PB97-963127
EPA/541/R-97/044
January 1998
EPA Superfund
Record of Decision Amendment:
Hanford Site - 100 Area (USDOE)
100-BC-l, 100-DR-l, & 100-HR-l OUs
Benton County, WA
4/4/1997
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United States Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
U.S. Department of Energy
Hanford Site - 100 Area
Benton County, Washington
Amended Record of Decision
Decision Summary and Responsiveness Summary
March 1997
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Signature sheet for the Amendment to the Record of Decision for the USDOE Hanford
100-BC-l, 100-DR-l, and 100-HR-l Operable Unit Interim Remedial Actions between the
United States Department of Energy and the United States Environmental Protection Agency,
with concurrence by the Washington State Department of Ecology.
yumnD. Wagoner
^Manager, Richland Operations
United States Department of Energy
•/Mi
Date
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Signature sheet for the Amendment to the Record of Decision for the USDOE Hanford
100-BC-l, 100-DR-l, and 100-HR-1 Operable Unit Interim Remedial Actions between the
United States Department of Energy and the United States Environmental Protection Agency,
with concurrence by the Washington State Department of Ecology.
Chuck Clarke
Regional Administrator, Region 10
United States Environmental Protection Agency
Date
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Signature sheet for the Amendment to the Record of Decision for the USDOE Hanford
100-BC-l, 100-DR-l, and 100-HR-1 Operable Unit Interim Remedial Actions between the
United States Department of Energy and the United States Environmental Protection Agency,
with concurrence by the Washington State Department of Ecology.
Michael Wilson
Program Manager, Nuclear Waste Program
Washington State Department of Ecology
Date
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
USDOE Hanford 100 Area
Hanford Site
Benton County, Washington
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) Amendment has been developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended
by the SuperfundAmendments and Reauthorization Act of 1986,42 U.S.C. Section 9601 et. seq.
and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 Code of Federal Regulations Part 300. This ROD Amendment is based on the
Administrative Record for the 100 Area.
The State of Washington concurs with the ROD Amendment.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the waste sites, if not addressed by
implementing the response actions selected in the ROD, as amended by this ROD Amendment,
may present an imminent and substantial threat to human health, welfare, or the environment.
DESCRIPTION OF THE AMENDMENT TO THE REMEDY
This decision document changes components of the selected interim remedial action for the
Hanford 100 Area radioactive liquid effluent disposal sites and clarifies the role of revegetation
of remediated sites with respect to the completion of the remedial actions. The Interim Remedial
Action ROD for the 100 Area radioactive liquid effluent disposal sites signed in September 1995
selected excavation, treatment as necessary or appropriate, and onsite disposal for 37 waste sites
in the 100-BC-l, 100-DR-l and 100-HR-1 Operable Units at an estimated cost of $491 million.
This amendment increases the scope of the selected remedy to include 34 additional sites in the
100 Area that received similar waste discharges and reduces the overall estimated cost for the
remedial action to $194 million for 71 sites. This amendment also recognizes the results of the
soil volume reduction treatability studies that indicate soil washing for volume reduction is not
cost effective. Therefore, this treatment step will no longer be retained as an option for the
100 Area radioactive liquid effluent disposal sites. This amendment also clarifies that
revegetation of remediated waste sites will be addressed using the guidance provided in the
current Mitigation Action Plan titled Mitigation Action Plan for Liquid Waste Sites in the
100-BC-l, 100-DR-l, and 100-HR-l Operable Units. Those activities will provide overall
environmental benefit to the site, but are not part of, or necessary, for the completion of the
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selected remedial action. All other elements of the selected remedy as set forth in the ROD are
unchanged.
DECLARATION
Although this ROD Amendment changes components of the remedy selected in the Interim
Remedial Action ROD, the interim remedy as modified continues to be protective of human
health and the environment. The remedy as amended complies with Federal and state
requirements that are legally applicable or relevant and appropriate to the remedial action and is
cost effective. The remedy as amended continues to utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable for this site. However, because
treatment of the principal threats of the sites was not found to be practicable, this amended
interim remedy does not satisfy the statutory preference for treatment of a principal element.
Because this remedy will result in hazardous substances remaining on site above health-based
levels, a review will be conducted every five years after the commencement of remedial actions
to ensure that the remedy continues to provide adequate protection of human health and the
environment.
n
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TABLE OF CONTENTS
DECLARATION OF THE RECORD OF DECISION
DECISION SUMMARY 1
SITE HISTORY 3
REMEDY SELECTED IN THE ROD 4
DESCRIPTION OF THE MODIFIED REMEDY 5
EVALUATION OF ALTERNATIVES 6
RCRA PAST-PRACTICE OPERABLE UNIT REQUIREMENTS 8
STATUTORY DETERMINATIONS 9
TABLES AND FIGURES 10
APPENDIX A - ADDITIONAL 100 AREA RADIOACTIVE LIQUID WASTE SITES
APPENDIX B - RESPONSIVENESS SUMMARY
VI
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DECISION SUMMARY
USDOE Hanford 100 Area
Record of Decision Amendment
INTRODUCTION
This document presents an amendment to the Interim Remedial Action Record of Decision
(ROD) for the 100-BC-l, 100-DR-l, and 100-HR-l Operable Units at the Hanford Site.
Site Name and Location
100 Area National Priorities List (NPL) Site, Hanford Federal Facility, Benton County,
Washington.
Lead and Support Agencies
The lead regulatory agency for this action is the U.S. Environmental Protection Agency (EPA).
