PB95- 964602
                                EPA/ROD/R10-95/100
                                February 1995
EPA Superfund
      Record of Decision:
       Hanford 200 Area (USDOE)
       (O.U. 14) Benton County, WA
       1/20/1995

-------
                      DECLARATION OF THE RECORD OF DECISION
 SITE NAME AND LOCATION

 USDOE Hanford Environmental Restoration Disposal Facility
 Hanford Site
 Benton County, Washington
 STATEMENT OF BASIS AND PURPOSE

 This decision document presents the selected remedial action for the USDOE Hanford Site
 Environmental Restoration Disposal Facility (ERDF), Hanford Site, Benton County, Washington,
 which was chosen in accordance with the Comprehensive Environmental Response,  Compensation,
 and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
 Act of 1986 (SARA), and to the extent practicable, the National Oil and Hazardous  Substances
 Pollution Contingency Plan (NCP).  This decision is based on the Administrative Record for this site,
 which is located in 2440 Stevens Center, Richland, Washington.
 ASSESSMENT OF THE SITE

 Actual or threatened releases of hazardous substances from the operable units on the Hanford Site, if
 not addressed by implementing the response action selected in this Record of Decision (ROD), may
 present an imminent and substantial endangerment to the public health, welfare,  or the environment.
 DESCRIPTION OF THE SELECTED REMEDY

 This ROD addresses the disposal of radioactive, hazardous/dangerous, asbestos, PCB, and mixed
 wastes resulting from the remediation of operable units within the 100, 200, and 300 Area National
 Priorities List (NPL) sites of the Hanfbrd Site. The ERDF will minimize migration of contaminants
'from waste, primarily'soils and debris, placed in the facility.  The 1100 Area ROD, issued in
 September 1993, specifies that the waste generated during remediation will be disposed of offsite.

 The major components of the selected remedy include the following:

  •     Initial construction and operation of two disposal cells that are expected to provide an
        approximate waste disposal capacity of 1.2 million yd3. These cells will be designed and
        constructed to RCRA minimum technological requirements (MTRs) (40 CFR Part 264,
        Subpart N).  The decision to expand the landfill in the future will be documented by
        amending this ROD or as part of the RODs for the Hanford operable units.

  •     The ERDF site will cover a maximum of 4.1 km2 (1.6 mi2) on the Central Plateau, southeast
        of the 200 West Area and southwest of the 200 East Area. The initial construction of the
        facility will require 165 acres of this area.

-------
•     The ERDF facility will provide sufficient leachate storage capacity to ensure uninterrupted
      operations, and will comply with 40 CFR Part 264, Subpart N. Leachate collected at the
      landfill will be managed at the 200 Area Effluent Treatment Facility, located in the 200 East
      Area, or other approved facility.

•     Surface water run-on/run-off will be controlled at the landfill and  other areas of the facility
      that are potentially contaminated.  Best management practices to control runoff shall be
      employed.

•     During excavation, suitable soils will be stockpiled at the ERDF site to provide materials for
      liner systems and for daily interim and closure covers for the landfill. Materials not suitable
      for construction of the liner and covers will be used for other construction purposes at the
      Hanford Site to the extent practicable.

•     Air monitoring will be accomplished by placement at ERDF of real-time.air monitors for
      radioactive contaminants and air samplers for hazardous and radioactive constituents to detect
      any offsite migration of contaminants.

•     Groundwater monitoring will be performed in accordance with 40 CFR Part 264, Subpart F.

•     Appropriate measures to protect facility workers and the public will be employed during
      ERDF operations including contamination control and dust mitigation, and protection of
      personnel from industrial hazards presented by ERDF operations.  Protective measures shall
      comply with applicable requirements found in the Occupational Safety and Health Act
      (OSHA), Washington Industrial Safety and Health Act (WISHA),  and other safety regulations
      or ERDF-specific safety requirements. Energy shall also comply with 40 CFR §300.150.

•     The ERDF facility will use existing or planned site transport systems for waste transport.
      Extension of the Hanford rail line was considered hi the RI/FS, but at this tune the rail line
      extension is not considered necessary.  As Hanford remediation accelerates, the option might
      be re-evaluated in the future.

•     Waste acceptance criteria shall be developed by DOE, in accordance with applicable or
      relevant and appropriate requirements (ARARs), risk/performance assessments, ERDF-
      specific safety documentation, and worker protection requirements.  Upon approval by EPA
      (and consultation with Ecology), these criteria will govern what wastes from the Hanford NFL
      sites can be placed in the ERDF. No waste may be placed into the ERDF until the waste
      acceptance criteria have been approved by EPA, and consultation with Ecology. Operable
      unit-specific waste disposal and treatment decisions will be made as part of the remedy
      selection and cleanup decision process for each operable unit.

•     The ERDF landfill will be closed by placing a modified RCRA-compliant closure cover over
      the waste. The cover will prevent direct exposure to the waste and includes a vegetated
      surface layer of fine-grained soils to retain moisture and encourage evapotranspiration,
      thereby minimizing infiltration and vadose zone transport of contaminants to groundwater.
      The upper SO cm (20 in.) of the soil cover system is composed of an admixture of silt and
      gravels. This layer is intended to both reduce infiltration through  the cover and enhance the
      resistance of the cover to burrowing animals and long-term wind erosion. The RCRA-
      compliant cover will be modified by providing a total of approximately IS ft of soil to deter .
      intrusion.  It is anticipated that additional research into closure covers may result hi site-
                                             11

-------
        specific enhancements to RCRA-compIiant designs.  Prior to cover construction, closure cover
        designs will be evaluated and the most appropriate closure cover design will be selected for
        construction.  Construction of the cover will occur on an incremental basis, as the trench is
        expanded.  The design will, at a minimum, comply with applicable RCRA requirements found
        at 40 CFR Part 264, Subpart N.  Basalt from Hanford Site borrow pits will not be required
        for construction of the ERDF  closure cover.

  •     Institutional controls shall be imposed to restrict public access to the landfill.

  •     Equipment will be available to transport wastes and operate the ERDF safely.

  •     Hanford Site infrastructure will be expanded as necessary to support the ERDF.
        Infrastructure improvements or extensions may include water, sewer, electric power, roads,
        operations facilities, and a chemical and fuel storage area.

  •     A decontamination facility will be constructed consisting of, at a minimum, an impervious pad
        with sump,  wash water  storage, and secondary containment.  Wash water used to
        decontaminate site equipment shall be managed in compliance with appropriate requirements.

  •     The detailed design will be submitted to EPA for approval (with consultation with Ecology)
        prior to construction of  the ERDF facility.  At a minimum,  it will  be submitted in two
        packages to allow for construction in phases.

  •     An operations plan will  be submitted to EPA for approval (with consultation with Ecology)
        prior to operation of the ERDF facility.

  •     Mitigation measures to reduce ecological impacts have been incorporated to satisfy the
        Remedial Action Objectives identified hi Section 7(4)(i) through 7(4)(v). In addition, DOE
        commits to  the development and implementation of a Mitigation Action Plan in coordination
        with the Natural Resource Trustees for additional mitigation measures.
STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, will comply with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial action, and is
cost effective. This remedy utilizes permanent solutions to the maximum extent practicable for this
site. Treatment of wastes will be addressed in the operable unit decision documents.  As a
consequence, the statutory preference for treatment as a principal element will be addressed in these
future documents rather than in this ROD.

This remedy will result in hazardous substances remaining onsite above health-based levels; therefore,
a review will be conducted within 5 years after commencement  of this action to ensure that the
remedy continues to provide adequate protection of human health and the environment.

The preamble to the NCP clarifies the stated EPA's interpretation that when noncontiguous facilities
are reasonably close to one another and wastes at these sites are compatible for a selected treatment or
disposal approach,  CERCLA Section 104(d)(4) allows the lead agency to treat these related facilities
as one site for response purposes and, therefore, allows the lead agency to manage waste transferred
                                              1U

-------
between such noncontiguous facilities without having to obtain a permit. Therefore, the ERDF and
the 100, 200, and 300 Area NPL sites are considered to be a single site for response purposes.
                                              IV

-------
EPfl HPNFORD  PROJ.  OFC.    ID:509-3/b-26'ib             JHN  ^U'ys    io=Dr  HU.UUO r.uz
                sheet tor the Record of Decision lor the USI30I:' Hanlbrd Environmenlal Resioi;iiion
        Dispnsiil Facility Remedial Action between the United States Department of l£nerj;y and the United
        Slates Environmental Protection  Agency, with concurrence hy the Washington State Department of
        (icoluyy.
                    ™
                 agoner          f                                                       Date
                Richland Operations
        Jn'ned States Department of Energy

-------
Signature sheet for the Record of Decision for the USDOE Hanford Environmental Restoration
Disposal Facility Remedial Action 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                                                                ' Date
Regional Administrator, Region 10
United States Environmental Protection Agency
                                             VI

-------
                 01/19/95      15:51           HPNFORD PROJECT DEPT ECOLOGY
Signature sheet Tor the Record ol Decision for thu USDQli Hanford Environmental Restoration
Disposal Facility Remedial Action between the United Sutes Department ol" Energy and the United
Stales Environmental Protection Agency, with concurrence by the Washington .State Department of
Ecology.
        Butler                                                                 Date
Program Manager, Nuclear Waste Program
Washington State Department of Ecology
                                          .  vii

-------
                                 CONTENTS
DECLARATION OF THE RECORD OF DECISION 	  i

DECISION SUMMARY	   1
      INTRODUCTION  	   1
      SITE NAME, LOCATION, AND DESCRIPTION  	   1
      SITE HISTORY AND ENFORCEMENT ACTIONS	   5
      HIGHLIGHTS OF COMMUNITY PARTICIPATION	   6
      SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY	   8
      SITE CHARACTERISTICS   	'.	   9
      SUMMARY OF RISK ASSESSMENTS	  20
      REMEDIAL ACTION OBJECTIVES 	  24
      DESCRIPTION OF ALTERNATIVES	  26
      SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ............  30
      SELECTED REMEDY  	'	  37
      STATUTORY DETERMINATIONS  	  39
      DOCUMENTATION OF SIGNIFICANT CHANGES 	'	  46

      APPENDIX:
       A   DECLARATION OF THE RECORD OF DECISION
           RESPONSIVENESS SUMMARY	  A-l
      FIGURES:
       1.    Hanford Site Map	  3
       2.    Location of the Environmental Restoration Disposal Facility	  4
       3.   ' Topography of the Hanford Site	  10
       4.    Environmental Restoration Disposal Facility Alternatives	  28
      TABLES:
       1.    Maximum Concentrations Detected for Radionuelides in
            100, 200, and 300 Area Wastes	;	  14
       2.    Maximum Concentrations Detected for Organic Compounds in
            100 and 300 Area Wastes	  16
       3.    Maximum Concentrations Detected and Background Screening for
            Inorganic and General Chemistry Constituents in
            100 and 300 Area Wastes	  18
                                     Vlll

-------
                                  DECISION SUMMARY
INTRODUCTION

The U.S. Department of Energy's (DOE's) Hanford Site was listed on the National Priorities List
(NPL) in July 1989 under authorities granted by the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA).  The Hanford Site was divided and listed as four NPL sites:
the 1100 Area, the 200 Area, the 300 Area, and the 100 Area. The  1100 Area ROD, issued in
September 1993, specifies that the waste generated during remediation will be disposed of offsite.

Restoration of the CERCLA past-practice sites at the Hanford Site is  expected to result in the
generation of wastes requiring further management. An Environmental Restoration Disposal Facility
(ERDF) has been proposed to serve as the receiving facility for waste generated during remediation of
CERCLA past-practice sites.  In accordance with Executive Order 12580  (Superfund Implementation)
and the National  Oil and Hazardous Substances Pollution Contingency Plan (NCP)  and the National
Environmental Policy Act (NEPA), the DOE performed a Remedial Investigation/Feasibility Study
(RI/FS) for the ERDF.

This Record of Decision (ROD) authorizes the most effective alternative for the design, construction,
and operation of the ERDF. The DOE, the U.S. Environmental Protection Agency (EPA),  and the
Washington State Department of Ecology (Ecology) (the Tri-Parties) anticipate a need for ERDF
because Of desires expressed by the public to remove waste from sites adjacent to the Columbia
River. Remedial evaluations conducted by the operable units must consider various options, with
removal and disposal on the Central Plateau being one of several potential remedies.
                     I.  SITE NAME, LOCATION, AND DESCRIPTION
The DOE Hanford Site near Richland, Washington, has been operated by the Federal Government
since 1943 for plutonium production for military use and nuclear energy research and development.
Past activities released hazardous and radioactive substances to the environment that contaminated
soil, air, and groundwater.

Four areas of the Hanford Site (the 100, 200, 300, and 1100 Areas) have been included on the EPA's
NPL under CERCLA. Under the Hanford Federal Facility Agreement and Consent Order (Tri-Party
Agreement) signed by Ecology, EPA, and the DOE, more than 1,000  inactive waste disposal and
unplanned release sites have been grouped into a number of source and groundwater operable units.
An operable unit is a grouping of individual waste units based primarily on geographic area and
common waste sources. These operable units contain contamination in the form of hazardous waste,
radioactive waste, mixed waste (radioactive and hazardous),  and other  CERCLA hazardous
substances.  At the time the original Tri-Party Agreement was written, numerous sites that normally
would have been designated CERCLA sites were administratively designated as Resource
Conservation and Recovery Act (RCRA) past-practice sites.  The mechanism for approving disposal of
RCRA past-practice remedial waste into the  ERDF will be determined  by the Tri-Parties.  It is
recognized by the Tri-Parties that contaminated material .from the operable unit remediations and

-------
ERDF operations is eligible for disposal in ERDF, provided the waste acceptance criteria are met and
the disposal is in accordance with the legal requirements.

The remedy selection process for remediation of operable units located along the Columbia River is
scheduled to commence in January 1995. Based on investigations and public input to date, it is
anticipated that the remedies selected for these operable units may include removal of waste from
proximity to the Columbia River and isolation of the waste on the Central Plateau.

The ERDF is anticipated to serve as the receiving and disposal facility for most waste generated from
response actions where disposal on the Central Plateau is the selected remedy for Hanford Site
operable units.  It is possible that some waste generated during remediation may not be acceptable for
ERDF disposal and will be handled elsewhere (e.g., transuranic waste).  Only remediation waste that
originates on the Hanford Site will be placed in the ERDF.  The remediation waste is expected to
consist of hazardous/dangerous, radioactive, mixed waste (containing both hazardous/dangerous and
radioactive waste) and minor amounts of polychlorinated  biphenyl (PCB) and asbestos waste.
A.  LOCATION

The Hanford Site is a 560-mi2 area located along the Columbia River in southeastern Washington,
situated north and west of the cities of Richland, Kennewick, and Pasco, an area commonly known as
the Tri-Cities (Figure 1).

The land surrounding the Hanford Site is used primarily for agriculture and livestock grazing.  The
major population center near Hanford is the Tri-Cities, with a combined population of nearly
100,000.  The southwestern area of Hanford, covering 120 mi2, is designated as the Fitzner-Eberhardt
Arid Land Ecology Reserve and is  managed by the DOE for ecological research.

Semi-arid land with a sparse covering of cold desert shrubs and drought-resistant grasses dominates
the Hanford Site. Forty percent of the area's average annual 6-1/4 in. of precipitation occurs between
November and January. In part due to the semi-arid conditions, no wetlands are contained within the
boundaries of the ERDF.

The selected ERDF site covers a maximum of 4.1  km2 (1.6 mi2) on the Central Plateau at an
elevation of 195 to 226 m (640 to 740 ft) above mean sea level, approximately in the center of the
Hanford Site, southeast of the 200 West Area and  southwest of the 200 East Area.  The primary site
encompasses most of the land formerly leased to the State of Washington (Figure 2).

At its nearest point, the Columbia River is located approximately 11.2 km (7.1 mi) from the ERDF
location.  Other surface water bodies located near the ERDF location include West Lake,
approximately 6.4 km (4 mi) north, and Rattlesnake Springs, approximately 6.4 km (4 mi) southwest.
The 200 Area is not within  the 100-year floodplain of the Columbia River.  Groundwater travel times
from this area to the Columbia River are greater than 90 years.

-------
                                   Figure  1.  Hanford Site Map.
                                                                            ADAMS CO.
  Seattl_,
        Spokane
PROJECT SITE
                                                                         Kennewick
Note: The 600 Area consists of afl
portions of the Hanford Site not
otherwise designated.
                                                         0
                                                          •
                                                         0
   16 KILOMETERS
  a
   10 MILES


923 E412/47B35/B-23-94

-------
                                                                                                                                                                    LEGEND
                                                                                                                                                                     ^  SHe
                                                                                                                                                                          Boundary

                                                                                                                                                                          Test Well Location
                                                                                                                                                                    .690  with elevation ol
                                                                                                                                                                          ground surface

                                                                                                                                                                          Topography (50 ft)
         Pit    .:•/'   4 1 st>
                       (1 6 sq miles)
                                                                                                                                                                          Topography (10 ft)

                                                                                                                                                                     •=  Paved Roadways
          Redox
. \       -Storage
,  \ .  I /  Area
.'  \ ..• '•*..*,,(te
  •»           . "«*j
                                                                                                                                                                     Note: Telephone
                                                                                                                                                                     generally runs w/
                                                                                                                                                                     easement along main
                                                                                                                                                                     roadways.
"*•£«.•'.. -:  •••••:  i'*11 w*v .••;.•• .-• '••:•  (  .--  -,O
  o^ci^y^..^.   .'--Xx'  "    ; -••-.'••-'     H.-/;/...
                                                                                                                                                            Figure 2.  Location of the Bnvironmental
                                                                                                                                                            Restoration Disposal Facility.

-------
 Site selection is based on the Siting Evaluation Report for the Environmental Restoration Disposal
 Facility, which evaluated three candidate sites located on the Central Plateau. The siting process first
 applied criteria based on siting requirements from applicable federal and state regulations and DOE
 Orders, and recommendations for future Hanford Site use from the Hanford Future Site Uses
 Working Group.  The three sites were further evaluated to determine if they met the State siting
 criteria as specified by the Washington State Dangerous Waste Regulations.  The final screening
 applied criteria derived from DOE orders and from CERCLA.  Each site included at least 10 km2
 (4 mi2) of contiguous land and at least 5 km2 (2 mi2) of nearby contingency space.

 The land requirement was based on early design assumptions for the ERDF. During the scoping
 period for the ERDF, the public expressed an interest in reducing the size of the facility  in order to
 minimize the impacts to shrub-steppe habitat.  By improving the trench design and. eliminating the
 contingency space, the ERDF would occupy only 4.1 km2 (1.6 mi2).  A review of potential sites
 within the 200 Areas was performed.  This review indicated that there is no other location that meets
 the current size requirement within the* waste management area as recommended by the Hanford
 Future Site Uses Working Group.

 During the public scoping process, an additional site, the BC control area, was identified as  a
 potential site for the ERDF.  This area has surface radioactive contamination that would require
 cleanup before constructing the ERDF. The site has no particular advantage and, in fact, a 2- to
 5-year delay in operation of the ERDF  could be anticipated, with a similar delay in cleanup along the
 Columbia River, if this site had been chosen.

 Although the chosen ERDF  site includes the largest amount  of shrub-steppe habitat, this site is the
 final selected location based on the following:  .             .

   •   Inclusion in the waste management area (as delineated by the Hanford Future Site Uses
       Working Group)

   •   Greatest depth to groundwater

   •   Greatest distance to the Columbia River

   •   Relatively flat topography (reducing complexity of design and construction)

   •   Lowest development cost.
                      . SITE fflSTORY AND ENFORCEMENT ACTIONS
The Hanford Site was established during World War n as part of the Army's "Manhattan Project" to
produce plutonium for nuclear weapons. Hanford Site operations began in 1943, and DOE facilities
are located throughout the Site and the City of Richland.  The land that Hanford now occupies was
ceded to the U.S. Government in treaties with the Confederated Bands and Tribes of the Yakama
Indian Nation and the Confederated Tribes of the Umatilla Indian Reservation in  1855. Certain
portions of the Hanford Site are known to have cultural significance and may be eligible for listing in
the National Register of Historic Places.

-------
In 1988, the Hanford Site was scored using EPA's Hazard Ranking System.  As a result of the
scoring, the Hanford Site was added to the NPL in July 1989 as four sites (the 1100 Area, the
200 Area, the 300 Area, and the 100 Area).  Each of these areas was further divided into operable
units (a grouping of individual waste units based primarily on geographic area and common waste
sources).  These operable units contain contamination in the form of hazardous waste,
radioactive/hazardous mixed waste, and other CERCLA hazardous substances.

In anticipation of the NPL listing, DOE, EPA, and Ecology entered into a Hanford Federal Facility
Agreement and Consent Order in May 1989.  This agreement established a procedural framework and
schedule for developing, implementing,  and monitoring remedial response actions at Hanford.  The
agreement also addresses RCRA compliance and permitting.
                   HI. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Tri-Parties developed a Community Relations Plan (CRP) in April 1990 as part of the overall
Hanford Site restoration.  The CRP was designed to promote public awareness of the investigations
and public involvement in the decision-making process. The CRP summarizes concerns that the
Tri-Parties are aware of based on community interviews.  Since that time, the Tri-Parties have held
several public meetings and sent out numerous fact sheets in an effort to keep the public informed
about Hanford cleanup issues. The CRP was updated in 1993 to enhance public involvement.  An
additional CRP for the ERDF was developed to clarify the regulatory streamlining process and its
effects on public involvement.

A public scoping period was held January 10 through February 8, 1994, to solicit input on the
proposal to construct a facility on the Central Plateau to receive cleanup wastes.  Scoping meetings
were held in Richland on January 25,  1994 and Seattle on February 1, 1994.  The Focus Sheet and
Expanded Public Notice/Washington State Notice of Intent for Corrective Action  Management Unit -
Hanford Environmental Restoration Disposal Facility were provided at the beginning of the scoping
period to provide preliminary information to the public. These documents were available hi both the
Administrative Record and the Information Repositories maintained at the locations listed below.

Presentations were made to the Hanford Advisory Board on June 2 and July 7, 1994, and the Hanford
Advisory Board members provided input on the siting and concept of the facility.

An information focus sheet, which provided a summary of the Proposed Plan and a notification of the
comment period, was mailed to the Hanford Tri-Party Agreement mailing list of 1,500 people.
Additionally, the Proposed Plan was mailed to interested individuals, Hanford Advisory Board
members, the Tribes, and the Hanford Natural Resource Trustees.  The final RI/FS Report and
Proposed Plan were made available to the public hi both the Administrative Record and the
information Repositories maintained at the locations listed below on October 17,  1994:

-------
       ADMINISTRATIVE RECORD (Contains all project documents)

           U.S. Department of Energy
           Richland Operations Office
           Administrative Record Center
           2440 Stevens Center
           Richland, Washington 99352

           EPA Region 10
           Superfund Record Center
           1200 Sixth Avenue
           Park Place Building, 7th Floor
           Seattle, Washington 98101

           Washington State Department of Ecology
           Administrative Record
           719 Sleater-Kinney Road SE
           Capital Financial Building, Suite 200
           Lacey, Washington 98503-1138

       INFORMATION REPOSITORIES (Contain limited documentation)

           University of Washington
           Suzzallo Library
           Government Publications Room
           Mail Stop FM-25
           Seattle, Washington 98195

           Go'nzaga University
           Foley Center
           E. 502 Boone
           Spokane, Washington  99258

           Portland State University
           Branford Price Millar Library
           Science and Engineering Floor
           SW Harrison and Park
           P.O.  Box 1151
           Portland, Oregon  97207

          .DOE Richland Public Reading Room
         .  Washington State University, Tri-Cities
           100 Sprout Road, Room 130
           Richland,  Washington 99352
The notice of the availability of the RI/FS and Proposed Plan was published in the Hood River News,
the Seattle Times P/I, the Spokesman Review-Chronicle, the Tri-CUy Herald, and the Oregonian on
October 16, 1994. The public comment period was held from October 17 through November 30,
1994. In addition, public meetings were held on November 14 hi Hood River, Oregon; on

-------
 November 15 in Seattle, Washington; on November 16 in Richland, Washington; and on
 November 30 in Portland, Oregon. Additional advertisements for the public meetings ran in the
 Seattle Times P/I, the Spokesman Review-Chronicle, the Tri-City Herald, and the Hood River News on
 November 13, and in the Oregonian on November 26. At the meetings, representatives from EPA,
 DOE, and Ecology answered questions about the project.

 All verbal comments provided at the public meeting and all submitted written comments are recorded
 verbatim in the Administrative Record for the ROD.  Responses to the public comments received
 during the public comment period are included in the Responsiveness Summary (Appendix A) and
 were considered during the development of this ROD. Public comments on the Proposed Plan are
 annotated to indicate which response in the Responsiveness Summary addresses each comment.

 This decision document presents the selected remedial alternative for the ERDF at the Hanford Site,
 Richland, Washington, chosen in accordance with CERCLA, as amended by SARA, and to the extent
 practicable, the NCP. The decision for this facility is based on information contained in the
 Administrative Record.
        IV.  SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
Since the signing of the Tri-Party Agreement in 1989, the Tri-Parties have recognized the need to
modify the approach to conducting investigations and studies at Hanford with a goal of maximizing
efficiency, optimizing use of limited resources, and achieving cleanup in the earliest possible time
frame. To implement this approach, the Tri-Parties jointly developed the Hanford Site Past-Practice
Strategy. The strategy document describes the concepts and framework for streamlining the
investigation and remedial study process in a manner that promotes a "bias-for-action" through
optimizing the use of interim remedial actions. The remedy selection process for remediation of
operable units located along the Columbia River is scheduled to commence in January 1995. Based
on significant public input to date, it is anticipated that the remedies selected for these operable units
may include removal of waste from proximity to the Columbia River and isolation of the waste in a
central location.

The ERDF is expected to serve as a disposal unit for Hanford remedial waste (primarily soil) for
which removal and disposal is the selected remedy.   It is anticipated that the ERDF will receive
low-level radioactive, hazardous, and mixed waste and small amounts of asbestos and PCB wastes
from the 100, 200, and 300 Areas.  The total volume of waste is expected to be less than 21.4 million
m3 (28 million yd3) and is expected  to consist of the following:  contaminated soil; demolition debris
(approximately 65% to 75%);  burial ground waste (approximately 15% to 20%); and wastewater
pipelines, ancillary equipment, and associated soil contamination (approximately 10% to 15%).  The
scope of the ERDF ROD is focused on the configuration and location of the landfill (also referred to
as the trench), the liner,  and the surface cover and the operation and closure requirements.

Information on the supporting  facilities, including the transportation system, waste handling
equipment and procedures, decontamination, and leachate treatment systems, is also presented. These
supporting facilities are not the primary focus of this ROD because they do not significantly affect
long-term performance of the facility and are considered design details. They will be fully addressed
during remedial design.

-------
 This remedy will result in hazardous substances remaining onsite above health-based levels; therefore,
 a review will be conducted within 5 years after commencement of this action to ensure that the
 remedy continues to provide adequate protection of human health and the environment.
                                V. SITE CHARACTERISTICS
A. SITE GEOLOGY AND HYDROLOGY

The Hanford Site is located in the Pasco Basin, a topographic and structural basin situated in the
northern portion of the Columbia Plateau.  The plateau is divided into three general structural
subprovinces: the Blue Mountains, the Palouse, and the Yakima Fold Belt.  The Hanford Site is
located near the junction of the Yakima Fold Belt and the Palouse subprovinces.  •
1.  Geology

The topography and principal geomorphic features of the ERDF site are shown in Figure 3.  The
ERDF site is on the south slope of the Cold Creek bar, and the Hanford formation is the principal
geologic unit at the surface.  Other surficial materials include stabilized dunes and active sand dunes.
The site is underlain by 159 to 177 m (521 to 580 ft) of suprabasalt sediments that rest on top of the
Elephant Mountain Member of the Columbia River Basalt Group.  The Elephant Mountain Member is
overlain by gravel unit A, the lower mud sequence, gravel unit E, and the upper unit of the Ringold
Formation.  Overlying the Ringold Formation in this area is the Plio-Pleistocene unit, early "Palouse"
soil, and Hanford formation.  The ERDF location is in a transitional zone between stratigraphic
characteristics of the 200  West and 200 East Areas.  Units present in the western part of the site may
not be present'in the eastern part because of erosion. The  nearest Quaternary faults to the site are
located at Gable Mountain approximately 7.1 km  (4.4 mi) north of the ERDF site.

The vadose zone beneath  the ERDF ranges between 67.7 and 10.5.5 m (222 and 346 ft) thick and
consists of the Hanford formation, the Plio-Pleistocene unit, and the upper unit and unit E of the
Ringold Formation. Flow characteristics through the vadose zone depend on the properties of particle
size and pore size, interconnectiyeness of pores, and moisture content, which are all favorable at this
site.
2. Groundwater

The suprabasalt aquifers beneath the ERDF site consist of the fluvial sands and gravels of the Ringold
Formation and the lower Plio-Pleistocene formation.  The silts of the Plio-Pleistocene unit, the upper
Ringold unit, and the Ringold lower mud unit may act as aquitards or confining units within the
aquifer. The uppermost aquifer beneath the ERDF site is contained primarily within unit E of the
Ringold Formation.  The lower mud unit of the Ringold Formation is known to occur beneath this
aquifer in the western side of the site, but the lateral extent is not known beneath the eastern side of
the ERDF. Where the lower mud unit is present, confined aquifer conditions exist hi unit A of the
Ringold Formation.  Units A and E of the Ringold Formation would be combined in a single
unconfined aquifer hi areas where the lower mud unit is not present. The thickness of the uppermost
aquifer beneath the ERDF  generally appears to range from 20 to 70 m (65 to 230 ft).

