PB97-964604.
                                EPA/541/R-97/048
                                November
EPA  Superfund
      Record of Decision:
       Hanford 200 Area (USDOE),
       (200-UP-l Operable Unit)
       Benton County, WA
       2/11/1997

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                                                                      043623
               DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION

U.S. DOE Hanford 200 Area
Hanford Site
Benton County, Washington
STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected Interim Remedial Action (IRA) for the U.S.
Department of Energy (U.S. DOE) Hanford 200-UP-l Operable Unit (OU), 200 Area,
Hanford Site, Benton County, Washington. The IRA 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), the Hanford Federal Facility Agreement and Consent Order (also known as the Tri-
Party Agreement, or TPA), 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.

The State of Washington concurs with the selected remedy.
ASSESSMENT OF THE SITC

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

The selected remedy consists of pumping the highest concentration zone of the contaminated
groundwater plume at 200-UP-l and treatment using the existing Effluent Treatment Facility
(ETF) located hi the 200 East Area. The selected remedy is intended to reduce contaminant
mass within the plume and minimize migration of uranium and technetium-99 from the 200
West Area. The selected remedy will remove and treat these two contaminants of concern,
in addition to the specific co-contaminants of nitrate and carbon tetrachloride which exist
within the groundwater.  The high concentration 'portion of the plume corresponds to that
area having contaminant greater than or equal to levels ten times the cleanup level of
uranium under the  Model Toxics Control Act (MTCA), and ten times greater than the

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                                                                          043623
 maximum contamination limit (MCL) for technetium-99 (see Figures 4 and 5). The cleanup
 level is based solely on an assessment of uranium toxicity, and not on cancer risk that it may
 pose.

 During this IRA the ETF, which is located in the 200 East Area, will be used for the
 treatment and removal of contaminants of the groundwater.  The ETF is a multistage facility
 that can remove and/or destroy a large number of contaminants, including nitrate and carbon
 tetrachloride, which are present at high concentrations in the 200-UP-l OU groundwater.
 The State of Washington has made a contained in determination of carbon tetrachloride for
 this action  in order to facilitate the treatment of carbon tetrachloride at the ETF.
BACKGROUND

A pilot scale system was started in April 1994 at a rate of about 60 liters per minute (15
gallons per minute [gpm]) to remove uranium and technetium-99.  The pilot scale system
proved to be successful hi the removal of contaminants from the groundwater. The system
was upgraded to 190 liters per minute (50 gpm)  in September 1995 by construction of
additional extraction and injection wells.  Based on the results of the actual field data analysis
of plume containment and mass removal, and the initial modeling results, a pumping rate of
190 liters per minute (50 gpm) is considered to be adequate to meet the IRA objectives. The
goal of the IRA is to reduce the uranium and technetium-99 to at least ten times  the cleanup
level.  Since there is no established value of maximum concentration limit (MCL) for
uranium, the MTCA cleanup value is used for uranium in the IRA. Periodic monitoring and
data collection activities will occur throughout the IRA.
STATUTORY DETERMINATIONS

This interim action is protective of human health and the environment in the short term and
is intended to provide adequate protection until a final ROD is signed. The groundwater
removed will be treated to meet requirements before discharge.  However, the underlying
groundwater will not be treated to achieve SDWA and MTCA cleanup levels.  This interim
action is only part of the total remedial action and is cost effective. Although this interim
action is not intended to address fully the statutory mandate for permanence and treatment to
the  maximum extent practicable, this interim action does utilize treatment and thus  is in
furtherance of that statutory mandate. Because this action does not constitute the final
remedy for the 200-UP-l  OU, the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element, although partially addressed
hi this remedy, will be addressed further hi the final response action.  Subsequent actions are
planned to fully address the threats posed by this .operable unit.

Because this remedy will  result in hazardous substances remaining onsite above health-based
levels,  a review will be conducted to ensure that the remedy continues to provide adequate

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                                                                 043623
protection of human health and the environment within five years after the commencement of
the remedial action.