The U.S. Department of Energy (DOE) and the Washington Department of Ecology (Ecology)
both concur with the need and justification to change the number of waste sites to be remediated,
to reduce the cost estimates for this project, and to no longer retain the treatment option of soil
washing for volume reduction. The three agencies (the Tri-Parties) participated jointly in the
decision and preparation of this document.
Statutory Citation for a ROD Amendment
The Interim Remedial Action ROD was signed by the EPA, Ecology, and the DOE in September
1995. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 Code
of Federal Regulations (CFR) 300.435(c)(2), provides for addressing and documenting changes
to the selected remedy after issuance of a ROD. This ROD Amendment documents changes to
the remedy set forth in the Interim Remedial Action ROD. Public participation and
documentation procedures have been followed as specified at 40 CFR 300.435(c)(2)(ii).
Need for the ROD Amendment
This amendment is necessary for the following reasons:
• The scope of the remedial action has been expanded to include 34 additional sites
within the 100 Area. These sites received similar discharges of radioactive liquid
effluent as the original 37 high-priority waste sites presented for remediation in the
September 1995 Interim Remedial Action ROD. The additional sites pose a similar level
of risk to human health and the environment that also requires remediation. The
additional sites are in the 100-BC-2,100-DR-l, 100-DR-2, 100-FR-l, 100-HR-l,
100-KR-l, and 100-KR-2 Operable Units and are identified in Appendix A.
1
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The estimated cost of remediation and disposal of wastes and contaminated soils from the
34 additional sites at the Environmental Restoration Disposal Facility (ERDF) is $112
million. The ERDF is a Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) disposal facility in the Hanford 200 Area that began accepting
wastes from the 100 Area cleanups in July 1996. The ERDF is designed and operated to
meet the substantive requirements of the Resource Conservation and Recovery Act
(RCRA).
• Cost evaluations during remedial design for the original 37 sites identified significant
opportunities for streamlining and coordination of remediation activities. Those
evaluations, together with lessons learned from demonstration projects and an expedited
response action (ERA), resulted in reductions to cost estimates for remediation of
100 Area waste sites. The most significant areas identified for cost savings included
reduction in contaminated soil volume estimates and reduction in sampling and analysis
costs. In addition, treatment for volume reduction prior to disposal is no longer being
considered. Therefore, that cost element has been dropped from the cost estimates.
Finally, the actual costs of disposal at the ERDF are lower than initially estimated due to
competitive bidding among commercial firms. Preliminary cost estimates for the 37
radioactive liquid waste sites in the Interim Remedial Action ROD totaled $491 million.
The current cost estimate for the same 37 waste sites is $82 million.
• The completion of pilot-scale treatability studies for soil washing to reduce contaminated
soil volumes has shown this treatment process is not cost effective. Therefore, it will no
longer be retained as a treatment option for soil volume reduction prior to disposal.
Tables 1 and 2 present a summary of the scope and cost changes from the September 1995 ROD
and this proposed amendment.
Public Involvement
A newspaper notice was placed in the Tri-City Herald on December 15,1996, announcing the
availability of the proposed amendment and the start of the public comment period.
Approximately 1,366 copies of a fact sheet were mailed out to individuals and organizations on
the "Highly Interested" mailing list for the Hanford Site. A public comment period was held
from December 16, 1996, through January 15,1997. No requests were received for a public
meeting; therefore, no public meeting was held. The proposed amendment was discussed with
the Hanford Advisory Board Environmental Restoration Committee at meetings held in July and
August 1996. The decision to amend the Interim Remedial Action ROD is based on the
administrative record for the 100 Area. Locations where the administrative record may be found
are listed below.
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Administrative Record
This ROD Amendment will become part of the Administrative Record for Hanford 100 Area, as
required by 40 CFR 300.825(a)(2), and will be available to the public at the following locations:
ADMINISTRATIVE RECORD (Contains all project documents)
U.S. Department of Energy - Richland Operations Office
Administrative Record Center
2440 Stevens Center
Richland, Washington 99352
INFORMATION REPOSITORIES (Contain limited documentation)
University of Washington, Suzzallo Library
Government Publications Room
Seattle, Washington 98195
Gonzaga University, Foley Center
E. 502 Boone
Spokane, Washington 99258
Portland State University, Branford Price Millar Library
SW Harrison and Park
Portland, Oregon 97207
DOE Richland Public Reading Room
Washington State University, Tri-Cities
100 Sprout Road, Room 130
Richland, Washington 99352
SITE HISTORY
The Hanford 100 Area lies at the north end of the Hanford Site in Benton County, Washington
State, along the southern shoreline of the Columbia River as shown in Figure 1. The 100 Area
NPL Site is composed of six non-contiguous reactor areas containing the nine retired plutonium
production reactors and their ancillary facilities. Large amounts of cooling water flowed through
the reactor cores and became contaminated with radionuclides and other waste. Soil and
underlying groundwater were contaminated when cooling water was disposed in cribs and
trenches and leaked from water transfer systems. Solid wastes contaminated with radionuclides
were buried in unlined trenches.
An Interim Remedial Action ROD was issued in September 1995 for the 100-BC-l, 100-DR-l,
and 100-HR-1 Operable Units to address actual or threatened releases at radioactive effluent
disposal sites. The Interim Remedial Action ROD identified 37 high-priority waste sites that had
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received liquid radioactive effluent discharges. The selected remedy for the 37 sites is to
remove, treat as appropriate or required, and dispose of the wastes on site. Full-scale cleanup of
the IOO-BC-1 Operable Unit began in July 1996 and in the 100-DR-l Operable Unit in
December 1996. Cleanup in the 100-HR-1 Operable Unit is scheduled to begin by
September 30,1998.