-------
                              Figure 3. Topography of the Hanford Site.
                         i KW and KE Areas
                      100 Band C Areas
                 Hanford
                 Site
                 Boundary
Note: Contours -in feet above mean sea level
    1m =3.28 ft

Source: Detaney etal.1991
15 KILOMETERS


 10 MILES

923 E412/48587/8-25-94
                                                  10

-------
 Groundwater levels in the area have risen significantly since the 1950's as a result of wastewater
 disposal activities conducted in the 200 West Area.  The groundwater levels stabilized in the late
 1960's and started to decline in the mid-1980's.  The groundwater level decrease is probably due to
 reductions in wastewater disposal occurring in the 200 West Area.  Contaminated groundwater from
 these disposal activities  exist beneath the ERDF site. The water table elevation generally ranges from
 123 m (405 ft) along the east side of the selected site to 139 m (455 ft) along the west side of the site.

 Groundwater flow beneath the ERDF site is predominately from west to east.  Saturated hydraulic
 gradients based on groundwater elevations range from 0.0045 along the northern boundary of the site
 to 0.0025 along the southern boundary.  Limited data are available for aquifer properties of
 transmissivity and hydraulic conductivity in the aquifer beneath the ERDF site. However, two wells
 near the site completed to unit E of the Ringold Formation were tested in 1958 and 1973.
 Transmissivity values of 2,700 m2/day (29,000 ft2/day) and  1,950 m2/day (21,000 fWday) have been
 measured in nearby wells.  Assuming a  saturated thickness of 40 m (130 ft), the hydraulic
 conductivities equal 70 m/day (220 ft/day) and 50 m/day (160 ft/day),  respectively.
3.  Waste Characteristics

100 Area Waste-Generating Activities.  Between 1943 and 1962, nine water-cooled, graphite-
moderated plutonium production reactors were built along the shore of the Columbia River upstream
from the now-abandoned town of Hanford.  Eight of these reactors (B, C, D, DR, F, H, KE, and
KW) have been retired from service and will be decommissioned.  The ninth reactor, N, was recently
shut down and will also be retired.  In some, of the reactor areas, after the reactor was retired from
plutonium production service, the ancillary facilities were used as laboratories for special studies or
for storage/treatment purposes.

The principal components of the original  eight reactors consisted of the reactor, the reactor cooling
water loop, the reactor gas and ventilation system, and the irradiated fuel handling system.  During
the course of reactor production work, liquid waste disposal sites, solid waste burial grounds,
contaminated facilities, and unplanned liquid waste release areas were established.

200 Area Waste-Generating Activities.  Historically, the 200 Areas were used for fuel reprocessing,
plutonium recovery,  and waste management and disposal. Because of significant human health and
environmental risks associated with the excavation of the majority of contaminated sites in the
200 Areas, in situ remediation methods may be used for most sites.

300 Area Waste-Generating Activities.  Activities  in the 300 Area have historically been related
primarily to the fabrication of nuclear fuel elements. In  addition, many technical support,  service
support, and research and development activities related to fuel fabrication were carried out.   As fuel
fabrication activities have decreased with  the shutdown of the Hanford  Site production reactors,
research and development activities in the 300 Area  have increased.  The newer buildings in the area
primarily house laboratory and large test facilities.

Physical Components of 100 Area Waste. The total  volume of 100 Area waste potentially to be
disposed of hi the ERDF is estimated to be approximately 7 million m3 (9 million yd3).  100  Area
waste includes soil, solid wastes, sediments, and sludges. Solid waste encompasses hard waste, soft
waste, demolition waste, and pipes.  Soft waste includes collapsed cardboard boxes, paper, rags,
clothing, plastic, and miscellaneous trash. Hard waste includes aluminum tubes and spacers, failed
steel and stainless steel equipment, timbers, and metal  drums. Demolition waste includes concrete


                                              11

-------
with and without rebar, steel plate, and timbers.  Pipes range from 1.3 to 61 cm (1/2 to 24 in.) in
diameter. The estimated percentages of the different types of waste are presented below.
                         Estimated Distribution of Waste in the 100 Area
Source
Contaminated soil
Solid waste
Volume
77%
23%
Physical Components of 200 Area Waste.  The total volume of 200 Area waste potentially to be
disposed of in the ERDF is estimated to be approximately 5.5 million m3 (7.2 million yd3). A
breakdown of the components of 200 Area waste that will likely be disposed in the ERDF is
presented below.  The percentages are based on relative volume estimates.  No information is
available on physical characterization of 200 Area soils likely to be disposed hi the ERDF.
                         Estimated Distribution of Waste in the 200 Area
Source
Contaminated soil
Solid waste
Volume
75%
25%
Physical Components of 300 Area Waste. The total volume of 300 Area waste potentially to be
disposed of in the ERDF has been estimated to be approximately 1.0 million m3 (1.3 million yd3)-
300 Area waste includes soil and solid wastes.  Sites have been grouped into two categories based on
similarities of cleanup requirements: (1) contaminated soil and (2) solid waste (e.g., pipelines, burial
ground waste).

The components of 300 Area waste are summarized below.
                             Estimated Distribution of Waste in the
                                          300 Area
Source
Contaminated soil
Solid waste
, Volume
47%
53%
                                             12

-------
Chemical Characteristics.  Tables 1 through 3 present the highest soil concentrations found to date
during remedial investigations conducted in 100, 200, and 300 Area waste units for radionuclides,
organic compounds, and inorganic constituents, respectively.  The sampling program (limited field
investigation) was conducted to target anticipated areas of maximum soil contamination
concentrations.  The detected concentrations are likely to bound the majority of the waste and provide
a valid basis for planning remediation development and operating activities.  These concentrations,
when assumed to apply to the total volume of remediation waste, also provide conservative total
inventories for evaluation of ERDF operation and performance.  It is anticipated that wastes of higher
concentration may be encountered during remediation activities and disposed of at ERDF; these will
be evaluated on a case-by-case basis to determine if operating procedures need to be adjusted to
accommodate them. The tables also list the waste units in which the highest concentrations occurred.
Soil concentrations found to date for organic compounds and inorganic constituents for 200 Area
wastes are not included hi the tables because 200 Area wastes have not been  sufficiently
characterized.

If the waste concentration exceeded the Hanford soil background concentration, the concentration was
considered to be representative of actual contamination and the constituent was retained for further
evaluation in the risk assessment. Maximum concentrations detected thus far for chloride, nitrate,
and phosphate were less than background concentrations. Therefore, chloride, nitrate, and phosphate
were eliminated from further evaluation in the RI/FS. The nitrite plus nitrate concentration was
compared to the background 95/95 upper tolerance level for nitrate, and this parameter was also
eliminated.  All other constituents were retained for further evaluation.
B.  CULTURAL RESOURCES

The Hanford Cultural Resources Laboratory (HCRL) conducted a cultural resources survey at and
surrounding the ERDF site during the summer of 1993.  Several historic and prehistoric isolated
artifacts were identified on the ERDF site, but these artifacts do not meet the criteria for listing on the
National Register of Historic Places.  The isolated finds were either collected during the survey or
recorded in survey notes.  No significant resources were identified at the ERDF site.

A cultural resources survey was also conducted along the proposed route for the railroad line
connecting with the ERDF.  This survey indicated that the railroad line would cross the White Bluffs
Road, a historic feature that is eligible for nomination to the National Register of Historic Places. An
alternative route was considered that passed through the 200 West Area and crossed the White Bluffs
Road in an area that had already been disturbed.  This alternative route was dropped from
consideration because of safety  concerns associated with increased rail traffic hi the 200 West Area
and three street crossings within the 200 West Area. The rail system was subsequently dropped from
consideration because initial waste projections indicate that trucks could handle the load for start-up.
As remediation accelerates hi the future, should the rail  line be determined necessary, the route would
be re-evaluated to try to avoid disturbing the intact portions of the White Bluffs Road.
                                               13

-------
Table 1.  Maximum Concentrations Detected for Radionuclides in
         100, 200, and 300 Area Wastes,  (sheet  1 of 2)
Radionuclide
Americium-241
Barium-140
Beryllium-7
Carbon-14
Cerium-141
Cerium-144
Cesium-134
Cesium-137
Chromium-51
Cobalt-58
Cobalt-60
Europium- 152
Europium- 154
Europium- 155
Gross alpha
Gross beta
Iron-59
Manganese-54
Nickel-63
Plutonium-238
Plutonium-239/240
Potassium-40
Radium-226
Ruthenium-103
Ruthenium-106
Sodium-22
Strontium-90
Technetium-99
Thorium-228
Thorium-232
Thorium-234
Tritium
Maximum
Concentration
(pCi/g)
34
400
90
640
3
.0.5 .
56
110,000
3.5
14
11,000
29,000
9,200
9,600
4,450
12,210
1
0.07
62,000
140
2,800
33
42.8
1
0.8
9.9
. 2,000
1.1
17
3.5
1
29,000
Waste Unit
116-C-5 Retention Basin
116-D-1A Storage Basin Trench No. 1
116-D-1A Storage Basin Trench No. 1
116-C-5 Retention Basin
116-D-1A Storage Basin Trench No. 1
116-D-1A Storage Basin Trench No. 1
116-B-ll
Process effluent pipeline (BC1)
618-5 Burial Ground No. 5
1 16-DR-l Liquid Waste Disposal Trench No. 1
(HR1) Process effluent pipeline (sludge)
116-B-ll
116-D-7
Process effluent pipeline (BC1)
316-5 3904 Process Waste Trenches
316-5 3904 Process Waste Trenches
116-D-1A Storage Basin Trench No. 1
HfrD-lA Storage Basin Trench No. 1
Process effluent pipeline (BC1)
Process effluent pipeline (BC1)
Process effluent pipeline (BC1)
116-H-7 Retention Basin
116-D-1A Storage Basin Trench No. 1
116-D-1A Storage Basin Trench No. 1
116-D-1A Storage Basin Trench No. 1
1 16-DR-l Liquid Waste Disposal Trench No. 1
Process effluent pipeline (BC1)
116-DR-2 Liquid Waste Disposal Trench No. 2
316-5 3904 Process Waste Trenches
316-2 Norm (new) Pond
116-D-1A Storage Basin Trench No. 1
116-B-5
                            14

-------
Table 1.  Maximum Concentrations Detected for Radionuclides in
         100, 200, and 300 Area Wastes,  (sheet 2 of 2)
Radionuclide
Uranium-233/234
Uranium-235
Uranium-238
Zinc-65
Zirconium-95
Uranium (Total)
Maximum
Concentration
(pCi/g)
2,100
640
9,100
0.3
0.56
20,000
Waste Unit
618-4 Burial Ground No. 4
316-5 3904 Process Waste Trenches
316-5 3904 Process Waste Trenches
116-D-1A Storage Basin Trench No. 1
1 16-H-7 Retention Basin
316-5 3904 Process Waste Trenches
                            15

-------
Table 2.  Maximum Concentrations Detected for Organic Compounds in
              100 and 300 Area Wastes,  (sheet 1 of 2)
Compound
Maximum.
Concentration _
Xpg/kg)
Waste Unit
VOLATILE ORGANIC COMPOUNDS
1,2-Dichloroethene (Total)
1,1, 1-Trichloroethane
1 , 1 ,2,2-Tetrachloroethane
2-Butanone
2-Hexanone
4-Methyl-2-Pentanone
Acetone
Benzene
Carbon Bisulfide
Carbon Tetrachloride
Chloroform
Ethylbenzene
. Methylene Chloride
Tetrachloroethene
Toluene
Trichloroethene .
Vinyl Chloride
Xylenes (Total)
1,000
6
3
390
9
11
2,800
190
200
8
80
330
4,500
1,100
150
390
24
1,100
316-5W 3904 Process Waste Trenches
100-D-Pond
100-D-Pond
100-D-Pond
100-D-Pond
116-B-2 Storage Basin Trench
UN-100-N-17 Diesel Oil Supply Line Leak
UN-100-N-17 Diesel Oil Supply Line Leak
116-B-5 Crib
116-N-l
3 16-5W 3904 Process Waste Trenches
UN-100-N-17 Diesel Oil Supply Line Leak
316-2 North (new) Pond
316-5W 3904 Process Waste Trenches
316-2 North (new) Pond
618-4 Burial Ground No. 4
316-5W 3904 Process Waste Trenches
130-D-l Gasoline Storage Tank
SEMIVOLATILE ORGANIC COMPOUNDS ,
4-Chloroaniline
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
2-Methylnaphthalene
4-Chloro-3-Methylphenol
4-Methylphenol
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
6,300
48
51
13,000
38
1,000
850
6,300
1,800
27,000
2,400
3,700
C-Sanitafy Trench (300 Area)
116-DR-l Liquid Waste Disposal Trench No. 1
116-N-2 Chemical Waste Storage Tank
UN-100-N-17
116-DR-l Liquid Waste Disposal Trench No. 1
C-Sanitary Trench (300 Area)
316-5W Process Waste Trenches
UN-100-N-17 .
1607-H-4 Septic Tank Discharge Pipe
316-5E 3904 Process Waste Trenches
1607-H-4 Septic tank Discharge Pipe
3 16-5E 3904 Process Waste Trenches
                              16

-------
Table 2.  Maximum Concentrations Detected for Organic Compounds in
              100 and 300 Area Wastes,  (sheet 2 of 2)
Compound
Maximum.
Concentration
0*§/fcg)
Waste Unit
SEMTVOLATILE ORGANIC COMPOUNDS (cont.)
Benzo(k)fluoranthene
Benzole Acid
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Carbazole
Chrysene
Di-n-butylphthalate
Dibenz(a,h)anthracene
Dibenzofuran
Diethylphthalate
Fluoranthene
Fluorene
Indeno(l ,2,3-cd)pyrene
Naphthalene
N-Nitrosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
760
1,300
33,000
2,600
54
43,000
5,500
1,700
500
1,000
2,900
1,700
1,600
4,100
1,800
1,500
3,900
240
12,000
116-H-l Liquid Waste Disposal Trench
316-5E 3904 Process Waste Trenches
C-Sanitary Trench (300 Area)
130-D-l Gasoline Storage Tank
1 16-D-1B Fuel Storage Basin, Trench No. 2
316-5E 3904 Process Waste Trenches
3 16-5E 3904 Process Waste Trenches
316-5E 3904 Process Waste Trenches
316-5W 3904 Process Waste Trenches
100-D-Pond
1607-H4 Septic Tank Discharge Pipe
UN-100-N-17
316-5E 3904 Process Waste Trenches
UN-100-N-17
316-5E 3904 Process Waste Trenches
316-5E 3904 Process Waste Trenches
316-5W 3904 Process Waste Trenches
100-D-Pond
316-5E 3904 Process Waste Trenches
PESTtCIDES/AROCLORS , - .-
4,4'-DDD
4,4'-DDE
Aroclor-1248
Aroclor-1254
Aroclor-1260
Beta-HCH (Beta-BHC)
Chlordane, Gamma-
Dieldrin
Methoxychlor
PCBs. ......
110
170
10,000
6,400
2,300
7.8
18
21
83
19,500
1607-H4 Septic Tank Discharge Pipe
100-D-Pond
316-2 North Process Pond
190-B
100-D Pond
116-D-1A Fuel Storage Basin, Trench No. 1
1607-H4 Septic Tank Discharge.Pipe
116-D-1A Fuel Storage Basin, Trench No. 1
100-D-Pond
Process Trenches (300 Area)
                              17

-------
Table 3.  Maximum Concentrations Detected and Background Screening for Inorganic and
      General Chemistry Constituents in 100 and 300 Area Wastes,  (sheet 1 of 2)
Constituent
Maximum
Concentration
— (mg/kg)
Waste Unit
Back-
ground
(95/95
" UTL)" "
(mg/kg)
INORGANIC CONSTITUENTS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Vanadium
Zinc
78,400
18.6
62.2
4,260
4.7
28.5
95,300
2,510
90
95,300
184,000
747
50,000
3,050
37
1,750
. , 13,000
11
362
2,610
31
5.4
389
6,160
100-B Pond
H-2 Septic Tank
100-D Pond
H-2 Septic Tank
116-H-9 Crib
H-2 Septic Tank
316-1 South (old) Pond
H-2 Septic Tank
116-KW-3B Retention Basin
316-1 South (old) Pond
116-H-9 Crib
618-4 Burial Ground No. 4
116-H-9 Crib
116-H-9 Crib
H-2 Septic Tank
316-1 South (old) Pond
116-H-9 Crib
100-B Pond
316-1 South (old) Pond
618-4 Burial Ground No. 4
Process Trenches (previous sampling)
H-2 Septic Tank
116-H-9 Crib
H-2 Septic Tank
'••'<• ""- ' - , GENSfcAli CHEMISTRY ' ',',-,
Ammonia '
Chloride
Fluoride
Nitrata .",;:/
138
194
40
125
Drums
316-5 3904 Process Waste Trenches
316-2 North (new) Pond
316-2 North (new) Pond
15,600
NC
8.92
171
1.77
NC
23,920
27.9
19.6
28.2
39,160
14.75
8,760
612
1.25
25.3
3,120
NC
2.7
1,290
NC
NC
111
79
••
28.2
763
12
199
                                       18

-------
     Table 3.  Maximum Concentrations Detected and Background Screening for Inorganic and
           General Chemistry Constituents in 100 and 300 Area Wastes, (sheet 2 of 2)
Constituent
Maximum
Concentration
(mg/kg)
Waste Unit
Back-
ground
(95/95
UTL)"
(mg/kg)
GENERAL CHEMISTRY . (cent.) .
Nitrite
Phosphate
Sulfate
Organic Halogen (Total)
Organic Carbon (Total)
Coliform (MPH)
Nitrate/nitrite
2.9
15
7,115
7.2
43.7
110
37
300 Area Sanitary Sewer System
1 16-KW-3B Retention Basin
H-2 Septic Tank
Process Trenches (previous sampling)
Process Trenches (previous sampling)
Process Trenches (previous sampling)
116-C-5 Retention Basin
NC
16
1,320
NC
. NC
NC '.
199b
    "95/95 UTL is the 95% upper confidence limit on the 95th percentile. Source:  Hanford Site
Background Part 1, "Soil Background for Nonradioactive Analytes."
    The background concentration for nitrate is used.

NC    =  not calculated
UTL   =  upper tolerance level
                                            19

-------
 C. ECOLOGICAL RESOURCES

 Ecological surveys of the ERDF site have found it to be largely undisturbed shrub-steppe habitat that
 has not sustained significant fire damage. The western part of the site is previously disturbed by past
 Hanford  operations and encompasses an old laydown yard, a gravel pit, several drill pads, dirt roads,
 and several large tanks. Site surveys identified long-billed curlews, sage sparrows, and loggerhead
 shrikes as nesting in the area.  Grasshopper sparrows were present and possibly nesting at the site.
 Swainson's hawks were observed hunting in the area. Burrowing owls, while not observed during the
 surveys,  have been seen at the site in the past and are presumed to currently inhabit the area.

 Mature shrub-steppe provides important habitat for several plant and animal species of concern that
 depend on the shrub component, usually sagebrush, for  nesting, food, and protection.  Certain birds
 rely on sagebrush or bitterbrush for nesting (i.e., sage sparrow, sage thrasher,  and loggerhead
 shrike).  Loggerhead shrikes are year-round residents that are present at low densities.  Sage sparrows
 are common summer residents of the Hanford Site that are restricted almost entirely to sagebrush
 stands.  Mature shrub-steppe habitat also provides prime foraging habitat for a  variety of raptor
 species (e.g., the Swainson's hawk). Shrub-steppe habitat available for species of concern on the
 Hanford  Site may become a more critical issue as agricultural, industrial, and urban development
 decreases the amount of this habitat type hi eastern Washington.

 The remaining undisturbed shrub-steppe habitat at the Hanford Site is  considered priority habitat by
 the State of Washington because of its relative scarcity and its importance as nesting,  breeding, and
 foraging  habitat for sensitive species.  No plants or mammals on the federal list of Endangered and
 Threatened Wildlife and Plants are known to reside or occur on the ERDF site, although several
 candidate species are known to occur. DOE (hi cooperation with  the State of Washington Department
 of Fish and Wildlife and the U.S. Fish and Wildlife Service) is currently developing a biological
 resources management plan to address potential ecological impacts from activities throughout the
 Hanford  Site.
                          VI. SUMMARY OF RISK ASSESSMENTS
A. OPERABLE UNIT RISK                          .

Actual or threatened releases of hazardous substances from some operable units on the Hanford Site,
if not addressed by implementing the response action selected in this ROD, may present an imminent
and substantial endangerment to the public health, welfare, or the environment.

Currently, contaminated areas along the Columbia River (100 and 300 Areas) at the Hanford Site are
not suitable for use by the general public. If this land were released for public use before cleanup,
the risks would be considered unacceptable. In the initial stage of assessing risk by performing
qualitative risk assessments (QRAs) attempts to estimate the potential future human health and
environmental risks that could result if contaminants are not remediated and left in place.
                                              20

-------
A detailed description of the findings, assumptions, and methods used can be found in the QRA for
each operable unit.  Currently, there are no residential or recreational users in these areas. Thus,
risks estimated in the QRA are not actual risks but, instead, provide estimates of potential future risks
if the area were to become utilized.

In preparing the QRA, conservative assumptions were used that weight in favor of protecting human
health and the environment (e.g., greater known soil contaminant concentrations found at depth were
used as overall soil concentrations).  The results of the risk assessment help determine if remedial
actions are necessary to protect human health and the environment.  The goal of the QRA is to
identify high-priority waste sites for expedited response actions and interim remedial measure by
estimating a range of risk (very low to high) for the contaminated soils and solid wastes.

The human health risk evaluation used two hypothetical exposure scenarios, frequent and occasional
use, to provide estimates of potential future risk that correspond with residential and recreational
exposure scenarios defined in the Hanford Site Risk Assessment Methodology.  The frequent-use
scenario assumes a person is exposed to contaminated media every day for each year.  The
occasional-use scenario assumes a person is exposed' to contaminated soil for 7 days each year.  The
selection of land use (i.e., residential  or recreational)  is based on probable uses considered for the
Hanford Site following environmental restoration.  The most probable exposures at the Hanford Site
are addressed by the occasional-use exposure scenario. The regulators use the occasional-use scenario
at the Hanford Site to make decisions concerning the need for interim remedial measures.  Therefore,
the results of the occasional-use exposure scenario are discussed in this ROD.

Potential pathways are evaluated as likely routes of human exposure to contaminants.  These include
soil  ingestion, inhalation of fugitive dust, inhalation of volatile organic compounds, and external
radionuclide exposure from soils, etc.  In these evaluations, the human health evaluation considers
carcinogenic and noncarcinogenic contaminants. Some of the completed evaluations have concluded
that human health risks are unacceptable  for the occasional-use exposure scenario.

An ecological evaluation estimates risk from existing contaminants at the operable unit using selected
ecological receptors.  An environmental hazard quotient (EHQ) is calculated that estimates risk in a
manner similar to the hazard quotient (HQ) used to assess human health risk, except that the EHQ is
applied to an ecological receptor exposed to. contaminants.  Some of the completed evaluations have
concluded that ecological risks are unacceptable.

Actual or threatened releases of hazardous substances from some operable units on the Hanford Site if
not addressed by implementing the remedial actions selected present a current or potential threat to
human health, welfare, or the environment.
B.  ERDFRISK

Long-term effectiveness was measured in terms of future risk to human health and the environment
and qualitative assessments of reliability. Future risks are associated with soil exposure resulting
from intrusion into the facility or exposure to groundwater impacted by migration of contaminants out
of the facility.  The risks assessment shows that the benefits of protective measures such as passive
controls and a barrier mat reduces infiltration are accounted for in the analysis.  However, it was still
assumed that all the waste in the ERDF was characterized by the maximum concentration detected in
100, 200, and 300 Area waste units and thus the results are-conservatively biased.
                                               21

-------
 All of the alternatives (except the no-action alternative) include active institutional controls (e.g.,
 fences, signs, patrols), passive institutional controls (e.g., markers and offsite records), and a surface
 barrier that is at least 4.6 m (15 ft) thick.  It is assumed that institutional controls prevent intrusion
 into the waste for at least 100 years and that passive controls prevent intrusion for 500 years.
 Furthermore, it is assumed that because the waste is covered with at least 4;6 m (15 ft) of cover
 materials, intrusion into the waste due to excavation is precluded.  Since none of the evaluated
 modified  barriers can prevent penetration by a drilling rig, however, it is reasonable to assume that
 someone  might inadvertently drill through  die waste sometime after 500 years. Therefore, soil
 exposures for both human and ecological health are calculated assuming the 500-year drilling
 scenario.

 The human health risks associated with soil exposure resulting from the 500-year drilling scenario
 include a  total incremental cancer risk (ICR)  of 4 x 10~5 (dominated by uranium) and a maximum HQ
 of 0.03 (associated with copper). These risks are the same for all the alternatives (except no action).
 The predicted HQ and ICR associated with the 500-year, drilling scenario meet the goals established  in
 the Tri-Party Agreement of 1 for HQ and 1 x 10^ for ICR.

 Groundwater impacts were calculated assuming that an engineered barrier is constructed over the
 facility to minimize infiltration through the waste and maximize the travel time to groundwater.  In
 addition,  it was assumed that the waste met the maximum leachate concentration criteria (either with
 or without treatment) before it was placed in the facility.  For alternatives with liners, it was further
 assumed that all leachate was retained by the high-density polyethylene liner and removed by the
 leachate collection system for the first 30 years of operation. In addition, the added travel time
 associated with migration though the clay layer was accounted for in the analysis.

 For all the alternatives except the no-action alternative, none of the  contaminants are predicted to
 reach groundwater within 10,000 years under current climate conditions.  Risks after 10,000 years are
 considered highly uncertain given the potential for climatic changes, geologic events, and human
 activities, and were not evaluated. Groundwater concentrations and associated risks were also
 predicted  assuming that the rainfall rate increased from the current average for Hanford of 18 cm
 (7 hi.) to  40 cm (16 in.)  at 100 years. This scenario was  intended to represent either a wetter climate
 or irrigation on top of the ERDF. Although the results of these analyses are intended to demonstrate
 potential effects associated with climate or  land use changes, they should not be considered the most
 likely scenario.  Based on the fate and transport modeling results of the RI/FS, none of the
 alternatives will allow contaminants to reach groundwater within 10,000 years under current climate
 conditions.  Under the hypothetical wetter climate, all of the alternatives result hi a  total ICR of
 2 x 10~5 and a maximum  HQ of 0.8 within  10,000 years.  Because leachate collection is assumed to
 last only 30 years and the rainfall rate does not increase for  100 years, only minor differences in risks
 and travel tunes can be attributed to the liners.
1. Ecological Risk
                            /
The maximum ecological health risks associated with soil exposure resulting from the 500-year
drilling scenario include a total radiological dose of 0.6 rad/day (dominated by uranium) and an EHQ
of 12 for copper.  The remaining EHQs were less than 0.05. It should be noted that the background
concentration of copper in soil  (28.2 mg/kg) results in an EHQ of 3, which has not resulted in
adverse impact to the environment. It is evident that the environmental exposure analysis results in
an overestimate of risk to-environmental receptors and it is likely that the intrusion scenario will not  .
                                               22

-------
 result in adverse impacts to the environment from any potential contaminants disposed in the ERDF.
 These risks are the same for all the alternatives (except no action).

 Ecological risk is expressed in terms of an EHQ (analogous to the human health HQ) for
 nonradionuclides and radiological dose for radionuclides. The ecological risk assessment predicted
 EHQs greater than 1 for seven contaminants: benzo(a)pyrene, aluminum, barium, copper,
 manganese, mercury, and zinc.  The total radiological dose after 100 years was predicted to equal
 0.8 rad/day (primarily due to cesium-137  and uranium).  A dose of 1 rad/day is generally considered
 acceptable for ecological receptors.
2.  Short-Term Worker and Public Risk

Short-term risks associated with construction and operation of the ERDF are evaluated below for the
ERDF workers, non-ERDF workers on the Hanford Site, and the public.

ERDF Worker Risk.  The evaluation of ERDF worker risk during operation of the ERDF relies on
the methods and conclusions provided in the Source Inventory Development Engineering Study for the
Environmental Restoration Disposal Facility.  The report developed contaminant-specific soil
concentrations associated with occupational regulatory limits.  The exposure pathways evaluated are
inhalation of fugitive dust, inhalation of volatile organic compounds, and external exposure to
radiation. Therefore, the regulatory limits of interest are those related to occupational air exposure
and external radiation dose. Limits for ingestion, dermal absorption, and skin and/or eye contact
were not determined because they are not probable exposure pathways.  Personnel normally
occupying the ERDF trench will include heavy equipment operators and truck drivers.  Precautions
will be taken to ensure that ERDF employees avoid direct contact with hazardous constituents under
normal operating conditions.

This analysis indicates that there are a number of contaminants of potential concern to workers during
ERDF operation. These contaminants are alpha-emitting radionuclides (a concern via inhalation) and
high-energy gamma emitters (a concern via external exposure).

It is noted mat it is not acceptable to expose workers to contaminants at the occupational soil concen-
tration limits.  A number of contaminants are known or probable human carcinogens, and it is
generally assumed that there is no safe dose that will not elicit a carcinogenic response.  Although it
is likely that occupational  exposure criteria will  not be exceeded, the as low as reasonably achievable
(ALARA) principle will be practiced.