Because this is an interim action ROD, review of this OU will be ongoing as the three
parties continue to develop and evaluate final remedial alternatives for the 200-UP-l OU.
                                       ui

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Signature sheet for the ROD for the U.S. DOE Hanford 200-UP-l OU, 200 Area National
Priorities List Site Interim Remedial Measure between the U.S. DOE and the Washington
State Department of-Ecology, and the U.S. Environmental Protection Agency.
                  AYZfa-i A ,\y
Wf 7
Manager, Richland Operati^
United States Department of Energy
                                                                    Date
                                      IV

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Signature sheet for the ROD for the U.S. DOE Hanford 200-UP-l OU, 200 Area National
Priorities List Site Interim Remedial Measure between the U.S. DOE and the Washington State
Department of Ecology, and the U.S. Environmental Protection Agency.
Chuck Clarke                                                         /   Date
Regional Administrator, Region 10
United States Environmental Protection Agency

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Signature sheet for the ROD for the U.S. DOE Hanford 200-UP-l OU, 200 Area National
Priorities List Site Interim Remedial Measure between the U.S. DOE and the Washington
State Department of Ecology, and the U.S. Environmental Protection Agency.
Michael A. Wilson                                                      bate
Program Manager, Nuclear Waste Program
Washington State Department of Ecology
                                         VI

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                              DECISION SUMMARY
                               1.0 INTRODUCTION

The U.S. Department of Energy's (U.S.  DOE's) Hanford Site was listed on the National
Priorities List (NPL) in November 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.

This  action is being taken as an interim action and is  expected to become part of a final
remedy selection for the 200-UP-l Operable Unit (OU),  which is part of the 200 Area NPL
site.
                2.0  SITE NAME, LOCATION, AND DESCRIPTION

The Hanford Site is a 1,450 square km (560 square mi) Federal facility 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 200 Area NPL site is located in the central portion of the Hanford Site, and covers less
than 39 square km  (15 square mi).  The 200-UP-l OU is located in the 200 West Area of the
200 Area NPL site. Contamination of the groundwater in the 200-UP-l OU resulted from
historic .discharges primarily from the uranium processing plant.

The land surrounding the Hanford Site is used primarily for agriculture and livestock
grazing. The major population center near the  Hanford Site is the Tri-Cities, with a
combined population of approximately 100,000.

The land is semi-arid with a sparse covering of cold desert shrubs and drought resistant
grasses.  Forty percent of the area's average annual  rainfall of 15.9 cm (6.25 in.) occurs
between November and January. In part due to the semi-arid conditions, no wetlands are
contained within the boundary of 200-UP-l OU.

The Columbia River is located approximately 16.1 km (10  mi) east and 7.5 km (4.7 mi)
north of the 200 West Area.  The 200 West Area is not within the 100-year flood plain of
the Columbia River.

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             Figure 1. Hanford Site Map.
 WuMngton CM*
                                                                 Araa
Arid Linda Ecology Rnarv*

CllyofRkMand

Saddle HounteJn Nrtenal WltdDta
fUftiga

WaaMneton SMa Dcpartnant of    BantDnJ
Oanw Raoarva                   city
       5IOtom«t*r«

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                3.0  SITE HISTORY AND ENFORCEMENT ACTIONS

The Hanford Site was established during World War II as part of the Army's  "Manhattan
Project" to produce plutonium for nuclear weapons. Hanford Site operations began in 1943,
and U.S. DOE facilities are located throughout the Site and in the City of Richland.   Much
of the land that the Hanford Site now occupies was originally ceded to the government by
treaty with various Native American tribes.  Certain portions of the Hanford Site are  known
to have cultural significance and may be eligible for listing in the National Register of
Historical Places.

In 1988,  the Hanford Site was scored using the U.S. Environmental Protection Agency=s
(EPA's) Hazard Ranking System.  As a result of the scoring, the Hanford Site was added to
the NPL  in November 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 OUs (a grouping of individual
waste units based primarily on geographic area and common waste,sources).

U.S. DOE, EPA, and the Washington State Department of Ecology (Ecology) entered into a
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 the Hanford Site. The agreement also addresses Resource  Conservation
and Recovery Act (RCRA) compliance and permitting.