REMEDY SELECTED IN THE ROD
As discussed in the previous paragraph, the September 1995 Interim Remedial Action ROD
identified 37 high-priority waste sites that had received liquid radioactive effluent discharges.
The selected interim remedy for the 37 sites is to remove, treat as appropriate or required, and
dispose of the waste in the ERDF. The selected remedy relies on the Plug-In Approach for
selection of the same remedy at multiple similar or "analogous" sites within the 100 Area. A
standard remedy is selected that applies to a given set of circumstances rather than to a specific
waste site. The approach combines historical information on former process operations with
limited field investigation information of the nature and extent of contamination to determine the
analogous nature of individual waste sites. This allows the EPA, Ecology, and DOE to select
and implement remedial actions at similar waste sites without expending resources to further
characterize analogous sites across the 100 Area.
The implementation of the selected interim remedy generally includes the following steps:
• Remove contaminated soil, structures, and debris from 100 Area source waste sites using
the "Observational Approach." The Observational Approach utilizes analytical screening
during remediation to guide the extent of excavation. Remediation proceeds until it can
be demonstrated through a combination of field screening and confirmational sampling
that cleanup goals have been achieved.
• Treat the waste as required to meet applicable waste disposal criteria.
• Dispose of contaminated materials at ERDF.
• Backfill excavated areas and revegetate.
The extent of remediation will take into account appropriate site-specific factors including
reduction of risk by decay of short-lived (half-life of less than 30.2 years) radionuclides,
protection of human health and the environment, remediation costs, sizing of the ERDF, worker
safety, presence of ecological and cultural resources, the use of institutional controls, and long-
term monitoring costs. The DOE will control access to and use of the Hanford Site for the
duration of the cleanup. Institutional controls and long-term monitoring will be required for sites
where wastes are left in place. Wastes will continue to be present in the 100 Area until final
remediation objectives are achieved and a final ROD is issued.
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DESCRIPTION OF THE MODIFIED REMEDY
The cleanup goals for the September 1995 Interim Remedial Action ROD and this amendment
are to remediate liquid radioactive waste disposal sites to levels that will not preclude any future
uses, to protect groundwater in the 100 Area, and to protect the Columbia River. Many of the
provisions of the interim remedy as described in the September 1995 Interim Remedial Action
ROD and this amendment are the same. The significant differences addressed in this amendment
to the September 1995 Interim Remedial Action ROD for the original 37 high-priority sites are
explained in the following sections.
Additional Radioactive Liquid Source Waste Sites
Additional radioactive liquid source waste sites exist at the 100 Area NPL Site that are analogous
to those in the 100-BC-l, 100-DR-l, and 100-HR-1 Operable Units selected for the Interim
Remedial Action ROD. The boundaries of the remedial action have been expanded to include 34
additional sites within the 100 Area that received discharges of radioactive liquid effluent similar
or identical to those which were received by the original 37 high-priority waste sites of the
Interim Remedial Action ROD. It was concluded that the 34 additional sites warrant interim
remedial action based on the Plug-In Approach because they all received similar historical
discharges of liquid radioactive effluent and the available limited field investigation results
indicate elevated risk levels comparable to those of the original 37 high-priority sites.
Information concerning the additional sites in the 100-BC-2,100-DR-l, 100-DR-2,100-FR-l,
100-HR-1,100-KR-l, and 100-KR-2 Operable Units is summarized in Appendix A. An
analogous site for each of the 34 additional sites is presented from the list of 37 high-priority
sites included in the Interim Remedial Action ROD.
Appendix A also presents information on waste site profiles for the additional 34 radioactive
liquid waste sites, including volumes, nominal site dimensions, anticipated or known
contaminants, and estimated remediation costs. Estimated remediation costs for the 34
additional 100 Area radioactive liquid waste sites total $112 million.
Reductions to Cost Estimates for Remediation of 100 Area Waste Sites
The EPA, Ecology, and DOE identified significant opportunities for streamlining and
coordination of remediation activities during remedial design for the original 37 waste sites. An
ERA was conducted in the 100-BC-l Operable Unit to address uncertainties in remedial design
planning and to initiate remedial action on 100 Area source waste sites. Lessons learned from
this ERA, revised cost modeling assumptions, and a reevaluation of site-specific analytical data
resulted in more accurate development of cost estimates and reductions to cost estimates for
remediation of 100 Area waste sites. It was determined that less material will need to be
removed during remediation than originally planned, that significantly fewer samples and
analyses will be needed for confirmation of cleanup, and that disposal costs will be significantly
lower than originally anticipated.
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The preliminary cost estimate for the selected interim remedial action (remove, treat as
appropriate or required, and dispose) for the original 37 sites was $491 million. Use of less
conservative assumptions and refining of the data inputs to the cost estimating model software
has reduced this estimate to $82 million. Remediation costs for the total 71 radioactive liquid
waste sites of the Interim Remedial Action ROD and this amendment are projected to be $194
million.
Elimination of Soil Washing Treatment Step for Volume Reduction
The soil washing treatment step for volume reduction will no longer be retained as a treatment
option prior to disposal. The completion of pilot-scale treatability studies for soil washing to
reduce contaminated soil volumes has shown this process is not cost effective for the liquid
radioactive effluent disposal sites in the 100 Area. A report was published in November 1995
that presents the results of the treatability studies1.