Physical Hazards to ERDF Workers. Construction and operation of the ERDF will expose workers
to physical hazards that can result in accidental injury to workers.  The risk associated with these
physical hazards can be quantified by multiplying the labor requirements by the injury rate to estimate
the expected number of accidents.  Injury rates can vary considerably for different activities, and a
detailed analysis of physical risk would account  for these variations.  For purposes of this document,
however, a more general approach mat treats all labor as general construction activity will be utilized.

Although operation of the ERDF is not truly a construction activity, many of the associated activities
are similar to construction.  The total number of employees for operation of the ERDF is estimated to
be a maximum of 167. Approximately 40 of these jobs are administrative or supervisory in nature
                                              23

-------
 and would entail relatively little physical risk. Assuming 230 work days in a year, the total number
 of worker days associated with operation of the ERDF is 29,000 days/year. Assuming the facility
 operates for 25 years, the total number of worker days is 725,000.

 Based on statistics from the U.S. Department of Labor, construction workers have a fatality rate of
 6 x 10"7 fatalities per person-day and a lost-time injury rate of 2 x 10"* injuries per person-day.
 Because fatalities are of most concern, only the fatality rate is used in the evaluations.  The estimated
 number of fatalities for each construction activity and ERDF operation are summarized below.
                  Estimated Number of Worker Fatalities Due to Physical Hazards
Activity
Trench excavation
Double liner
RCRA-compliant cover
ERDF operation
Worker Days
110,000
79,000
27,000
725,000
Estimated Fatalities
0.066
0.047
0.016
0.44
Risks to Non-ERDF Hanford Workers and the Public.  The facility hazard classification provides
qualitative evaluations of potential radiological impacts of ERDF operations and accident conditions to
non-ERDF Hanford Site workers and the public.  The scope of the hazard classification did not
include nonradioactive contaminants.  The impacts were evaluated for three scenarios:  normal
operations, abnormal occurrence of continuous strong winds (113 km/h [70 mi/h]j for 24 hours, and a
container breach. In all cases, risks were characterized as low.
                          VH.  REMEDIAL ACTION OBJECTIVES
The NCP states that remedial action objectives (RAOs) should reflect the media and contaminants of
concern, the exposure pathways, and the remediation goals (40 CFR 300.430(e)(2)(i)).

Remedial action objectives for the ERDF are unusual in that the scope in this instance is limited to the
siting and configuration of a waste disposal facility and does not address remediation of specific
contaminated sites.  Current risks and RAOs for the contaminated sites will be evaluated in the
operable unit RI/FSs.  The Tri-Parties recognize the concern associated with long-term management
of waste.  The decision to establish a central disposal facility stems from the concern that current
conditions, i.e., numerous uncontrolled waste sites along the Columbia River, are less desirable.  The
primary objective of the ERDF is to provide a centralized land disposal facility at the Hanford Site
for consolidation of remediation wastes found suitable for land disposal.  In order to support the  siting
design of a facility that provides safe disposal of remedial wastes, the following supporting RAOs
have been selected.

  (1)   Prevent unacceptable direct exposure to waste in accordance with applicable or relevant
       and appropriate  requirements (ARARs) and health-based criteria.  Direct exposure to the
       |ypes.df waste received at the_ERDF could result in unacceptable health risks. Direct
       exposure of Workers and biota to waste could occur during operation of the ERDF (i.e.,
       during waste transport and filling operations).  Because of access control at the Hanford Site,
                                              24

-------
      the direct exposure pathway does not apply to the public during operations. Once the ERDF
      is closed, direct exposure to waste is only possible if institutional controls fail and the surface
      cover is breached.

(2)   Prevent unacceptable contaminant releases to air in accordance with ARARs and health-
      based criteria.  Inhalation exposure to the types of waste received at the ERDF could result
      in unacceptable health risks.  Similar to the direct exposure pathway, inhalation of waste by
      workers and biota could occur during operation of the ERDF (i.e., during waste transport and
      filling operations).  Airborne transport of waste off the Hanford Site could result in exposures
      to the public, but these exposures would be negligible compared  with worker risks.  Once the
      ERDF is closed, air releases are only possible if institutional controls fail and the surface
      cover is breached.

(3)   Prevent contaminant releases to groundwater above ARARs and health-based criteria.
      Migration of contaminants through the vadose zone to groundwater could result in
      unacceptable human exposure to contaminants. This RAO has been acknowledged in the
      fourth amendment to the Tri-Party Agreement, which states:  "the point of [risk] assessment
      will be the intersection of the groundwater and the vertical line drawn from the edge of the
      disposal facility".  The Tentative Agreement on Tri-Party Agreement Negotiations, which was
      circulated for public comment in 1993, and formed the basis for the Fourth Amendment to the
      Tri-Party Agreement, further provided the time of assessment (10,000 years) and the
      compliance standard (10~5 for the first 100 years and 1C4 thereafter).  Since the risk
      assessment indicates that the risk associated with the groundwater pathway should remain
      below 10"5 for the first 100 years, the relevant compliance standard is Itt4.

(4)   Minimize Ecological Impacts.   Construction of the ERDF will result in harmful impacts to
      the ecology of the ERDF site and possibly to the borrow sites (if needed) that provide
      materials for ERDF construction.  Significant value is attached to the ecology at these sites.
      Mitigation measures to reduce ecological  impacts have been incorporated into the alternatives.
      Potential options for additional mitigation measures will be evaluated by DOE.

      Mitigation measures included in the alternatives are (i) clearing of the site in preparation for
      construction prior to nesting season to ensure that wildlife is not destroyed, only displaced;
      (ii) constructing the landfill in a sequential fashion on an as-needed basis, which may
      minimize ultimate habitat loss; (iii) use of the deep area-fill trench configuration to minimize
      the amount of land disturbed at the ERDF; (iv) initiating site clearing activities in the southern
      corner, progressing to the north, to buffer the shrub-steppe habitat immediately south of the
      ERDF site from ongoing construction activities; (v) revegetation.  Additional mitigation
      measures to be evaluated include restoration of the site,  creation or enhancement of similar
      habitat, and actions to acquire or provide protection for similar habitat.

      40 CFR Part 300 National Oil and Hazardous Substances Pollution Contingency Plan
      (NCP) and the Comprehensive  Environmental Response, Compensation, and Liability
      Act of 1980 (CERCLA) Determination

      CERCLA Section 104(d)(4) states that where two or more noncontiguous facilities are
      reasonably related on the basis of geography, or on the basis of the threat or potential threat
      to the public health or welfare or the environment, the President may, at his discretion, treat
      these related facilities as one for  the purposes of this section.         .."..—..
                                            25

-------
        The preamble to the NCP clarifies the stated EPA's interpretation that when noncontiguous
        facilities are reasonably close to one another and wastes at these sites are compatible for a
        selected treatment or disposal approach, CERCLA Section 104(d)(4) allows the lead agency to
        treat these related facilities as one site for response purposes and, therefore, allows the lead
        agency to manage waste transferred between such noncontiguous facilities without having to
        obtain a permit. Therefore, the ERDF and the 100, 200, and .300 Area NPL sites are
        considered to be a single site for response purposes.

The primary ARARs for this facility are listed below.

        Resource Conservation and Recovery Act, as amended - Title 42 USC 6901

        RCRA regulates the generation, transportation, storage, treatment, and disposal of hazardous
        waste.  Federal regulations promulgated under 40 CFR Part 260 through 268 implement
        RCRA requirements for disposal facilities including specific design, operation, monitoring,
        closure, and postclosure care requirements and are considered applicable to the ERDF.

        Facilities that treat, store, or dispose of hazardous wastes (treatment, storage, or disposal
        [TSD] facilities) are covered by 40 CFR Part 264.  Subparts A through H are general
        standards applicable to TSD and Subparts I through DD apply to specific types of treatment,
        storage, and disposal activities or to specific types of equipment.

        Part 268 restricts the land disposal of all hazardous wastes and specifies the treatment
        standards that must be met before these wastes can be land disposed unless a waiver is
        granted.                                                                  •

        Dangerous Waste Regulations  - WAC 173-303

        The Washington State Dangerous Waste Regulations implement the federal Hazardous Waste  .
        Regulations promulgated pursuant to RCRA as well as requirements of the state Hazardous
        Waste Management Act, Chapter 70.105 RCW.  The regulation establishes requirements for
        generation, storage, treatment, and disposal of dangerous waste.
                             . DESCRIPTION OF ALTERNATIVES
A range of alternatives were developed for the ERDF.  The key elements of each alternative are
described and briefly discussed below. Other than the no-action alternative, all the alternatives rely
on a centralized waste management facility at the ERDF location.

Treatment of the incoming waste at the ERDF  facility is not included in any of the alternatives.
Waste acceptance criteria will be established and approved by EPA prior to operation of the facility.
Compliance with ARARs shall be addressed by the generating operable unit for any waste transported
to ERDF.   All such waste will satisfy the ERDF waste acceptance criteria.  Treatment will be
considered in the feasibility studies for the individual operable units and will be conducted at the
operable units as appropriate.
                                             26

-------
Institutional controls, dust control, surface water management, transportation, and wastewater
treatment are components of all of the alternatives (except no action), and are discussed as common
elements. These elements are considered to be necessary for each of these alternatives, but are not
expected to affect the relative performance of the alternatives.

In addition to a no-action alternative, nine alternatives were assembled by selecting combinations of
cover and liner technologies.  The nine alternatives represent combinations of no liner, a single
composite liner, and a RCRA minimum technological requirement (MTR) double composite liner,
with a low-infiltration soil cover, a modified RCRA-compliant cover, and the Hanford Barrier.

Shallow trench and shallow area-fill designs were eliminated because of their high cost and the large
area required to provide sufficient waste capacity.  Therefore, each of the nine alternatives is based
on the deep area-fill design, which minimizes the area impacted by construction of the facility. The
alternatives assembled for evaluation include:

  •     Alternative 1   -  No action
  •     Alternative 2   -  No liner and a low-infiltration soil cover
  •     Alternative 3   -  No liner and a modified RCRA-compliant cover
  •     Alternative 4   -  No liner and a Hanford Barrier
  •     Alternative 5   -  Single composite liner and a low-infiltration soil cover
  •     Alternative 6   -  Single composite liner and a modified RCRA-compliant cover
  •     Alternative 7   -  Single composite liner and a Hanford Barrier
  •     Alternative 8   -  RCRA double composite liner and a low-infiltration soil cover
  •     Alternative 9   -  RCRA double composite liner and a modified RCRA-compliant cover
.  •     Alternative 10  -  RCRA double composite liner and a Hanford Barrier.

For the purpose  of detailed alternative evaluation, it was assumed that a modified RCRA-compliant
cover would be used on the ERDF.  The modified RCRA-compliant cover consists of a standard
RCRA-compliant cover composed of clay, geomembrane material, and soil, with additional soil
(approximately IS  ft) added for shielding and intrusion protection.  The alternatives with the other
cover options were therefore eliminated from further consideration.

The four remaining alternatives listed below were carried through the evaluation utilizing liner
technologies in combination with a modified RCRA-compliant cover (see Figure 4).

  •     Alternative 1 -   No action
  •     Alternative 2 -   No liner and a modified RCRA-compliant cover
  •     Alternative 3 -   Single composite liner and a modified RCRA-compliant cover
  •     Alternative 4 -   Double composite liner and a modified RCRA-compliant cover.
ALTERNATIVE 1 - NO ACTION

Evaluation of the no-action alternative is required under CERCLA and the NCP
(40 CFR 300.430(e)(6)).  The no-action alternative consists of not constructing a centralized waste
management unit on the Hanford Site to accommodate remediation waste from Hanford Site past-
practice operable units.
                                              27

-------
S3
00
                           Alternative  ERDF  Designs
          OPTION 1
                     No Action
                       Taken
          OPTIONS

             Protective Cap
           1 ft Thick
           Clay Layer
Leachate Collect
System
                     Single Synthetic Membrane
                     Liner
                          OPTION 2

                              Protective Cap
                                                         Waste
                                                                        (NOTE: No Liner)
                          OPTION 4

                            Protective Cap
3 ft Thick
Clay Layer
         Leachate Collection
         System    •.'••'•' :

Double Synthetic
Membrane Lirier
                                                                    H-

                                                                    C

                                                                    ro

                                                                    £~
                                                                                     E9501029. B&W

-------
 ALTERNATIVE 2 - NO LINER AND THE MODIFIED RCRA-COMPLIANT COVER

 This alternative consists of an unlined trench and the modified RCRA-compliant cover.  The cover
 prevents direct exposure to the waste and includes a vegetated surface layer of fine-grained soils to
 retain moisture and encourage evapotranspiration, thereby minimizing infiltration and vadose zone
 transport of contaminants to groundwater. The upper 50 cm (20 in.) of the soil cover system is
 composed of an admixture of silt and gravels. This layer is intended to both reduce infiltration
 through the cover and enhance the resistance of the cover to burrowing animals and long-term wind
 erosion.
ALTERNATIVE 3 - SINGLE COMPOSITE LINER AND THE MODIFIED
RCRA-COMPLIANT COVER

This alternative consists of a single-composite liner and the modified RCRA-compliant cover. The
cover prevents direct exposure to the waste and includes a vegetated surface layer of fine-grained soils
to retain moisture and  encourage evapotranspiration, thereby minimizing infiltration and vadose zone
transport of contaminants to groundwater. The upper 50 cm (20 in.) of the soil cover system is
composed of an admixture of silt and gravels.  This layer is intended to both reduce infiltration
through the cover and  enhance the resistance of the cover to burrowing animals and long-term wind
erosion.  The liner retains leachate within the trench which is then pumped out using a leachate
collection system and treated.
ALTERNATIVE 4 - RCRA DOUBLE COMPOSITE LINER AND THE MODIFIED
RCRA-COMPLIANT COVER

This alternative consists of a RCRA Subtitle C double-composite liner and the modified RCRA-
compliant cover.  The cover prevents direct exposure to the waste and includes a vegetated surface
layer of fine-grained soils to retain moisture and encourage evapotranspiration, thereby minimi/ing
infiltration and vadose zone transport of contaminants to groundwater. The upper 50 cm (20 in.) of
the soil cover system is composed of an admixture of silt and gravels.  This layer is intended to both
reduce infiltration through the cover and to enhance the resistance of the cover to burrowing animals
and long-term wind erosion.  The primary liner retains leachate within the trench which is  then
pumped out using a leachate collection system and treated.  A secondary liner and leachate collection
system retains any leachate that leaks through the primary leachate collection system and allows it to
be pumped out and treated.
COMMON ELEMENTS OF ALTERNATIVES 2, 3, AND 4

Alternatives 2, 3, and 4 include institutional controls, dust control, surface water management,
groundwater monitoring, air monitoring, decontamination facilities, waste offloading and  .
transportation, buildings, equipment for internal and external communications, and personnel
protection.  In addition, all of the alternatives (other than the no-action alternative) utilize a deep,
single trench approximately 20 m (70 ft) deep and 300  m (1,000 ft) across at the bottom,  which can
be expanded when authorized by the EPA to meet Hanford cleanup needs.

implementation of Alternative 2, 3, or 4 will require an irreversible and irretrievable commitment of.
resources such as liner material, borrow material, natural resources, building and facility construction


                                             29

-------
 materials, and energy resources. The commitment of resources required to implement each
 alternative is similar,  with the exception of trench liner material. The liner material requirements of
 Alternative 4 are twice those of Alternative 3, which are greater than Alternative 2 (the no-liner
 alternative).

 Potential environmental impacts to elements such as visual resources, noise, air, water, socioeconomic
 considerations, indirect impacts, transportation impacts,  cumulative impacts, and environmental justice
 issues were considered in the RI/FS.  These elements were determined to be affected in an essentially
 similar manner for all of the alternatives.

 Additionally, each option includes mitigation measures to reduce ecological impacts and an evaluation
 of  additional mitigation options. Further examination of alternative cover designs is also included in
 the options.
            K. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section summarizes the relative performance of each of the alternatives with respect to the nine
criteria identified in the NCP and with respect to the substantive evaluation criteria of NEPA.  These
criteria fall into three categories: the first two (Overall Protection of Human Health and the
Environment and Compliance with ARARs) are considered threshold criteria and must be met. The
next five are considered balancing criteria and are used to compare technical and cost aspects of
alternatives.  The final  two criteria (State and Community Acceptance) are considered modifying
criteria.  Modifications to remedial actions may be made based on state and  local comments and
concerns. These were  evaluated after all public comments were received.
A.  THRESHOLD CRITERIA

The remedial alternatives were evaluated in relation to the two threshold criteria:  overall protection
of human health and the environment and compliance with ARARs.  The threshold criteria must be
met by the alternatives for further consideration as potential remedies for the ROD.
1. Overall Protection of Human Health and the Environment

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.

The no-action alternative provides an environmental baseline against which impacts of the other
alternatives can be compared.  It is difficult, however, to meaningfully evaluate the no-action
alternative against the standard CERCLA criteria of long-term effectiveness and permanence, short-
term effectiveness, implementability, and cost. It should be noted that the no-action alternative will
hot support the removal of contaminants from portions of the Hanford Site (including near the
Columbia River) in a timely manner. Existing facilities do not have the capacity required to support
projected waste volumes. Therefore, a potential result associated with implementation of the no-
action alternative is mat source operable units would develop alternatives that are limited to in situ


                                              30

-------
 remedial actions, or excavation and disposal at the operable unit.  Furthermore, given the ready
 availability of a surface water source, and therefore the likelihood of human habitation, the risk of
 future intrusion into the landfill is greater along the Columbia River than on the Central Plateau.  It
 should also be noted that existing facilities at the Hanford Site do not have the capacity to support the
 projected waste volumes.  For these reasons, the no-action alternative is considered less effective in
 the long-term than other alternatives.

 The no-action alternative could involve use of an offsite waste management facility for disposal of
 Hanford remediation waste.  Use of an offsite waste management facility for permanent disposal is
 similar in concept to the other waste management facility options discussed above.  The offsite facility
 would probably be a general low-level waste facility serving a state or regional area and would most
 likely offer similar long-term effectiveness as a centralized Hanford Site waste management facility.
 The disadvantages of using an offsite waste management facility are as follows.

  •.     Few  existing or planned facilities are prepared to accept significant quantities of mixed waste.
        The nearest  existing facility is Ehvirocare of Utah, Inc., located west of Salt Lake City, Utah,
        approximately 1,100 km  (700 mi) from the Hanford Site.

  •     The potential for  accidental contaminant release over long transportation distances outside of
        Hanford Site controlled areas presents significantly greater short-term public risk than an
        onsite waste management facility.

  •     Public opposition to offsite disposal of Hanford waste is high.

  •     Transportation distances associated with an offsite facility would be significantly greater than
        for an onsite facility.

Therefore, while an  effective offsite waste management facility could be constructed, this alternative
is not retained* past the screening stage, based on poor short-term effectiveness, low implementability,
and high cost.  The no-action alternative was not carried further into the detailed evaluation for the
reasons noted above.

All the retained alternatives can satisfy the overall protection of human health and the environment
and are carried forward into the detailed  evaluation.
2.  Compliance with ARARs

CERCLA, as amended by SARA, requires that alternatives for CERCLA sites either comply with
federal and state substantive requirements that are applicable to the action being taken or provide
grounds for invoking a waiver from such requirements. The actions must also comply with the
substantive requirements of laws and regulations mat are not directly applicable, but are relevant and
appropriate.  These are requirements that pertain to situations sufficiently similar to those encountered
at a Superfund site, so their use is well suited.  Combined, these are referred to as ARARs.  State
ARARs are limited to.those promulgated requirements that are more stringent than federal counterpart
requirements, or for which there is no corresponding federal requirement.  Compliance with ARARs
requires evaluation of the alternatives for compliance with chemical-, location-, and action-specific
ARARs or justification for a waiver.  Other criteria, advisories, and guidelines were also considered.
                                               31

-------
 The most significant ARARs for construction and operation of a disposal facility receiving
 hazardous/dangerous waste include federal RCRA landfill requirements specified in 40 CFR Part 264,
 Washington State dangerous waste landfill requirements specified in WAC 173-303-665, RCRA LDRs
 specified in 40 CFR Part 268 and WAC 173-303-140, and Toxic Substances Control Act (TSCA)
 requirements specified hi 40 CFR Part 761.

 The applicable RCRA landfill requirements include MTRs for landfill liners and covers.  The liner
 requirements call for a double-lined landfill with a leachate collection system.  Only alternatives with
 a RCRA double liner are compliant with this requirement. The alternatives with either no liner or a
 single liner would require a CERCLA waiver or a RCRA variance for the liner design.  The RCRA
 MTRs for the landfill cover include a requirement that the permeability of the cover be less than or
 equal to the permeability of the bottom liner.  This  requirement is satisfied by the flexible membrane
 liner and clay layer in the RCRA-compliant cover.

 Compliance with LDRs would be required unless alternate standards are approved for each individual
 operable unit via an approved regulatory mechanism such as a CERCLA waiver or a RCRA-
 treatability variance as part of the decision-making process at the individual operable units and
 documented in those operable unit RODs.

 The most significant TSCA requirement is that PCBs greater than 50 mg/kg must be disposed in a
 lined facility.  In order to accept wastes with PCB concentrations greater than 50 mg/kg, alternatives
 that do not include a liner would require a waiver under CERCLA.

 Evaluation of how each alternative complies with ARARs is based on the number of waivers that
 would likely be required to implement the alternative. Regulations that may require waivers include
 (1) RCRA MTRs for landfill liners, (2) RCRA MTRs for landfill covers, and (3) TSCA landfill liner
 requirements. It is expected that Alternatives 2, 3,  and 4 will comply with all other ARARs.

 Alternative 2.' This alternative would require waivers for the RCRA liner MTRs and the TSCA liner
 requirements.

 Alternative 3. This alternative would require waivers for the RCRA liner MTRs.

 Alternative 4. This alternative requires no waivers and therefore best meets this criterion.
B.  PRIMARY BALANCING CRITERIA

The balancing criteria are used to refine the selection of alternatives.  The five balancing criteria are
long-term effectiveness  and permanence; reduction of toxicity, mobility, or volume through treatment;
short-term effectiveness; implementability; and cost.
3. Long-Term Effectiveness and Permanence

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 tune. Factors that
are considered, as appropriate, include the following.
                                             32

-------
        Magnitude of residual risk remaining from untreated waste or treatment residuals remaining at
        the conclusion of the activities.  Residual risk is associated with migration of contaminants to
        groundwater and is addressed by predicting the risk via the groundwater pathway for each
        alternative. Long-term effectiveness and permanence is measured in terms of future
        groundwater risk and qualitative assessments of liner and cover reliability. Because each  of
        the alternatives will use the modified RCRA-compliant cover, cover reliability does not factor
        into the ranking of alternatives.  Liner reliability is considered least important because the
        liner is expected to fail over the long-term and does not significantly affect risk estimates.
        Based on the fate and transport  modeling results of the RI/FS, none of the alternatives will
        allow contaminants to reach  groundwater within 10,000 years under current climate
        conditions. Under the hypothetical wetter climate, all of the alternatives result in a total ICR
        of 2 x ltt5 and  a maximum HQ of 0.8 within 10,000 years.  Since all of the alternatives rank
        equally, this criterion is not evaluated further.

        Adequacy and reliability of controls such as containment systems and institutional controls.
        This factor addresses the uncertainties regarding long-term protection from residuals, the
        assessment of the potential need to replace technical components of the alternative, and the
        potential exposure pathways  and risks posed should the remedial action need replacement.
        This factor is addressed by qualitatively evaluating the durability and redundancy in the liner
        and  cover systems provided by each of the alternatives.

Alternative 2. The no-liner alternative provided the least ability to determine the remedial action's
effectiveness and is ranked third for  this criterion.

Alternative 3. The single-liner alternative provides the ability to monitor leachate and determine the
remedial action's effectiveness. However, it does not provide an indication of liner failure and is
ranked second for this criterion.

Alternative 4.' The double-liner alternative provides the ability to monitor leachate, the primary liner
system, and determine the remedial action's effectiveness.  It is ranked first for this criterion.
4. Reduction of Toxicity, Mobility, or Volume through Treatment

This criterion addresses the statutory preference for selection of remedial actions employing treatment
technologies that permanently reduce toxicity, mobility, or volume of the hazardous substances as
their principal element.

Treatment of the incoming waste at ERDF is not included hi the ERDF alternatives.  Instead, waste
treatment will be considered in the feasibility studies, proposed plans, and the RODs for the
individual operable units and will be conducted at the operable units as appropriate.  Waste coming to
the ERDF shall meet all ARARs and satisfy the waste acceptance criteria.
5. Short-Term Effectiveness

Short-term effectiveness refers to the speed with which the remedial action achieves protection, as
well as the remedial action's potential to create adverse impacts on human health and the environment
during the construction and implementation period.
                                               33

-------
The short-term impacts of alternatives are.assessed by considering the following.

  •     Short-term risks that might be posed to the community during implementation of an
        alternative.  Risks to the community during implementation are associated with potential air
        releases of waste constituents during waste transport and placement.  Because operations
        would be conducted in the same manner for all the alternatives  (except the no-action
        alternative), this criterion will not differentiate between the alternatives. The dust controls
        Included in all the alternatives will be sufficient to protect worker health. Because the ERDF
        is isolated from the public, public risk is considered negligible compared with worker risk.

  •     Potential impacts on workers during remedial action and the effectiveness and reliability of
        protective measures.  Risks to workers include both exposure to hazardous and radioactive
        substances hi the waste and physical hazards associated with construction activities and
        equipment operation.  Potential worker exposure to waste contaminants during waste transport
        and placement would be the same for all the alternatives (except the no-action alternative).
        Since all the alternatives involve similar types of construction activities, the magnitude of
        physical hazard associated with an alternative would be approximately proportional to the
        amount of labor necessary to construct the facility. Generally, the more complex liners and
        covers require the most labor and thus are expected to produce greater risk to construction
        workers.

  •     Potential environmental impacts of the remedial action and the effectiveness and reliability of
        mitigative measures during implementation. Because all the alternatives (except the no-action
        alternative) utilize the same trench configuration, environmental impacts at the ERDF are
        virtually the same.

  •     Time until protection is achieved.   Assuming that all alternatives will result in a facility ready
        to receive waste by September 1996, this factor would be the same for all the alternatives.
        As discussed below under the implementability criterion, however, those alternatives that
        include non-RCRA-compliant liners may require  greater technical effort to defend and
        consequently may take longer to approve.

Given these factors, short-term effectiveness will be measured primarily in terms of the estimated
number of fatalities due to physical accidents and the impacted areas at the borrow sites. Worker
accidents is weighted less than the other criteria because the differences between the alternatives are
relatively minor. Because the construction of a modified RCRA-compliant cover is the same for each
alternative, impacts at borrow sites are expected to be identical.

Alternative 2.  The estimated worker fatalities for this alternative (0.522) provides the best short-term
effectiveness score.

Alternative 3.  The estimated worker fatalities for this alternative (0.546) ranks this alternative
second in terms  of overall short-term effectiveness.

Alternative 4.  The estimated worker fatalities for this alternative (0.569), resulting in the third best
overall short-term effectiveness score.
                                               34

-------
 6.  Implementability

 The implementability criterion has three factors requiring evaluation: the technical and administrative
 feasibility of a remedy, and the availability of materials and services needed to implement the
 solution.

  •     Technical feasibility, including technical difficulties and unknowns associated with the
        construction and operation of a technology, the reliability of the technology, ease of
        undertaking additional remedial  actions, and the ability to monitor the effectiveness of the
        remedy.  In general, all the alternatives are technically feasible.  However, certain alternatives
        that include complex liners are more likely to result in schedule delays.  The number of layers
        in the liner are a relative measure of technical complexity.

. •     Administrative feasibility,  including activities needed to coordinate with other offices and
        agencies  and  the ability and time required to obtain any necessary approvals and permits from
        other agencies (for offsite actions).  CERCLA waives administrative requirements (such as
        permitting) for onsite activities.  Because none of the alternatives include offsite transport,
        treatment, or disposal, this factor is not significant to the detailed evaluation.

  •     Availability of services and materials,  including the availability of adequate offsite treatment.
        storage capacity, and disposal capacity and services: the availability of necessary equipment
        and specialists, and provisions to ensure any necessary additional resources: the availability of
        services and materials: and availability of prospective technologies.  The primary differences
        between the alternatives regarding this factor are related to the types and quantities of
       . materials included in the liners and covers.  Off-the-shelf materials or materials that utilize
        soil excavated at the ERDF are considered easy to obtain.

In summary, the only factor considered  significant is technical implementability.

Alternative 2. This alternative has no liner, ranking it first for technical implementability.

Alternative 3. This alternative has a single liner,  ranking it second for technical implementability.

Alternative 4. This alternative has a double liner, ranking it third for technical implementability.
7.  Cost

Cost includes capital and operation and maintenance costs for a facility of 36 disposal cells (the
maximum extent of the ERDF facility over the life of the project).  The estimated costs are present-
worth costs (capital costs plus annual costs over the life of the project, with a 5% discount rate).
Capital costs include design, construction, equipment, buildings, start-up, and contingency costs.
Operating and maintenance costs include labor, power, disposal of residuals, administrative, and
periodic reviews.                                         '
                                                35

-------
 The types of cost factors assessed include the following.

  •     Capital costs, including both direct and indirect costs. Construction costs for the different
        liners will vary significantly.  Therefore, capital costs will be the primary factor in evaluation
        of the alternatives.  Costs for excavating the trench and constructing facilities will also be
        determined to provide a perspective on the relative significance of the liner costs.

  •     Annual operation and maintenance costs. Only costs incurred during operation of the ERDF
        will be considered.  Long-term, postclosure monitoring, and maintenance costs will be
        relatively small and are not included.

 Comparative performance of the alternatives was based on the total net present value of capital and
 operation and maintenance costs.

