored through pumping and treating.

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There is already onsite, documented evidence that pump/treat cannot
restore  an  aquifer to  drinking vater standards.   Ground  water
cleanup  of organics using pump and treat has been  ongoing since
1985  in the H-Area.   There is  no technically competent person
onsite (or off site) that will state or predict that the aquifer in
the  M-Area  will  be  restored  to  drinking  water  standards  for
organics using pump and treat only.

DOE's Office of Environmental  Restoration (EM-40) recognizes the
futility of  the F and  H Area  pump and treat system (5).   DOE
identified all proposed  pump and treat projects within the complex
and categorized them into three categories:  (1) technically sound
and reduces risk to the public, (2) limited  risk reduction to the
public, and (3) little or  no risk reduction -and may be technically
unsound.  The proposed pump  and treat  system for the  F  and  H
seepage basins falls into category three, "No measurable risk" with
a  recommended path  forward to "negotiate  with  regulators  for
combined   institutional   control   and   innovative   technology
demonstration". This approach has been rejected by the regulators.
It is most important to note that  in  12.3 years of  institutional
control, half  of  the tritium  decays  away/  in 24.6 years  75%  -
without taking into account any loss of tritium through seepage.

Comments and Questions

In order for the public  to fully understand the impact, or lack of
impact, to the environment please provide the following information
in your response to my questions.  What has been the water quality
trends  over  the last six years on Four Mile  .Creek  at  sampling
stations IB,  1C,  2B,  2,  3A,  3, 6, and  A7  while describing the
source  terms  that contribute  to  the contaminants?   What data
indicates that  the contribution of hazardous substances  to Four
Kile Creek,  including radionuclides, will increase  over time with
no  further  action.   Over  thirty water" quality  parameters  are
sar.pled  routinely.   Identify those parameters that do not meet
SCDHEC water quality standards  for Class B streams on a consistent
basis  {50%  of the tjme or more).   For noncompliant parameters
provide documentation that the impact is due to releases from the
seepage basins, that is there is a significant  difference between
upgradient and downgradient values from the F and H area basin seep
lines along Four Mile  Creek. Provide documentation that the flora
and fauna on Four  Mile  Creek downgradient from the  seepage basin
are  significantly  different  based  on  species   diversity  and
abundance.  Provide similar documentation for the area between the
seep line and Four Mile  Creek.  Provide a map showing the ecotypes
and acreage along the Four Mile Creek and calculate the acreage and
percent of the total ecotype harmed by discharge from the basins.
Provide documentation  on the presence and/or bioaccumulation  of all
those contaminants found in wells above drinking water standards in
the water, flora and fauna  from the seep line  to Four Mile Creek
and  along  Four Mile  Creek (for example,  gross alpha/beta,  heavy
metals,  transuranics,   etc.)?    Finally,  tritium  production  is
currently at an all time low.  However, at some future time tritium
production may have to increase.   Please  document  the  maximum

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 allowable tritium  emissions  from air  sources  and the  B Area
 Effluent Treatment Facility and compare .them to current discharges
 to Four  Mile creek from the F and H area seepage basins (excluding
 -the  contribution from the  old burial ground)  and in  12.3  years
 (assuming no seepage from the basins).  Numerous veils in the F and
 H area  seepage  basins are poor  quality, low  yield yields from
 perched  water  tables.  How many of the water table wells  provide
 less  than six gallons per minute  continuous yield,  that  is, are
 unsuitable for home  use  as a drinking water source?  What is the
 water quality  for these wells?   How many of  these  wells do not
 yield enough water to provide  a representative sample  (airiT^m of
 three casing volumes)?  How many of the wells evidence  faulty well
 installation?  Does  SCDHEC and EPA require the same ground water
 protection for perched water  tables  which are  unsuitable for a
 drinking water supply system as for legitimate aquifers?   Provide
 documentation on the level of contamination that is discharged from
 the congaree aquifer to  Upper Three Runs Creek.  Provide  similar
 documentation  for the deeper aquifer  that discharges into the
 Savannah River.   Finally, provide trend data over  the past six
 years for those RCRA contaminants and  radionuclides  that are
 discharged to Four  Mile Creek  on select but  key  downgradient
 groundwater  wells  for  the  shallow water table and Congeree
 aquifers.  As  a comparison, include upgradient wells particularly
 those that show contamination from the old burial ground.   Discuss
 and comment  on whether the  data  trends support  an  improving or
 deteriorating  groundwater quality.   Provide the same information
 for nitrates and sodium.   If  the  water  quality is improving and
 there is no  longer a source term  recharging the basins does the
 risk  of contamination of  the deepest aquifer increase or decrease?
 Similarly, for the Congaree does the risk of contaminated discharge
 to the Upper Three Runs Creek increase or decrease? Numerous wells
 have  been identified where gross  alpha and  nonvolatile beta are
 above drinking water standards and/or -drinking water standards for
 other radionuclides  are  exceeded  based  on  a  maximum dose.
 Radiological dose is  based  on an average dose  - not a single
 maximum  datum  point.   What has been the  average gross alpha and
 beta  values?   Is  the data normally distributed or is -a geometric
mean  more  representative?    If  the  geometric  mean is  more
 representative, is it above the established standard?

 The EPA has determined that capping is protective of human health
 and the environment capping.   Is capping and institutional  control
 an   allowable   remedial   alternative   under   CERCLA?     Since
 implementation of capping,  groundwater has improved dramatically
 thus  decreasing  future risk to human health and the. environment
 through  institutional control.    What  period  of institutional
 control  was considered by SCDHEC/EPA in  evaluating the no action
 alternative under CERCLA.  If  it  wasn't  evaluated why not?  As a
 means for comparing the effectiveness of pump and treat onsite as
 a viable technology, how  long  will it  take the existing pump and
 "treat system to clean up the ground water in the M-Area to drinking
 water standards and at what cost?

 SCDKEC requires  that ground water used  in the reinjection wells

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meet drinking water standards.  How can SCDHEC  allow tritiated
groundvater  that is  1,000  tines  drinking-water  standards  be
reinjected.  Eow can  it allow nitrates that  are  10-100 drinking
water standards be reinjected when treatment technology exists to
treat nitrates.

Pumped water can simply be adjusted  for low pH and  discharged to
the Savannah River meeting all health and safety  requirements of
both EPA and SCDHEC at significant cost savings over the required
remedy.  What is SCDHEC's and EPA's justification, under RCRA, for
not  requiring  the  most cost  effective  remedy which meets  all
drinking and surface water quality standards?

The remedial action  for  H area includes Basin H-3.  This site is a
CERCLA site and not a RCRA site.   Based on groundwater monitoring
data it  also the primary source of the metal  contaminants down
gradient from the basin complex.   Under what  authority was this
site included under the  RCRA regulations and where was the public
input.   Why isn't this site considered separately?

A different environmental  remedy for the same  site can be arrived
at under CERCLA  versus RCRA.  In fact, the DOE submittal to SCDHEC
and EPA for the proposed remedy under CERCLA is that no action be
taken  (10).  What has been SCDHEC's and EPA's  response to DOE's
proposed remedy  under  CERCLA of no further action (Rev.O, Proposed
Plan for F and  H Area Groundwater Operable Units).  What was your
basis for rejecting  the proposal, particularly for basin H-3 which
is not regulated under RCRA.