Revegetation of Remediated Areas
The revegetation of the additional remediated waste sites will be addressed using the guidance
provided in the current Mitigation Action Plan titled Mitigation Action Plan for Liquid Waste
Sites in the JOO-BC-J, 100-DR-l, and 100-HR-l Operable Units. This document was developed
in coordination with the Hanford Trustees through the Hanford Natural Resource Trustee
Council. The implementation of activities outlined in the document will provide overall
environmental benefit to the Site. The revegetation activities are not part of the remedial action
because they are not a feature necessary for the effective performance and completion of the
selected remedial action. However, revegetation activities will be conducted following the
completion of remedial action activities.
EVALUATION OF ALTERNATIVES
The NCP establishes nine criteria for evaluating remedial action alternatives. These criteria are
divided into three categories of weighted importance, which include threshold, balancing, and
modifying criteria. Overall protection and compliance with applicable or relevant and
appropriate requirements (ARARs) (unless specifically waived) are threshold criteria that all
remedies must meet to be considered. The seven balancing and modifying criteria help describe
relative differences between the alternatives. A discussion of the original remedy and the
modified remedy relative to the nine criteria evaluation is required by CERCLA. In this section,
the addition of 34 sites, the reduction in overall cost estimates, and the elimination of soil
washing as a volume reduction option are compared to the original remedy, relative to the nine
criteria.
It is important to note that the additional sites for cleanup are very similar to the sites selected in
the original Interim Remedial Action ROD. These types of waste sites have been evaluated in a
'Belden, R. D., 100 Areas Soil Washing Tradeoff Study, BHI-00624, Rev. 0,
November 1995, Bechtel Hanford, Inc, Richland, Washington.
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feasibility study report that supports the cleanup actions. Another key point is that the
evaluations that support the initial cleanup decision still hold and do not change.
Threshold Criteria
1. Overall Protection of Human Health and the Environment
Both the existing Interim Remedial Action ROD and this amendment meet the threshold criterion
of protection of human health and the environment. The approach to remediation of
contaminated sites, as well as the cleanup goals, are the same for both. A key provision of the
remediation goal to protect human health is the proposed standard to limit radiation dose from
contaminated sites to 15 mrem/yr above natural background levels.
2. Compliance with Federal or State Environmental Standards (ARARs)
The existing Interim Remedial Action ROD and this amendment will both comply with ARARs.
The key ARARs are the Model Toxics Control Act for metals and organics in soils, Safe Drinking
Water Act maximum contaminant levels for groundwater, and Clean Water Act criteria for the
Columbia River.
Balancing Criteria
3. Long-Term Effectiveness and Permanence
The existing Interim Remedial Action ROD and this amendment have the same approach to
remediation of the waste sites and the same remediation goals. Therefore, both will result in
permanent protection of human health and the environment after cleanup goals are met. The
remediation of 34 additional sites will increase the overall long-term effectiveness of the remedy
in the 100 Area.
4. Reduction of Toxicity, Mobility, and Volume Through Treatment
The existing Interim Remedial Action ROD and this amendment have the same approach to
remediation of the waste sites and the same remediation goals. The completion of soil reduction
treatment studies has shown that volume reduction is not cost effective for the liquid radioactive
waste disposal sites. However, treatment to meet Land Disposal Restrictions prior to disposal in
the ERDF may be required at some sites.
5. Short-Term Effectiveness
The existing Interim Remedial Action ROD and this amendment have the same approach to
remediation of the waste sites. Both are similar with respect to meeting this criterion. However,
the proposed amendment will add additional sites for remediation, which will increase the overall
amount of time for completion of the remediation. No significant worker exposure concerns are
expected that cannot be addressed through common remediation practices.
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6. Implementability
The existing Interim Remedial Action ROD and this amendment have the same approach to
remediation of the waste sites. Therefore, both are essentially the same with respect to meeting
this criterion. The addition of 34 more sites will allow for better long-term planning of remedial
action construction, transportation, and disposal activities.
7. Cost
The Interim Remedial Action ROD estimated cost of remediation of the original 37 sites was
$491 million. The updated estimate for those 37 sites is $82 million. This amendment would
also add 34 more sites at an estimated cost of $112 million. This amendment represents an 83%
reduction in the estimated cost for the original 37 sites, and a 60% total reduction from the
September 1995 ROD. The Tri-Parties will continue to work towards further streamlining
activities in order to focus resources on cleanup.
Modifying Criteria
8. State Acceptance
The State of Washington has concurred with this proposed amendment.
9. Community Acceptance
Newspaper notices, a fact sheet, and a proposed plan were issued on December 15,1996. One
comment was received during the 30-day public comment period. That comment was in support
of the proposed amendment and is included in the Responsiveness Summary that is included as
Appendix B of this amendment.
RCRA PAST-PRACTICE OPERABLE UNIT REQUIREMENTS
Waste sites in the 1OO-DR-2 Operable Unit are included in this action. Wastes from remediation
of this RCRA past-practice unit can be disposed of at the ERDF according to the provisions
made in the August 1,1996, Explanation of Significant Differences (BSD) for the January 20,
1995, ERDF ROD. No redesignation of regulatory pathway from RCRA Past Practice (RPP) to
CERCLA Past Practice (CPP) is required prior to disposal of wastes from this operable unit at
ERDF. However, the ERDF ESD does require that all waste be the subject of a CERCLA
decision document prior to disposal at the ERDF.