The 200-UP-l OU  is one of two groundwater OUs located  in the 200 West  Area and  is
shown in Figure  2.  Contamination in the 200-UP-l OU resulted from historic discharges to
five primary liquid waste disposal sites.  These five sites are at cribs 216-U-l, 216-U-2, 216-
U-8, 216-U-12, and 216-U-16.  The predominant  contaminants  in the waste stream were
uranium and technetium-99.  It is estimated that 4,000 kg (8,800 Ib) of process waste  from
Uranium  Oxide (UO3) Plant, consisting primarily of dilute nitric acid containing uranium,
technetium-99, and small quantities of other fission products, was discharged to the soil
columns via two  cribs (216-U-l and 216-U-2) between 1951 and 1968. Most  of these
contaminants were  initially retained in the upper 20 m (65 ft) of soil.  During  the final years
of crib operation (1966 through 1968), highly acidic wastes were disposed, which resulted in
mobilizing the contaminants. The mobile uranium was transported  to groundwater when
large volumes of cooling water were discharged to the adjacent 216-U-16 Crib in 1984. A
pump and treat action was initiated in 1985 that removed 680 kg (1,500 Ib)  of uranium,
reduced contaminant levels resulting  in the concentrations present today (DOE-RL 1993).

During 1993, the U.S. DOE completed aggregate area management studies  (AAMS) that
compiled and evaluated information about source and groundwater contamination in the
200 West Area.  Recommendations generated from the AAMS included interim actions to
accelerate removal and limit the potential spread of contamination where information  is
sufficient to successfully plan and implement the actions.  For the 200-UP-l OU, the  area
containing the highest concentration of uranium, technetium-99 and nitrate was recommended

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       Figure 2. Location of 200-UP-l Groundwater Operable Unit.
                                                W T-PLANT
200-ZP-1
GROUNDWATER
OPERABLE UNIT
200-UP-1
TEST SITE
 200-UP-1
 6ROUNOWATER
 OPERABLE UNIT
              200 WEST MCA
              POBtfTER
                                                  0   250   500 METERS
                                                            JJA:PT5DA-A2

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for an Interim Remedial Action (IRA).  Subsequently, it was determined that nitrate should
be removed from consideration as a contaminant of concern for this remedial action because
the nitrate plume emanating from the 200 West Area is so extensive.  Treatment of the
portion of the nitrate plume within 200-UP-l will not result in a significant reduction in the
overall nitrate plume.

              4.0  HIGHLIGHTS  OF COMMUNITY PARTICIPATION

The U.S. DOE, Ecology,  and  EPA (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 promote public involvement in the
decision-making process.  Since April 1990, the Tri-Parties  have held several public
meetings and sent out numerous fact sheets in an effort to keep the public informed about
Hanford Site cleanup issues. The CRP was updated in 1993 and 1996 to enhance  public
involvement.

The 200 West Groundwater Aggregate Area Management Study Report, the Interim Remedial
Measure Proposed Plan for the 200-UP-l OU, Hanford, Washington, and the Engineering
Evaluation/Conceptual Plan for the 200-UP-l OU Interim Remedial Measure (BHI-00187,
Rev. 0) were  made available on August 8, 1995, to the public in both the Administrative
Record and the Information Repositories  maintained at the locations listed below:

      ADMINISTRATIVE RECORD (contains all project documents)

      U.S. Department of Energy
      Richland Operations Office
      Administrative Record Center
      740 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
      300 Desmond Drive
      Lacey, Washington 98503-1138

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       INFORMATION REPOSITORIES (contains limited documentation^

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

       Gonzaga 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

       U.S. DOE Richland Public Reading Room
       Washington State University, Tri-Cities
       100 Sprout Road, Room 130
       Richland, Washington  99352
A fact sheet, which explained the proposed action, was mailed to approximately 2,000
people.  In addition, an article appeared in the bi-monthly newsletter, the Hanford Update,
detailing the start of public comment.  The Hanford Update is mailed to over 5,000 people.
The Proposed Plan went for public comment for 60 days from August 8 to October  6, 1995.
Public notices were also published in the leading regional newspapers, such as Tri-Ciry
Herald, the Seattle Times P/f,  the Spokesman Review, the Oregonian, and the Hood River
News on August 8, 1995. Ecology made a presentation at the Hanford Advisory Board's
Environmental Restoration Committee (HAB-ER) on September 8,  1995.  A public  meeting
was also held at Kennewick on September 26, 1995. The public supported use of the pump
and treat technology as a remedial alternative.  However, the majority of the comments
recommended consideration of the existing Effluent Treatment Facility (ETF) for the
treatment of 200-UP-l OU groundwater, as it was not considered in the original proposal.
The public recommended use of the existing  state of art treatment system of the ETF, located
in the 200 East Area.  Along with uranium and technetium-99, the ETF is capable of
removing a wide variety of contaminants. A summary of the public response is provided in
the Appendix A of this document.