 Alternative 2. The total net present value for this alternative is $600 million. This alternative is the
 lowest cost alternative.

 Alternative 3. The total net present value for this alternative is $690 million. This alternative is the
 second lowest cost alternative.

 Alternative 4. The total net present value for this alternative is $779 million. This alternative is the
 most expensive alternative.
C.  MODIFYING CRITERIA

The modifying criteria are used in the final evaluation of remedial alternatives.  The two modifying
criteria are state acceptance and community acceptance. For both of these criteria, the factors
considered include the elements of the alternatives supported by the public, the elements of the
alternatives not supported by the public, and the elements of the alternatives having strong opposition.
8.  State Acceptance

State acceptance indicates whether, based on its review of the final RI/FS Report and Proposed Plan,
the State concurs with, opposes, or has no comment on the preferred alternative.

Ecology concurs with the selection of the final remedial alternative described in this ROD with the
understanding that the DOE has committed to evaluate mitigation options.  Based on that evaluation,
Ecology would expect mitigation to occur in a timely manner for habitat losses at ERDF. Ecology
has been involved in the development and review of the Remedial Investigation, Feasibility Study,
Proposed Plan, and ROD.  Ecology comments have resulted in significant changes to these
documents.     '..            .
9. Community Acceptance

Community acceptance refers to the public's support for the preferred alternative and is assessed
following a review of the public comments received on the final RI/FS Report and the Proposed Plan.
                                               36

-------
On November 14, 15, 16, and 30, 1994, public meetings were held to discuss the Proposed Plan for
the ERDF.  The results of the public meeting and the public comment period indicate general
acceptance of the preferred remedial alternative, with some exceptions.  Community response to the
alternatives is presented in the responsiveness summary, which addresses questions  and comments
received during the public comment period.

The major concerns expressed during the scoping period for the ERDF focused on minimizing the
amount of land used for waste management activities.  Commentors requested that previously
contaminated areas be considered for siting the ERDF.  Several commentors requested that the
agencies consider areas that would minimize the impact to mature shrub-steppe habitat.

The agencies responded to these concerns by downsizing the land requirements for the ERDF through
the engineering design of a deep area-fill trench.   This reduced the land requirements  from 6 mi2 to
1.6 mi2. Additionally, the initial two cells will be sized to handle remediation requirements for the
next 6 years and will be expanded only as needed, thereby minimizing the impact on shrub-steppe
habitat.  The agencies also conducted an independent siting study that considered a contaminated area
for the ERDF location. Due to safety, tuning, and cost considerations, the site was not selected.
                                  X. SELECTED REMEDY
On the basis of consideration of the requirements of CERCLA, the detailed analysis of alternatives
using the nine CERCLA criteria, NEPA, and public comments, this ROD selects Alternative 4 (a
RCRA-compliant double-lined trench with a modified RCRA-compliant cover) at the ERDF location
for the disposal of radioactive, hazardous, and mixed wastes resulting from the remediation of
operable units within the 100, 200, and 300 Area NPL sites of the Hanford Site. Only remediation
wastes from the Hanford NPL sites will be allowed in the ERDF.

Of the alternatives proposed, this ERDF alternative provides the best combination balancing nine
CERCLA criteria and ARAR compliance, selection of a protective site, and consideration of Hanford
Future Site Uses Working Group and public recommendations. The liner, compliant with RCRA
Subtitle C MTRs, will be double lined  and equipped with a leachate collection system.  This design
provides a more reliable, system to protect groundwater than a single liner. The chosen ERDF site is
above the Columbia River floodplain and distant from the river; of the sites examined, this site is
farthest from groundwater and provides the greatest distance from the Columbia River. Finally,
constructing the ERDF at the selected site is consistent with the Hanford Future Site Uses Working
Group recommendations to consolidate waste management activities  on the Central Plateau.  The
downsized design is consistent with public recommendations to limit the amount of land dedicated to
waste management.

The ERDF will be located on the Hanford Site Central Plateau, southeast of the 200 West Area.  The
site is located within the waste management area as recommended by the Hanford Future Site Uses
Working Group, and does not intrude into the recommended buffer zone (see Figure 2).

The ERDF is designed as a single, 70-ft-deep trench consisting of a  series of two side-by-side cells,
each measuring 500 by 500 ft at the base, with finished wall slope of 3  horizontal to 1 vertical. Two
cells are authorized for Initial construction, with final dimensions of 1,420 ft wide and 720 ft long at
                                             37

-------
the lip of the trench. An additional 350 ft will be excavated within the trench footprint to facilitate
initial excavation and potential expansion.

The components of the selected remedy include the following.

  •     Initial construction and operation of two disposal cells that are expected to provide an
       approximate waste disposal capacity of 1.2 million yd3.  These cells will be designed and
       constructed to RCRA  MTRs (40 CFR Part 264 Subpart N).  The decision to expand the
       landfill in the future will be documented by amending this ROD or within the RODs for the
       Hanford operable units.

  •     The ERDF site will cover a maximum of 4.1 km2 (1.6 mi2) on the Central Plateau, southeast
       of the 200 West Area and southwest of the 200 East Area.  The initial construction of the
       facility will cover 165 acres of this area.

  •     The ERDF facility will provide sufficient leachate storage capacity to ensure uninterrupted
       operations, complying with 40 CFR Part 264, Subpart N.  Leachate collected at the landfill
       will be managed at the 200 Area Effluent Treatment Facility, located  in the 200 East Area, or
       other approved  facility.

  •     Surface water run-on/run-off will be controlled at the landfill and other areas of the facility
       that are potentially contaminated. Best management practices to control runoff shall be
       employed.

  •     During excavation, suitable soils will be stockpiled at the ERDF site to provide materials for
       liner systems and for daily interim and closure covers for the landfill.  Materials not suitable
       for construction of the liner and covers will be used for other construction purposes at the
       facility to the extent practicable.

  •     Air monitoring  will be accomplished by placement at ERDF of real-time air monitors for
       radioactive contaminants and air samplers for hazardous and radioactive constituents to detect
       any offsite migration of contaminants.

  •     Groundwater monitoring will be performed in accordance with 40 CFR Part 264, Subpart F.

  •     Appropriate measures  to protect facility workers and the public will be employed during
       ERDF operations including contamination control and dust mitigation, and protection of
       personnel from  industrial hazards presented by ERDF operations.  Protective measures shall
       comply with applicable requirements found in the Occupational Safety and Health Act
       (OSHA), Washington Industrial Safety and Health Act (WISHA), and other safety regulations
       or ERDF-specific safety requirements.  Energy shall also comply with 40 CFR §300.150.

  •     The ERDF facility will use existing or planned site road systems for waste transport.
       Extension of the Hanford rail lines was considered in the RI/FS, but at this time the rail line
       extension is not considered necessary. As Hanford remediation accelerates, the option might
       be re-evaluated  in the future.

  •     Waste acceptance criteria shall be developed  by DOE, in accordance with ARARs,
       risk/performance assessments, ERDF-specific safety documentation, and worker protection  .
       requirements. Upon approval by EPA (and consultation with Ecology), these criteria wDl


                                             38

-------
      govern what wastes from the Hanford NPL sites can be placed in the ERDF.  No waste may
      be placed into the ERDF until the waste acceptance criteria have been approved by EPA (with
      consultation with Ecology).  Operable unit-specific waste disposal and treatment decisions will
      be made as part of the remedy selection and cleanup decision process for each operable unit.

•     The ERDF landfill will be closed by placing a modified RCRA-compliant closure cover over
      the waste.  The cover will prevent direct exposure to the waste and includes a vegetated
      surface layer of fine-grained soils to retain moisture and encourage evapotranspiration,
      thereby minimizing infiltration and vadose zone transport of contaminants to groundwater.
      The upper SO cm (20 in.) of the soil cover system is composed of an admixture of silt and
      gravels.  This layer is intended to both reduce infiltration through the cover and enhance the
      resistance of the cover to burrowing animals and long-term wind erosion.   A RCRA-
      compliant cover generally consists of a layer of clay, geomembrane material, and sand and
      gravel.  The RCRA-compliant cover will be modified by the addition of approximately 15 ft
      of soil to provide shielding from radioactive material and to deter intrusion: It is anticipated
      that additional research into closure covers may result in site-specific enhancements to RCRA-
      compliant designs.   Prior to cover construction, closure cover designs will be evaluated and
      the most appropriate closure cover design will be selected for construction. The design will,
      at a minimum, comply with applicable RCRA requirements found at 40 CFR Part 264,
      Subpart N.  Basalt  from Hanford Site source areas will not be required for construction of the
      ERDF closure cover.

•     Institutional controls shall be imposed to restrict public access to the landfill.

•     Equipment will be available to transport wastes and operate the ERDF safely  and efficiently

•     Hanford Site infrastructure will be expanded as necessary to support the ERDF.
      Infrastructure improvements or extensions may include water, sewer, electric service, roads,
      operations facilities, and a chemical and fuel storage  area.

•     A decontamination  facility will be constructed consisting of, at a minimum, an impervious pad
      with sump,  wash water storage, and secondary containment. Washwater water used to
      decontaminate site equipment shall be managed in compliance with appropriate requirements.

•     The detailed design will be submitted to EPA for approval (with consultation  with Ecology)
      prior to construction of the ERDF facility.  At a minimum it will be submitted in two
      packages to allow for construction in phases.

•     An operations plan will be submitted to  EPA for approval (with consultation from Ecology)
      prior to operation of the ERDF facility.

•     Mitigation measures to reduce ecological impacts have been incorporated to satisfy the
      Remedial Action Objectives identified hi Section 7(4)0) through 7(4)(v).  In addition, DOE
      commits to the development and implementation of a Mitigation Action Plan hi coordination
      with the Natural Resource Trustees for additional  mitigation measures.
                                            39

-------
                           XI.  STATUTORY DETERMINATIONS
Under CERCLA Section 121, selected remedies must be protective of human health and the
environment, comply with ARARs, be cost effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practical. In
addition, CERCLA includes a preference for remedies that employ treatment that significantly and
permanently reduces the volume, toxicity, or mobility of hazardous wastes as their principal element.
The following sections discuss how the selected remedy meets these statutory requirements.

40 CFR Part 300 National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) Determination

CERCLA Section 104(d)(4) states where two or more noncontiguous facilities are reasonably related
on the basis of geography, or on the basis of the threat or potential threat to the public health or
welfare or the environment, the President may, at his discretion, treat these related facilities as one
for the purposes of this section.                                     .

The preamble to the NCP clarifies the stated EPA's interpretation that when noncontiguous facilities
are reasonably close to one another and wastes at these sites are compatible for a selected treatment or
disposal approach,  CERCLA Section 104(d)(4) allows the lead agency to treat these related facilities
as one site for response purposes and, therefore, allows the lead agency to manage waste transferred
between such noncontiguous facilities without having to obtain a permit.  Therefore, the ERDF and
the 100, 200, and 300 Area NPL sites are considered to be a single site for response purposes under
this ROD.
A.  PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

The selected remedy protects human health and the environment through isolation of waste away from
the groundwater and the Columbia River.  Modeling indicates that, at this location, the ERDF design,
a double-lined trench with a modified RCRA-compliant cap, will minimise risk to less than 10~5 for
up to  10,000 years under current climate conditions assuming that the cover remains intact.  The
trench design provides a more reliable system for the protection of groundwater. The'primary liner
system provides for collection of leachate generated during operation and after closure. The
secondary liner system provides for early detection of leaks from the primary liner and provides for
additional collection of leachate. The ERDF design also addresses public  concern by minimizing the
impact to shrub-steppe habitat. The selected ERDF site is protective of human health and the
environment because it is located at the greatest distance from the Columbia River and from
groundwater.  The surface cover protects human health and the environment by providing a cover mat
prevents direct exposure to the waste and includes a vegetated surface layer of fine-grained soils to
retain moisture and encourage evapotranspiration, thereby minimising infiltration and vadose zone
transport of contaminants to groundwater.  Implementation of this remedial action will not pose
unacceptable short-term risks toward site workers.
                                             40

-------
B.  COMPLIANCE WITH ARARs

The selected remedy will comply with the federal and state ARARs identified below.  It is important
to note that as detailed evaluation of ARARs progresses, changes to the ARARs in this ROD may be
necessary.  Such changes will require an Explanation of Significant Differences or a ROD
amendment. The chemical-, action-, and location-specific ARARs for the ERDF are the following:
1. Chemical-Specific ARARs

       Resource Conservation and Recovery Act - Title 42 USC 6901 et seq, Subtitle C

       The Resource Conservation and Recovery Act (RCRA) regulates the generation,
       transportation, storage, treatment, and disposal of hazardous waste.  These regulations also
       provide authority for the cleanup of spills and  environmental releases of hazardous waste to
       the environment as a result of past practices.  Hazardous waste management regulations
       promulgated pursuant to RCRA are codified at 40 CFR Part 260 through 268.  Washington
       State Dangerous Waste Regulations implement the federal hazardous waste regulations and are
       administered by Ecology.  Regulations established under RCRA are applicable to the ERDF
       as chemical-specific ARARs because the facility is expected to receive hazardous waste and
       operation of the facility may generate hazardous waste.

       National Primary and Secondary Ambient Air Quality Standards - 40 CFR Part 50

       National primary and secondary ambient air quality standards were established pursuant to the
       Clean Air Act to protect air quality and maintain public health. The EPA has promulgated
       national primary air quality standards for six criteria pollutants: sulfur oxides, particulate
       matter, carbon monoxide,  ozone, nitrogen dioxide, and lead.  The requirements of this
       standard are applicable because potential airborne emissions of particulates or lead may result
       during operation of the facility.

       National Emission Standards  for Hazardous Air Pollutants - 40 CFR Part 61

       The Clean Air Act directs the EPA to develop and periodically revise a list of National
       Emission Standards for Hazardous Air Pollutants (NESHAPs). Hazardous air pollutants are
       ah- contaminants that affect human welfare for which no ambient air quality standard exists.
       The NESHAPs are promulgated for emissions  from specific sources, and only the NESHAPs
       established for radionuclide emissions from DOE facilities are applicable to die ERDF. The
       remaining NESHAPs are considered relevant and appropriate to the ERDF if operation of the
       facility incorporates operations similar to operations associated with the sources identified in
       the NESHAP.

       EPA standards for radionuclide emissions from facilities owned and operated by DOE under
       40 CFR 61.90, National Emission Standards for Hazardous Air Pollutants, are applicable
       because radionuclides will be present in wastes managed at the facility and there is potential
       for airborne release.  The regulation establishes general radiation dose limits to members of
       the public from radionuclides emitted  into the air from DOE facilities. The dose equivalent
       rate to" any member of the public shall not exceed 25 mrem/year to the whole body or 75
       mrem/year to any critical organ.  Also, no member of the public may receive a continuous
       exposure, excluding natural background and medical exposure, of more than 100 mrem/year


                                            41

-------
 effective dose equivalent and a noncontinuous exposure of more than 500 mrem/year effective
 dose equivalent from all sources.

 Health and Environmental Protection Standards for Uranium and
 Thorium Mill Tailings - 40 CFR Part 192

 Requirements of 40 CFR Part 192, Health and Environmental Protection Standards for
 Uranium and Thorium Mill Tailings, are relevant and appropriate requirements to the ERDF
 because they establish performance standards for radioactive waste disposal facilities.  The
 standard requires that waste disposal facilities be designed for an effective life up to 1,000
 years, to an extent reasonably achievable, and in any case, no less than 200 years.  This is a
 design standard, and monitoring after disposal is not required to demonstrate  compliance.
 These requirements are not applicable to the ERDF because the facility is not associated with
 uranium or thorium milling.

 Standards for Protection Against Radiation - 10 CFR Part 20

 The NRC Standards for Protection Against Radiation found in 10 CFR Part 20 are relevant
 and appropriate to the facility because the regulation establishes standards for protection
 against radiation hazards that may result from occupational exposure or discharges to air and
 water.

 NRC licensed facilities must limit occupational dose to the following:

 (1) an annual limit, which is the more limiting of
 (i) a total effective dose of 5 rem
 (ii) the total dose to any organ or tissue, other than the eye, equal to SO rem

 (2) the annual limits to the lens of the eye, to the skin, and to the extremities, which are:
 (i) An eye dose equivalent of 15 rem
 (ii) A shallow-dose equivalent of 50 rem to the skin or to any extremity.

 Derived air concentration and annual limit on intake values, presented in Table  1 of
 Appendix B of 10 CFR Part 20, were  calculated based upon the occupational  dose limits
 described above.  The regulation also describes how to add external and internal doses to
 calculate the total effective dose equivalent. Dose limits for minors are 10% of the annual
 dose limits specified for adult workers.

 In addition, the licensee must conduct operations so that the total effective dose equivalent to
 individual members of the public may  not exceed 0.1 rem/year.  The dose in  any unrestricted
 area from external sources may not exceed 0.002 rem/h. The licensee must survey radiation
levels in unrestricted areas and radioactive materials in effluent released to unrestricted areas
 in order to demonstrate compliance with the dose limits for individual members of the public.

The standard is not applicable to the ERDF because it only applies to operations licensed by
the U.S. Nuclear  Regulatory Commission.
                                       42

-------
Toxic Substances Control Act 15 USC 2601 et seq.

TSCA requirements found at 40 CFR Part 761 are applicable to the ERDF because PCBs
have been identified as potential contaminants of concern and may be disposed of at the
ERDF above the regulated concentration of 50 ppm. This regulation establishes handling,
storage, and disposal requirements for wastes with PCB concentrations greater than 50 ppm.

Dangerous Waste Regulations - WAC 173-303

The Washington State Dangerous Waste Regulations implement the federal Hazardous Waste
Regulations promulgated pursuant to RCRA.  The regulation establishes requirements for
generation, storage, treatment and disposal of dangerous waste. General requirements for
dangerous waste management facilities are discussed as action-specific ARARs, and
requirements for facility siting are presented as location-specific ARARs. However,
Section WAC 173-303-070 establishes procedures and methods to determine if solid waste
requires management as dangerous waste.  These requirements are considered applicable as
chemical-specific ARARs to wastes generated at the ERDF.  Section WAC  173-303-090
identifies classification of wastes based on specific characteristics such as ignitability,
corrosivity, reactivity,  and toxicity. Classification of wastes as either dangerous or extremely
hazardous is also considered as an applicable chemical-specific ARAR.

State Radiation Protection Standards - Ch. 70.98 RCW

Washington State Radiation Standards (Ch. 70.98 RCW) were developed pursuant to the
Atomic Energy Act of 1954 and are implemented in WAC 246-220 through WAC 246-255.
Not all the standards in the referenced chapters are specifically applicable to the ERDF, and
only the following standards are considered as chemical-specific ARARs. WAC 246-221,
Radiation Protection Standards, is applicable because it establishes the maximum allowable
radiation dose to individuals hi restricted areas, exposure to minors, and permissible levels of
radiation from external sources  in unrestricted areas. The occupational dose limit for adults,
excluding planned special exposures, shall not exceed an annual limit of a total effective dose
equivalent equal to 5 rem, or the sum of the deep dose equivalent and the committed dose
equivalent to  any individual organ or tissue other than the lens of the eye should not exceed
50 rem.  An eye dose equivalent of 15 rem is set for exposure to the eye. The shallow dose
equivalent for the skin or any extremities is 50 rem.  Occupational dose limits for minors are
set at 10% of the annual occupational dose limits for adults.

The standard identifies the methods required to demonstrate compliance and provides  derived
air concentration and annual limit on intake values that may be used to determine an
individual's occupational dose limits. Dose limits that individual members of public may
receive in unrestricted areas or from radioactive effluent are not to cause an individual
continually present in an. unrestricted area, to receive from external sources, more than
0.002 rem in an hour or 0.50 rem in a year. Chapter 246-221 also establishes concentration
limits in effluent released to unrestricted areas. The WAC 246-247, Radiation Protection -
Air Emissions, promulgates air  emission limits for airborne radionuclide emissions at  the
same levels as defined in WAC 173-480, which are consistent with federal NESHAPs. The
ambient standard requires that emission of radionuclides to the air must not cause a dose
equiyalejat of 25 mrem/year to the whole body or 75 mrem/year to any critical organ.
Radiation protection standards for uranium and thorium milling sites are presented in
WAC 246-252 and are not applicable to the ERDF because it was not used for uranium or
                                       43

-------
        thorium milling.  However, the regulation is considered relevant and appropriate because it
        presents specific radiation protection standards for groundwater.


2. Action-Specific ARARs

        Resource Conservation and Recovery Act, as amended - Title 42 USC 6901

        The Resource Conservation and Recovery Act (RCRA) regulates the generation,
        transportation, storage, treatment, and disposal of hazardous waste. Federal regulations found
        at 40 CFR Part 260 through 268 implement RCRA requirements for disposal facilities
        including specific design, operation, monitoring, closure, and postclosure care requirements
        and are considered applicable to the ERDF.

        Dangerous Waste Regulations - WAC 173-303

        The Washington State Dangerous Waste Regulations implement the federal Hazardous Waste
        Regulations promulgated pursuant to RCRA.  The regulation establishes requirements for
        generation, storage, treatment,  and disposal of dangerous waste and are applicable to the
        ERDF because the facility will accept hazardous/dangerous waste.


3. Location-Specific ARARs

        The Endangered Species Act - 16 USC 1531

        The Endangered Species Act of 1973  is applicable and must be considered during siting,
        design, operation, and closure of the ERDF because the Act establishes requirements to
        protect species threatened by extinction and habitats important to their survival.

        Dangerous Waste Regulations, Siting Criteria - WAC 173-303-282(6) and (7)

        The substantive siting criteria in WAC 173-303-282 are relevant and appropriate to the ERDF
        because the facility will manage hazardous waste.

        Radioactive Waste, Licensing Land  Disposal - WAC 246-250-300

        Substantive requirements established for licensing land disposal facilities for radioactive waste
        are relevant and appropriate to  the ERDF because Section WAC 246-250-300 identifies
        criteria and considerations used to evaluate site suitability for land disposal of low-level waste.
        The requirements of this regulation- are not applicable to the ERDF because the regulation
        only addresses land disposal of radioactive wastes received from others. The ERDF will
        manage only low-level waste resulting from Hanford Site remediation.
                                             44

-------
 4. Other Criteria, Advisories, or Guidance to be Considered for this Remedial Action (TBCs)
                                      i

        Radiation Protection of the Public and Environment - DOE Order 5400.5

        Site Selection - DOE-RL Order 4320.2C

        Hanford Future Site Uses Working Group Recommendations

        Radiation Protection for Occupational Workers - DOE Order 5480.11

        Radioactive Waste Management - DOE Order 5820.2A

        Chapter III of DOE Order 5820.2A requires that low-level waste management practices limit
        external exposure to radioactive material released to the environment to levels that will not
        result in an effective dose equivalent to any member of the public in excess of 25 mrem/year
        and that any air release meet the emission limits specified in 40 CFR Part 61. The DOE
        Order also specifies radiation exposure be limited to ALARA.  Low-level waste disposal
        systems must be capable of limiting the effective dose equivalent received by inadvertent
        intruders into the disposal system after institutional controls cease, to not more than 100
        mrem/year or 500 mrem for a single acute exposure.

        The DOE Order also specifies that material with transuranic waste concentrations greater than
        100 nCi/g shall be managed as transuranic waste. Transuranic wastes  will not be disposed of
        at the ERDF.


 C. COST EFFECTIVENESS

 The selected remedy provides overall effectiveness proportional to its increased cost.  The cost for the
 RCRA double-lined facility appears to be higher than for the other alternatives, but the other
 alternatives may not comply with the minimum technology requirements.
 D. UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
    TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

 Alternative 4 is considered the best solution because it meets the minimum requirement for landfill
 design without having to apply a ARAR waiver option.  Over the long term, this alternative is
 expected to perform effectively. Input from the public indicates that this is the most acceptable design
 alternative. The selected remedy is protective of human health and the environment, will comply with
 Federal and State requirements that are legally applicable or relevant and appropriate to the remedial
 action, and is  cost effective.
                           /
 The selected remedy utilizes permanent solutions practicable for this site.  This action provides a
 landfill for Hanford remediation waste, and alternative treatment technologies were not utilized for
 this action.  Waste coming to the ERDF shall meet all ARARs and satisfy the waste acceptance
 criteria.  Waste treatment is considered in the feasibility studies, proposed plans, and RODs for the
 individual operable units and will be conducted at the operable units as appropriate.  Alternative
-treatment technologies shall be used in remedial decisions for the Hanford Site where practicable.
                                             45

-------
E.  PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

This remedy utilizes permanent solutions to the maximum extent practicable for this site. Treatment
of wastes will be addressed in the operable units decision documents. As a consequence, the statutory
preference for treatment as a principal element will be addressed in these future documents rather than
in this ROD.
                  HI.  DOCUMENTATION OF SIGNIFICANT CHANGES
DOE and EPA reviewed all written and verbal comments submitted during the public comment
period.  Upon review of these comments, it was determined that no significant changes to the selected
remedy, as originally identified in the Proposed Plan, were necessary.
                                           46

-------
              APPENDIX A

DECLARATION OF THE RECORD OF DECISION
       RESPONSIVENESS SUMMARY
                 A-l

-------
A-2

-------
       USDOE HANFORD ENVIRONMENTAL RESTORATION DISPOSAL FACILITY

                             RESPONSIVENESS SUMMARY
The U.S. Department of Energy (DOE), the U.S. Environmental Protection Agency (EPA), and the
State of Washington Department of Ecology (Ecology) (the agencies) held a public comment period
from October 17, 1994 through November 30, 1994 for interested parties to comment on the
Environmental Restoration Disposal Facility (ERDF) Proposed Plan.  The Plan presents the preferred
alternative for waste management of Hanford remedial waste.  The primary supporting document is
the Remedial Investigation/Feasibility Study for the Environmental Restoration Disposal Facility
(Rev. 1).

Public meetings were held in Hood River, Oregon on November 14; in Seattle, Washington on
November 15; in Richland, Washington on November 16; and in Portland, Oregon on November 30
to describe the waste disposal technologies that were evaluated and to present the agencies' preferred
alternative for the ERDF.

A responsiveness summary is required by the Comprehensive Environmental Restoration,
Compensation, and Liability Act (CERCLA) for the purpose of providing the agencies and the public
with a summary of citizens comments and concerns about the site, as raised during the public
comment period, and the agencies' response to those comments and concerns.

I. RESPONSIVENESS SUMMARY OVERVIEW. This section briefly describes the  background of
the Hanford Site and the ERDF and outlines the preferred alternatives for the ERDF.

H. BACKGROUND ON COMMUNITY  INVOLVEMENT AND CONCERNS.  This section
provides a brief history of community interest and concerns regarding the ERDF.

ffl. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND THE AGENCIES' RESPONSES TO THOSE
COMMENTS. This section summarizes both oral and written comments submitted to the agencies at
the public meeting  and the public comment period, and provides the agencies' responses to those
comments.

IV. REMAINING CONCERNS.  .This section discusses community concerns that the  agencies
should be aware of as they prepare to undertake remedial design and remedial action for the ERDF.

I. RESPONSIVENESS SUMMARY OVERVIEW
SITE BACKGROUND

In 1988, the Hanford Site was scored using EPA's Hazard Ranking System. As a result of the
scoring, the Hanford Site was added to the National Priority Listing (NPL) in July 1989 as four sites
(the 1100 Area, the 200 Area, the 300 Area, and the 100 Area). Each of these areas was further
divided into operable units (a grouping of individual waste units based primarily on geographic area
and common waste sources). These operable units contain contamination in the form of hazardous
waste, radioactive/hazardous mixed waste, and other CERCLA hazardous substancesT"
                                          A-3

-------
The ERDF will serve as a management unit for the majority of waste (primarily soil) excavated
during remediation of waste management sites on the Hanford Facility.  The scope of the ERDF
Record of Decision (ROD) is focused on the location and configuration of the landfill (also referred to
as the trench), the liner, and the surface cover. Summary information on the supporting facilities,
including the transportation system, waste handling equipment and procedures, decontamination, and
leachate treatment system, is also presented.  They will be fully addressed during remedial design.
SUMMARY OF ERDF PREFERRED ALTERNATIVE

On the basis of consideration of the requirements of CERCLA, the detailed analysis of alternatives
using the nine CERCLA criteria, the evaluation criteria of NEPA, and public comments, DOE, EPA,
and Ecology have determined that Alternative 4 (Resource Conservation and Recovery Act {RCRA}
double composite liner and the RCRA-compliant cover) is the most appropriate remedial action for
the ERDF for the Hanford Site.

This alternative consists of a deep single trench approximately 20 m (70 ft) deep and 300 m (1,000  ft)
across at the ERDF location with a double-composite liner and, at minimum, a RCRA-compliant
cover.  The cover prevents direct exposure to the waste and includes a vegetated surface layer to
uptake water and fine-grained soils to retain moisture and encourage evaporation, thereby minimizing
the quantity of water  able to reach the waste.  Evaluation of alternative covers that will comply with
ARAR and increase performance will continue. The minimum cover design includes an admixture of
silt and gravels in the top 50 cm (20 in).  This layer is intended to both reduce infiltration through the
cover and to enhance the resistance of the cover to burrowing animals and long-term wind erosion.
In the double liner system the first liner collects leachate, water which passes through the waste and is
contaminated.  This leachate is then pumped from the trench and treated. A second liner below the
first collects any leachate that has leaked from the first liner.