The risk  assessment process used  is flawed.   Proposed tritium
standards are three times higher than  current standards.   When
performing your risk assessments you used proposed  concentration
Units when they were higher than existing  limits.  However, in the
case of tritium you  used the existing" limits when  proposed limits
are over  three  times higher.   There  is no  rational basis  for
ignoring nitrates in the risk assessment process nor is there any
health/environmental  based  reason  for   pumping/treat ing  and
recirculating the  tritium plume  to maintain a   20,000  pCi/mL
contour.   If you are not  maintaining the drinking water standard
isopleth then 200,000 pCi/mL or current levels  are as equally valid
as  the 20,000   pci/ml isopleth  for tritium.   Why weren't  the
proposed tritium standards used ( 60,900 pCi/L)?

The State and the EPA have specific areas of  regulatory authority.
The  State  does  not  regulate  ground   water contaminated  by
radionuclides.    Does SCDHEC  claim regulatory  authority  over
radionuclides?   Under what authority and has  the Federal government
given up its sovereign immunity?

Besides the DOE SRS,  SCDHEC  regulates  municipalities,  private
businesses, and other State  and  Federal agencies.   For example,
there  is  tritium  contaminated groundwater  at the  adjacent Chem
Nuclear facility in Barnwell.  Municipalities frequently fail to
meet solid waste and groundwater requirements.   Federal military

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bases have a variety of environmental problems.  Does the DOE SRS
receive equal  treatment under the law relative to enforcement or
fines?  What other facilities are being required to pump/treat and
reinject as a  remedial action?  How many are allowed to reinject
contaminated   water  above  drinking   water  standards?    What
concentrations?  How many ACL's have been granted by SCDHEC in the
last five years?  How many by  EPA Region IV in past five years?
Given  the  number  of  approvals,   are  ACL's  in fact a  viable
alternative to restoring aquifers to drinking water standards?  How
many pump and treat actions of similar scope in South Carolina have
resulted in  the return of the  contaminated  aquifer  to drinking
water standards?

Regulatory oversite by SCDESC at SRS is funded by a grant from DOS.
Kow many municipalities,  private industries, and other government
agencies fund  their own  regulatory oversight?  How  does SCDHEC
avoid a conflict of interest,  that is,  the more remedial actions
required the higher the funding level for SCDHEC?

As expensive and futile as the proposed remedy is there was another
solution which met the requirements under RCRA, complied with all
other environmental laws,  presented so significant risk, and was a
lot cheaper.   Th«. remedy is to pump the shallow aquifer, adjust for
Ph,  and  discharge  to  the  Savannah River.   Has the  SCDHEC/EPA
required   municipalities,   private   businesses,    or   other
State/government agencies  in South Carolina to implement the most
expensive ground water treatment option when a  second, less costly
alternative would meet all of the State and EPA requirements for
protection of human health and the environment?  Would the State be
willing to pay the incremental cost between the two options?  Under
the law, can  the EPA ever conclude under CERCLA that no further
action was required where RCRA  requires that a remedial action be
implemented?  Has the DOE been asked/requesfeed/pressured to include
the CERCLA site, 643G  (Old Burial Ground),  under  RCRA?  What has
been DOE's response?  If yes, what was the justification?

SUMMARY AND CONCLUSIONS

Due  to the  holidays  I   was unable  to  obtain additional  data
supporting  the  position   that   no  further  action  is  required.
Consequently,  I have  asked that  comments be  held  open  for  an
additional 90 days  (given the  lengthy time  required  to obtain
documents under the Freedom of  Information Act) and that a second
public meeting be held so  that  all questions can be addressed.

I have polled friends and  family in the Aiken, South Carolina area.
When I describe  what is being proposed and how much it will cost
they are dumb founded.  They have seen the public notices regarding
these  activities but  they  do  not highlight  the  facts  I  have
included nor do they address the questions I have posed nor do they
make the public aware  of the costs.  I  am appalled at the lack of
effective public communication.

I   will  be   forwarding   my   comments   to   my   Congressional

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representatives  from Tennessee.   Copies  will also .be sent  to
Senator  Strom  Thurmond  and  the Governor B of  South  Carolina.
Incumbents were removed from office because of governmental actions
such as this and new people elected to sake government accountable.
This process  reminds me of the  EPA proposed action for the ski
resort town in Colorado which has lead contaminated soil  from a
mining operation in the 1800's.   EPA's remedy  was  to dig up four
feet of the town and backfill vith clean dirt.  It wasn't until
after several  years of arguing with the residents that they finally
looked at lead  blood levels  in children and  found  that they were
below the national average.   The  selected remedial action is still
being  disputed.   Signs  have  been  posted  in  the town  by  the
residents - the stake holders - those who are impacted by the site
the most - for EPA to go home.  This type of action at SRS does not
enhance a person's belief or confidence that the  regulators are
here to help you.  The proposed remedy at SRS appears to be along
the same line  as the  Colorado incident.  However, this is just the
first  of  many  ground  water  remedial  actions  that  will  be
implemented by SCDHEC and  EPA and SRS.  In other words, the quarter
of a billion action is just a down payment.  Wasteful expenditures
on  this scale,  without  a  real  benefit  or enhancement  of  the
environment   or human   health,   undermines  and   distorts  the
productivity of our  economy.   I'm hopeful that during  a time  of
huge Federal deficits I  will  get  an audience with the new Congress
as they seek methods  to  cut the Federal budget and make government
accountable.  One method is to  have Congress with hold funding for
this activity.  Under the Federal Facility Agreement,  the DOE can
only be held  accountable  for activities that are funded.   I will
also be encouraging my Congressional representatives not to support
DOE funding in general for projects of this type.   A quarter of a
bill ion-dollars could achieve measurable, quantifiable improvements
to  human  health and  the  environment through  a  myriad of  other
programs  such  as   education,   job  training,   weight  reduction
programs,  etc.    It   won't  achieve measurable,   quantifiable
improvements  to human  health and the environment through  the
proposed remedial action of pump, treat,  and reinject.

Finally, I  would liks to address the issue of effective  public
participation, or lack of it,  in the decision  making process for
selecting  environmental remedies.   It is not  working and  the
response is narrowly orchestrated by  such groups  as  the  Energy
Research Foundation and the NRDC who don't speak  for the general
public in the area.   For example, how many comments were received
from the public on the F and  H  Area post closure permit.  How many
of those originated from the EOF,  other special interest groups and
their members, other regulatory agencies,  and how many originated
from the public in general from the Aiken, Bamwell, and Allendale
area?   I  had  hopes that  the Citizens Advisory Board  would have
addressed the  issue of expensive  remediation without environmental
benefit  but  it  appears  that  they  too  are  unsuccessful  in
identifying and effectively communicating the concept of risk and
the cost of cleanup to  the public.  I understand;  however, there
has been some  lively  discussion between some  members over who gets
reimbursed for meals. Is a possible reason for this  immutable wall

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of  silence that key Citizens Advisory Board^ chairs dealina with
risk assessment are held by ERF personnel?

I have a great faith in the American public.  Give them the facts
and they will make the right decisions.   Simplify the regulatory
aumbo jumbo and put in a  context that the public understands,   i
believe once the  citizens of the area understand  what is really
happening to them, the right decision  will be reached and it won't
involve squandering a quarter of a billion dollars.

