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 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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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
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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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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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£..
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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Figure 1. Site Area Map
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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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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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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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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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Fig. 3. Contaminant Plumes In Water
Table Aquifer, F- and H-Area
Groundwater Operable Units
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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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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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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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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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
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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
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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.
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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
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&.
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.
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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.
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. 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
-------
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.
-------
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
-------
Groundwat
Pump-And-Tre
Act/vitk
Office of Environment
Restoration (EM-4
August
Final E
United States Department of Energy
-------
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."
-------
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
-------
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
-------
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
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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?
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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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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.
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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
-------
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
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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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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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