The alternative includes a leachate collection and recovery system, institutional controls, surface water
management, decontamination facilities, waste offloading and transportation, buildings,, equipment
for internal and external communications, personnel protection and mitigation measures to reduce
ecological harm.
                                            A-4

-------
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

A public scoping period was held January 10 through February 8, 1994 to solicit input on the
proposal to build a facility to receive cleanup wastes. Individual scoping meetings were held in Pasco
on January 25 and Seattle on February 1.  The Focus Sheet arid Expanded Public Notice/Washington
State Notice of Intent for Corrective Action Management Unit - Hanford Environmental Restoration
Disposal Facility were provided during the onset of the scoping period to provide available
preliminary information to the public. These documents were made available in both the
Administrative Record and the Information Repositories.

Additional presentations were made to the Hanford Advisory Board, the Confederated Tribes of the
Umatilla Indian  Reservation, the Confederated Tribes and Bands of the Yakama Indians, and the
Hanford Natural Resource Trustee Council.  Many of the concerns expressed by these groups were
addressed within the RI/FS and Proposed Plan for the ERDF.

The major concerns expressed during the scoping period for the ERDF focused on minimizing the
amount of land used for waste management activities. Commentors requested that previously
contaminated areas be considered for siting the ERDF. Several commentors requested that the
agencies consider areas that would minimize the impact to mature shrub-steppe habitat.

The agencies responded to these concerns by down-sizing the land requirements for the ERDF
through the engineering design of a deep area-fill trench.  This reduced the land requirements from
6 mi2 to 1.6 mi2. Additionally, the approved trench will be sized to handle remediation requirements
for the next 6 years and will be expanded only as needed, thereby minimizing the impact on shrub-
steppe habitat. The agencies also conducted an independent siting study considering a contaminated
area for the ERDF.  Due to safety, timing and cost considerations, the site was not evaluated further.
m.    SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
       PUBLIC COMMENT PERIOD AND THE AGENCIES' RESPONSES TO THOSE
       COMMENTS

Written and oral comments received during the public comment are presented in this section .   The
person and group affiliation providing the comment is also identified. Responses  follow each
comment or a series of comments.  The comment responses often reference the Remedial
Investigation and Feasibility Study for the Environmental Restoration Disposal Facility, Rev. 1.

Transcripts of the Fall 1994 public meetings are available for viewing in the Administrative Record.
                                           A-5

-------
 A.    GENERAL

 Comment 1. A member of the general public noted that while the Washington DOE, USEPA, and
 USDOE presented a plan for storage and further cleanup, it appears that they are very slow in
 constructing and getting into operation that vital plant/storage facility, (name)

 Response:  While it may seem as though the initial planning and public involvement phases of
 the ERDF were time consuming, these are vital steps in the process. The ERDF will be ready to
 accept cleanup waste in September 1996, the projected date for the start of continuous and
 substantial cleanup of the Hanford Site.  A RCRA-permitted facility is available at Hanford for
 smaller quantities of cleanup waste generated prior to time.

 Comment 2. A member of the general public commented that they strongly agree that mixed,
 hazardous, and radioactive waste should be buried in the same place.  This simplifies the disposal
 process.

 Response:  Thank you for  the comment.

 Comment 3. A member of the general public commented that the idea of disposing Hanford wastes at
 landfills outside Hanford is ludicrous.  The ERDF should be the choice if all precautions at the site
 and monitoring are in place  from day one and a law is in place that states only Hanford site past-
 practice wastes go into this landfill.

 Response:  The ERDF is authorized under the Comprehensive Environmental Response,
 Compensation, and Liability Act (CERCLA).  By law, only waste generated during CERCLA
 cleanup actions at the Hanford site can be placed in this facility.  Additionally, all applicable
 requirements will be followed for environmental monitoring of the facility.

 Comment 4. Larry Penberthy of Penberthy Electromelt International, Inc. stated that the proposal to
 landfill hazardous (chemical), low-level radioactive, and mixed wastes is a bad idea, landfills for
 hazwaste have gone out of style. If this project is carried out, the net result will be another
 Superfund site, hugely expensive to clean up. The far superior way to handle these wastes is to use a
 Penberthy "Pyre-Converter" furnace which includes a pool of molten glass kept hot electrically.

 Response:  It is not feasible to glassify large volumes of Hanford waste. However, treatment
 options such as vitrification are and will continue to be evaluated during the feasibility studies
 for individual cleanup  actions. It is expected that significant quantities of cleanup wastes will
 require a disposal facility if waste sites adjacent to the  Columbia River are to be restored.

 Comment 5. Columbia  River United commented: We understand that the ERDF .is definitely an
onsite facility, but I'll play the devil's advocate and ask how could we get around that? We could get
around it by having a closure of one of the cells, say in 10 years, and then they could go out for a
permit again, do an EIS or EA on it, and possibly if the public didn't really care, or if the whole way
to do business changed, we were back into the closed-door policy, which I don't think will ever
happen, they could possibly  bring  in outside waste. So one thing we want to make sure from the
public's concern is, mis is a dump for Hanford, it is for cleaning up the site.

Response:  Under the current regulatory framework, the use of the ERDF would be limited to
CERCLA cleanup wastes from the Hanford Site. Any significant changes or future decisions
will require public input.


                                            A-6

-------
Comment 6. The Coho Coalition commented: "I think, first of all, something really unfair has
happened to the public, and that is that we are not really talking about cleanup.  The DOE is not
talking about cleanup; it's talking about a more effective way to treat and store wastes for the country
and possibly from other parts of the world. We don't know yet.  I know they said that this was only
Hanford waste, but that was only for the disposal facility. We have to keep mat in mind.  And I
think that it is really unfair that they haven't made that very clear to the public.

But I am totally against tearing down the buildings.  Our group is not so sure that we think that we
should be worried about the soil, tearing up the soil and bringing it to another area.  The Hanford
Site has been used for all kinds of dumping for years.  The river has been dumped in for years. We
shouldn't be surprised the figures that we are  seeing now. I imagine that they were much higher
many years ago.  I think we should not try and put anything dangerous near the river that we know
that there are underground streams mat are going to carry it into the river.  We need to be concerned
about that.  Maybe that is why we need the disposal  facility to keep some of this stuff away from the
river, but I am very much against removing the soil that is already there, spending the time and the
money to do that to put it into this facility.  I  think that a lot of the buildings we are talking about are
not in the 100 Areas but in other areas of tearing down and removing. We could consider using
those buildings for storing drums, other lands of materials. I don't think because they are
contaminated we should be tearing them down."

Response:  Each building is evaluated for potential uses, including waste storage,  before
demolition. However, the majority of buildings have been there for many years and, in most
cases, have outlived their usefulness. Removal of contaminated soil is only recommended after
an evaluation is made of the risk posed by leaving it in place.  Only after the risk is shown to be
unacceptable and public comment on the remedy sought, will a cleanup  decision be made.

Comment 7. "The Yakama ERWM Program  is not convinced that this ERDF proposal adequately
protects the health and safety of all people.  The lack of protection of human and health safety over
an extended period of time is very disturbing to us.  Present ERDF planning and structure has the
effect of putting real hazard management responsibilities on future generations.  This responsibility is
made more difficult through the below ground disposal option exercise for the facility.  Now in
addition to  finding adequate management techniques our children and their children must also disinter
the wastes that they wish to treat."

Response:  The Tri-Parties recognize the problem of long term management of waste. The
decision to establish a central disposal facility stems from the idea that the current condition,
i.e., numerous uncontrolled waste sites along the Columbia River, is much less desirable.
Consolidation of waste into  a central facility that is well marked and obviously incongruent to
the surrounding environment will help deter inadvertent subsurface intrusion.  The physical act
of disinterring the waste material is technically feasible even by today's standards and,
hopefully, will only improve.  The primary  obstacle to a more suitable option than land disposal
is the development of a practical treatment  alternative for the type of waste projected. An above
ground storage/disposal facility does not appear practical considering safety, technology, and
cost implications.  The disintennent process would not be significantly different for an above or
below ground facility.

Comment 8. A member of the general public  commented: "Well, I've been  out there a long time and
she's talked about a place to bury stuff.  At East and West there's two big tunnels, concrete cover on
them, you could bury a lot of stuff.  Cover taken off and they got about 4 ft of soil on top of them.
Up at Gable Mountain, the Indians had Gable Mountain filled back in again, and up there we have


                                            A-7

-------
holes 400 ft deep and one hole 1,000 ft deep and equipment to drop the capsules in there and release
them.  I know it would take a lot of years, I don't know of any reason why that can't be used to take
and put dry waste,  a lot of dry waste down there.  They were down 400 feet and that was a big hole.
So there's another place a lot of stuff could be put."

Response: Proposals have been made with  regard to using various onsite facilities for disposal of
waste; thus far, no place has had the necessary capacity (even when combined) to accommodate
the waste volume expected.

Comment 9. A Hanford Watch Representative commented: "We support wholeheartedly Oregon
Department of Energy Representative Dirk Dunning's comments tonight that we see that there is a
crucial need for the ERDF landfill, but we feel that Dirk has hit upon some really important elements
that this hasn't been done in the most efficient and most conscientious manner and that we would like
this whole thing relooked at in an as expedient way as possible. Our group is interested in the wastes
at Hanford having a home there.  We are really supportive of not having other wastes brought into
that landfill. We're going to have enough of those issues to face in this nation with the spent fuel and
other things like that.  I also would like to say that we support wholeheartedly that in the redeciding
or redesigning or relooking at ERDF we too support the trustees must be made a part of the decision
in the planning and construction of this.  That is paramount otherwise the trust continues to erode
between us and the Department of Energy and the agencies involved."

Response: Hie Tri-Parties will not consider resiling of ERDF. We feel that resiling will have
unacceptable delays and would pose an unacceptable threat to the environment.  The ERDF
would dispose of wastes generated from cleanup on the Hanford Site.  The Tri-Parties will
coordinate mitigation actions with the trustees.

Comment 10. A Hanford Watch Representative commented:  "If we say yes, we want this landfill,
the one with the double-lined trench and the cap, is there going to be money for it or is this once
again been a pipe dream?"

Response: Current funding levels support the construction of the double-lined landfill.

Comment 11. The  Oregon Department of Energy commented:  "In touring the site on Monday, one
of the things that was impressive about the old growth sage and the road that had been cut through
was the very large piles of tumbleweed that had built up along it even though there's been no traffic
on that road yet. And one of the concerns I have is particularly associated with ERDF, since it's a
larger perimeter area that's going to be involved is it poses a fairly large jeopardy for fire to this very
pristine habitat. And I think that's something  both for ERDF and for the road and any other areas
bordering those facilities needs to be very carefully considered and preventive measures be put in
place to ensure that doesn't happen."

Response: The Hanford Site has a tumbleweed control program to remove and dispose of
tumbleweeds that accumulate along fencelines and other barriers.  The facility operator will be
responsible for fire prevention activities within the fenced portion of the ERDF site.
Additionally, water service for fire control is being extended to the ERDF site as a  precautionary
measure.

Comment 12. A member of the general public commented: "I want to address the issue of limiting
mis to Hanford waste only.  I think that the whole thing that is happening at Hanford has to be looked
at as a whole, not just hi some little narrow areas here and there. Because what's happening there is


                                            A-8

-------
 like some person digging a ditch in one side and they're shoveling the dirt out while at the same time
 somebody's behind them shoveling dirt right back into it again.  So it never really gets anywhere
 because this program you're talking about here tonight is not operating in a vacuum or hermetically
 sealed box where it's just happening all by itself separately.  I don't really see how you can keep
 talking about environmental restoration without addressing the continued additions of great volumes of
 various radioactive materials such as the Trojan Power Plant remains, medical science waste and
 foreign wastes, etc., that will be coming in the future.  In reality when you think about it,  what is
 going to happen in the future? Hanford is the only place to put a lot of this stuff. You either have to
 leave it where it is or put it some place and where else is stuff going to go, radioactive stuff.  There's
 just no where else basically because either the other areas don't want it or don't have any ability to
 take care of it except Hanford.  I really think that you need to plan for this and not just figure it out
 as it comes up.' Each episode at a time."

 Response: The purpose of the ERDF project is to make available a disposal facility to accept
 cleanup wastes from the Hanford Site.  Other programs within the DOE are exploring disposal
 alternatives for other radioactive wastes.                                            -       .
B.  ALTERNATIVES

Comment 1.  One member of the general public commented that alternative plan 4 should be adopted
at the ERDF site at Hanford.

Response:  Thank you for the comment,

Comment 2.  One member of the general public commented that they agree that the ERDF should be
constructed, and that the proposed alternative, use of a double RCRA liner, is the best choice.

Response:  Thank you for the comment.
C.  REGULATORY PROCESS

Comment 1. A member of the general public commented that they strongly agree that only the
requirement of CERCLA should be used for this project.  By not trying to apply RCRA or the State
Environmental Policy Act (SEPA), resources can be spent on facility construction (versus) paperwork.

Response: Thank you for the comment.
D.  SITING OF THE ERDF

Comment 1. A member of the general public commented mat they agree with the proposed size and
location of the ERDF.

Response:  Thank you for the comment.

Comment 2. The Confederated Tribes of the Umatilla Indian Reservation (CTUIR) commented that
the siting of the ERDF was a decision that DOE made internally, without consulting with affected
Indian tribes or natural resource trustees, and without public involvement. This was simply improper.


                                            A-9

-------
 Virtually all ERDF impact decisions derive from the choice of site.  DOE has made the most
 important decision behind closed doors and then allows everybody else to argue about how it will be
 implemented.  This is a sham of tribal consultation or public involvement.

 DOE has no excuse for excluding tribes, trustees and the public from the siting decision.  If the
 RI/FS were an EIS, it would have to include alternative sites.

 We agree that for practical reasons it is pointless for DOE to try to go back and undo the harm this
 time. They have forced the tribes, trustees, and public into the position dial if we protest this
 violation of our rights, we force delay in the remediation of the Columbia River area. That result is
 even more intolerable than being barred from the ERDF siting decision.  Nevertheless, DOE should
 not conclude that it is acceptable practice to play these sorts of political games with consulting
 governments. DOE failed to perform proper process and to consult with the CTUIR regarding siting.
 We ask that DOE admit as much in its response to comments.

 We also ask that DOE commit in writing to work closely with the CTUIR and other tribes and
 trustees to plan the location and impact of future projects in the Central Plateau before making
 effectively irreversible decisions.  This need is particularly critical in the 200 Areas, where siting
 decisions about a variety of facilities are essentially being made in an uncoordinated manner within
 DOE, and without consultation with tribes  and other trustees.

 We urge DOE to begin, with the full participation of tribes and trustees, a comprehensive planning
 process for the location of future DOE facilities  at Hanford.  These decisions directly affect the
 CTUIR's treaty rights and the potential liability of DOE to the natural resource trustees.  As the
 ERDF  and the 240 Road Access Extension decisions demonstrate, DOE is currently making these
 decisions with essentially no consideration of the impacts of these decisions to natural resources or
 treaty rights.  This is  an unacceptable practice, and should be reformed immediately.

 Response: It seemed most effective to rely on the ERDF siting evaluation report to describe
 siting alternatives rather than reproducing the document in the RI/FS, which is  already rather
 voluminous.  Based on comments received from the public during the scoping process, the
 proposed  site was down-sized from 6 mi2 to 1.6 mi2 and moved north into an area that the State
 of Washington had leased from DOE for industrial and waste management purposes.  In this
way the ERDF is entirely encompassed within the waste management area identified by the
Hanford Future Sites Uses Working Group (HFSUWG).

 It is true that when the initial siting evaluation was performed, the Indian tribes were not
 directly consulted. However, site selection was considered and commented on during scoping.
Based on scoping, another site was considered. An evaluation for this site was completed but
the site was not chosen.

DOE recognizes that the tribes and natural resource trustees have a role to play in future siting
decisions.  There are efforts underway to open the Hanford site evaluation process to include
affected Indian tribes and other interested parties. To that end, DOE is developing a
comprehensive land and  facility policy that provides a basis for ecosystem-based land-use plan
accomplished with tribal and trustee involvement. The end goal of land management policies at
Hanford is to avoid impacts to natural resources and to evaluate mitigation options for those
Impacts that are unavoidable.
                                           A-10

-------
 Comment 3.  CTUIR commented that under typical National Environmental Policy Act analysis, the
 scope of alternatives is based upon the purpose and need for the proposed action. In the case of
 ERDF, the purpose and need statement is found at section 1.2 of the RI/FS and is reprinted hi the
 NEPA Roadmap. The purpose of the ERDF is  "to support the ... removal of contaminants from
 portions of the Hanford Site in a timely manner .  . . ."  The need is "to support the disposition of
 contaminants during restoration activities on the Hanford Site."  This is a well-drafted purpose and
 need statement, reflecting the true priorities for the ERDF. Nothing in this purpose and need
 statement, however, places any practical limit on the location of the ERDF site. This purpose and
 this need cannot be  used as  a basis for limiting the proposed action and alternatives to only one site.

 Response: It is true that the purpose and need statement does not limit the location of the
 facility (other than an implicit assumption that it not be located near the Columbia River). The
 criteria to be most protective of human health and the environment and to keep  the facility on
 the central plateau within  the squared-off boundaries of the 200 Areas significantly limits siting
 options.  The Tri-Parties believe that the site chosen is most favorable for long-term
 protectiveness, consolidating waste management activities, and to support environmental
 remediation activities.

 Comment 4.  CTUIR commented:  We also could find no analysis in the RI/FS that identifies why the
 rail spur is being constructed where it is.  The map at 9F-1 (in the RI/FS) indicates that there are
 much shorter routes that might well avoid destroying as many natural resources as the proposed route
 does. Why is not the rail line going to be attached to one of the nearby spurs in the 200 West Area?

 Response: It should be noted that the project has been modified to exclude construction  of the
 rail at this time. Instead,  waste will be delivered to.the facility in tractor-trailers over the
 Hanford road system. The rail spur was not attached to one of the nearby spurs in the 200
 West Area because:

 •     The alignment of the rail through 200 West Area would adversely affect existing area
       operations, would require rail crossings at Beloit Avenue, 23rd Street, and 27th Street,
       which would create unacceptable train-vehicle safety hazards.

 •     Much of the acreage located inside the 200 West Area would be fragmented by the rail
       line and unavailable for waste management activities (thus requiring location elsewhere
       on the Hanford Site).                .

 Any future rail  proposal would require a NEPA analysis and decision.

 Comment 5.  CTUIR, Oregon Department of Energy, and U.S. Department of Interior - U.S. Fish
 and Wildlife commented that the ERDF facility is proposed to be sited in the middle of the last of the
high-quality shrub-steppe habitat at Hanford. This habitat is home to at least 11 species of special
concern. Washington State  identified this habitat of particular importance for preservation.

We were not formally notified and consulted in their Trustee roles for the planned activities as
required by the Comprehensive Environmental Response, Compensation and Liability Act. When we
learned of the Tri-Parties' plans, we requested the Tri-Parties present their plans to and consult with
us. The presentation by the Tri-Parties raised even more serious questions about the siting process.
                                            A-ll

-------
 When we suggested it might be necessary for the Tri-Parties to reopen the siting process, the Tri-
 Parties responded that reopening the siting process would delay opening of ERDF and cleanup of the
 100 Areas by 2 years, and could possibly jeopardize funding of Hanford cleanup by Congress.

 This placed us  in a completely unacceptable position. If we actively object to and oppose the siting
 process, we will be blamed for delaying and jeopardizing the whole cleanup.  If we do not object, by
 omission we allow the destruction of a large area of rare habitat needed by the Loggerhead Shrike,
 the Sage Sparrow, the Whiptail Snake, and eight other species of concern.

 In our role as Natural Resource Trustees, we cannot endorse the  Tri-Parties plans.  At the same time,
 we cannot reasonably oppose the ERDF  facility without placing other habitat and human health in
 further jeopardy.

 It is absolutely  vital that the U.S. Department of Energy, Washington State Department of Ecology,
 and the U.S. Environmental Protection Agency not allow a repeat of this error.  The Trustees must be
 made an active part of all planning that could result in impacts to the ecosystems and species at
 Hanford.

 Response: The siting process has obviously been less than satisfactory to the concerned parties.
 The Tri-Parties have, however, attempted to incorporate into the siting decision the multitude of
 values expressed over the course  of the environmental restoration process.  The Tri-Parties
 recognize that  the natural resource trustees are concerned about siting decisions that have major
 land use implications.  To that end,  DOE is developing a plan to involve all Natural Resource
 Trustees and affected Tribes  in siting decisions.

 Comment 6.  CTUIR, Oregon Department  of Energy, and U.S. Department of Interior - U.S. Fish
 and Wildlife commented that the process used to site the ERDF is unacceptable. The following are
 several specific areas where the RI/FS and  the Siting Evaluation Report (SER) for the Environmental
 Restoration Disposal Facility fall short.

 The SER is based on an early design assumption of a 6-mi2 site.  Only areas with a contiguous 6 mi2
 were evaluated  in the SER. The ERDF  as  currently proposed will occupy an area of up to 1.6  mi2.
 The dramatic de-sizing of the facility has not resulted in a re-evaluation of potential sites. This issue
 is only superficially addressed in the RI/FS's Fig. 1-3. The figure is limited to the  Hanford  Future
 Site Uses Working Group (HFSUWG) "exclusive" zone and assumes large tracts of land are
 unusable. The  figure has no accompanying explanation or references.

 The SER does not allow for consideration of areas placed in reserve for other purposes.  The Tank
 Waste Remediation System (TWRS) plans place off-limits three large areas. Only one of these  will
 be needed for TWRS. The siting of facilities must be coordinated, but should not be limited in this
 way.

The northwest corner of the 200 West  Area was not considered because it was placed in reserve for a
potential National low-level and mixed waste repository. This is  completely unacceptable. Hanford
uses must be given first priority over uses from offsite.  It is particularly unacceptable that ERDF be
sited in an area of such important habitat when another similar disposal facility is reserving space in
 an area of lower habitat value which is entirely within the fence line of the 200 West area.

The HFSUWG  placed a high priority on limiting waste management activities to within the fence line
of the 200 Areas, and only expanding  into the area between the 200 Areas if there was not enough


                                            A-12

-------
 room inside the fence line.  In the opinion of the Trustees, siting of a national repository on the
 Hanford site should not be considered until siting for all Hanford needs is done.

 The SER uses as one of its central assumptions the HFSUWG recommendation to "Use the Central
 Plateau wisely for waste management."  However, the SER does not address another recommendation
 of the HFSUWG, to "Do no harm during cleanup or with new development." Included in that
 finding is a statement that "habitat should be protected as cleanup and future development proceeds."

 Response:  As is evident from the comments, the issue of siting is complex and controversial.
 The siting  evaluation was re-visited when the facility land requirements were down-sized from
 6 ml2 to 1.6 mi2. It was determined that unless down-sizing was far more significant (less than
 1 mi2),  there was only one additional site readily available on the Central Plateau within the area
 defined by the Hanford Future Sites Uses Working Group for waste management.  A siting
 evaluation was performed for this additional site (the BC Control Area). This additional site
 was not chosen because of its current contaminated condition and other difficulties.

 In considering future land use requirements of projects such as the new tank farms, it is DOE's
 position that it would be irresponsible not to consider the acreage requirements of these
 proposed projects.  The siting process considered the desires expressed by numerous parties to
 expedite Hanford  cleanup in a safe and cost effective manner.

 Comment 7. Columbia River United commented:  The other question came up that in the selection of
 the site, there were four proposed areas, and the one in between 200 West and 200 East Areas was
 chosen.  But after doing some investigation, we found that the northwest corner of the 200 Area was
 basically not even being considered.  And we wondered why.  We found that there's a possible
 proposed national low-level mixed waste disposal, facility that's going in there potentially.  It's
 proposed, and I don't know if this is something that's outdated.

 Response:  The 200 West Area was considered both early and late in the siting process and was
 eliminated as a candidate site for reasons other than those stated in the comment.  The
 overriding consideration has centered around the ability to expand the facility as needed.  The
 volumes of waste are very imprecisely estimated because they rely on knowledge that is not
 currently available, for example: the extent of contamination of the numerous waste units; the
 final land-use designation which will determine the extent of removal actions needed; the
 practical application of waste reduction technologies. All these factors contribute to the ultimate
 size of the  ERDF and make it imperative that the site chosen be cost effective and avoid having
 to re-site and move the facility at each expansion.

 Comment 8. The U.S. Department of the Interior commented that:  Habitat was only summarily
 considered  in the SER's Site Selection section. The SER lays out seven criteria derived from USDOE
 orders.  Habitat is discussed briefly in the Site Acceptability and Potential Consequences section, and
 the  currently proposed site is found to be the least desirable. Within the site evaluation, sites are only
 qualitatively compared. No attempt is made to rank or weigh the seven criteria. While habitat
 quality varies greatly between the sites, other criteria such as Topography and Geology do not
 significantly differ.  In future site evaluations, habitat quality should be carefully considered, and the
 criteria should be addressed in proportion to their potential significance.

 Response: In earlier revisions of the Siting Evaluation Report the ranking criteria were
weighted.  Comments from Internal and external reviewers took exception to weighting and felt .
 it wns hot justified, and the evaluation was subsequently redone.


                                            A-13

-------
 At three of the four candidate sites, habitat quality does not differ significantly, particularly
 since the ERDF has been moved as far north as possible to avoid native habitat.  On the other
 candidate site with  less valuable habitat, topographic as well as geologic considerations (e.g.,
 depth to groundwater, general stratigraphy) contributed significantly to a lower preference for
 that site.  Topography, geology, and geohydrology are most favorable at the preferred ERDF
 site. For the future, DOE is developing an ecosystem-based land-use plan.
 Comment 9.  The Yakama Nation ERWM Program recognizes the reevaluation which has reduced the
 proposed site from the original 6 mi2 to the current 1.6 mi2.

 Response: Thank you for the comment.

 Comment 10.  The Yakama Indian Nation commented: In addition to human and health and safety
 issues, we're disturbed that there appears to be a limited commitment to the mandate to not cause
 additional disturbance during remediation activities.  The ERDF represents a nearly 2-mi2 disturbance
 to the environment.  If the area currently targeted for the ERDF is covered with old growth
 sagebrush, this is a unique shrub-steppe community that is quite sensitive to perturbation.  Old growth
 sage represents the habitat for a number of both mammalian and avian species. We feel that natural
 resources are at risk if the Hanford mission has  indeed shifted to environmental considerations then
 activities should not pose a greater risk to sensitive resource areas.

 Response: The proposed ERDF site is composed of a mix of habitat types, ranging from mature
 shrub-steppe habitat at the eastern end, to previously disturbed areas, such as the REDOX lay-
 down yard, at the western end.  DOE intends to limit  disturbance during environmental
 remediation as much as possible, but we must expect difficult trade-offs between competing
 priorities in the future. Because of the long-lived nature of the radiological contaminants, DOE
 must take a long-term  view of the situation when weighing the positive and negative aspects.
 There will be'disturbance of existing habitat at the ERDF site. However, DOE intends to
 minimize that  disturbance to the extent possible, and to mitigate for those losses that cannot be
 avoided.
 E. MITIGATION

 Comment 1.  The Lower Columbia Basin Audubon Society representative commented: We're very
 concerned that the restoration and mitigation is not going to happen. We've got the north slope as
 our example of how it's done.  I don't want to just stand here and criticize the Department of Energy,
 the Corps of Engineers. What we want is the north slope to be restored and we want the ERDF area
 to be, the minimal amount of habitat to be disturbed.  Keep it at the very minimum and men after the
 job is done, get in there and restore it.  Now you just told us that we're only going to be disturbing
 165 acres over the next 5 years.  I think right now, we need to start mitigating for the entire 1.6 m?
 so that these species have a place to migrate to.  I don't think it's of any value to go in there and just
 rip up all this habitat and then a couple of years later go over a mile and try to start reestablishing.  It
 takes tune for these native grasses and shrub steppe, sagebrush to mature.  So we need to get in and
 do it as early as possible.  We're off to a bad start. I hope we can turn that around. Thank you.
 Comment 2.  CTUlK commented:  We simply wish to emphasize that, for decisions to be made in a
"Cooperative and trusting environment, DOE must be willing to disclose information, consult fully, and
 make real commitments — even, sometimes, commhments mat go beyond the bare minimum that the
                                            A-14

-------
 law requires.  Is DOE willing to make such commitments?  In the case of mitigation for impacts from
 the construction of ERDF, DOE has made no commitments, only promises to examine the issue
 further.  The CTUIR  can put little faith in such nice-sounding but non-binding words.

 As steward of Hanford's natural resources, as the agency that manages the CTUIR's trust resources at
 Hanford, and as a natural resource trustee for Hanford, DOE has a duty to manage Hanford's natural
 resources wisely and to conserve those resources.  If DOE is going to irreversibly commit natural
 resources at Hanford, it should also commit to fully mitigate those impacts. That commitment should
 be made in concrete terms by which DOE's performance of its commitment can be measured. That
 commitment should also be made in good faith consultation with the tribes and the other natural
 resource trustees. We request that DOE,  in compliance with its own NEPA mitigation policy, begin
 discussion  with the tribes and other trustees of concrete mitigation plans for impacts associated with
 the ERDF  project.  We further urge that DOE commit to fully mitigate for ERDF impacts, and that
 the goal  of these discussions be  concrete,  measurable, enforceable commitments by DOE that are
 designed to fully mitigate these impacts.                                             .

 Response:  DOE commits to minimizing  habitat loss to the extent possible. This project was
 downsized in part to minimize habitat disturbance. We recognize that the shrub-steppe
 vegetation community plays an increasingly important role within the Columbia Basin,  because
 this habitat is rapidly shrinking elsewhere in the region.  In addition to minimization, DOE
 intends to  evaluate mitigation options for the  loss of habitat on the ERDF site, in coordination
 with the Natural Resource Trustees.