To meet applicable requirements of both CERCLA and RCRA while avoiding unnecessary
duplication, the regulatory agencies will take the following steps for RPP waste that is to be
disposed at the ERDF. The lead regulatory agency will prepare a CERCLA decision document
following the CERCLA public involvement process that will authorize the selected response
action. This ROD amendment meets this requirement for the RPP sites addressed herein.
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In addition, Ecology will modify the Hanford Site-Wide RCRA Permit at the next scheduled
modification. This modification will incorporate by reference the CERCLA remedy selection
decision documents into the RCRA permit for purposes of satisfying corrective action
requirements of WAC 173-303-646. Because the public received notice of the proposed remedy
under CERCLA and was provided with an opportunity to comment, Ecology intends to use the
Class I permit modification procedures for such changes, unless other changes being made at the
same time require that Class II or Class III permit modification procedures be used instead.
Specifically, a chapter will be added in Part IV of the Dangerous Waste portion of the RCRA
permit for each RPP operable unit that is being addressed. Each chapter will incorporate by
reference the documents upon which the CERCLA decision document was based, the CERCLA
decision document, and any remedial design and/or remedial action documents. The schedule
for completion shall be as specified in the approved CERCLA remedial design report. The
Hanford Site-Wide RCRA Permit will be modified again by removing each of these chapters
after the area addressed by the chapter has been deleted from the NPL and no further action is
required, including institutional controls or monitoring. Again, Ecology intends to use the
Class I permit modification procedures when removing these chapters, unless other changes
being made at the same time require that Class II or Class III permit modification procedures be
used instead. NPL deletion will occur only after applicable CERCLA requirements, including
public involvement, have been met.
The Tri-Party Agreement recognizes the similarity of the RPP and CPP processes, and their
common objective of protecting human health and the environment from potential releases of
hazardous substances, wastes, or constituents. The regulatory conditions, such as ARARS,
controlling remediation should remain similar and consistent in implementation whether a waste
site is designated as RPP or CPP.
STATUTORY DETERMINATIONS
Considering the new information that has been developed and the broadening of the scope of
cleanup activities, the EPA and Ecology believe that the amended interim remedy (remove, treat
as required, and dispose) remains protective of human health and the environment, complies with
Federal and state requirements that are applicable or relevant and appropriate to this remedial
action, and is cost-effective. The addition of 34 analogous sites to the original 37 high-priority
radioactive liquid waste sites selected for remediation in the September 1995 Interim Remedial
Action ROD does not change the applicability of statutory requirements. The remediation
project will continue to utilize permanent solutions to the maximum extent practicable for
100 Area source waste sites. However, because treatment of the principal threats of the sites was
not found to be practicable, this amended interim remedy does not satisfy the statutory
preference for treatment of a principal element.
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Table 1. Cost Estimates From the September 1995 Interim Action ROD.
Number of
Sites
37
Volume for
Disposal
1, 685,000 LCY*
Cost of Site
Remediation
(S million)
$361
Cost of
Disposal
(S million)
$130
Total
($ million)
$491
' Loose Cubic Yards
Table 2. Amended Cost Estimates.
Number of
Sites
37-Initial
34-Additional
71-Total
Volume for
Disposal (LCY*)
535,000
668,000
1,203,000
Cost of Site
Remediation
($ million)
$49
$71
$120
Cost of
Disposal
(Smillion)
$33
$41
$74
Total
($ million)
$82
$112
$194
1 Loose Cubic Yards
10
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Figure 1. Map of The Hanford Site Showing the Reactors in the 100 Area and ERDF.
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11
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APPENDIX A
ADDITIONAL 100 AREA RADIOACTIVE LIQUID WASTE SITES
A-l
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Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 1 of 7)
Operable
Unit
100-BC-2
100-DR-l
100-DR-2
Site Name
1I6-C-2A
Pluto Crib
116-C-2B/C
Pluto Crib
Pump
Station/ Sand
Filter
II6-D-3
French Drain
1 16-DR-3
Storage Basin
Trench
116-DR-4
Pluto Crib
Current Site Knowledge
Received contaminated effluent
from 1 16-C-2C Pluto Crib Sand
Filter. Site is an unlined earthen
structure 6.9 m by 4.7 m by 1 .5 m
deep with 5.7 m clean fill.
Received process effluent from
C Reactor contaminated during
fuel element cladding failures.
Site is a pump station 4.6 m by 4.6
m by 9. 1 m deep connected to an
open-bottomed concrete box 12.7
m by 5.5 m by 5.6 m deep.
Received radioactive and
hazardous liquid wastes from 108-
D Maintenance Shop and Cask
Decontamination Pad. Site is a
0.9-m-diametcr gravel-filled pit
1.5m deep.
Received radioactive sludge and
water from the 105-DR Fuel
Storage Basin. Site is an unlined
trench 18 m by 12 m by 3.1 m
deep covered with clean fill.
Received DR Reactor process
effluent contaminated during fuel
element cladding failures. Site is
an unlined trench 3.1 m by 3.1 m
by 3.1 mdeep.