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REFERENCES
1.   Alternatives for Ground  Water Cleanup, National  Academy of
Sciences, June, 1994
2.  Before It's Too Late A Scientist's Case for Nuclear Energy, Dr.
Bernard L. Cohen, 1983
3.  Curtis C. Travis and Carolyn B. Doty, Can Contaminated Aquifers
at  Superfund  Sites Be Remediated, 24 Environmental  Science and
Technology 1465, 1990
4.  Environmental Bulletin, Savannah River Site, Volume 5, Number
28, December 14, 1994
5.  Groundwater Pump-And-Treat Activities, Office of Environmental
Restoration (EM-40), August, 1993
6.   Proposed Plan  for  F and H Area Groundwater  Operable Unit,
Rev.o, November, 1993
7.  Savannah River Site Environmental Report for 1990
8.  Savannah River Site Environmental Report for 1992
9.  Savannah River Site Environmental Report for 1993
10. Savannah River Site Interim Actions Proposed Plans for the F-
and H-Areas Groundwater Operable Units, November, 1994

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             Groundwat
          Pump-And-Tre
                 Act/vitk
        Office of Environment
          Restoration (EM-4
                      August
                      Final E
United States Department of Energy

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                                                                   Depanmem 01
United States Government
        . EK-42 (J- Here, 903-8141)

  SUBJECT: Ground-water Pump-and-Treat Kotebook


      T& R. p. tfhitfield, EM-40
         0. Baublitz, EM-40
         R. lightner, EK-4S
         V. Vtsenbaker,  £8-43
         S. Kann, EH-44
          I an pleased to forward  the attached notebook on ground-water pump-and-treat
          activities managed by the  Office of Environmental Restoration (EM-40).  The
          notebook has  been compiled is  a result of data collected to support  *
          July 25, 1993,  senior managers' review panel which met to critique all of
          EH-40's pump-and-treat projects.

          The effort which went into collecting and presenting data for the senior
          eanager's review provided an opportunity for. an  in-depth study of-a  type of
          remediation activity cotsnon to all areas aanaged by EM-40.  Please identify
          what,  if any,  actions you would like relative to keeping this book up to

          date.
                                          James J.- Fiore
                                         /Director
                                         //Office of Eastern Area Programs
                                        //Office of Environmental Restoration
           Attachment


           cc:         ™  .«•
           K.  Larson,  EM-45
           0.  Lehr, EH-44
           V.  Murphie, EM-42
            G.'Turi, EM-43.

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                              Background

IRB briefing identified pump-and-treat systems not cost effective for protection of
human health and safety.

EM-40 was tasked to review all pump-and-treat projects to determine their
contribution to off-site  risk reduction.

25 projects identified across EM-40.

Senior Manager's review panel met on July 25, 1993 to critique all 25 projects.

Identified:

o   Three Category A  proje6ts -  Technically sound; reduces risk to public health
    & safety;
o   Sixteen Category B proje'cts - Limited risk reduction to public  health &
    safety; and,
<»   Six Category C projects -  Little or no risk reduction to public health &
    safety; may not be technically sound.

Category C projects are proposed fpr potential "Push Back."

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                Results From Review Board

Six Category C projects:

o   Two in the Eastern Area:

    •    General Separations Area (includes F&H) at Savannah River; and,
    »    TNX Area at Savannah River.

o   One in the Northwest Area:

    •    Lawrence Livermore National Laboratory, Main Site.

o   Three in the  Southwest Area:
                     i                             .

    «    South Valley in Albuquerque, NM;
    «    UMTRA site in1 Monument Valley, AZ; and,
    "    UMTRA sites at Tuba City, AZ.

Two "low end" Category B projects:

o   Site 300, Eastern General Services Area, Lawrencelivermore National
    Laboratory;
o   Groundwater Treatment & Monitoring, Kansas City Plant

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                Results From Review Board

Six Category C projects:

o   Two in the Eastern Area:

    »    General Separations Area (includes F&H) at Savannah River; and,
    •    TNX Area at Savannah River,

o   One in the Northwest Area:

    «    Lawrence Livermore National Laboratory, Main Site.

o   Three in the  Southwest Area:              .      '

    • ••  South Valley irf Albuquerque, NM;
    «    UMTRA site in Monument Valley, AZ; and,
    *    UMTRA sites  at Tuba City, AZ.

Two "low end" Category B projects:

o   Site 300, Eastern General Services Area, Lawrencellvermore National
    Laboratory;
o   Groundwater Treatment & Monitoring, Kansas City Plant

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                    PUMP AND TREAT WORK SHEET
ADS:
SR-515
Project: General
Separations Area
Location:
 Savannah River
Office:
EM-422
Purpose of Pump & Treat
Groundwater Treatment
Principal Contaminant(s)
Other Contaminants)
Baseline Risk
Post-Action Risk
Amount of Water Contaminated (gal)
Pumping Rate (gal/day)
Estimated initial Mass of
Principal Contaminant(s) [Jbs]
Estimated Removed Mass (to date) of
Principal Contaminants(s) [!bs]
Cost of Construction ($M)
Cost of Operation ($M)
Other Cost ($JV!)
Start Date (FY)
Completion Date tFY)
Legal Driver
I Other Pertinent Information
Cleanup of contaminated GW "
Currently proposed is neutralization,
settling, filtration and reinjection of the
effluent as well as air stripping with
catalytic oxidation off-gas.
Tritium; Trichloroethylene (TCEJ; lead;
mercury; radionucfide metals
Nitrate
1 X ID"7
No measurable risk reduction off-site
> 100 million
500.000 (34-7 gpm)
Further characterization required
None - Corrective action not yet
underway
$37.2 - ~
$186.0
$228.0
1992
2040
SCHW Pan B permit issued in 1992
requires F&H CAP (Oct 1993);MWMF
CAP (Nov 1993) per Settlement
Agreement
<£>s
FY 95 Cost - $t£3 million
Total Cost - $2/0 million
Pump-and-Treat Operational in FY 97
Category C
                                                               Jwtv 27. 1993

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                  Conceptual Behavior / Response • F & II Seeepage Bajln Groundwtler Corrective Acllun
   30000
^•^
I
10000
niH»/apMjtqnoN
        I98S
          1990
                                 1995
2000
2005
—H-
 2010
5015
1030
                                                          Yt.r

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        TRITIUM MIGRATION IN GROUNDWATER
     Refer to ftgyre litkd: Conceptual Behavior/Response of Tritium during F St. II Groundwater Remediation.)
Concentration of Tritium in 1990 was at 15,000 Ci/yr.

Concentration of Tritium in 1997 would be at 6,000 Ci/Yr with no action

Concentration of Tritium would decrease rapidly with pump and treat, but would
surpass the no action level in 2005 due to reinsertion.
                         *
In the long run (2015) Tritium concentration levels would be the same with or without
pump and treat

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Chapters
            [SRS Data. 1994]. Like tritium migration, strontium
            migration is expected to continue to decline from these
            dosed seepage basins.

            la 1993, no eeshcn-137 migration wis detected from
            the  F-Area or H-Area seepage tmim  However,
            160 mCi (5.9E+09 Bq)of ceshnn-137 weredeteaedtt
            fee sampling location near the Four Miie Greek mouth
            over and above the 246 tnCi (9.1E-*09 Bo,) eeshnn-137
            delected in direct process discharges. This additional
            cesium-137 is attributed to desorption of past cesium
            releases from the stream bed.