 Comment 3. The Trustees commented that mitigation for impacts to natural resources is required
 under several statutes. ERDF is part of a series.of CERCLA hazardous substance response actions,
 and as such, restoration of natural resources injured by the construction and operation of ERDF is
 required under CERCLA Natural Resource Damage Assessment (NRDA) provisions:  NEPA requires
 agencies preparing EISs to address appropriate mitigation measures (40 CFR  1502.14f,  1502.16h,
 1505.2d, and 'I508.25b).  USDOE regulations also require a mitigation plan to be developed (10 CFR
 part 1021.331).  Finally, USDOE, as a federal land manager, has stewardship responsibilities for
 natural resources.

 Mitigation  under both CERCLA and NEPA includes, in order of preference:

 a) Avoiding the impact altogether by not taking a certain action or parts of an action

 b) Minimizing impacts by limiting the degree of magnitude of the action and its implementations

 c) Rectifying the impact by repairing, rehabilitating, or restoring the affected natural resources

 d) Reducing or eliminating the impact over time by preservation and maintenance operations during
the life of action

 e) Compensating for the impact by replacing or providing substitute resources.

The ERDF siting process did not consider impacts to habitat, and  those impacts were not avoided or
minimized. Compensatory mitigation for habitat destruction must be provided.

The RI/FS  identifies development of a mitigation evaluation (page 9-31) but contains no commitment
to actually perform mitigation for habitat destroyed by the proposed project.  USDOE must fully


                                            A-15

-------
 commit to mitigating for habitat destruction in both the RI/FS and in the Record of Decision (ROD)
 to ensure funding will be appropriate and guaranteed for implementation of the mitigation actions.
 The NRTC also recommends preparation and submission of a mitigation evaluation and
 implementation plan be identified as an enforceable interim Tri-Party Agreement (TPA) milestone.

 The RI/FS identifies habitat removal as an irreversible and irretrievable commitment of resources.
 The Natural Resource Trustee Council (NRTC) strongly recommends that any onsite natural resources
 that are identified as irreversible and irretrievable commitments should be fully mitigated for.  The
 habitat impacts associated with the McGee Ranch "borrow" site are not well documented in the
 RI/FS. Because a "borrow"  site for basalt has not yet been identified, these habitat impacts cannot be
 documented.  This lack of information will be an impediment to creating an adequate mitigation
 evaluation.

 The mitigation evaluation should be developed concurrently with this environmental planning process
 and comprise an  integral part of it.  The  benefits of mitigation planning early in the planning process
 include a more efficient and cost effective cleanup. The NRTC is concerned that delaying  -
 development of the mitigation evaluation until after the ROD is signed may result hi an ineffective
 plan which is not supported by adequate funding, staffing or support.

 The ERDF RI/FS mentions the Hanford sitewide mitigation plan, but does not clarify whether
 mitigation for natural resources impacts will occur as part of the sitewide plan or as a project specific
 plan.  The sitewide mitigation plan is in an early draft stage.   The NRTC supports the sitewide
 mitigation plan as the most effective method to protect, preserve, and enhance habitat and other
 natural resource values, and supports ensuring ERDF mitigation measures are consistent with the
 sitewide plan.  However, if the sitewide plan does not go forward, the ERDF mitigation plan must
 compensate for natural resource impacts as an independent plan.

 If USDOE chooses to  address ERDF mitigation under the sitewide plan before the sitewide plan has
 received official sanction, a legally binding commitment between USDOE and the Trustees will be
 required prior to issuance of the ROD to ensure ERDF mitigation.  Even though a sitewide mitigation
 plan for the Hanford site is being developed, this does  not remove the need to conduct  site-specific
 analysis to determine mitigation needs and requirements for individual projects. The October 26 draft
 of the plan states that it is not intended to provide specifications and procedures on conducting habitat
 improvements or protection for specific projects.

 Mitigation for adversely impacted resources must be based not only on the amount of habitat lost, but
 also on habitat quality and value.  For example, linear disturbances such as the proposed rail line will
 fragment blocks of habitat. Figure 9-1 shows that two substantial blocks of habitat will be fragmented
 by the rail line: between the north border of the proposed ERDF site and route 3, and between the
 north border of the 200 West Area and route  HA. Linear fragmentation of shrub-steppe habitat
 allows the spread of noxious weeds into relatively pristine or intact habitats. Other more subtle
 impacts may also occur.

 Similarly, the value of McGee Ranch as a habitat corridor between Hanford and the Yakima Training
 Center, two large areas of relatively undisturbed shrub-steppe  habitat, must be assessed and mitigated
 for. As the borrow site for basalt barrier material has not yet been identified, it is not clear what
 additional habitat values may  need to be considered.
• '  .'  '•*'  .  ,--• .1  i . ..       '
 Mitigation for habitat loss requires long-term planning.  The NRTC makes the following
 recommendations:
                                             A-16

-------
 1.     Native seeds and nursery stock are very limited. There will be competition for available
       stocks from other Hanford and non-Hanford projects. To make this volume of material
       available in a timely manner, planning and propagation should start as soon as possible.

 2.     USDOE should begin immediately to develop the needed nurseries and seed stocks to allow
       this habitat restoration/improvement to occur as soon as possible. We suggest USDOE
       develop a long-term contract for the construction and management of a native species nursery
       to provide revegetation material on a sitewide basis.

 3.     Ensuring revegetation success  is  crucial to the successful mitigation of habitat values.
       Monitoring of the mitigation site for a minimum of .10 years is recommended, and funding
       should be identified to support this effort.

 Response:  DOE is committed to the preparation and implementation of a Mitigation Action
 Plan for mitigation of the ERDF. The development of this plan will be coordinated with the
 Hanford Natural Resource Trustee Council.  Although DOE agrees that concrete habitat
 mitigation commitments are necessary, it will be difficult to commit  to specific mitigation
 measures  at this time,  because  the technical needs and criteria of the surface cover are not yet
 identified, and because the final size of the ERDF landfill will depend entirely on the decisions
 made at the source operable units in the future. Because of these  uncertainties, the Mitigation
 Action Plan will probably be periodically revised and supplemented, as additional engineering
 and biological data become available.

 Comment 4.  The Oregon Department  of Energy commented:  In particular, a number of things in the
 ERDF gave us a  lot of concern.  One of them has to do with the point that has already been
 mentioned a little bit about the NRDA provisions under the Superfund law.   There are provisions
 within that are going to be problematic hi the future because the costs associated with this facility are
 not just the costs  of today. There are  also the costs associated with the damage done to the habitat
 where this facility is going to be placed.

 Response:  Thank you for the comment.

 Comment 5.  The Coho Coalition commented:  I would like to comment on restoring the area for
 environmental beautification. A  lot of this is a waste of tune. This area is  never going to be
 considered an area where people can come and where it is going to be clean. This area is being
 cleaned up for treatment and storage of wastes. The money that we spend to try and clean something
up, to beautify it for the public, is  a waste.

Response:  It is accurate to note that the area cannot  be restored to the exact condition  it was in
 before it was used for nuclear fuel production and fabrication. However, great strides can be
made to restore  and  enhance the area for general use by future generations.
F. WASTE ACCEPTANCE CRITERIA FOR THE ERDF

Comment 1.  Columbia River United commented that the waste selection criteria must be designed to
limit the total amount of waste. Emphasis must be put on waste reduction/compaction and recycling.
The goal must be to limit the overall size of ERDF.
                                            A-17

-------
 Columbia River United also questioned "Is, cleanup going to be digging up the whole site, just take a
 backhoe, dig it up, put it in a truck and dump it in the ground and put a big mound out there, who
 knows how big and how long and how high, and that's cleanup?  or is cleanup really going to be
 finding the best available technologies, reducing the actual waste that we're burying and do the best
 available job with the best minds out there...  So in the waste criteria selection we want to make sure
 that they utilize the best available technologies to limit the amount of waste they have and also to
 recycle or reuse anything that can be used out there and we have to be involved with that process to
 make sure that they do it."

 Response:  New and innovative technology identification is a key element to the remediation
 selection process.  Treatability studies are being carried out to explore waste minimization
 possibilities. These  technologies will be evaluated, if applicable, in the Focused Feasibility
 Studies for each operable unit cleanup.  Remedy selection will be made in the Record  of
 Decision for the individual operable unit cleanups.  ERDF will accept  the waste if it is identified
 in these RODs for disposal at ERDF.

 Comment 2.  The Trustees commented that the radioactive and hazardous wastes from the 100 Area
 cleanup will continue to pose a threat to people and the ecosystem for so long as they remain
 dangerous.  Many of the radioactive materials released in the 100 Areas have extremely long half-
 lives.  Many of the hazardous materials are extremely persistent.

 Closure of ERDF must protect  the Tribal Treaty rights of the Confederated Tribes and Bands of the
 Yakama Indian Nation, the Confederated Tribes of the Umatilla Indian Reservation and the Nez Perce
 Tribe.

 Response:  ERDF will be dosed with, at a minimum, a RCRA-compliant cover.  This  cover is
 protective of human health and the environment and will allow limited uses of the site following
 closure.
Comment 3. A member of the general public commented that "Mixed waste generated in the state of
Washington should be allowed to be buried in this landfill.  There currently is no other way to
dispose of this waste, and the quantity (volume) from onsite and offsite generators would be orders of
magnitude smaller than that generated during Hanford cleanup activities. It would not be cost
effective to build another pit in the state to dispose of these wastes. A new pit would probably be
located on the reservation anyway, adding millions of dollars of new permitting and administrative
costs.  These mixed wastes, just like the Hanford wastes, would have to meet RCRA requirements,
such as treatment standards."

Response:  Under .the current regulatory framework, the use of the ERDF would be limited to
wastes generated from cleanup under CERCLA on the Hanford Facility. Public comments to
date have expressed a strong desire that ERDF be limited to accept only wastes generated  from
Hanford cleanup efforts.    '                '

Comment 4. Columbia River United commented  mat "The regulators need to tell die public what
they propose to do with the soil mat does  not meet the current Curie [radioactive] content of ERDF.
CRU feels that this is one factor that has not been discussed and is a critical part of the entire she
remediation. Are the regulators proposing to build another site that will store this HOT soil until
further remediation can be done?" —             :   ;  "•'••
                                            A-18

-------
 Response: High-level wastes, transuranic wastes, and wastes exceeding the Class C (Greater
 Than Class C, or GTCC) limit as defined in 10 CFR 61.55 will not be disposed of in the ERDF,
 as they are not acceptable for near-surface disposal.  If encountered, these wastes would be
 treated and/or stored until such time that an appropriate disposal facility becomes available.
 There is likely to be little or no soils that exceed an activity level that would necessitate disposal
 elsewhere.  Low level wastes classified as Class A or Class C, using criteria defined in 10 CFR
 61.55, are acceptable for disposal in the ERDF.

 Comment 5. Columbia River United commented: "For the environmental restoration disposal
 facility, as I stated earlier, the public must be involved in the waste criteria selection set for this site.
 We hope this will limit the size and materials buried in this landfill and assure waste reduction, and
 we want to make sure all possible available technologies assured the lowest amount of waste and that
 recycling of any items out there that we can use for something else be looked at and actually be
 done."

 Comment 6. Heart of America Northwest commented: We want to ensure that strict acceptance
 criteria are in place.  We also want to have some public input into that process. We feel it is
 important enough for the public to be able to work with you on that and give you input on it.

 Response:  Waste acceptance criteria are fundamentally dictated by state and federal  regulations
 as well as DOE Orders.  The regulations limit ERDF waste acceptability primarily in the areas
 of chemical concentration, radioactivity level, treatment standards, and waste form. The
 generation of the waste at remediation sites must be where the decisions concerning waste
 reduction, innovative technologies, recycling, etc., are made. Public input into those decisions
 will be sought during public involvement periods for the operable units.

 Comment 7. Heart of America Northwest commented:  "I know that there is also a possibility that
 there will be a Resource Conservation and Recovery Act permit applied for by this facility, which
 may not be limited to only Hanford waste at some future date.  I just want to put on record that we
 are very concerned about offsite waste. I am also concerned about what I have understood is the
 potential for proposal for a new disposal facility for offsite waste in the north corner of the 200 West
 Area.  That is a serious concern, especially since stakeholders have said repeatedly that they do not
 want offsite waste.  I realize it is DOE's plan to start playing a shell game with DOE's waste from
 INEL and Rocky Flats, etc. But we don't accept the premise that just because we are large we
 should take all  of their stuff."  .

 Response:  Under the current regulatory framework, the use of the ERDF would be limited to
 wastes that are generated from cleanup under CERCLA on the Hanford Facility.  There are
 currently no plans to permit the facility under  RCRA.

 Comment 8. A member of the general public commented: "I want to say mat I am glad that you
have made a commitment not to accept waste from outside of the Hanford Site; everybody agrees that
 would be a bad idea.  Obviously you have to make some commitments to that in writing that you are
going to stick to."

Response:  Thank you for the comment.

 Comment 9. Heart of America Northwest, on ERDF. We are concerned that the waste acceptance
criteria very explicitly include Washington Sale's management priorities as treatment standards.
Washington state has in its law a set of waste management priorities that say you don't landfill unless


                                            A-19

-------
 you can treat and have attempted to treat, and this is very important that we insist that these be
 followed. Now, a second concern that rises from that is the fact that you said in the presentation
 either Norm or Pam that ERDF would follow Washington State laws, but and that you would not
 accept any extremely hazardous wastes which is a Washington State term for  a certain level of
 toxicity.  And you wouldn't accept transuranic waste, etc.  I am concerned mat apparently there is an
 effort to place a low-level waste dump at Hanford or expand the current site to include both Hanford
 and non-Hanford low-level wastes.  What is very disturbing to us is that the Westinghouse Hanford
 Company has been using our tax dollars to lobby for an end to the regulation  that creates the
 extremely hazardous waste category in Washington State law.  They have been lobbying to lower to
 10% of the current standard what is a dangerous waste.  That would mean that 90% of the wastes that
 are now expected to be dug up to go into ERDF because of then- toxicity levels would suddenly be
 reclassified as low-level wastes only and they'd be free to go from a RCRA-compliant double-lined
 trench.  We are glad that you are choosing that option and now they'd be going instead to simple
 "random" disposal in unlined trenches with no leachate collection system, no monitoring
 requirements, and no regulator oversight by Ecology or EPA.  And we are very concerned about that
 and we would like a response on the record as to why Westinghouse Hanford  Company has -been
 allowed to lobby for those two changes on our federal tax dollar, which we understand is illegal.
 Secondly, we would like responses to what the impacts would be of eliminating EHW as a category
 and lower the toxicity level to 10% of what it is currently is for dangerous waste in terms of
 protection of human health .and the environment as we cleanup Hanford  and dig up soils that we need
 to dig up and remove."

 Response:  The ERDF will be a landfill that is regulated by the CERCLA, and as such, it is
 subject to applicable or relevant and appropriate requirements (ARARs).  The Resource
 Conservation and Recovery Act (RCRA) and Washington State's Dangerous Waste Regulations
 (WAC 173-303) will be the primary regulations under which the ERDF will be operated.  WAC
 173-303 contains the management priorities to which you allude. The applicability of these
 standards will be evaluated and  determined in the feasibility studies, proposed plans and RODs
 fortheOUs.'

 The Low-level Burial Grounds (LLBG) on the Hanford Site is a RCRA landfill that has interim
 status. The LLBG dispose of low-level waste from other DOE sites and defueled  submarine
 reactor compartments. As a CERCLA landfill, the ERDF cannot accept waste from outside the
 Hanford Facility. The Hanford Facility is defined in the Hanford Facility RCRA Permit.

 The assertion that "...90% of the wastes that are now expected to be dug up to go into ERDF
 because of their toxicity levels would suddenly be reclassified as low level  wastes only..."  appears
 to assume that 100% of the wastes to be generated by ER remedial actions would be otherwise
 classified as EHW; in fact little of the remedial waste to be generated by remedial actions is
 anticipated to be EHW. Instead, the majority of the waste is  expected to  be Category A  or
 Class 1 LLW, which will be excavated, transported, and disposed of in bulk form in the  ERDF.
 Given that little of the remedial waste is anticipated to be classified as EHW, the  impact  on the
 ERDF of redefinition of the EHW levels as noted in the comment would be negligible; very little
 remedial waste would be impacted.           .

 Comment 10.  The Yakama Indian Nation commented:  "Waste acceptance criteria are being
 formulated. We would support criteria mat meet the nuclear waste policy act  500-year past closure
requirements.   We're opposed to the long-term reliance on institutional controls for safety and health
 assurance. Aside from a lower long-term effectiveness,  such policy is against the nuclear waste
policy act, which calls for unrestricted use of a site after 500 years past closure."


                                           A-20

-------
 Response: It is assumed that institutional controls (such as, deed restrictions, fences, etc) will
 prevent intrusion into the waste for at least 100 years and that passive controls (such as,
 markers, barrier, etc) will prevent intrusion for 500 years. Furthermore, it is assumed that
 because the waste is covered with at least 4.6 m (15 ft) of cover materials, inadvertent intrusion
 into the waste due to excavation is minimized. Since none of the evaluated barriers can prevent
 penetration by a drilling rig, however, it is reasonable to assume that someone might
 inadvertently drill through the waste sometime after 500 years. The likelihood that someone will
 drill through the waste is not addressed.

 Comment 11.  A member of the general public commented:  "I also must admit that I am a little bit
 skeptical when I hear some assurances that all of this business is going to be for Hanford waste only.
 This particular project might be. But next year when the nuclear waste policy act is opened up, there
 may be a  lot  of political pressures that change the whole scene and everyone I think has to be very
 vigilant and take on all kinds of possibilities that might happen.  I think the public is a little bit
 skeptical when we see so many problems coming from what we had thought was being handled before
 by smart scientists and planners in the government.  We would like to see comprehensive coordinated
 plan."

 Response: Thank you for your comment. DOE at Hanford is integrating the Tank Waste
 program  tasks and the Environmental Restoration Program.  Hanford is one of 26 sites that will
 be further evaluated for a possible mixed waste disposal facility for the disposal of treatment
 residues.  No decisions have been  made at this time and public participation will be solicited.
G. FACILITY DESIGN

Comment L A Hanford Watch Representative commented:  "We still have the question of the mis-
definition of low-level and high-level in this country.  You say high-level and transuranic waste will
not go into this landfill, only low-level waste.  Some low-level waste is much more toxic, much more
radioactive, and much more long-lived than some of the high-level and transuranic wastes. I have a
concern about that because this waste will be in that landfill beyond its operational time, beyond the
30 years.  And  I know that there are enough life forces going on in this planet right now that there's
going to be some leakage, so that's a real concern for me."

Response:  The liner and leachate collection system for a landfill trench is only expected to
function for the operating life and the postclosure care period. The postclosure monitoring will
end when it is demonstrated that no leachate is being generated.  The cover placed over the
landfill at the time of closure is designed to prevent water from entering the landfill and
generating leachate.  The long-term prevention of leakage is based upon the cover preventing
water from entering the landfill such that there will be no liquid to leak.  Long-term ground
water monitoring of the closed landfill will be implemented in accordance with RCRA
requirements.

Comment 2. One member of the general public commented that "They don't agree that the decision
for the type of protective cap needs to be decided before construction or use of the pit begins. It will
take several years to build and load some waste into the pit.  By then, studies should be complete and
the best cap for the pit can be chosen."
                                            A-21

-------
 Response:  The RCRA-compIiant cover is currently considered the minimum required to be
 protective of human health and the environment.  Additional options may be evaluated prior to
. construction of the cover.

 Comment 3.  Heart of America Northwest commented:  "I want to ensure that there is plenty of
 monitoring around this facility, that there is air monitoring and other monitoring to make sure that
 nothing goes offsite that you are  all now thinking will not go off the site."

 Comment 4.  A member of the general public commented:  "I am concerned about how you are going
 to do monitoring at the site. I was asking somebody about monitoring and nobody seemed to know
 about that.  Monitoring is obviously been a serious problem (the  high-level waste tanks).  I think that
 we need to learn from that example and make this a safe facility."

 Columbia River United commented: The only way that you can  assure worker and public safety is to
 monitor with Continuous Air Monitors (CAMs).  These monitors must be installed at all remediation
 sites and ERDF.  To do anything less is putting the workers and  the public at risk.  We must keep in
 mind that worker safety is a number one priority.

 Response: Continuous Air Monitors will be installed and operated as a part of the site's
 operational safety procedures.  Currently existing  groundwater monitoring system will document
 conditions prior to accepting  waste at the facility and a RCRA compliant system will continue to
 monitor groundwater during  operation.

A member of the general public had the following written facility design comments:

 Comment  5.  The clay liner is shown in plans as only 3 ft thick.  Clay liners built for regular solid
 waste (household garbage) landfills are usually 5 ft thick. I think the ERDF liner should be thicker
 for this massive landfill.

With the clay content of the liner being only 9% with a total thickness of 36 in., this means that if the
 compacted clay were separated as a pure layer (separated from 91 %  sand) it would be about 4-1/4 in.
thick.  The remaining sand would be 31.75 in. thick.  This amounts to being a very thin skim coating
of a clay layer to contain 70 ft  of waste materials, and;

A thicker  liner with a higher clay content would provide for more chemisorption capacity.  I think
that 4-1/4 in. of clay will not have enough chemisorption capacity for 70 ft. of overlaying waste
materials should failure of the plastic liners occur. Moreover, I would like to see a clay subliner
installed which is adequate to contain through sorption, the fullest capacity (or ability to sorb) as
much of the radionuclides and chemical contaminates present in the completed landfill as possible.
Because of even the slight chance that the pump and treat leachate collection could terminate in the
future of the landfill should be  designed to take care of its self in the absence of human caretakers,
and itself prevent dispersion of radionuclides and dangerous chemicals into the environment (or
biosphere), rather than reliance upon indefinitely being pumped out.

Sodium bentonite is used as a sealing liner for landfills because it swells up greatly in size (or
volume) with the absorption of pure water. Sodium bentonite mined from certain deposits will swell
up to 20 x (time) the original dry size after saturation with pure water.

Response; The liner system is not intended to provide long-term containment of waste. It is
only intended to collect leachate during the period  when waste is  being emplaced and for the


                                            A-22

-------
 first few years after closure.  After this time, the permanent closure cover will limit infiltration
 of surface water to the waste. As required by EPA regulations (RCRA Subtitle C), the closure
 cover will have a permeability less than or equal .to that of the liner.  Thus, the long-term
 performance of the ERDF will be controlled by the cover, not the liner system.  Likewise, long-
 term performance of the ERDF does not rely upon ongoing leachate pumping.

 The compacted admix layer is 3 ft thick in accordance with EPA RCRA Subtitle C and
 Washington Department of Ecology requirements for hazardous waste landfills.  The ERDF has
 a double-liner system with a lower composite liner. Based on the analytical work underlying the
 EPA requirements as well as  experience at other hazardous waste landfills, this liner system is
 expected to contain leachate with  a high degree of reliability.  It is true that some municipal
 waste landfills have clay liners that are thicker than 5 ft; these are often located in areas
 underlain  by natural clay deposits.  On the other hand, many municipal waste landfills have
 clay liners thinner than 3 ft, and  often do not have two geomembrane liners as does the ERDF. .
 Comparison of ERDF and municipal waste landfills should consider all liner system components.

 Comment 6.  As shown in plan drawings for the ERDF,  the terms "compacted clay liner" are used.
 However, the completed liner will actually consist of 91%  sand and 9% sodium bentonite clay
 mineral (by wt.). The term clay as used by geologist, mineralogist, and soil scientist is applied to
 geologic materials composed of at least 51 % clay content.  Therefore, the term clay  cannot be
 properly applied to describe the liner as shown in plan drawings. The proper term should be sand
 liner, or sand-clay liner.                 .

 Response:  The term "compacted  admix" is now being used on the ERDF drawings.

 Comment 7.  Sodium bentonite day used in the liner may be chemically altered over time with
 resulting degradation of its sealing performance.

 Response:  As noted above, long-term performance of the ERDF will be controlled by the cover,
 not the liner system.

 Comment 8.  Sodium bentonite is used in all the liners and containment barriers at Hanfbrd. Sodium
 bentonite is also named Na montmorillonite, Wyoming bentonite, high yield bentonite, and Western
 bentonite.  Sodium bentonite is a member of the smectite group of minerals. The other
 montmorillonite clay minerals being calcium bentonite (Ca montmorillonite, non-swelling bentonite,
 southern bentonite, and fullers earth), magnesium montmorillonite (saponite, armargosite), potassium
 montmorillonite (metabentonite), and lithium montmorillonite (hectorite).  The structure of these clay
 minerals are extremely microscopically small aluminum silicate sheets with sodium, calcium,
 magnesium, iron, potassium, lithium, and other elements may be present. The particular
 montmorillonite mineral being named for the element which is dominant over the others as the
principal exchangeable cation.  The chemical and physical properties are determined  by the cations
present.  The chemical and physical properties have a great variation between group  members.  The
montmorillonites (or bentonites) are the best clays to use for sealing or liner applications because they
are the least permeable to water. Also, these clays have a strong property of chemisorption, which is
the ability to bond substances to die surface and between the silicate sheets of the clay minerals
crystals.  The sorption property will attract certain atoms, molecules, and even small particles like a
magnet by electrostatic and other atomic forces and coat the clay crystals  with a layer called the Stern
layer.  The sorption property will extract (or filter) certain dangerous chemicals and  radionuclides as
they very slowly percolate through the sand-clay liner in solution with.water.  The other clay minerals
                                            A-23

-------
 kaolinite and illite are much more permeable to water, and have weak to very weak sorption
 properties.

 Response:  When performance of the ERDF was analyzed, no credit was taken for permanent
 adsorption of contaminants by the clays in the admix, only for a slight retardation.  Therefore,
 the geochemical properties of the admix are not relied upon for performance of the ERDF.

 Comment 9.  The swelling of the clay effectively seals pores in the sand-clay liner, and forms a very
 tight low permeability material.  The sand in the liner is to provide physical stability and
 densification.  The sand-clay mixture will compact easily whereas a purer clay is difficult to compact
 into a dense layer (or liner).  The sand stabilized against extrusion (flow or displacement) from the
 weight of the overlaying waste and landfill liner cap.  If pure clay were used for the liner, it will
 become plastic due to its rheological properties with the addition of enough water, and could flow or
 be displaced.  A compacted dense sand-clay mixture of less man 10% sodium bentonite will not flow
 under pressure.  Pure sodium bentonite saturated with pure water behaves rheologically as a watery
 gel, with strong lubricating properties.  Also,  hydration pressures in montmorillonites may reach 2000
 psi., because of these reasons the clay content for sodium bentonite - sand liners cannot exceed 10%
 or so.

 Response: Thank you for the comment.

 Comment 10.  Sodium bentonite does not swell (or expand) to the same Volume in solutions of
 chemicals such as acids, alkalies, and saline solutions.  The swell may be greatly reduced.  Sodium
 bentonite does not swell in organics (such as oil), unless it is specially treated, as organoclay (organic
 clad clay). Bentonite clays are also subject to ionic exchange. The principal exchangeable cations
 can be removed and replaced by other cations present in solution, when the clay is placed into the
 solution.

 Response: Thank you for the comment.

 Comment 11.  I read hi Hanford literature regarding a previously completed sodium bentonite liner
 that it would take "50 years for the waste water to pass through the liner".  The liner was constructed
 (or built) to the same thickness (3 ft.) and permeability (1 x 10.7 cm/sec) specifications as the
 proposed ERDF landfill. Therefore, the liners are somewhat permeable, albeit slowly.

 My point is that should something happen to human caretakers of the ERDF, so  that the pump-and-
treat leachate collection system would become abandoned, then chemicals hi the  waste will be passing
through the liner.  In a long time period the leakage will be significant. The chemicals and alkaline
metals in the waste will interact with the sodium bentonite.  The chemicals will cause shrinking to
occur in the bentonite by reducing its swelling or expansion, and that will cause  an increase in
permeability.  Moreover, the actual clay mineral will likely be altered chemically into another
montmorillonite clay mineral by cationic exchange with cations present in solution from the
overlaying waste.  Sodium cations may be leached by acidic or alkaline solutions and replaced by
other metal cations, this too will cause an increase hi permeability, because sodium bentonite has the
highest swell volume of the montmorillonites,  and when altered to another montmorillonite it may be
a low or non-swelling type (it may become a none-swelling clay).

Response: The admix for ERDF will contain a nominal 12% bentonite  by dry weight.  This
same mixture y^as used at a smaller landfill on the Hanford Site and had excellent strength and .
constructabiJtty characteristics. It also had  a permeability of 1 x 10* on/sec with pure water, 10


                                            A-24

-------
 times lower than the RCRA requirement of 1 x 10'7 cm/sec.  Because of the same concerns raised
 by the reviewer, this admix was also tested using a synthetic leachate containing the chemical
 compounds expected at the landfill, which will have a waste stream similar to ERDF. For this
 testing, the admix was also irradiated to check the effects of radionuclides. Even under these
 conditions, the permeability of the admix remained under 1 x 10~7 cm/sec. The protective cap is
 relied on for long-term prevention of leachate.

 Conunent 13.  If I may make a suggestion, I would like to see a non-swelling bentonite used in the
 liner. Non-swelling bentonite such a calcium bentonite, and nontronite (iron aluminum silicate) have
 chemical and physical properties that may be better in a liner application.  The iron content helps
 bonding of certain radionuclides to the clay crystals.  Calcium bentonites from certain deposits also
 have a high iron content.  The impermeability of calcium bentonite will not be adversely affected by
 acidic and saline solutions as will sodium bentonite.  Acidic solutions will remove some of the
 calcium cations, however, in doing so the edges of the sheet structure will be expanded around the
 edges and cause a slight swelling to occur. The slight swelling will tighten up the sand-clay mix
 resulting in decreased permeability.  Saline solutions will further disperse any calcium bentonite clay
 aggregates to smaller particles which will cause a slight swelling, to seal up  the liner. Note that this
 is the opposite effect as compared to sodium bentonite, which becomes more permeable when exposed
 to the same chemicals. Calcium bentonite or nontronite would have to be added in higher percentages
 to the sand to achieve the same impermeability (up to 30%). The greater amount of clay would
 provide for more sorption capacity.  Calcium bentonite bonds the sand together more strongly than
 sodium bentonite in the moist state.  Much more calcium bentonite may be added to the sand and still
 be stable against flow or extrusion. The clay is also less sensitive to the amount of water needed for
 compaction during the building (construction process).