Media/
Material
Timbers,
Soil
Concrete,
Steel, Soil
Soil
Soil
Timbers,
Soil
Contaminants of
Potential
Concern
C-14, Sr-90,
Cadmium
Co-60, Sr-90,
Cs-137,Eu-152,
Pu-238,
Pu-239/240
Undetermined
radionuclides
Tritium, Co-60,
Sr-90, Cs-137,
Eu-I52,Eu-154,
Pu-238,
Pu-239/240
Co-60, Sr-90,
Cs-l37,Eu-l52,
Eu-155,
Pu-239/240
Estimated
Volume for
Disposal
(LCV •)
7,439
(Included
with
116-C-2A)
36
1,099
160
Estimated
Cost of Site
Remediation
($ in OOO's)
$2,799
(Included
with
116-C-2A)
$82
$204
$155
Estimated
Cost of
Disposal
($ in OOO's)
$459
(Included
with
I16-C-2A)
$2
$68
$10
Estimated
Total Cost
($ in OOO's)
$3,258
(Included
with
1I6-C-2A)
$84
$272
$165
Analogous
Site"
I16-B-3
Pluto Crib
1 16-B-3
Pluto Crib
116-B-4
French
Drain
I16-D-1A
Fuel Storage
Basin
Trench
II6-D-2A
Pluto Crib
>
-------
Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 2 of 7)
Operable
Unit
100-DR-2
(cont)
100-FR-l
Site Name
116-DR-6
Liquid
Disposal
Trench
UPR-100-F-2
Basin Leak
Ditch
(IOO-F-3)
IOO-F-19
Process
Effluent
Pipelines
108-F French
Drain
(IOO-F-15)
116-F-l
Process
Effluent
Disposal
Trench
Current Site Knowledge
Received process effluent from
DR Reactor released during
effluent system maintenance and
process upgrades. Site is an
unlined trench 15.2 m by 3.1 m by
3.1 m deep covered with clean fill.
Unplanned releases of process
effluent from the north end of the
107-F Retention Basin. Site is a
ditch approximately 30 m by 6.1 m
by 4.6 m deep covered with clean
nn.
Transported process effluent from
the F Reactor to the retention
basins and outfall structures. Does
not include process sewer or other
pipelines.
Received condensate from 108-F
Biology Laboratory hoods. Site is
a 1.2-m-diameter gravel-filled
concrete pipe extending to an
unknown depth.
Received process effluent from
F Reactor, 190-F Building, and
1 16-F-14 Retention Basin, plus
decontamination wastes from the
189-F Building. Site is an unlined
trench 914 m by 12 m by 3 m
deep.
Media/
Material
Soil
Soil
Concrete,
Steel, Soil
Concrete,
Steel
Soil
Contaminants of
Potential
Concern
Undetermined
radionuclides
Co-60, Sr-90,
Cs-137, Eu-152
Co-60, Cs-137,
Eu-152, Eu-155
Pu-238,
Pu-239/240
C-14, Co-60,
Sr-90, Cs-137,
Eu-152,Eu-154,
Lead, Zinc
Estimated
Volume for
Disposal
(LCY ')
491
6,389
28,301
2
5,111
Estimated
Cost of Site
Remediation
($ in OOO's)
$97
$880
$4,230
$92
$528
Estimated
Cost of
Disposal
($ in OOO's)
$30
$394
$1,745
$0
$315
Estimated
Total Cost
($ in OOO's)
$127
$1,274
$5.975
$92
$843
Analogous
Siteb
II6-DR-1
Process
Effluent
Disposal
Trench
1I6-B-I
Process
Effluent
Disposal
Trench
100-BC
Process
Effluent
Pipelines
1 16-B-4
French
Drain
1 16-B-1
Process
Effluent
Disposal
Trench
-------
Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 3 of 7)
Operable
Unit
IOO-FR-1
(cont)
Site Name
116-F-2
Process
Effluent
Disposal
Trench
116-F-3Fuel
Storage Basin
Trench
116-F-4 Pluto
Crib
116-F.SBall
Washer Crib
116-F-6
Liquid Waste
Disposal
Trench
Current Site Knowledge
Received process effluent from
F Reactor. 190-F Building, and
1 16-F-14 Retention Basin, plus
decontamination wastes from the
189-F Building. Site consists of
three unlined trenches connected
together.
Received process effluent and
sludge from the F Reactor fuel
storage basin. Site is an unlined
trench 30 m by 6. 1 m by 2.4 m
deep.
Site was excavated as part of a
trcatability study in 1993.
Contaminated soil was disposed at
ERDF in 1996. Verification
sampling may be required to
confirm that the site meets cleanup
goals.
Received wastes from
decontamination of F Reactor
equipment. Site is a below-ground
structure approximately 4.6 m by
4.6 m by 3 m deep.
Received process effluent diverted
during maintenance shutdowns of
F Reactor. Site is an unlined
trench 91 m by 30.5 m by 3.1 m
deep.
Media/
Material
Steel, Soil
Soil
Soil
Concrete,
Steel, Soil
Soil
Contaminants of
Potential
Concern
C-14, Co-60,
Sr-90, Cs-137,
Eu-l52,Eu-154,
Chromium,
Cadmium
Eu- 152, Barium,
Chromium, Lead,
Mercury
Tritium, Co-60,
Sr-90, Cs-137,
Eu-152,Eu-154,
Eu-155,Pu-238,
Pu-239/240
Sr-90, Cs-137,
Eu-154,Eu-l55
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-154.