            An estimated 22 mCS (&2E+OS B
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 3.325 B«xX»hir« Circle
 Jobn«on Tify-r TK
 February IS, 1995

 SPA Region XV                                .       .
 Attn:  3tt±t Cr-ane
 34S courriand street          '       .                .
 Atlanta,  GA 3O365

 Dear Kr.  C3rroundvater Renediation.
Sincerely,



Philip

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Interim Action ROD                                                 WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                           Revision 1
        	April 1995
                                                             £.
Letter #2 from Mr. Philip Brandt to the EPA
                                       B-12

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ADDITIONAL COMMENTS TO THE PROPOSED P&H GStOTJNDWATER REM2DXATZON

I. During the expended comment period, I was able to ascertain that
•the KPDES permitted•F&H Area Effluent Treatment  Facility (ETF)  is
allowed to discharge to onsite surface streams up to 30,000 Curies
of tritium per yaar.  Hill th* regulators explain to the* public the
difference  in potential  environmental impact -firoTti the  permitted
discharge  of 30,000  Curies ot tritium and  the  estimated  (1993)
3,20O Curies of tritium seeping from the FfiH Seepage Basins «nd the
cstisaated (1993) 12,2OO Curias of tritium jral*ae*d to  th« Savannah
River  from  all sources (discharge and all  seepage  basin*)?   If
ther« i» documented environmental bans from 3,2OO curies of tritiua
di«charging  to a" surface  stream  riien how can  3O,OOO curies  be
allowed to  discharge to  a  surface stream?   if the RCRA a*<=ision
«A)cing process selected determined that pump/treat/reinjection was
the lovact  ri«3c option how can  you justify  or allow  a  potential
30,000 Curies of tritium be released to a surface  stream?

2. - The  costliest and technologically weakest option, pump/treat
and reinject,  was  selected under RCRA  in  1992.  At the  public
meeting held in North Augusta, South Carolina on January 9, 1995,
the question was asked why wasn't puiap/treat and. discharge to a
surface stream  or Savannah River  selected eince it was  {a-} much
cheaper end  (to) met all regulatory requirements-   The  response was
that there  was concern over increasing the  tritium dose  to down
stream users. . Under a no action alternative  &nd «. pump/tr-eat tund
discharge  alternative  wouldn't  the drinking water  standards  of
downstream  water  vx»tar=  be  met?   Aren't  the  EPA  regulations

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governing dri.Ti3ci.ng water standards protective of the human health
and th
-------
froa  the F&H  Area ETP  can be legally allowable under  an - NPDES
permit  wlx«r«a»  a 12,2Op  curie  di*cnarg« .(froi  a.11 sources)  i$
justification  for placing  the  site  on  the  list  or  Che  worst
environmental  sires in the country?  I hope in the BPA response to
thi« question  that the EPA is astute enough to recognize there is
sufficient  real  data to  demonstrate  that thexe  is no  credible
Bschanism  foz;  concluding  that  there is  a  measurable. off site
ehamleal or  radiological risX other  than tritiuan..

6.  I have never been involved, in a CSRCXA public weeting in which
the selected remedy has been presented in such a circuitous manner.
Ostensibly,  the public meeting van held to see Lt there  vere  any
cosoaonts *«  to whether additional treatment was required above  and
beyond  pimp/treat .and  reinject.   Has  the  NZPA  process been
subverted?     weren't   alternatives,   including  a  no   action
alternative, considered?  Where has the public been involved in  the
CERCIA review process in the selection of the remedial alternative?
As part or the KEPA process, a citieens Advisory Board  (CAB)  vac
created  to  obtain  representative  ooaonents-  f roa  the  affected
eojnrounities.  The Co—Chair, Mr', w. F. lawless,  of the  Envirornaental
Restoration  Subcoaaittee of the CAB indicated that they had serious
concerns over the proposed remedy i.e Mne> aciaxvtlfic justification1*
to support the choice.. Mr. Lavless stated that the proposed remedy
vill be  the subject  of  the CABs March aeeting  and  requested  an
extension on public  comments until after their meeting.   Isn't it
reasonable to extend the eososent period so  that the citizens group
created under the  CERCLA process can respond to and participate in
the CERCLA  decision  xaalcing process?  I . request  an  even  further
extension since a draft RCRA  perait is expected to be available
from SCDHEC  by March  1,  1995.  The public will then  have  a 45  day
comment period b&eed  on  the latest, facts.  The environmental data
clearly indicate ir^proving water quality and that sanall, localized
areas  of stressed vegetation are  comrng back  so  there is   no
environmental iiarm in waiting.  By postponing the  CERCLA  decision
making  prooes*  a  more  reasoned  and  logical  conclusion  can   be
arrived at,  one that aay be equally protective  of human  health  and
the environment, but costs much leas than  a quarter  of a  billion.
dollars.   What is the reason or basis for the  State and EPA  to
reach a. conclusion so quickly  given  the timing of  the .RCRA permit
renewal and  the concerns raisod by the CAB? Do individuals at  the
state or Federal  level  receive  any  sort  of merit award  for  the
number of RODs. completed?  Zs there a statutory requirement that
requires the ROD to foe completed within a certain tine?

7.  Would the State of South Carolina please explain  to  the public
«t what point  in -the  gaohydrologiea.! cycle  that  precipitation
feeco&es waters  of  the state?  Is it when it infiltrates  the. soil
but prior to evapotranspiration?   Is it after evapotranspiration?
Does it  inelud*  all  soil  w&t*r?   Does it include' near  surface
groundwater  that discharges to surface streams?   Are all  shallow
groundwaters considered watera of the state regardless of sustained
yield and  water quality  parameters?  If  the  answer to the last
question,  is  yes,  is  the  State  consistently  enforcing   the
regulations to agricultural users, municipalities, other-

-------
 entities,  and the  general  public?   Per example,  is there  «£  fch»  b<.»in?    What
 radionuclides and wnat are their concentrations  along  the   canal
 system  and. intervening ponds that .discharged  contaminated  water
 from the reactors ro the Parr iPond?  What steps are being taken  to
 prevent biological uptake and concentration  in Che flora and  fauna
 in  these arsas?            .

 9.   The  Energy   Research Foundation  in their  January  31,  199S
 response etatsd  chat th* public  hax nhad ampl*  opportunity for
 input".  Technically, I would have to agree with the statement that
 the  Jreqtlirements  of the  law regarding  public commant  have  bean
 complied with.  However,  has the  intent^ot  the  law been complied
 with?  How successful have you been'in conmunicating the intent  of
 your actionsi At any time was the public informed in plain English
 as  to how much the  clean up would cost  or  that  the contamination
 could never contaminate  offcit»  groountdwater?   Exactly  how  many
 response were there from the  stakeholders  around SRS  in Aiken,
 Jackson, Barnwell, etc. to the F&H grounawater permit?  Considering
 the population base  for that area does any one believe that there
was  a-significant public response?   I strongly  disagree with the
 ERF statement Mthe evidence  of the spread of contamination and its
measurable  impact  on  affected  surface  waters  is &  sound and
 compelling  basis  for the remedial action".   What Class  8  water
parameters  were   exceeded in  Pour Mile  Creek and  for the  ones
 exceeded which showed a significant di££orene* vipgra
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        of RCRA. and  CERCXA is  to protract  nunan  health and  the
             and tHat; soaetines • this  c«n occur .under a no  further
action  scenario.    Z would  counter  «ur^ue ciiaX. it  ie entirely
appropriate  to ch*llenga under czRCIA a bad  dacision arrived under
RCR&  due  .to. procedural requirements.    By  illuninating such
differences, may fe* at  sone point In  tb« future we  can Inject come
coTajaon  cense  and reality into  the  remedial  procecc  instead of
needlessly Vasting resources  on  "inprovsments" in envlronntental
quality tlia.t exict only on paper and teengf it 'abselu-fcelv  pp

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Interim Action ROD                                                         WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                  Revision 1
	April 1995
                                                                       s.-
Response: Several of the comments identified in Mr. Brandt's letters have been previously addressed as
part of the comment responses prepared for comments summarized from the public meeting transcript,
and therefore, are not repeated. The following responses are provided for comments that have not been
previously addressed and are numbered in order as they were extracted from the letters. The numbering
sequence does not correspond to the question numbers that appear in letter #2.