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Subsequently, U.S. DOE considered the use of ETF and the details were provided in the
Engineering Evaluation/Conceptual Plan for the 200-UP-1 Operable Unit Interim Remedial
Measure (BHI-00187, Rev. 2) with an accompanying transmittal letter (030528 of April 24,
1996).  A focus sheet was published and distributed for public comment for a period of 60
days (from August 5, 1996, to October 4, 1996) explaining the use and benefit related to the
proposed change.  Public notices were also published in the leading regional newspapers of
the State, such as Tri-City Herald, the Seattle Times /*//, the Spokesman Review, the
Oregonian, and the Hood River  News on August 5, 1996.  The new proposal for the use of
ETF was presented to the HAB-ER-subcommittee for their recommendation.  The HAB
endorsed use of ETF. This decision document presents the selected interim remedial
measure for the 200 UP-1  OU at the Hanford Site, Richland, Washington, chosen in
accordance with CERCLA, as amended by SARA, and to the extent practicable, the NCP.
    5.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY

This action is being taken in an effort to address one of the most serious groundwater
problems on the Hanford Site.  It is believed that, by reducing the uranium and technetium-
99 within the high concentration portion of the plume, the potential for spread of
contaminants to offsite receptors above a risk threshold can be reduced or eliminated. This
action will facilitate further investigation of the 200-UP-l OU by providing information about
aquifer parameters based on data from the groundwater extraction and monitoring wells.  In
addition, this interim action will provide site specific performance  information that can be
used to evaluate alternative technologies, determine optimum process sizing, and estimate
costs. This interim  remedial action is expected to be consistent with any planned future
actions.  Because this interim action is not the final remedy for the 200-UP-l OU,
subsequent remedial actions will address any future potential  threats posed by this site.  This
IRA and any subsequent remedial actions are based on Administrative Record (AR).
                           6.0 SITE CHARACTERISTICS

6.1   Site Geology and Hydrology

6.1.1 Geology

The Hanford Site is located in the Pasco Basin, which is 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 as shown in Figure 3. The 200 Area is located in the center of the Hanford
Site. The geologic structure beneath the 200 Area  is  similar to much of the rest of the
Hanford Site, which consists of three distinct levels of soil formations. The deepest level is
a thick series of basalt flows that have been folded, resulting in protrusions that crop out as .

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Figure 3. Conceptual Stratigraphic Column at 200-UP-l Operable Unit.
Ill
V) (/) O
 I  I  I
               Eolion Sand. 0-10 ft Thick
   • o
               Hertford fm. unit  1  (upper coarse),  sandy, pebble-cobble
               gravel,  sand interbeds  and open—framework texture common.

               Hanford fm, unit  2  (fine),  interbedded  sand and  silt  that
               generally fines downwards,  contact w/  unit  1  sharp to
               graduational.


               Hanford fm, unit  3  (lower  course),  localized sandy gravel
               similar  to Unit  1.
               Hanford fm, unit  4 (lower  fine),  localized silt  and sand.
               Plio-Pleistocene  unit, upper silt interval and  lower carbonate-
               rich  silt.  sand, and grovel, carbonate beds discontinuous.


               Ringold Fm. upper unit, sand  w/ interbedded silt.	
        JL Approximate  Water  Level at  240 ft.
               Ringold  Fm, unit  E.  sandy pebble—cobble  gravel with
               lenticular interbedded sand  and silt locally.
               Ringold Fm. lower mud unit, silt w/ minor  sand,  continuous
               beneath  area.
                Ringold Fm, unit A.  sandy pebble—cobble gravel similar  to
                that of Unit E.
                Qephant Mountain Basalt Member.

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                                                                                                 Injection Well



                                                                                                 Extraction Well


                                                                                                 Monitoring Well
wi9.u   vm.M   U Plant


          459
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rock ridges in some places.  Layers of silt, gravel, and sand (known as the Ringold
Formation) form the middle level.  The uppermost level  is known as the Hanford formation
and consists of gravel and sands deposited by catastrophic floods during glacial retreat.  A
geologic cross section for the 200 West Area is shown in Figure 4.  Both confined and
unconfmed aquifers can be found beneath the Hanford Site

6.1.2  Hydrology

In the 200 West Area,  the uppermost aquifer is located in the Ringold  Formation and
displays unconfmed to  locally confined or semi-confined  conditions. The Ringold Formation
is made up of a series of alluvial sands and gravels. The depth to groundwater ranges  from
approximately 58 to 82 m (190 to 269 ft) in  the 200 West Area and in general flows from
west to east. Groundwater recharge to the aquifer below  the 200 Area has been primarily
from  process effluents.  In the area near U Plant  Area the depth to groundwater is from 60
to 66 m (197 to 216 ft).  The saturated thickness  of the unconfmed aquifer around the U
Plant is approximately  67 m (220 ft). The hydraulic conductivity for the Ringold Formation
varies widely.  The hydraulic conductivity for the Ringold Formation in the 200-UP-l  OU is
approximately 50 ft per day.  Groundwater flow direction is thought to be from the
southwest.