Chromium, Lead
Estimated
Volume for
Disposal
(LCY «)
2,556
3,067
0
1,208
27,408
Estimated
Cost of Site
Remediation
(S in OOO's)
$359
S361
$49
$376
$2,762
Estimated
Cost of
Disposal
($ in OOO's)
$158
$189
$0
$74
$1,690
Estimated
Total Cost
($ in OOO's)
$517
$550
$49
$450
$4,452
Analogous
Siteb
116-B-l
Process
Effluent
Disposal
Trench
116-B-2
Fuel Storage
Basin
Trench
1 16-B-3
Pluto Crib
116-B-3
Pluto Crib
116-B-l
Process
Effluent
Disposal
Trench
-------
Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 4 of 7)
Operable
Unit
IOO-FR-1
(cont)
100-FR-2
100-HR-l
Site Name
116-F-9PNL
Animal
Waste Leach
Trench
II6-F-10
French Drain
116-F-ll
Cushion
Corridor -
French Drain
1I6-F-I4
Retention
Basins
126-F-l
Powerhouse
Ash Pit
100-H-5
Sludge Burial
Trench
Current Site Knowledge
Received radioactively
contaminated wash and waste
water from animal pens. Site
consists of two unlined trenches
connected together.
Received water and nitric acid
from decontamination of F Reactor
fuel element spacers. Site is a 1-
m-diameter gravel-filled tile pipe
2 m deep.
Received radioactive liquids from
decontamination of F Reactor
equipment Site is a 0.9-m-
diameter gravel-filled tile pipe
extending to an unknown depth.
Received process effluent from
F Reactor. Site is a reinforced
rectangular concrete retention
basin approximately 415 m by 1 10
m by 7.3 m deep.
Contains coal ash and soil
radioactively contaminated by
leakage from the F Reactor process
effluent line. Site is an irregular
area approximately 335 m by
145 m by 6.1 mdeep.
Received sludge from the 1 16-H-7
Retention Basins. Site is a 45.7-m
by 4.6-m by 4.6-m-deep trench
covered to grade with 1.5 m of
clean fill.
Media/
Material
Soil
Tile, Steel,
Soil
Tile, Steel,
Soil
Concrete,
Steel, Soil
Coal Ash,
Soil
Soil
Contaminants of
Potential
Concern
C-14
Co-60, Sr-90,
Cs-137,Eu-I52,
Eu-154,Eu-155.
Pu-238,
Pu-239/240
Tritium, Co-60,
Sr-90, Cs-137,
Eu-152,Eu-155,
Pu-238,
Pu-239/240
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-154,
Pu-239/240,
Chromium,
Cadmium
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-154,
Chromium
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-154, Pu-238,
Pu-239/240
Estimated
Volume for
Disposal
(LCY ')
13,289
3
92
50,449
290,243
1,267
Estimated
Cost of Site
Remediation
($ in OOO's)
$1,116
$92
$133
$3,793
$32,978
$213
Estimated
Cost of
Disposal
($ in OOO's)
$820
$0
$6
$3,111
$17,899
$78
Estimated
Total Cost
($ in OOO's)
$1,936
$92
$139
$6,904
$50.877
$291
Analogous
Sitek
116-B-l
Process
Effluent
Disposal
Trench
116-B-4
French
Drain
1I6-B-4
French
Drain
1I6-B-II
Retention
Basin
116-B-l
Process
Effluent
Disposal
Trench
II6-B-13
Sludge
Trench
>
-------
Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 5 of 7)
Operable
Unit
100-HR-l
(cont)
100-KR-1
Site Name
100-H-I7
Overflow
116-H-3
French Drain
IOO-KR-1
Process
Effluent
Pipelines
116-K-lCrib
I16-K-2
Process
Effluent
Trench
Current Site Knowledge
Two acres flooded by H Reactor
process effluent from 1608-H
Liquid Waste Disposal Trench.
Site is bounded on the north by the
trench and on the east, west, and
south by railroad tracks. Site is
covered with clean fill.
Received radioactively
contaminated water and nitric acid
from decontamination of H
Reactor equipment. Site consists
of two 0.9-m-diameter gravel-
filled clay pipes extending to an
unknown depth.
Transported process effluent from
KE and KW Reactors to the
retention basins, trenches, and
outfall structures. Does not
include process sewer or other
pipelines.
Received process effluent from KE
and KW Reactors. Site consists of
a crib area 61 mby 61 m
surrounded by an earthen
embankment extending 6.1 m
above the crib bottom.
Received process effluent from KE
and KW Reactors. Site consists of
an unlincd trench 1,250 m by 13.7
m by 7.6 m deep that has been
covered with clean fill.
Media/
Material
Soil
'
Tile, Steel,
Soil
Concrete,
Steel, Soil
Soil
Soil
Contaminants of
Potential
Concern
Tritium, Co-60,
Sr-90,Cs-137,
Eu-152, Eu-154,
Eu-155,
Pu-239/240,
Chromium
Tritium, Co-60,
Sr-90,Cs-137,
Eu-152, Eu-154,
Pu-238,
Pu-239/240,
Chromium
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-155
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-154,
Pu-239/240
Co-60, Sr-90,
Eu-152. Eu-154,
Pu-239/240,
Chromium,
Mercury
Estimated
Volume for
Disposal
(LCY ')
26,833
234
6,040
10,229
84,984
Estimated
Cost of Site
Remediation
(S in OOO's)
$1,943
$187
$3,272
$857
$6,953
Estimated
Cost of
Disposal
(S in OOO's)
$1,655
$14
$372
$631
$5,241
Estimated
Total Cost
($ in OOO's)
$3,598
$201
$3,644
$1,488
$12,194
Analogous
Site6
1I6-B-1
Process
Effluent
Disposal
Trench
116-B-4
French
Drain
100-BC
Process
Effluent
Pipelines
116-B-l
Process
Effluent
Disposal
Trench
116-B-l
Process
Effluent
Disposal
Trench
-------
Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 6 of 7)
Operable
Unit
100-KR-l
(cont)
100-KR-2
Site Name
I16-KE-4
Retention
Basin
116-KW-3
Retention
Basin
100-K-1
French Drain
116-KE-l
Condensate
Crib
1I6-KW-I
Condensale
Crib
116-KE-2
Waste Crib
Current Site Knowledge
Received process effluent from
KE Reactor. Site of three tanks
76.2 m diameter by 7.62 m high
that were removed during
1994-1995. Leakage
contaminated the soil beneath the
tanks.