1.    What has been the water quality trends over the last six years on FMC at sampling stations IB, 1C,
      2B, 2,3 A, 3, 6, and A7 while describing the source terms that contribute to the contaminants?
      What data indicates that the contribution of hazardous substances to FMC, including radionuclides,
      will increase over time with no further action? Discuss and comment on whether the data trends
      support an improving or deteriorating groundwater quality? Does the risk of contamination of the
      deepest aquifer and discharge to Upper Three Runs Creek increase or decrease?
      Response:  In the most recent report "Semi-Annual Sampling of Fourmile Branch and Its
      Seeplines in the F and H Areas of SRS: February 1993, July 1993, and April 1994", a summary of
      the water quality is provided in the introduction section with a comparison of analytes detected in
      1989 samples. It is stated in this report and the 1993 Environmental Report that the sources
      contributing to these contaminants  are the F&H Seepage Basins. There is no data that indicates
      that the radionuclides will increase over time with no further action.

      Levels of tritium in the groundwater plumes have been generally decreasing since use of the basins
      for disposal of was.   ^ter was discontinued in 1988. Construction of the low permeability caps
      over the basins has served to control any further migration of contaminants  to the groundwater.
      These source control measures have resulted in decreasing the risk of contamination to the deeper
      aquifer and Upper Three Runs Creek.  However, levels of contaminants in the groundwater
      continue to be measured at levels which exceed primary drinking water standards.

2.    Numerous wells in the F&H area seepage basins are poor quality, low yields from perched water
      tables. How many of the water table wells provide less than six gallons per  minute continuous
      yield, that is are unsuitable for home use as a drinking water source? What is the water quality for
      these wells? How many of these wells do not yield enough water to provide a representative sample
      (minimum of three casing volumes)? How many of the wells evidence faulty well installation?
      Does SCDHEC and EPA require the same groundwater protection for perched water tables which
      are unsuitable for a drinking water  supply system as for legitimate aquifers?
      Response:  Wells  at the F and H Area seepage basins have been installed to provide representative
      samples from the aquifer units that they monitor. No perched water zones are monitored. Low
      yield is not an indication of an inadequate monitoring well.  Many of the wells monitor zones that
      have a high percentage of clays and fine grained materials. In some locations the water table
      surface is very close to the underlying confining unit; this results in a very thin water table aquifer.
      Wells in these zones (high clay content and thin  water table) tend to produce a low yield. This is in
      contrast to wells which are installed to provide water for domestic use, which are specifically
      designed to extract water from thick units of coarse grained materials in order to ensure a high
      yield.

      The integrity of the monitoring network is evaluated regularly, and corrective actions are taken to
      repair and/or replace any wells which do not provide representative samples or show evidence of
      faulty hardware or construction.

3.    Provide documentation on the level of contamination that is discharged from the Congaree aquifer
      to Upper Three Runs Creek? Provide similar documentation for the deeper  aquifer that discharges
      into the Savannah River?
                                             B-13

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interim Action ROD                                                       WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                Revision 1
	April 1995

      Response:  Environmental monitoring indicates that contamination which is discharged to Upper
      Three Runs Creek and to the Savannah River from deeper aquifers is negligible.

4.    The EPA has determined that capping is protective of human health and the environment  Is
      capping with institutional control an allowable remedial alternative under CERCLA? Since
      implementation of capping, groundwater has improved dramatically thus decreasing future risk to
      human health and the environment through institutional control. What period of institutional
      control was considered by SCDHEC/EPA in evaluating the no action alternative under CERCLA?
      Response:  A future land use policy for the Savannah River Site is currently being prepared  Until
      future land use issues are resolved and a policy is implemented, institutional control cannot be
      considered  as a remedial alternative under CERCLA.

5.    SCDHEC requires that groundwater used in the reinjection wells meet drinking water standards.
      How can SCDHEC allow tritiated groundwater that is 1000 times drinking water standards to be
      reinjected?  How can it allow nitrates that are 10-100 times drinking water standards to be
      reinjected when treatment technology exists to treat nitrates?
      Response:  Injection of water which contains tritium and nitrate in levels which exceed drinking
      water standards can be allowed in the context of this RCRA corrective action because overall
      groundwater quality in the aquifer will be improved.

6.    Pumped water can simply be adjusted for low pH and discharged to the Savannah River meeting all
      health and safety requirements of both EPA and SCDHEC at significant cost savings over the
      required remedy.  What is SCDHEC's and EPA's justification under RCRA for not requiring the
      most cost effective remedy which meets all drinking and surface water quality standards?
      Response:  It would not be acceptable to extract contaminated groundwater that is currently not
      used as a drinking water source and to only adjust for low pH and then discharge it to the Savannah
      River. One of the  remedial alternatives considered for the F and H Seepage basins was to extract
      groundwater and pump it directly to the Savannah River with minimal treatment  It was estimated
      that levels in the Savannah River would remain below drinking water standards if this alternative
      were implemented. However, this alternative was not selected. It seemed to be counter intuitive to
      pump contaminated water out of the ground where it is relatively isolated from environmental
      receptors and place it directly in the Savannah River which serves as a public drinking water
      source.

7.    A different  environmental remedy for the same site can be arrived at under CERCLA versus
      RCRA.  In  fact, the DOE submittal to SCDHEC and EPA for the proposed remedy under CERCLA
      is that no action be taken: What has been SCDHEC's and EPA's response to DOE's proposed
      remedy under CERCLA of no further action (Rev. 0, Proposed Plan for F and H Area Groundwater
      Operable Unit). What was your basis for rejecting the proposal, particularly for basin H-3 which is
      not regulated under RCRA.
      Response:  DOE is subject to the Federal Facility Agreement which mandates that all RCRA
      regulated units should be addressed under RCRA and then reviewed under CERCLA to determine
      if additional action is necessary to protect human health and the environment. (Reference comment
      response number 17 in the general response section)

8.    The risk assessment process used is flawed. Proposed tritium standards are three times higher
      current standards.  When performing your risk assessment you used proposed concentration limits
      when they were higher than existing limits. However, in the case of tritium you used the existing
      limits when proposed limits are over three times higher. There is no rational basis for ignoring
      nitrates in the risk assessment process nor is there any health/environmental based reason for
      pumping/treating and recirculating the tritium plume to maintain a 20,000 pCi/mL contour. If you
                                            B-14

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Interim Action ROD                                                       WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                 Revision 1
	       April 1995
                                                                     _:.
      are not maintaining the drinking water standard isopleth then 200,000 pCi/mL or current levels are
      as equally valid as the 20,000 pCi/ml isopleth for tritium.  Why weren't the proposed tritium
      standards used (60,900 pCi/L)?
      Response:  Quantitative Risk Assessment based on the most current data has not been performed.
      Risk assessment work performed to evaluate the potential risk associated with groundwater
      contamination at the F and H Area Seepage Basins is based on an extensive list of hazardous and
      radioactive constituents. The primary drinking water standard for tritium (whether proposed or
      current) is not a significant factor in the estimation of risk.