 Calcium bentonite liners (or sorptive barrier technology liners) are used at chemical plants in Texas,
 Mississippi, Florida,  South  Carolina, and elsewhere.  A hazardous waste landfill in South Carolina
 uses such a liner and cap, and not only to contain the waste but for backfilling around the waste
 containers in order to provide a sorptive medium for dangerous chemicals.

 Sodium bentonite has been a standard at Hanford for years. I think that the  ERDF is moving ahead
 too fast for construction under the "lets get the cleanup going" attitude.  This is one area where more
 time should be taken to test the liner materials performance over time before completing the main
 landfill at Hanford, its too big to not have as good as possible.

Response: As part of the liner design for the completed, smaller landfill project at Hanford, a
calcium bentonite from a commercial source in the Ephrata, Washington, area was tested. An
admixture containing 10% Ephrata bentonite had a permeability of about 5 x 10*5 cm/sec, well
outside of the minimum  requirements.  It was decided that even if sufficiently low permeability
could be achieved with this material, a very large percentage of bentonite would be required.
Due to potential problems  with strength, workability, and higher costs resulting  from use of a
higher percentage .of bentonite, the Ephrata bentonite was considered an unattractive
alternative. See information noted above.

 Comment 14. Finally, if I may, I would like to outline a recent incident regarding plastic pipes in
analogy to liners.  I saw a report on CBS news about plastic water pipes. The pipe has become
brittle due to exposure to  chlorine in city water supplies.  The pipe was in service for about 15 years,
ana then the pipes began to  crack or split open. Water damage was estimated to be 800 million
dollars in homes and buildings all over the U.S. The plastic in the pipes was made by major
chemical  manufacturers wfco have been ini business for a longtime.


                                            A-25

-------
 Response: Comment noted.
H. DUST MITIGATION

Comment 1.  Columbia River United commented that "One of the things that we will have to be
shown to agree that the ARARs are being met are that adequate controls are being made to control the
spread of contaminated dirt.  And the issue of continuous air monitors was mentioned.  I believe
those will not be CAMs, but will instead be air samplers. CAMs do have an instantaneous response.
If you set up air samplers, though, generally those results are not back for a week or so, basically
after the fact.

Dust mitigation as we mentioned before is another concern.  We hope that the workers aren't out
there  working in high wind conditions breathing in the dust that's contaminated.   We want to make
sure that they use the best available technologies for remediation and burial and dust mitigation. The
question tonight was about continuous air monitors.  Now we know that they're actually proposing
not to use continuous air monitors and we're going to request that they do use continuous air monitors
at the burial site.

Response:  Continuous Air Monitors (CAMs) will be installed to monitor air emissions for
worker and public safety.  Because of the large area to be cleared and the generally dry and
windy climate, DOE recognizes the particular importance of dust control at the ERDF site.
Specific dust mitigation options such as water sprays, binders, and uncontaminated operational
covers on emplaced wastes will be employed during construction and operation of the ERDF to
prevent spread of contamination and to protect worker safety.  Please refer to the responses
below for more information.

Comment 2. Columbia River United commented that dust mitigation must be done with the best
available technology.  The Hanford Site is extremely dry and is noted to have very high winds. The
Dust Mitigation Study (DSM) has some erroneous assumptions about the threshold velocities for
ERDF. The threshold wind speeds of 36 mph for untreated ERDF soil and 42 to 53 mph for treated
ERDF soil does not even come close to protecting the workers.  It is amazing to find out that when
Wal-Mart was under construction, the stop worker order was in place at winds much  lower. The
DSM  gives no recommendation as far as  work stoppage hi relation to wind speeds. The DSM does
not take into consideration all the different contaminated sites across the Hanford complex that will be
excavated.  There is no mention of how we will protect the workers and public from these
excavations. More work needs to be done on a comprehensive Dust Mitigation Strategy to assure
worker and public strategy.

Response:  There may be some misunderstanding  about the report. The report shows (on fig. 5-
1) that the  threshold velocity for untreated soil varies from 11 mph to 36 mph depending on the
soil type and conditions and that the threshold velocity for treated soil varies from 42 mph to 53
mph depending on soil type. Dust emissions can vary greatly depending on the moisture of the
soil, particle size, silt content, presence of binding agents, and initial suspension by outside
forces other than wind (such as machinery). Consequently, comparisons  of observed dust
emissions at the Wai Mart construction may not be comparable to some of the cases evaluated in
the report.  The Wai Mart site was a shallow excavation using heavy equipment that stirred up
the eolian deposits of fine sand. The eolian soil at the Wai Mart site is anticipated  to be quite
different from the coarse gravelly soils that would be more typical of the waste coming to the
ERDF. It would be reasonable to expect  that the eolian soil of the Wai Mart site would be


                                           A-26

-------
 associated with dust emissions at relatively low wind speeds (such as the 11 mph from fig. 5-1),
 whereas coarse, clean gravels would not emit dust even up to 36 mph.  Some of the
 computations shown in the report are for undisturbed conditions (fig. 5-2, Open Area Wind
 Erosion), while others  are for situations where heavy equipment would  initially suspend dust
 particles (fig. 5-4, Particle Emissions from Dumping Operations, and fig.  5-5, Particulate
 Emissions from Dozer  Operations).  The threshold values shown for fig. 5-1 and probably for
 the range indicated by your comment (42 -53 mph) are for undisturbed conditions that are not
 comparable to the Wai Mart conditions with its heavy equipment operation.  Better comparisons
 to the Wai Mart conditions would be made from fig. 5-4 and fig. 5-5.

 Because of the large area to be cleared and the generally dry and windy climate, DOE
 recognizes the particular importance of dust control at the ERDF site.  Specific dust mitigation
 options such as maintaining moist conditions (sprinkler irrigation), adding binding agents to
 form larger particles (that are to heavy to be suspended/carried far), and  covering the waste as
 it is placed (with stabilizing chemicals or clean soil) are being evaluated for their usefulness
 during construction and operation of the ERDF. The  ultimate method or combination of
 methods for controlling dust will consider the range of soils and conditions (undisturbed and
 heavy equipment operations) that will be present at the facility. Once the methodology of
 controlling dust is decided upon, then operational safety limits  tailored for that specific method
 will be developed.

 Comment 3.  Columbia River United commented:  We also were looking at it (siting) in the Hanford
 Advisory Board.  We learned from one of the people out there that his preference was the northern
 site because the northern site didn't have as much light sand and soft silty stuff that would fly around
 when you start cleaning it up, start digging the hole, and  start burying it, and  that brought up the
 question about what are we going to do for dust mitigation. The winds blow from anywhere
 (between) 5 mph to 50-60 mph out there; what are we going to do for mitigation to protect the
 workers, protect the people offsite.

 Response:  Upon completion of excavation and construction of  the drainage layers, the facility
 will be covered with an operational layer of native soils, which  will be treated with a soil binder
 for purposes of dust control.  When the facility is operational,  wastes will be covered with clean
 soils as  they are emplaced, and dust control measures  will be employed  to limit generation of
 airborne dust. For these reasons the nature of soils on the ERDF site are  of concern primarily
 during the construction phase and become less of a concern when the facility is completed and
 operational.  For a more complete discussion of the dust control measures to be employed,
 please refer to the comment responses above.
I. CONSULTATION WITH THE CTUIR

The CTUIR had the following comments:

Comment 1 The ERDF staff are to be commended for promptly consulting with me CTUIR early in
the scoping process for the ERDF.  Moreover, the ERDF staff provided us with all drafts of ERDF-
related documents at the same time they were sent to the regulators.  Despite the CTUIR's committed
involvement in Hanford matters, DOE still fails to send us many documents — particularly documents
concerning the 100 Areas — in anything approaching a timely manner.  The ERDF staff have shown
tnat timely consultation with tribes is not some sort of indecipherable mystery. We appreciate their
professionalism.


                                           A-27

-------
 Response:  Thank you for the comment.

 Comment 2. Nevertheless, we are aware that many natural resource trustees were not consulted in a
 timely manner. We assume that the ERDF staffs consultation with the CTUIR was based more on
 DOE's duty to consult with affected Indian tribes (under the federal trust responsibility to tribes) than
 on the CTUIR's status as a natural resource trustee.  Of course, this does not explain the fact that the
 Nez Perce were not consulted at the same time the CTUIR was.  Nevertheless, in the wake of various
 trustees'  (valid) criticism of DOE's failure to involve them in a timely manner, we did not want to
 lose sight of the fact that the ERDF staff did at least meet with CTUIR staff early in the process and
 get documents to us at the appropriate time.

 Response:  Thank you for the comment.

 Comment 3. As for consultation over the siting of the ERDF, we agree with the other trustees that
 we all should have been consulted about alternative sites, and that alternative sites should have been
 analyzed  in the RI/FS.

 Response:  It seemed most effective to rely on the ERDF siting evaluation report rather than
 reproducing the document in the RI/FS, which is already rather voluminous.  Alternate sites
 were analyzed in the Siting Evaluation Report (WHC-SD-EN-EV-009, Rev. 2), which is cited in
 the ERDF RI/FS.
J. INTEGRATION OF NEPA EIS COMPONENTS INTO THE ERDF CERCLA RI/FS

Comment 1.  The CTUIR commented that generally speaking, DOE has done a good job of
integrating all of the components of an EIS into the ERDF RI/FS. Unfortunately, the content of those
components is sometimes sorely lacking.  We address the key failings of the planning process for
ERDF later in this letter. Nevertheless, as fiar as fulfilling the Tri-Parties' goal of producing an
RI/FS that was embellished to include most EIS components, DOE has succeeded in doing that.

Response: Thank you.  We appreciate your effort  to provide supportive as well as critical
comments.

Comment 2.  The Oregon Department of Energy commented:  There were comments within the
Remedial Investigation Feasibility Study document, which is the basic work document for this, that
indicate that there's Natural Resources being committed and that therefore it's just assumed there will
be mitigation, but that mitigation will be included in some sort of a sitewide restoration plan.  The
way that this entire document came about we definitely feel does not cause it to be equivalent to
what's required in the National Environmental Policy  Act for the performance of a environmental
impact statement. This remedial investigation/feasibility study is not a good substitute, the process is
not equivalent, and the damages caused by it are damages that will have to be mitigated and
compensated for at some time in the future.

Response: Thank you. We appreciate your effort  to provide supportive as well as critical
comments. The intent of the regulatory package for the ERDF was to provide an integration of
NEPA values within CERCLA documentation.  The DOE has committed to the development and
implementation of a Mitigation Action Plan, hi coordination with the Natural Resource Trustee
council.
                                           A-28

-------
 Comment 3. Heart of America Northwest commented:  Let me just say that (NEPA/ CERCLA
 integration) was something that the State Advisory Council and the Oregon Waste Board and citizen
 groups encouraged integration of the two. I am not sure that it has worked perfectly.  I mean the
 biggest difficulty is that under NEPA, the number one value is to produce the readable document and
 I am not sure we met that, quite honestly, in terms  of value.

 Response:  Thank you for the comment.  The RI/FS is admittedly technically oriented and
 voluminous.

 Comment 4. Heart of America Northwest commented:  NEPA requires that you address the
 cumulative impacts and the impacts of related actions in the one document for the action you're
 proposing this landfill. Since the lead agency is the Department of Energy taking the action, which
 apparently has plans or is considering other actions  that are related that would bring similar wastes
 from all over the country, perhaps the world, to landfills at Hanford including, we've just learned,
 defense low-level wastes to be brought to the region including wastes under the federal facility
 compliance act from other nuclear weapons sites. Therefore, whether or not these wastes  are off
 limits to ERDF, you must fully disclose what those wastes are, where they are going, what the
 cumulative risks and impacts are.  This is what would be required under the NEPA. I know that .
 EPA and Ecology may have trouble obtaining this information as it has been closely held.  I would
 suggest that you must force the Department of Energy to fully disclose this information otherwise we
 cannot meet the promise that everything that would be covered under NEPA would be covered under
 the ERDF CERCLA documents, and it is imperative that the public see what the Department of
 Energy is considering to  bring into another landfill at Hanford.

 Response:  The cumulative impacts section of the RI/FS (9.4.10) included a  discussion of.
 potential impacts from the Low-Level Burial Grounds, located in 200 East and 200 West Areas.
 These Burial Grounds accept low-level waste from other DOE sites and defueled submarine
 reactor compartments.  Hanford is one of 26 sites that will be further evaluated for a possible
 mixed waste disposal facility for the disposal of treatment residues.  No decisions have been
 made at this time and public participation will be solicited.

 K.  "NEPA ROADMAP"

 Comment 1.  The CTUIR commented that the NEPA Roadmap is a remarkable document.  It contains
 a generally forthright and comprehensible discussion of the EIS and RI/FS processes, their similarities
 and differences, and an index for finding EIS components within the RI/FS.  DOE has  attempted the
 index idea before,  most notably in the RI/FS for the 1100-EM-l Operable Unit (OU) and the
 LFI/FFS for the other three 1100 OUs.  The NEPA index to these documents was a dismal failure,
precisely because those CERCLA documents bad not been enhanced to contain NEPA elements.  By
comparison, the ERDF Roadmap is very well done.  DOE deserves credit for this accomplishment.

Response:  Thank you. We appreciate your effort, to provide supportive as well as critical
comments.
L. JUDICIAL REVIEW

The CTUIR had the following comments:
•~"^* •• -        ~.-? .- i. .




                                           A-29

-------
 Comment 1. CTUIR staff have some extremely serious concerns, nonetheless, about DOE's (and
 EPA's) intention to completely discard formal compliance with NEPA on CERCLA projects. As we
 said, DOE has done a fine job on the ERDF "NEPA Roadmap," and on integrating most NEPA
 components into the RI/FS.  Nevertheless, the ERDF is a high^rofile project.  As this is the "pilot
 project" for the concept of subsuming the NEPA process  into CERCLA, DOE could be expected to
 do a good job on the integration of NEPA and CERCLA  this time.  We are concerned, however, that
 in future, less high-profile projects, DOE will not integrate EIS components into RI/FSs with as much
 attention to detail as DOE has shown this time.  In the past, when DOE/RL has written run-of-the-
 mill NEPA documents (such as the EA for the 240 Road  Access Extension), the CTUIR has often
 found them to be poorly crafted and legally inadequate. Considering DOE/RL's general poor track
 record on NEPA documents, CTUIR staff are concerned that in future projects the standard for the
 "integrated" NEPA/CERCLA process will be much lower.

 Response:  DOE intends to substantially comply with NEPA. In other words, DOE will meet all.
 significant requirements of a  non-administrative nature.  In the future, DOE hopes to continue
 to produce high quality documents.

 Comment 2. Moreover, since DOE has done a generally  good job, this time, of integrating NEPA
 and CERCLA elements in one  document, we are left wondering why DOE has parted from its prior
 policy of producing a single document and calling it an "EIS - RI/FS" (See DOE Order 5400.4  §
 7(d).). It appears that the only thing DOE gains from not calling the ERDF planning document an
 "EIS - RI/FS" is that DOE avoids any threat of judicial review under NEPA. This is an improper
 motivation for DOE.  Judicial review is an extremely valuable process that protects those who would
 otherwise be improperly ignored. It protects entities with less power and forces discipline upon
 agencies that might otherwise show contempt for the law or for tribes and the public. Does DOE
 believe that accountability for its actions is a bad thing? If not, then why is DOE trying to avoid
 accountability?

 Response:  In* June 1994, the Secretarial Policy for NEPA was issued, which commits the DOE
 to rely on the CERCLA process for review of actions to be taken under CERCLA. Under this
 policy, we will continue to incorporate NEPA values such as analysis of cumulative, offsite,
 ecological, and socioeconomic impacts, to the extent practicable. This is consistent with
 guidance from the Council on Environmental  Quality (CEQ) (40 CFR 1502.25).  This  policy
 resulted from negotiations between EPA, CEQ, DOE,  the U.S. Department of Justice, and
 others. The EPA expressed concerns about separate implementation of NEPA for CERCLA
 actions because of apparent unnecessary duplication of analyses and potential delay of project
 implementation, such as might be caused by judicial review.  Congress has clearly  expressed the
 intent in the CERCLA statute that cleanup not be delayed due to litigation prior to cleanup.

 Comment 3.  The usual complaint (raised by DOE and DOJ in recent litigation) about judicial review
 is that it can cause delay. Delay is, sometimes, the price  of justice. Yet we can see in the example
of ERDF that entities do not always seek judicial review even when they have cause to.  Any citizen
of the U.S.  could file suit against DOE under NEPA for DOE's failure to perform and  EIS for the
ERDF.  Citizens may also be able to sue claiming that DOE has not complied with legal requirements
 concerning the siting and licensing of a low level nuclear  waste disposal facility.  Tribes could sue
DOE under the federal trust responsibility to Indian tribes for DOE's failure to consult  with them
 about siting. The natural resource trustees could file suit  against DOE for its failure to consult with
them before making the siting decision.  Yet no one has filed any suits to delay the ERDF on any of
these grounds, precisely because everybody recognizes that in mis case, delay is unacceptable. Does .
DOE have so little respect for tribes, states, and the public mat it expects them to file reckless suits?


                                           A-30

-------
 Response:  DOE, EPA and Ecology appreciate the cooperative attitudes that have been
 evidenced by all of the interested parties who have participated in the reviews and discussions of
 the ERDF Proposed Plan and related documentation. DOE, EPA and Ecology feel that the
 decision reached in the ROD is supported by the record, and hope that any remaining concerns
 can be resolved through  continued discussions, without the need for litigation. With regard to
 any issues that cannot be so resolved, judicial review will be available.  Congress did not
 preclude judicial review  of issues under CERCLA, it merely required that such review be
 postponed until implementation of the selected remedy. The CERCLA statutory bar on pre-
 enforcement review of cleanup actions is a matter that only the courts can decide and interpret.

 Comment 4.  Moreover, judicial review is not a process that is outside of reasonable control. Every
 decision in a judicial review case is made by a federal judge.  Judges have enormous discretion to
 dismiss cases that they feel are frivolous or unjustified.  Indeed, the usual response to a complaint
 calling for judicial review, is for the defending agency to seek dismissal of the claim.  This process is
 designed to filter out the merely delaying or "political"  lawsuit very early in the process, before the
 suit can cause significant delays. Defendants can even file their own motions, seeking to' impose
financial penalties against those who file frivolous lawsuits.  Judicial review is not a process that
 takes place irrationally or  on "autopilot."  So why does  DOE fear this process? Does DOE distrust
 the judgment of federal judges?  Or does DOE itself believe that its actions are often illegal or
 inadequate?  Isn't DOE seeking to avoid judicial review precisely because it knows its actions often
 fail to live up to the minimum standards of the law, and because it wants to avoid being accountable
 when it breaks the law?

 Response:  DOE and EPA agree that judgements of the federal judiciary should be accorded
 respect and deference. Federal courts have uniformly held that judicial  review of issues under
 CERCLA must await implementation of the remedy.  Courts have held that the legislative
 history of CERCLA is dear, and that in balancing the right to review a  potentially inadequate
 or flawed response plan with the interest in implementing  prompt cleanup of hazardous waste
 sites, Congress gave priority to prompt cleanup. Neither EPA nor DOE can change CERCLA,
 only Congress can amend the statute. In making this decision, Congress apparently intended
 both to facilitate prompt cleanup action and to give some deference to the judgement of EPA,
 which it created to protect the public interest in  enforcing federal environmental laws.  In
 reaching the decision that is reflected in the ERDF ROD, EPA, DOE and Ecology are not
 turning a deaf ear to the needs and desires of interested parties and the public:  significant
 considerations have been incorporated into the final decision based on input from these parties.
 For example, the location selected was consistent with criteria developed by the Future Site uses
 Working Group, the size of the facility was reduced to minimize the area disturbed,  construction
 will commence on an extremely expedited schedule to assure that surface disturbance activities
 occur outside of sensitive nesting time periods.

 Comment 5.  Another concern that is sometimes raised about performing both NEPA and CERCLA is
 that doing so creates redundant paperwork and process.  Yet the ERDF project shows this need not be
 the case. Moreover, DOE has-produced EIS — RI/FSs  in the past under its former policy, with
 apparently little difficulty. DOE even has a headquarters-based NEPA office that provided guidance
 for the production of these documents. We cannot see how DOE achieves any significant reduction in
paperwork or process by discarding NEPA.

Response: DOE has not  discarded NEPA.  Instead DOE has incorporated the substantive
evaluation of NEPA elements into the CERCLA  documentation.  This approach, is consistent
                                           A-31

-------
with the DOE NEPA policy, streamlines the procedural aspects, reduces redundant analyses,
saves paper, and allows for a single, integrated decision.

Comment 6.  The history of DOE's interaction with the people it is supposed to serve is a history of
DOE erecting walls to accountability.  One by one, those walls have been pulled down by the states,
tribes and the public, only to have DOE erect new ones in their place.  CTUIR staff are concerned
that DOE's attempt to escape from judicial review is simply a repeat of this familiar theme.  There
may be some compelling procedural reasons for preferring the CERCLA RI/FS process over the
NEPA EIS process. The NEPA Roadmap describes some of these. But as long as the CERCLA
process leaves DOE essentially unaccountable for its actions, we cannot support a wholesale
abandonment of NEPA.l

Response: In CERCLA remediations, DOE analyzes alternatives and suggests a remedy, but the
regulatory agencies are responsible for choosing the remedial action to be implemented.  Neither
DOE nor the regulatory agencies are left unaccountable for their actions by the CERCLA
process.  It is true under the CERCLA statute, Congress has determined that citizen suits must
await implementation of the selected remedy, however, the tribes and the public has significant
opportunity for meaningful impacts on this remedy selection process.
M. ECOLOGICAL IMPACTS OF CONNECTED ACTIONS AT QUARRY SITES

Comment 1.  The CTUIR commented that the RI/FS places no limit on where basalt quarry sites
might be.  Use of existing quarries or development of new quarries are connected actions to the
ERDF project. Yet the RI/FS makes no attempt to describe the ecological impacts of those quarries.
Further, the RI/FS makes no attempt to describe the transportation corridors or the ecological impacts
of that transportation.   From a NEPA standpoint, this is inadequate as a disclosure of affected
environment and as a description of impacts to that environment.  DOE should fully evaluate these
issues in the RI/FS, and the CTUIR should be consulted about these decisions.

Response: The requirements for the surface cover have not yet been developed in detail.  At this
time,  a RCRA-compliant cover has been selected for the closure of the ERDF, which does not
include the use of basalt. To  the extent practical, materials excavated from the ERDF site
during construction will be used to construct the ERDF cover.
N.  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

Comment L  The Ci'UlK commented: Because the tribes and trustees were not allowed to participate
in the single most important decision concerning the site - its location — we can hardly be bound by
DOE's decision to commit the resources at the ERDF site, "borrow" sites, and transportation
corridors.  This is the most glaringly obvious in the case of the basalt quarry site, the location of
which, if a quarry is even required,  is nevertheless undisclosed.
U  'Judicial review under the citizen suit provision of CERCLA is essentially a chimera,
since § 113(h) bars review until after the remedial action is complete — far too late for a
plaintiff to have any meaningful impact on the remediation.

                                          A-32

-------
 Response: Because the ERDF cover design does not specify a basalt biointrusion layer, or any
 other basalt layer, there is no need at this time to develop a source of basalt, or a basalt quarry,
 to support construction or closure of the ERDF. For this reason, no location for potential
 borrow sites are identified or proposed. Tribal  and public participation will be invited at the
 time that a need for borrow sites is identified.

 Comment 2. The CTUIR commented:  CERCLA  § 107(f) exempts a PRP from natural resource
 damages if the damages are identified as an irreversible and irretrievable commitment of resources in
 an EIS or comparable planning document and if various other conditions are met.  This provision
 assumes that the EIS (or comparable environmental analysis) was performed properly. As the single
 most important decision concerning the ERDF was made without our participation, we must conclude
 that the commitment of resources was performed improperly.  If it is true that the Rl/FS process
 typically handles such decisions less rigorously than the EIS does, that only indicates that the RI/FS is
 not a comparable environmental analysis to  an EIS.

 Response: Evaluation of alternative sites  has been an ongoing process in response to facility
 redesign and comments received from the public scoping meetings and from Hanford Site
 trustees. As noted in  your previous comments, the analysis of issues in the RI/FS substantially
 complies with the  requirements  of NEPA. The DOE therefore believes that the ERDF RI/FS is
 an environmental  analysis comparable to  an EIS for the purposes of irreversible and
 irretrievable commitments of resources and that identification of such commitment was proper
 and appropriate.

 The Oregon Department of Energy had the following comment:

 Comment 3. In Section 9.3.17 the RL/FS makes a  sweeping claim for irreversible and irretrievable
 commitment of resources. This claim abrogates USDOEs duties as a Trustee and as a land and
 resource  Steward.  Additionally, this claim may be invalid because:

 1.     The siting process for ERDF failed  to consider reasonable alternatives.  The original facility
       size was predicated on a simple shallow burial. This did not comply with USDOE orders, or
       with prior guidance from the Future Site Use Working Group.  When public demands caused
       the Tri-Parties to change the design  of the facility and reduced its area from six square miles
       to 1.6 square miles,  siting was not reconsidered.

 2.     The siting process relies on treating ERDF as a CERCLA facility.  It is not clear this is
       allowable.  The wastes intended to be placed in this facility are from remote sites in the 100
       Areas.  Based  on guidance in CERCLA, it appears ERDF should have been sited using a full
       NEPA process rather than the CERCLA RI/FS process, including licensing under the Atomic
       Energy Act.

The CERCLA RI/FS process used for ERDF is significantly different from the NEPA process. The
public involvement process was inadequate and judicial review is not allowed.

4.     USDOE is required under CERCLA and DOE orders to mitigate for ecological damage. The
       irreversible and irretrievable claim is very broad.  The mitigation measures  identified in the
             are all future actions with no  detail provided and no detailed plans provided.
USDQB sfopuld at a minimum commit to:
                                            A-33

-------
 1.      Minimize the ecological harm done at ERDF, at the borrow material sources and along the
        transport routes to each of these locations.

2.      Replace the destroyed habitat with sufficient new or upgraded existing habitat adjoining the
        remaining high shrub-steppe habitat to offset the harm done.

3.      Work closely with Trustees  from the earliest moment on future projects to avoid these
        problems and to protect and preserve the remaining habitat.

4.      A comprehensive process to protect species of concern and habitat at Hanford.

Since the Tribes and Trustees were not allowed to participate in the important siting decisions for
ERDF,  we cannot be bound by USDOE's decision to commit the resources at ERDF, the borrow sites
or the transportation corridors.

Response: Following the CERCLA process for documenting the irreversible and irretrievable
commitment of resources does not abrogate DOE's duties as a trustee and as a land and
resource steward. The siting evaluation report evaluated multiple sites. When the facility was
down-sized the siting evaluation was reconsidered.  Because this is an on-site facility, licensing is
not required.  The CERCLA RI/FS process substantially complies with NEPA.  DOE intends to
perform mitigation as required and to minimize ecological harm.  Methods for mitigation will be
analyzed and the tribes will have an opportunity to participate.

The U.S. Department of the Interior - U.S. Fish and Wildlife Service had the following comment:

Comment 4. The RI/FS claims irreversible and irretrievable commitment of habitat and other natural
resources for areas which have either not been identified (basalt borrow site), or for areas which have
not been specifically identified and habitat value has not been assessed (McGee Ranch borrow site).
The Service strongly objects to these actions and considers the claims to be inappropriate and
unethical. This claim abrogates USDOE's duties as a Trustee and as a land and resource Steward.

It is not clear whether alternative borrow sites for fine material were considered. The Service
strongly recommends that this be done.  McGee Ranch may be in a critical location to provide a
wildlife corridor between  Hanford and the Yakima Training Center.  Thus, while the habitat quality
at McGee Ranch may not particularly high, its location value to wildlife and populations of plants and
animals may be very high, and the impacts created by a borrow site may be essentially unmitigatable.

Response: The discussion about use of borrow sites is preliminary.  At the time that a  need for
a borrow site is identified,  all required evaluations will be performed in consultation with
appropriate entities.
O.     MINES, BASALT, AND GABLE MOUNTAIN

The CTUIR had the following comments:

Comment 1.  We sincerely request that the Tri-Parties refrain from referring to mines and quarries as
"borrow" sites. Does DOE have any intention to return mis material to these sites some day? Of
course not. This material is not being borrowed, it is being taken — taken with often extreme
ecological impacts. Stone, once quarried, cannot be made whole again.


                                            A-34

-------
 Response:  The use of the term "borrow sites" in relation to mines and quarries is legitimate,
 and its use is not in any way intended to imply that any given source area, once mined, will be
 somehow reconstructed.

 Comment 2.  Also, please do not respond that this euphemism is somehow "customary" in the mining
 industry.  The fact that others lie does not change the lie. Calling these mines "borrow" sites  is
 deceptive and dishonest.  Such jargon and euphemism needlessly defeats the tribes' and the public's
 need for clear, frank, honest discussion of issues and impacts.