Received process effluent from
KW Reactor. Site of three tanks
76.2 m diameter by 8.8 m high that
were removed during 1994-1995.
Leakage contaminated the soil
beneath the tanks.
Received radioactive effluent from
119-KW Sample Building. Site
consists of a 0.3-m-diameter
gravel-filled concrete pipe
extending to an unknown depth.
Received condensate from KE
Reactor gas purification system.
Site is a cobble-filled crib 12.2 m
by 12.2 m by 7.9 m deep.
Received condensate from KW
Reactor gas purification system.
Site is a cobble-filled crib 12.2 m
by 12.2 m by 7.9 m deep.
Received liquid waste from KE
Reactor effluent test loop. Site is a
wooden crib structure 4.9 m by 4.9
m by 9.8 m deep.
Media/
Material
Concrete,
Steel, Soil
Concrete,
Steel, Soil
Soil
Concrete,
Steel, Soil
Concrete,
Steel, Soil
Timbers,
Soil
Contaminants of
Potential
Concern
Co^O, Sr-90,
Eu-152, Eu-154,
Pu-239/240,
Chromium
Co-60, Sr-90,
Eu-152, Eu-154,
Pu-239/240,
Chromium
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-154,Pu-238,
Pu-239/240
Tritium, C-14
Tritium, C-14,
Co-60, Sr-90,
Cs-137, Eu-154,
Eu-155,U-238
Tritium, C-14
Estimated
Volume for
Disposal
(LCY ')
48,060
47,890
2
137
137
384
Estimated
Cost of Site
Remediation
($ in OOO'i)
$2,634
$2,714
$110
$139
$139
$477
Estimated
Cost of
Disposal
($ in OOO'i)
$2,964
$2,953
$0
$8
$8
$24
Estimated
Total Cost
($ in OOO's)
$5,598
$5,667
$110
$147
$147
$501
Analogous
Site"
1I6-B-11
Retention
Basin
116-B-ll
Retention
Basin
116-B-4
French
Drain
1 16-B-3
Pluto Crib
II6-B-3
Pluto Crib
I16-B-3
Pluto Crib
>
•ij
-------
Table A-l. Additional 100 Area Radioactive Liquid Waste Sites, (sheet 7 of 7)
Operable
Unit
100-KR-2
(cont.)
Site Name
116-KE-3
French Drain
116-KW-2
French Drain
Current Site Knowledge
Received overflow from KE
Reactor fuel storage basin. Site is
a 6. 1 -m- diameter drain field with
a 0.2-m-diameter perforated steel
pipe 23.8 m deep.
Received overflow from KW
Reactor fuel storage basin. Site is
a 6. l-m- diameter drain field with
a 0.2-m- diameter perforated steel
pipe 23.8 m deep.
Media/
Material
Steel, Soil
Steel, Soil
Contaminants of
Potential
Concern
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-155,
Pu-239/240
Co-60, Sr-90,
Cs-137, Eu-152,
Eu-155,
Pu-239/240
Totals
Estimated
Volume for
Disposal
(LCY ')
34
34
664,408
Estimated
Cost of Site
Remediation
(S in OOO's)
$141
$140
$71,005
Estimated
Cost of
Disposal
(S in OOO's)
$2
$2
$40,922
Estimated
Total Cost
(S in OOO's)
$143
$142
$111,927
Analogous
Site"
II6-B-4
French
Drain
1I6-B-4
French
Drain
' Loose Cubic Yards
b Also see Table 6 of the September 1995 ROD for a more complete description of analogous sites in the 100-BC-l, 100-DR-l, and 100-HR-1 Operable Units.
-------
APPENDIX B
RESPONSIVENESS SUMMARY
U.S. Department of Energy
Hanford Site - 100 Area
Benton County, Washington
Amended Record of Decision
INTRODUCTION
This responsiveness summary meets the requirements of Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) as amended. The purpose
of this responsiveness summary is to summarize and respond to public comments on the
proposed amendment for the September 1995 Record of Decision (ROD) for the Hanford
100-BC-l, 100-DR-l and 100-HR-1 Operable Units. The proposed amendment, issued on
December 15, 1996, presented for public comment proposed changes to components of the
remedy set forth in the September 1995 ROD.
The Tri-Parties announced the issuance of the proposed plan in the community newspaper. A
30-day comment period was provided for the public to read the proposed plan, review documents
in the administrative record, and submit written comments. No request was made for a public
meeting; therefore, no meeting was held. The proposed amendment was to add 34 more sites for
remediation, lower the overall cost, and drop the treatment option of soils washing for volume
reduction, and clarify the role of revegetation of waste site after remediation.
COMMUNITY INVOLVEMENT
The proposed amendment was presented to the Hanford Advisory Board, Environmental
Restoration Committee in July and August 1996.
COMMENTS AND RESPONSES
One comment was received during the public comment period. That comment supports the
proposed amendment.
B-l
------- |