9.    The state and EPA have specific areas of regulatory authority. The state does not regulate
      groundwater contaminated by radionuclides.  Does SCDHEC claim regulatory authority over
      radionuclides? Under what av Jiority and has the Federal government given up its sovereign
      immunity?
      Response:  SRS signed a Memorandum of Agreement on April 8, 1985, agreeing to comply with
      the substantive requirements of the South Carolina Pollution Control Act (PCA); the South
      Carolina Hazardous Waste Management Act (SCHWMA) and regulations promulgated thereunder.
      The definition of pollutants under the PCA can be interpreted to include radionuclides.
      In addition, to the above, SRS entered into a Settlement Agreement (87-27-SW), as amended on
      June 14, 1989, in which DOE agreed to address the hazardous constituent contaminants in the
      groundwater as defined by RCRA as well as groundwater contamination by other constituents such
      as nitrates and radionuclides as defined by the SC PCA.  These actions were taken as a matter of
      comity rather than as a waiver of sovereign immunity.

10.   Besides the DOE SRS, SCDHEC regulates municipalities, private businesses, and other State and
      Federal agencies. Does the DOE SRS receive equal treatment under the law relative to
      enforcement or fines? What  other facilities are being required to pump/treat and reinject as a
      remedial action?  How many are allowed to reinject contaminated water above drinking water
      standards?  How many ACL's have been granted by SCDHEC in the last five years?
      Response:  SRS receives equal treatment under the law as compared to other industrial and
      governmental facilities. The F and H Areas Seepage Basins groundwater plumes contain both
      hazardous and radioactive constituents that differ greatly from those found at most facilities
      requiring groundwater remediation. Therefore, the proposed corrective action is unique. No other
      facilities are currently required to pump/treat and reinject, or to reinject water which exceeds
      drinking water standards.

      No ACL's have been approved by EPA Region IV or SCDHEC in the past five years. However,
      ACL's are a viable alternative to complete restoration of aquifers to drinking water standards. In
      fact, the corrective action required by the RCRA permit specifically allows for evaluation of an
      ACL demonstration at the conclusion of Phase I.

11.   Regulatory oversight by SCDHEC at SRS is funded by a grant from DOE. How many
      municipalities, private industries, and other government agencies fund their own regulatory
      oversight? How does SCDHEC avoid a conflict of interest, that is, the more remedial actions
      required the higher the funding level for SCDHEC?
      Response:  Through permit fees and other funding mechanisms, all municipalities, private
      industries, and other government agencies fund their own regulatory oversight. There is no conflict
      of interest.  The grant is based on a scope of work submitted by SCDHEC and approved by DOE on
      an annual basis so more remedial actions do not necessarily mean more funding as both parties
      must agree as to the level of work necessary for the year.
                                            B-15

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GEORGE M.  MINOT
3 Bateau Road
Hilton Head  Island. SC 2992S-3012
803-363-5150
          Memorandum
                               /
          To:          SRS Remedial Project Manager. U.S. EPA. Region IV
          From:       George M. Minot
          Date:        February 6.! 995
          Subject:      Resolution Regarding SRS F- and H-Area Groundwater Operable Units
          WHEREAS, the F-Area Hazardous Waste Management Area consists of a series of three faydraulically
          connected. unlined basins (F-l. F-2 and F-3) to which wastewater flow was terminated on November 7.
          1988 and the H-Area Hazard'  • Waste Management Area consists of a series of three hydrauiicaliy
          connected, unlined basins (h-.. H-2 and H-4) to which wastewater flow was terminated on Novc.nber 7.
          1988. and
          WHEREAS, the radioactivity released to the unlined basins constituting the F-Area Hazardous Waste
          Management.Facility and the H-Area Hazardous Waste Management Facility is due primarily to tritium, a
          radioactive form of Hydrogen with a half-life of about 12.5 years, and
          WHEREAS, currently, there is no known effective method to remove tritium from groundwater. and
          WHEREAS. F- and H-Arcas and vicinity are on a surface and groundwater divide; shallow groundwater
          flows toward either Upper Three Runs or Fourmiie Branch, both of which discharge directly into the
          Savannah River, and                                           ., _
          WHEREAS .the Maximum Containment Level (MCL) for tritium (Le. the maximum permissible level of
          tritium in water that is delivered to a user of a public watersystem) is 20 picbcuries per millfliter (pCi/mL).
          and
          WHEREAS, the Savannah River supplies domestic and industrial water for the Port Wentwonh
          (Savannah. GA) water treatment plant and for Beaufort and Jasper Counties in SC and analytical results of
          calendar 1993 water studies indicated that the water in the Savannah River downstream from SRS showed
          a maximum reading during one sampling event of 1.92 pCi/mL of tritium (approximately 10% of MCLX
          and
          WHEREAS, analytical results of calendar 1993 water studies indicated that the water quality of the Upper
          Three Runs and Fourmiie Branch was "generally acceptable, \rith the exception qflhe tritium
          concentrations'" (Lc, Fourmiie Branch maximum reading during one sampling event was 68.9 pCi/mL or
          approximately 3.5 times the MCL: Upper Three Runs maximum reading was 17.9 pQ/mL or
          approximately 90% of MCL). and

          WHEREAS, in mid-1993. the contaminated groundwater plume, as defined by the 1.000 pCi/mL tritium
          isoactiviry contour (i.e.. SO times the MCL). in the F-Area was less than 400 feet from the Fourmiie
          Branch and the contaminated groundwater plume in the H-Area was approximately 135 feet from the
          Fourmiie Branch.. At the same time, it was reported that the F-Area plume contained zones of tritium
          concentrations as high as 30.000 pCi/mL or t.500 times the MCL and the H-Area plume contained zones
          of tritium concentrations as high as 16.000 pCi/mL or 800 times the MCL. In addition, it should be noted
          that the aforementioned contaminated groundwater plumes are generally confined to the shallow aquifers

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                                           02/05/95                                     Page 2
(i.e.. Steed Pond. Upper Three Runs. *nd Gordon aJLa. the Fioridan Aquifer System) which are the
primary source of domestic water supplies in AikenCounty.SC. «nd

FURTHER, in 1987. DOE identified 56 major municipal, industrial and agricultural groundwater users
within 20 miles of the center of SRS. and in 1992, the maximum tritium concentration measured in any
one of the 217 wells in the shallow aquifer units within die area designated as "Separations and Waste
Management" was 180.000 pCi/hiL or 9,000 times the MLR, and
FURTHER, the Westinghouse Savannah River Company (SRC) has stated that "Actual or threatened
release! of hazardous substances from the site, if not addressed by the preferred alternative or one of the
other act/on measures considered, may present a current or potential threat to public health, welfare, or
the environment." but has not quantified the F» and H-Arca Groundwater Operable Unit-specific nsk(s) to
humans (or the wildlife) resulting from exposure to groundwater contaminated with hazardous and
radioactive constituents, including tritium, and

FURTHER, to the best of my  knowledge, neither DOE. SRC, or any other entity has made available for
public review in the SRS-area any recently de-classified Los Alamos National Laboratory or other studies
involving human exposure to tritium and other radionuclides detected in the F-and H-Area groundwater in
concentrations that require remediation.
FURTHER, the SRC Environmental Monitoring Section's Environmental Geochemistry Group (EGG).
which regularly samples approximately 1,400 groundwater wells throughout SRS, has publicly stated
"groutuJvwier aquifers cuii he a major patlnrvyfar hazardous and radioactive suhstances la move beyond
the site hoi/mlary. as well ax iintt the Savanmih River? However, to my knowledge, the public has not
been made aware of the rate(s) of migration of the identified hazardous and radioactive substances toward
the site boundaries and/or the six SRS tributaries that drain to the Savannah River and/or the Savannah
River, nor has the total estimated volume of contaminated groundwater to be remediated been disclosed.