 Response:  In using the term "borrow pits," DOE did not mean to be deceptive or dishonest.
 The term is clearly defined in Webster's Ninth New Collegiate Dictionary as "an excavated area
 where material has been dug for use as fill at another location."

 Comment 3.  In our scoping meeting with ERDF project staff, we repeatedly emphasized the
 importance of protecting Gable Mountain and other basalt outcrops (such as Gable Butte) on the
 Hanford site.  Gable Mountain is of great religious importance to CTUIR members. The CTUIR can
 be expected to zealously oppose any impact to Gable Mountain.  Other basalt outcrops are also of
 religious importance.

 Response: DOE understands the importance of basalt outcrops to the CTUIR and other tribes.
 This is one reason that the preferred action (which requires no basalt) was chosen.

 Comment 4.  In addition, rock outcrops are a habitat feature that provides unique services to a variety
 of species.  Once these geomorphic features are destroyed, they cannot be restored artificially.

 Response: Thank you for the comment. Current design does not include the use of rock
 outcrops.

 Comment 5.  For these reasons, we urge that the protective cap for the ERDF be constructed without
 basalt.  Either the modified Hanford barrier should be used, or stone should be derived from the
 process described below.

 Response: Current design does not include the use of basalt.

 Comment 6.  The Hanford site is composed mostly of stone.  The ERDF area is no exception.  It is
 underlaid by many feet of Pleistocene flood deposits. Much of the material removed in the
 construction of the trench will be stone. If a crushed stone layer is needed for a biotic intrusion
 barrier in the ERDF cap, then this stone should be used. Simply sieve the appropriate-sized stone
 from the soil, crush it,  and use it in place of the "crushed basalt" layer. Properly processed, this
 local stone should perform well as a biotic barrier.

Response: In fact, locally excavated materials will be utilized to the extent feasible in the
construction of the ERDF cover layer.  And, as noted above, closure of the ERDF site is planned
to be accomplished using a RCRA-compliant cover, which will not require the use of basalt
riprap.

 Comment 7. .This process should be less expensive than quarrying, involve no transportation costs
and quarrying costs, and wholly avoid ecological impacts at yet-to-be-proposed quarry sites and along
transpoi|atipn routes. It should also  render a crushed stone material that is adequate for the
engineering needs of the cap.  Please respond specifically to this proposal.


                                            A-35

-------
 Response:  Please note the comment response above.


 P.  DOE PROMISES TO THE CTUIR CONCERNING GABLE MOUNTAIN

 The CTUIR had the following comments:

 Comment 1.  On at least two separate occasions, at the July NRTC meeting with ERDF staff (on the
 day of the NRTC tour of ERDF sites), and at the September ERDF meeting between the NRTC and
 the Tri-Parties, ERDF project staff made oral promises to CTUIR staff that Gable Mountain would
 not be used as a quarry site for ERDF basalt. We took a good measure of relief from these promises,
 and publicly stated our gratitude and pleasure at this result. As this is an issue of great importance to
 the CTUIR,  we expected this oral promise to be reflected in writing in the RI/FS.  Unfortunately, no
 such promise is made in the RI/FS.  Indeed, the RI/FS leaves open any possibility concerning quarry.
 sites for basalt. So now we must ask, is DOE going to keep its commitment to the CTUIR, that
 Gable Mountain will not be used as a quarry site for basalt? Please respond in writing.

 Response: The current design does not include the use of basalt, which encompasses Gable
 Mountain.

 Comment 2.  DOE often says to tribes and the public "Trust us."  Consider the discussion, above,
 concerning judicial review. Of course, based on past actions, tribes and the public have little reason
 to trust DOE.  Yet, that does not stop DOE from coming back time and time again demanding our
 trust. This Gable Mountain basalt issue is but the smallest of examples of why DOE cannot be
 trusted. Despite our repeated statements to DOE about the importance of Gable Mountain, and
 despite promises by DOE that it would protect Gable, DOE has failed to put the least assurance about
 the future of Gable Mountain in this document.

 Response: Comment noted. When evaluating remedial alternatives, DOE has  a responsibility to
 evaluate reasonable alternatives and to justify the exclusion of certain alternatives from further
 consideration.
Q.  ERDF ECOLOGICAL RISK ASSESSMENT EVALUATION

The Trustees had the following comments:

Comment 1.  The goal of the ERDF baseline risk assessment is to evaluate the likelihood that adverse
ecological effects may occur if organisms are exposed to contaminants that may be disposed in the
facility. The goal of baseline risk assessment per 40 CFR 300.43 (e)  (2) Q) (G) is to characterize
current and likely future ecological risk attributable to releases of contaminants, especially when
sensitive habitats and critical habitats of species protected under ESA may be impacted. The Hanford
Site Natural Resource Trustees have evaluated the ERDF ecological risk assessment and, as such,
have the following comments:

General Response;

EPA, Ecology, and DOE share the Trustees concerns regarding potential ecological effects and
haveinade a conscientious effort to evaluate and mitigate these effects to the extent possible
given the scope of this effort and the desire to remediate areas along the Columbia River.  The


                                           A-36

-------
 relatively simple ecological risk assessment provided in Chapter 6 demonstrates that
 unacceptable ecological risk would result if the wastes to be received at the ERDF were released
 to the environment.  This conclusion would not be altered if a more complex risk assessment
 were conducted. Based  on the conclusions of the risk assessment, the proposed remedied
 alternative is designed to prevent release of-waste to the environment, thereby eliminating
 ecological risk associated with the waste. Furthermore, the report acknowledges that physical
 ecological impacts (i.e., stressors) will occur at the ERDF site due to construction. These
 impacts have been explicitly evaluated as part of the short-term effectiveness criteria (see
 Section 9.2) and significant design modification have  been implemented to minimize the size of
 the facility and the magnitude of the impacts. For example, the trench design has been
 deepened to minimize the impacted surface area.  As stated in Section 9.4.2, habitat value will
 be assessed before the start of construction, and impacts will be mitigated based on the
 ecological value of the habitat disturbed.

 Comment l.a.  In general, the ERDF risk  assessment should have been conducted consistent with the
 Hanford Site Risk Assessment Methodology (HSRM). In the case of ERDF,  it appears that-portions
 of the Risk Assessment (RA) are not complete.

 Response:  The reviewer is correct that the ERDF risk assessment is not entirely consistent with
 the HSRAM methodology, primarily because the HSRAM methodology was not intended for the
 unique situation at the ERDF. Whereas the HSRAM provides guidance for evaluating existing
 environmental contaminants (primarily to determine if cleanup action is warranted), the ERDF
 risk assessment  (Chapter 6) was conducted to determine the need for a engineered barrier over a
proposed landfill. The results of the risk assessment demonstrated that unacceptable risks to
 human and ecological receptors would occur if exposure to materials intended for ERDF was not
 prevented (i.e., by an adequate barrier). This conclusion is already adequately documented in
 existing operable unit remedial investigation reports.

 Comment l.b.  Problem formulation should examine  the nature of the contamination for potentially
 impacted habitats and/or ecosystems. ERDF RA indicated that this assessment does not evaluate
 impacts to populations or the ecosystem, rather, it assesses one ecological receptor, the Great Basin
 pocket mouse.  For this type of risk assessment, it may be more appropriate to assess 2 or 3 receptors
 at the trophic level.  Further, the RI/FS states that it  does not use the pocket mouse as a surrogate for
 any other receptor.

 Response:  Chapter 6 provides adequate evidence that unacceptable ecological risks would occur
 if exposure to ERDF wastes were to occur.  As a result, the remedial alternatives are designed to
 prevent such exposure.  Expanding the risk assessment to include higher trophic levels would not
 change this conclusion or the barrier designs.

 Comment I.e.  Problem formulation should examine the stressors, not only chemical, and
 radionuclide, but also physical,  which would examine changes to natural conditions, such as habitat
 alteration. This risk assessment does not attempt to assess the physical conditions.

Response:  The.report acknowledges that physical  ecological impacts (he., stressors) will  occur at
the ERDF site due to construction. However, it is beyond the scope of this report to compare
the impact of leaving contaminants in their current locations (the no action alternative) with the
impact of physical stressors associated with ERDF construction.  In addition, each of the
alternatives (except the no-action alternative) are-sufficiently similar that an evaluation of
 physical stressors could not be used to rank the alternatives.


                                            A-37

-------
Comment l.d.  Problem formulation should examine indirect as well as direct effects associated with
the release of contaminants.  ERDF RA does not attempt to address the indirect effects associated
with the contaminant release.

Response:  A conclusion of Chapter 6 is that the remedial alternatives need to be designed to
prevent exposure to contaminants intended for disposal in ERDF.  Increasing the scope of the
risk assessment is unnecessary because it will not change this conclusion.

Comment I.e.  Problem formulation should identify ecosystems potentially at risk,  including critical
and sensitive habitats located on, adjacent to, or near the hazardous substance release site of interest.
ERDF RA  does not acknowledge that mature shrub is a priority habitat for several  candidate species
that could potentially be impacted either directly or indirectly.

Response:  Mature shrub habitat is identified as a priority habitat at and near the ERDF in the
RI/FS Sections 2.8.1.1, 2.8.2, and 9.4.2. Impacts on this habitat are a primary concern for this
project and have been explicitly addressed as a decision criteria for the remedial alternatives.
The issue of mitigation of these impacts has been fully acknowledged in Section 9.4.11.

Comment l.f.  Endpoint selection may not be adequate.  Given there are candidate species to be
considered, a second type of indicator species should have been assessed.

Response:  The agencies believe that the endpoint selection is adequate for the purposes to
evaluating the  impact of contaminants (see response to comment Ib).  Similarly, it is
unnecessary  to expand the scope of the risk assessment to evaluate the impact of physical
stressors (see response to comment lc).

Comment l.g.  The Risk Summary is not clear. This should pull the components of the assessment
together into a meaningful  discussion of ecological significance, including the nature and magnitude of
the effects, spatial and temporal patterns of the effects, and potential recovery. It's not clear what the
magnitude of effects are, but there is an indication that there would be significant risk to the
environment (should be more clear) based primarily on heavy metal concentrations and a potential
hazard to wildlife receptors (should be more specific) due to ingestion. It does not discuss potential
recovery due to the impacts.

Response:  The reviewer is correct that "there is an indication that  there would be significant
risk to the environment" if ecological receptors were allowed to be exposed to ERDF wastes. As
a result of this conclusion, remedial alternative barriers are designed to prevent exposure.
Refinement of  the risk assessment is unnecessary because it will not alter the barrier designs.

Comment 2.  The Yakama  Indian Nation commented:  Intrusion scenarios in the ERDF plan are      o
optimistic at best. At no point is the potential for inadvertent intrusion as to the drilling of a well
considered.  Since the current proposal does call for the placement of a layer of top soil over the
facility, it is reasonable to assume that at some point past closure, the land would be utilized due to
the obviously arid nature of this region utilization of the land would presumably require a water
source such as a well. Some intrusion scenario based on this assumption is logical. That is what
would happen if some future resident wishes to drill a well on top of what is currently known as the
environmental restoration disposal facility.  We see a very real need for consideration of such a
potential and  we do recognize the difficulty in identifying a solution for this scenario.
                                            A-38

-------
 Response: Section 6.3 of the RI/FS extends the risk assessment for current exposure to soils to
 determine the risks associated with the 500-year drilling scenario.  This scenario is considered a
 reasonable soil exposure scenario for all the remedial alternatives (except no action). The
 alternatives evaluated include active institutional controls (e.g., fences, signs, patrols), passive
 controls (e.g., markers and offsite records), and a surface barrier that is at least 4.6 m (15 ft)
 thick. It is assumed that institutional controls prevent intrusion into the waste for at least
 100 years and that passive controls prevent intrusion for 500 years. Furthermore, it is assumed
 that because the waste is covered with at least 4.6 m (15 ft) of cover materials, intrusion into the
 waste due to excavation is precluded.  Since none of the evaluated barriers can prevent
 penetration by a drilling rig, however, someone might inadvertently drill through the waste
 sometime after 500 years.  The human health risks associated with soil exposure resulting from
 the 500-year drilling scenario include a total incremental cancer risk (ICR) of 4 x 10~5
 (dominated by uranium) and a maximum HQ of 0.03 (associated with copper).  These risks are
 the same for all the alternatives (except no action). The predicted HQ and ICR associated with
 the 500-year drilling scenario meet the goals established  in the Tri-Party Agreement of 1 for HQ
 and 1 x 10*4 for ICR. The likelihood that someone will drill through the waste is not addressed.

 The U.S. Department of Interior - Fish and Wildlife Service (the Service) had the following comments:

 Comment 3.  The RI/FS  considers the human health risk assessment in much greater detail than the
 ecological risk assessment. This discrepancy in  effort is inappropriate.  Likely future scenarios
 suggest very little use of the site by humans, while buffer zones, mitigation banking, and other land
 uses are likely to retain high quality habitat around the 200  Area, resulting in a much greater potential
 for exposure of nonhuman organisms. Ecological risk assessment should be given at least as much, if
 not more, consideration than human health risk assessment.

 Response:  EPA, Ecology, and DOE share these concerns regarding potential ecological effects
 and have made a conscientious effort to evaluate and mitigate these effects to the extent possible
 given the scope of this effort and the desire to remediate areas along the Columbia River.
 Furthermore, it is acknowledged that the ecological risk assessment is based  on oversimplified
 assumptions regarding the receptor species and exposure scenario. However, this approach
 utilized in the RI/FS is appropriate considering the goals of the risk assessment; that is, to
 determine the need for an engineered barrier to eliminate biointrusion and/or waste release to
 the surface.  The relatively simple ecological risk assessment provided in Chapter 6 demonstrates
 that unacceptable ecological risk would result if the wastes to be received at the ERDF  were
 released to the environment. This conclusion would not be altered if a more complex risk
 assessment were conducted.  Based on the conclusions of the risk assessment, the proposed      e
 remedial alternative is designed to prevent biointrusion and release of waste to  the environment,
 thereby eliminating ecological risk associated with the waste. Although a more detailed
 ecological risk assessment may be more accurate, it would not alter the conclusions of this report
 or the proposed landfill design.

 Comment 4. The Service considers the ecological risk assessment to be inappropriate and incomplete
 for the following reasons:                                     •

 Comment 4a  Risk to aquatic organisms when potentially contaminated groundwater discharges into
the Columbia River  was not assessed.

Response: An unstated assumption is that protection of human health from exposure via a
hypothetical residential  drinking water well at the ERDF edge will result in adequate protection


                                            A-39

-------
 of all receptors at the Columbia River. Qualitatively, dilution, decay, and degradation would
 occur, and support the assumption of adequate protection at the Columbia River.  It is worth
 noting that the ERDF concept supports the TPA goal of removal of contaminants from portions
 of the Hanford Site, especially near the Columbia River, as a means of reducing the likelihood
 of exposure.

 Comment 4b.  Risk to terrestrial organisms during the several decades of the active phase of the
 landfill when contaminated materials would be exposed and fugitive dust would be likely was not
 assessed.

 Response: As summarized in Section 9.4.7 of the ERDF RI/FS, potential risks to workers
 associated with releases during operations are expected to be low and within acceptable limits.
 These risks are expected to be low even with relatively conservative assumptions regarding the
 concentration of airborne particulates. In practice, stringent dust control measures will be
 implemented to minimize dust releases far below the  conservative assumptions in the analysis.
 Given that any ecological receptors will receive much less exposure than workers, ecological risk
 assessment is not warranted.  Exposure to contaminants by ecological receptors during active
 phases of the ERDF could occur, but this exposure is not expected to result in unacceptable risks
 due to the implementation of dust mitigation measures and daily covers over the waste.

 Comment 4c.   Use. of the human health screening process to determine contaminants of potential
 concern for ecological risk assessment (page 5-1, paragraph 4 and pages 6-25, paragraph 6) is not
 appropriate; exposure scenarios and contaminant sensitivities between humans and wildlife are
 substantially different.                            •

 Response:  The document, as well as other remedial investigation reports, provide adequate
 evidence that unacceptable ecological risks would exist if exposure were allowed to occur.  As a
 result, an ERDF barrier would be designed to prevent such exposure.  Expanding the scope of
 the risk assessment would not change this conclusion.

 Comment 4d.   Potential impacts based on cumulative exposure to several contaminants was not
 assessed.

 Response: See above responses.

 Comment 4e.   Ecological risk assessment based on individuals of a single species is not appropriate.
 If just a single species is used, the RI/FS should be appropriately characterize the information
 presented as the "Great Basin Pocket Mouse Risk Assessment:, and not as an "Ecological Risk
 Assessment".

 Response: See above responses, (specifically Ib.)

 Comment 5.  The Service considers the risk assessment using the Great Basin pocket mouse to be
 flawed and based on faulty assumptions. It is stated on page 5-1, paragraph 4 mat animal studies are
 expected to be generally applicable to the pocket mouse.  This statement is misleading.  The pocket
 mous'e is fairly unique among mammals in having an extremely efficient metabolism, require no
 drinking water and excreting highly concentrated urine.  The pocket mouse also spends a significant
portion Of. timei hibernating or estivating. Thus, uptake, eliminations, and exposure rates are likely to
be different from laboratory animals which are provided continually with water and live at a constant.
temperature, and different from standard man (page 6-29, paragraph 2). The unique aspects of pocket


                                            A-40

-------
 mouse life history should be discussed, and should be taken into account when creating exposure
 models such as those on pages 6-28 and 6-29.

 Response: As discussed above, it is acknowledged that the ecological risk assessment is based on
 oversimplified assumptions regarding the receptor species  and exposure scenario. However, this
 approach utilized in the RI/FS is appropriate considering the goals of the risk assessment; that
 is, to determine the need for an  engineered barrier to eliminate biointrusion and/or waste release
 to the surface.

 Comment 6.  The exposure scenario of the pocket mouse, which limited the exposure to dietary
 exposure from seeds, is not appropriate. Additional factors should be included in the exposure
 scenario.  Because the pocket mouse is a burrowing animal, soil exposure will make up a substantial
 portion of total exposure, including increased dermal exposure from living underground, increased
 ingestion exposure from grooming, .and increased inhalation exposure from dust associated with
 digging.  Although soil exposure from radionuclides was assessed, it was not clear which of the above
 factors were included.  Also, regarding plant uptake of contaminants, it is not clear why plant uptake
 by deposition was not considered (page 6-27, paragraph 5); this statement should be justified.

 Response: See response to comments 1  and 5 above.

 Comment 7.  Throughout the Ecological Risk Assessment section, lack of specific information upon
 which to base risk assessment assumptions is frequently mentioned.  The Hanford cleanup is a long
 term project.  The Service strongly recommends that the necessary studies be conducted to obtain
 ecological and contaminant exposure and sensitivity information on the Great Basin pocket mouse and
 several .other key species so that ecological risk can be adequately assessed  in the future.

 Response: See above responses.
R.  CONTAMINANT FATE AND TRANSPORT

Comment 1.  The Trustees commented: Section 4.1.1 describes the conceptual model used.  The
description notes that the mechanisms: controlling contaminant fate and transport in the vadose zone
are highly coupled, unsteady, and non-linear.  Furthermore, the hydrogeologic strata are
heterogeneous and anisotropic.

It .then describes the conceptual model as assuming "the media are homogeneous and isotropic", "the
flow is plug flow in both the vadose zone and saturated zone", and "constituent release form ERDF is
controlled by either solubility or partitioning between the waste and pore water."

It is clear the conceptual model bears little or no relation to the actual conditions. There is no data
provided to justify the model selected as being in any way representative of the actual conditions.
There is no analysis or data provided to show that bounding conditions exist which would allow the
use of such a simplified model.

Response:  See general and specific responses noted below.

The CTUIR had the following comments:
                                            A-41

-------
Comment 2.  By DOE's own admission, quoted above, the design of the model bears little relation to
the reality of the site. As a result, CTUIR technical staff view the extensive results and additional
assumptions outlined in Appendix A to be a house of cards.

Response:  See general and specific responses noted below.

Comment 3.  Simplistic and unrealistic assumptions about homogeneous hydrogeologic conditions,
vertical-only flow paths, and the physical and chemical behavior of only single contaminants make it
highly doubtful that:

1)     a complete range of contaminants of concern has  been identified,

2)     identified infiltration characterization and subsurface behavior are representative,

3)     interactive effects of contaminants or critical conditions such as Ph, discontinuous caliche
       layers, or bedding have been adequately accommodated,

4)     contaminant mixing or transport processes  are as  simplistic as portrayed, and

5)     calculated travel times  are anything but meaningless when they are assumed to vary only in
       proportion to vadose zone thickness.

Response:  See general and specific responses noted below.

Comment 4.  We find additional reason to doubt the accuracy of the model and assumptions when we
review the summary tabulation of potential groundwater contaminants identified through this modeling
(Table 4-11). This table indicates Identical travel times for such physically and chemically diverse
constituents as radionuclides, heavy metals, and selected anions.    Such an implausible result is
highly suspectj and would, by itself, call the model into question.

Response:  See general and specific responses noted below.

Comment 5.  These deficiencies indicate to CTUIR staff that the adopted modeling approach,
combined, as it is, with too many unrealistic assumptions, fails to  serve its stated goal of
"identify[ing] groundwater contaminants, perform[ing] contaminant screening, and evaluating]
alternative ERDF designs" (Section 4.1).

Moreover, despite the foregoing quote, Section 4.1 does not apply the results of the modeling to
"evaluation of] alternative ERDF designs."

Given these deficiencies, CrUiK technical staff conclude that the model used for evaluating the
ERDF proposal — and the data generated by that model - is of little value.

Response:  See general and specific responses noted below.

Comment 6.  The CTUIR staff request that before further steps on the design of the ERDF are
completed,  a  more representative model should be  developed that represents field conditions more
realistically and that is designed specifically to evaluate barrier and subsurface characteristics and
develop appropriate engineering design criteria. The results of the new modeling will be essential for
                                             A-42

-------
 informed decision making concerning engineering and design of the ERDF, including but not limited
 to the Remedial Design portion of the project.

 General Response

 The predictive fate and  transport model for the site is based on a parametric approach that
 utilizes empirically-based parameters that are relatively easy to measure instead of a mechanistic
 approach that would rely on physically-based parameters that are highly variable and difficult to
 measure.  Although relatively simple, the parametric approach has experimental analogs (such
 as lysimeter observations, laboratory column testing, and field measurements of plume
 migration) that demonstrate a good comparison between the conceptual model and actual
 conditions.  In contrast  with the reviewer's comments, the simple parametric approach utilized
 for this analysis is solidly based on direct field and laboratory observations. The primary
 parameters (including infiltration rate, moisture content,  and soil/water partitioning coefficient)
 are relatively easy to measure and have a relatively low degree of variability.

 The reviewer appears to be recommending a mechanistic  approach that relies on physically-
 based parameters such as unsaturated hydraulic conductivity (which can vary over many orders
 of magnitude with very  small changes in moisture content or soil texture).  Such an approach is
 not possible given the current state-of-the-art.  Although we know that unsaturated  fate and
 transport is complex, the scientific community has not yet developed the conceptual
 understanding, tools, and data to simulate this complex process.

 Understanding the physical mechanisms of unsaturated flow and transport is important in terms
 of furthering our understanding of contaminant fate and  transport; DOE and others have
 supported such research for many years.  As a result, a review of the literature will provide
 many examples of physically-based models for simulating unsaturated fate and  transport.
 Careful review of these  models will reveal that they are not useful for practical application for a
 variety of reasons, including one or more of the following:

 1)     the model focuses on specific segments of the process and does not address the entire
       system;

2)     the model requires extensive data  that are not possible to collect for a field application;

3)     the model requires vast computing resources and thus is not feasible for field applications
       that include large variable model domains, multiple constituents, and long time frames.

Specific Responses;

Re:  Contaminants of Concern. The analysis considered every constituent that has been
identified as a potential  constituent of concern  at the Hanford Site. Risk associated with the
ERDF will be driven by constituents that  are mobile, long-lived, and toxic.  Furthermore,
constituents that are found in groundwater beneath the waste units are likely to be potential
contaminants of concern. The modeling results were compared with a qualitative evaluation of
these factors to ensure that no potential contaminants of concern were overlooked. Therefore,
given the limits of our knowledge and experience at Hanford and other sites, we can state with
confidence that the list of potential constituents of concern is complete.
                                           A-43

-------
Re: Infiltration characterization and subsurface behavior. Due to lysimeter studies and      °
observation of existing contaminant plumes, the Hanford Site has many field analogs for
infiltration and subsurface fate and transport. The modeling parameters relied on these data to
the extent possible and the results are consistent with these observations.

Re:  Geochemical interaction and stratigraphic conditions.  The complex geochemical
interactions and other chemistry factors cited by the reviewer have been identified as potentially
important factors under certain conditions.  In particular, low-pH or high-organic contents
found in some of the waste streams in the 200 Area can significantly increase the migration rate
of some radionuclides and metals. However, chemical  conditions in the waste and below the
ERDF are expected to be characteristic of the 100 and  300 Areas, which are neutral pH and low
organic content. Based on observations of plume migration in the 100 and 300 Areas, the
geochemical interactions and chemistry factors cited by the reviewer are second-order
considerations that would not significantly impact the results.

Re:  Stratigraphic layering and mixing. Stratigraphic layering can impact groundwater
migration by inducing horizontal migration and impacting vertical migration and mixing.  These
effects are more important in cases where the modelled facility received liquid effluent and
infiltration rates were quite high. Given the low rates of infiltration (i.e., similar or less than
background) these effects were considered relatively unimportant and were incorporated into the
model using a parametric approach.

Re: Travel times.  The comment suggests that travel times were only a function of vadose zone
thickness and that all the constituents have identical travel times. As described in Appendix A,
travel times were a function of vadose zone thickness, infiltration rate,  and retardation (as well
as other minor parameters.  Furthermore, although some of the constituents have identical
travel times, in general they are divided into a range of travel  times ranging from completely
mobile (the same migration rate as water transport) to  highly immobile (up to 100,000 times
slower than water transport).

Re: Evaluation of alternative ERDF designs.  Alternative ERDF  designs are not evaluated in
Section 4. They are evaluated in Section A.4 and the results are summarized in Section 9.5.
IV.  REMAINING CONCERNS

Issues and concerns that the Tri-Parties were unable to address in detail during remedial planning
activities include the following:

  •    Mitigation - A mitigation action plan will be prepared to address mitigation requirements for
       the ERDF.  The Hanford Natural Resource Trustees will be consulted in development of this
       plan.
                         /

  •    Waste Acceptance Criteria - Several public interest groups requested that the public have an
       opportunity to provide input into the development of waste acceptance criteria.  EPA is
       committed to providing interested parties a copy of the draft waste acceptance criteria for the
       ERDF when it becomes available.
                                           A-44

-------
Tribal Cultural Resource Review - The CTUIR and Yakama Indian Nation requested the
opportunity to perform a cultural resource review of the ERDF site prior to construction.
DOE is in consultation with the Tribes concerning this issue.
                                     A-45

-------
                              RESPONSIVENESS SUMMARY
                                LIST OF COMMENTORS
Written Comments

Don Sivula
41 H Street SE
Ephrata, Washington  98823-1920

Gregory deBruler
Columbia River United
P.O. Box 912
Bingen, Washington 98605

United States Department of the Interior
Fish and Wildlife Service                   U.S. Fish and Wildlife Service
David C. Frederick                        Liz Block
3704 Griffin Lane SE, Suite 102             P.O. Box 1157
Olympia, Washington 98501-2192           Moses Lake, Washington 98837

Mrs. Pamela Lindstrom
960 Cedar St.
Edmonds, Washington 98020

Oregon Department of Energy               Oregon Department of Energy
Mary Lou Blazek                          Dirk Dunning
Nuclear Waste Program                     625 Marion Street NE
625 Marion Street NE                     Salem, Oregon  97310
Salem, Oregon  97310

Confederated Tribes of the Umatilla Indian Reservation (CTUIR)
Michael Farrow
Department of Natural Resources
P.O. Box 638
Pendleton, Oregon  97801

Nell  Zajac
11311 26th Ave. S, #2-310
Seattle, Washington 98168

Joan Clish
2410 S.E. Bay Point Dr., #63
Vancouver, Washington  98684

Vera Wilson
2880 Five Mile Road
The Dalles, Oregon 97058
                                          A-46

-------
 Bruce Bordenick
 7035 Bayview Drive
 Port Orchard, Washington  98366

 BettieJ. Stone
 8651 St. Hwy 3 S.W., Sp 44
 Port Orchard, Washington  98366

 Penberthy Electromelt International, Inc
 Larry Penberthy
 631  South 96th Street
 Seattle, Washington 98108
Formal Comments During Public Meetings

Al Conklin
Washington Department of Health
P.O. Box 47827
Olyrnpia,WA  98504

Greg deBruler
Columbia River United
P.O. Box 912
Bingen,WA 98605

Pat Herbert
Coho Coalition
P.O. Box 95966
Seattle, WA

Cindy Sarthou - Staff Attorney
Gerald Pollet - Executive Director
Heart of America Northwest
13.05 4th Avenue
Cobb Building, Suite 208
Seattle, WA  98101

Kathryn Crandel
5928 48th Ave. S.W.
Seattle, WA  98136

Patrice Kent
Yakama Indian Nation
Environmental Restoration Waste Management Program
2802 Main Street                           P.O. Box 151
Union Gap, WA  98903                     Toppenish, Yakama Nation  98948
                                           A-47

-------
Rick Leaumont
Lower Columbia Basin Audubon Society
9016 Sunset Trail
Pasco, WA 99301

Lynn Sinuns
no address found

Page Knight
Hanford Watch
2285 SE Cypress
Portland, OR  97214

Ross Tewksberry
P.O. Box 25594
Portland, OR  97225
                                         A-48

-------