THEREFORE. BE IT REQUIRE DTHAT, DOE and/or SRC promptly .and before proceeding with Phase
I of the preferred alternative for groundwater remediation at the F-Area and H-Area Groundwater
Operable Units (at an estimated Capital Cost of approximately S32 minion plus an estimated on-going
Maintenance & Operation cost of $4 to $6 million per year for an unknown number of years), take all
necessary actions to further quantify the 'current or potential threat to public health, welfare or the
environmenr associated with Alternatives 1.2 and 3 and. concurrently, provide more complete
information regarding the tritium and other radionuclide concentrations in the groundwater plumes, the
SRS streams and the Savannah River, and publish a response to the following comments and questions:

1. Given that the half-life of tritium is approximately 123 years, bow much of the tritium concentration
recently recorded is attributable to the pre-Novemoer 1988 operations conducted at the Separations and
Waste Management area? How many liters of contaminated water at what pCi/L is being  contributed
daily, weekly, and/or monthly by the "processing of existing inventories of materials for a variety of
purposes' within the F- and H-Area Groundwater Operable Units? Since seepage basin closure activities
were reportedly completed on January 4. 1991 (F-Area) and on June II. 1991 (H-Area). where, and in
what manner are the contaminated wastes from continuing operations being stored? Is this waste stream
being addressed by any of the alternatives?

2. Given that the geography/geology in question is located within portions of the SRS she mat will
undoubtedly continue to be DOE-owned and contractor-operated for a very long time, h is not obvious to
me why the contaminated groundwater needs to be cleaned to residential drinking water standards to
satisfy DOE objectives, nor is it clear from the public information provided that the preferred alternative
for remediation will be able to meet this standard. Does DOE have in hand or has the U.S. Congress

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                                            02/05/95
budgeted sufficient ear-marked funds to fully implement«!! Phases of this project and still have funds
available to address other alleged severe environmental remediation problems at SRS (Le_, the Canyons.
High Level Waste tank farms. Plutonium storage, etc.) at the same time?

3. Inasmuch as "there is no known effective method to remove tritium from the groiauhvater' it would
seem appropriate for DOEAVestinghouse SR to establish a Human Studies Project Team to coordinate
reser_ ih efforts with the Los Alamos ML team and personnel/teams at other Research Laboratories (Le..
Argonne NL. Brookhaven NL, Idaho National Engineering Laboratory. Lawrence Berkeley Laboratory.
Lawrence Livermore NL. Oak Ridge NL, Pacific Northwest Laboratory. Sartdia NL, etc.) in an effort to
determine the public health risks associated with absorption of tritium-contaminated water and water vapor
through the skin, inhalation of tritium-contaminated water-vapor, ingesdon of tritium-contaminated
liquids, etc.. and document the findings in various public reports, press releases, audio tapes, and video
taped presentations as soon as possible! Also, it wiU be important to educate the public with regard to the
origin of the radiation, the effects on humans and animals at different concentrations or dosages and how
to recognize the symptoms of tritium poisoning.
c: Drew Slaion, Public Involvement Coordinator. Westinghouse SRC
    Brian Costner. Energy Research Foundation

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Interim Action ROD                                                        WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                                  Revision 1
	April 1995

      Letter from Mr. George M. Minot to the EPA

      Response:

1.    Levels of tritium in the groundwater plumes have generally decreased since operation of the basins
      was discontinued in 198S.  Additionally, the installation of the low permeability caps over the
      basins has further controlled the migration of contaminants into the groundwater.  All of the
      tritium currently contained in the F&H Seepage Basins is due to pre-1988 operations. There is no
      contaminated water currently being contributed to the F&H Area Seepage Basins.  Contaminated
      effluent water and any contaminated water due to processing of existing inventories is transferred
      to the Effluent Treatment Facility for processing.
      As stated in the WSRC Report, "Assessment of Tritium in the Savannah River Site Environment,**
      is a tritium balance for SRS operations from 1952 to 1991.  The F&H Seepage Basins have received
      669,790 Curies of tritium, released 268,533 to Fourmile Creek, released 202,567 Curies to the
      atmosphere through evaporation, and currently (as of 1991) the basins contain 37,618 Curies.
      Subtracting the last three numbers from the first gives a difference of 161,072 Curies, which is the
      amount of radioactivity eliminated through the radioactive decay process.

2.     Currently, only funding for Phase I of the F&H Groundwater Remediation Project has been
      budgeted. Additional funding would be requested for the remaining phases, if required following a
      technical evaluatic:   the Phase I Operations.

3.     Since the early fifties, a significant amount of research has been conducted on the transport,
      metabolism, and radiation dose due to tritium in the environment.  One of the better references was
      published by the National Council on Radiation Protection and Measurements (NCRP) as NCRP
      Report No. 62, Tritium in the Environment. It may be ordered from:
        NRCP Publications
        7910 Woodmont Avenue
        Suite 800
        Bethesda, MD 20814-3095

      The International Commission on Radiological Protection (ICRP) has developed a quite thorough,
      although somewhat complicated system for calculating radiation dose from ingestion, inhalation,
      and absorption of tritium through the skin. ICRP Publication 30, Part 1, contains tritium
      information in addition to a description of the radiation dose calculation system. It can be ordered
      through your local bookstore by referring to the identifier, ISBN 0 08 022638 8.

      During the approximately 40 years of SRS operation, the tritium dose for customers of the
      Beaufort-Jasper Water Treatment Plant was about 3 millirem (WSRC-TR-93-214, Table 4-7).
      During the same time period, the very conservative EPA limit of 4 millirem per year would have
      allowed a dose of 160 millirem.  Future liquid releases of tritium will decline since all reactors are
      shut down and the inventory of tritium in the seepage basins will be depleted by the natural
      decaying process.
                                            B-16

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interim Action ROD                                                     WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                               Revision 1
	April 1995
                                                                    e.
Letter from Mr. W. F. Lawless to the DOE

Response:  The specific comments addressed regarding the lack of a scientific justification for the project
and concerns regarding cleanup to a residential standard have been previously addressed in the general
response section. (Reference comment responses for numbers 2 and 4)
                                           B-17

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                                                          PAINE  COLL!
Division cfNature! Sciences andMathematics         . .1235 fifteenth Scact  Augusta. Gears J3 30901-3182
          Dr. Mario P. Ron, Manager
          Department of Energy
          Savannah River Operations Office
          P.O. Box A
                 SC 29802
          Dear Dr. Fiori:              January 10, 1995

                I was delighted Last night to have the opportunity to attend the meeting in North
          Augusta on the proposed plans for remediation cf contaminated ground water beneath the
          F-Area and H-Area Seepage Basins. But I was disturbed by the lack of scientific
          justification provided to support what appears to be a high-minded fishing expedition by
          the EPA and DHEC. Both agencies repeatedly stated thai the "purnp-and-treat"' method,
          ai a capital and operating cost of S30-200 million dollars, is a five-year trial "to see what
          happens" to the ^rpundwater contamination in the area.  That makes the project, in my
          opinion,  an experimental enterprise insufficiently justified as a fafl-fiedged environmental
          remediation capital project.
                Another concern that I have is that the cleanup standard of the residential
          alternative for this project was mandated by EPA/DHEC, yet no scientific justification
          was provided to support their choice'. Further, this EPA/DHEC choice may conflict with
          a motion moving through the SRS CAB to zone the area encompassing the Seepage
          Basins as industrial for cleanup purposes.
                Before continuing with the Seepage Basin project. I recommend that it be
          submitted to independent scientific peer review to determine whether or not the project is
          justified on a scientific,  engineering,  and cost basis. ^


          Sincerely,
         WP Lawless
         Associate Professor of Mathematics and Psychology
                   A CetJ«5« of Th« Unittd Mtttodutt Church afld th« Qin»e*n M«ho<4l5f £pucop«J Church

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                                                         PAINE  COLLM
Division cf Natural Sciences cxdUtakemanes          -1235 Fifteenth SireS  Augusta. Georgia 30901-3182   (706)821-
             Dr. Manor P. fieri. Manager
             Department of Energy
             Savannah River Operations Office
             P.O. Box A
             AiVen. SC 29802

             DcarDr.Fiori:             January 25,  1995

             Re: My last letter ID you on F/H Seepage Basin Groundwater Cleanup

                    I iccornmended to you in a letter dated January 10. 1995. that before DOE
             continues with the Seepage Basin project, .the project be submitted to independent
             scientific peer review to determine whether or not it is justified on a scientific,
             engineering,  and cost basis.
                    My recommendation was based on the following:  there appeared to be a
             lack of scientific justification for the project; the cleanup standard of the residential
             alternative for the project was mandated by EPA/DHEC, yet no scientific
             justification was provided to support their choice: and the EPA/DHEC choice may
             conflict with a motion moving through the SRS CAB to zone the area
             encompassing the Seepage Basins as industrial for cleanup pu
                   As you are aware, the motion was passed by the SRS CAB. The reason
             that 1 am writing to you today is because the CAB'S ER Subcommittee, of which I
             am Co-Chair, has decided to consider the F&H groundwater remediation project as
             the subject of its next motion to be presented at the CAB's March meeting. Not
             knowing how this new motion wili be drafted (e.g.,  it likely will have input from
             EPA.  DHEG.  and others),  and because of Jts timeliness and the need to involve
             the public in important discussions of SRS issues.  I request that you extend the
             F&H Grbundwater public comment period until after the March meeting.
             Sincerely.
             WP Lawless
             Associate Professor of Mathematics and Psychology
                   A CeO«g* ofTS« Draw! Methodist Ourcfc and Sic Qcl«U* Methodic* Ep*tcop«l Church

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Interim Action ROD                                                      WSRC-RP-94-1163
H-Area Groundwater Operable Unit                                               Revision 3
                                                      	April 1995
                                                                 c-
Letterfrom Mr. Tim Connor to the EPA

1.     We see no evidence at this time that remedial actions beyond those currently being implemented
      under the RCRA Post Closure Care Requirements are necessary to protect human health and the
      environment
      Response: The IROD has been modified and it is stated that tie SRS RCRA permit is viewed as
      the primary decision-making authority and that the selected interim action under CERCLA is no
      further action beyond that required by the corrective action as identified in the SRS RCRA permit

2.     We respectfully take issue with the decision to seek public comment on a "No Remedial Action"
      option for the basins under CERCLA.
      Response: The "No Remedial Action" alternative is included in the description of alternatives
      section as one of the three alternatives that were evaluated for remediation of the contamination at
      the F-Area Groundwater Operable Unit  Alternative 3 (groundwater recovery, treatment, and
      injection)  is the corrective action described in the 1992 RCRA Permit This action has been
      determined to be protective of human health and the environment Therefore, no further action is
      required under CERCLA.
                                           B-18

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ENERGY

RESEARCH

FOUNDATION

                                         January 31. 1995

Frances Close Hcrf                                                    TlfTl Connor
BcxsciChan^cman                                                   ASSOCiate Director
TheoctacK Harris
ftesdert


      Mr. Jeff Crane
      U.S. Environmental Protection Agency, Region IV
      345 Courtland Street
      Atlanta, GA 30365

      Dear Mr. Crane:

            The Energy Research Foundation (ERF) has the following comments with
      respect to plans submitted in December of 1994 by the U.S. Department of Energy's
      Savannah River-Site (SRS) to meet the requirements of the Comprehensive
      Environmental Response, Compensation and Liability Act (CERCLA) as such
      requirements pertain to the F and H Area seepage basins at SRS.
            ERFs interest in the timely remediation of the F & H seepage basins and the
      contaminated groundwater associated with the basins goes back several years.
      During that time our views on the issues involved have been repeatedly conveyed to
      both the South Carolina Department of Health and Environmental Control (SCDHEC)
      and to SRS. Most recently, we submitted detailed comments on the Post Closure Care
      Requirements of the basins in October 1992 as part of the compliance process
      required by the federal Resource Conservation and Recovery Act (RCRA). This
      process fed to SRS agreeing to install a remedial system at the basins designed to
      prevent the further spread of contamination into a surface stream at SRS which is a
      tributary to the Savannah River.
            It was and remains our view that the evidence of the spread of contamination
      and its measureable impact  on affected surface waters is a sound and compelling
      basis for the remedial action. Moreover, we believe the requirements imposed by
      SCDHEC are well-anchored in the law and settlement agreements negotiated with
      and signed by SRS.
            The only question which should be on the table now is whether additional
      remedial actions to contain contaminants from the F & H seepage basins are
      necessary to satisfy the requirements of the Comprehensive Environmental Response,
      Compensation and Liability Act (CERCLA). Our view on this is two-fold:

            1) We see no evidence at this time that remedial actions beyond those currently
      being implemented under the RCRA Post Ctosure Care Requirements are necessary
      to protect human health and the environment

537 Horcten Street
CoiumWo. South Carolina 29205
605-256-7298

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 Page 2 of 2
      2) We respectfully take issue with the decision to seek public comment on a "No
 Remedial Action" option for the basins under CERCLA  In our view, the Federal
 Facility Agreement for SRS (Section 4, paragraph A) is clear that EPA's CERCLA
 process will be used to augment, rather than supplant, corrective measures reached
 under RCRA permit. In other words, the CERCLA process ought not be used to
 undermine RCRA or RCRA-based consent agreements and enforcement by the State
 of South Carolina of its hazardous waste laws.
      The most sensible approach is one we thought the FFA laid out whereby RCRA
 and CERCLA activities are coordinated to ensure a minimum of duplication and
 conflicting requirements. We agree that it is appropriate to examine RCRA-based
 decisions to ensure they satisfy CERCLA requirements. Yet, we dont believe the
 process is well-served when a CERCLA review invites challenges to remedial actions
 already agreed to by all parties via an open decision-making process in which ali
 parties, including the public, have had ample opportunity for input.

      Jt is our hope that potential future conflicts and confusion can be avoided. We
 strongly recommend that in instances like that presented  by the F & H seepage basins-
 -where a RCRA-based K  .adiaJ action has been developed and approved in
 accordance with the SRS RCRA permit and other applicable requirements-that EPA
 replace the "No Remedial Action* option wrth a "No Further Remedial Action" option.
      Notwithstanding EPA's consideration of the "No Remedial Action" option at the
 F & H basins, we believe the process and the outcome of the RCRA Post Closure Care
 Requirements were fair to all parties and consistent with the consent agreements and
the law. We therefore urge EPA to accept the existing RCRA Post Closure Care
 Requirements as satisfying the requirements of CERCLA for the remediation of
 contaminated groundwater at the basins.
                             Sincerely,
cc. Tom Treger, DOE
   Drew Slalion, WSRC
   Keith Colimsworth, SCDHEC
   Brian Costner, ERF

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