6.2    Nature and Extent of Contamination

The 200 West Area is an operational area of approximately 5.1 square  km (1.97 square mi)
where spent nuclear fuel  was processed in four main facilities:  U Plant (primarily uranium
recovery); Z Plant (primarily plutonium separation and recovery); and S and T Plants
(primarily uranium and plutonium separation from irradiated fuel rods).

Monitoring programs have been in place for  many years  at the Hanford Site.  Information
from  these monitoring programs was used to determine that an interim remedial action was
needed at the 200-UP-l OU.

Contamination in the 200-UP-l OU resulted  from historic discharges of process water  from
the UO3 Plant to five primary liquid waste disposal sites  (cribs).  The predominant
contaminants were uranium and technetium-99. The major portion of discharge to the soil
column was via two cribs (216-U-l and 216-U-2) between 1951  and 1968, which transported
the mobile constituents, particularly technetium-99, to the water  table.  However, most of the
uranium discharged to  the cribs was retained in the upper 20 m (66 ft) of the soil column.
During the final years of the crib operation (1966 through 1968), small volumes of highly
acidic decontamination wastes were discharged, which resulted in the dissolution of part of
the previously deposited autunite (uranium carbonate) and transport of a small fraction of
uranium  phosphate. Low concentrations of uranium were seen in the groundwater
monitoring wells near the 216-U-l  and 216-U-2 cribs during this period.  The majority of
dissolved uranium  was distributed throughout the soil  column beneath the crib with the
largest concentration deposited above a caliche layer at about a 50 m (164 ft) depth.  During
                                           10

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1984, large volumes of cooling water were discharged to the adjacent 216-U-16 crib which
resulted in transport of uranium to the groundwater.  During 1985 uranium concentrations in
the groundwater abruptly increased from  166 to 72,000 pCi/L. Limited pump and treat
activities were initiated in 1985 to recover the uranium from the groundwater using ion
exchange. During the six months of pump and treat about 687 kg (1,500 Ib) of uranium were
recovered and the concentration in well 199-W19-3 was reduced to 1,700 pCi/L.

In addition to the uranium and technetium-99 plumes, nitrate and carbon tetrachloride are
also present within 200-UP-l OU in concentrations above the maximum concentration limit
(MCL) for drinking water under the Safe Drinking Water Act.  Nitrate contamination resulted
from discharges of neutralized nitric acid to various cribs located in the U Plant and S Plant
areas.  The source for the carbon tetrachloride is believed to be upgradient and outside the
200-UP-l OU,  and associated with the Z Plant disposal sites.  The extent of carbon
tetrachloride and nitrate contaminant plumes are much larger compared to uranium and
technetium-99 plumes. Carbon tetrachloride contamination in  the groundwater is found
throughout the entire 200 West Area. The nitrate plume extends from west of the 200 Area
to the Columbia River. A small portion of carbon tetrachloride was used as a degreasing
agent in the  200 Area. Therefore, the carbon tetrachloride plume was reported and
designated as a listed waste. The nitrate plume  is much larger and coalesces with other
nitrate contaminant plumes  from a number of 200 West Area facilities.  Table 1 shows the
list of contaminants encountered  in the 200-UP-l OU.

The present  plume distributions for uranium, technetium-99, nitrate and carbon tetrachloride
are illustrated in Figures 4, 5, 6, and 7.   The leading edge of contamination for all these
plumes has migrated beyond the  200 West Area boundary.  The combined uranium and
technetium-99 plume covers an area of 0.5  square km (0.2 square mi).

                           7.0  SUMMARY OF SITE RISKS

This section presents an overview of the risk assessment methodology and the qualitative risk
evaluations undertaken as part of the assessment of the contaminated groundwater plumes in
the 200-UP-l OU.

During the assessment and  information gathering phase, U.S. DOE performed an initial risk-
based screening, as well as a comparison of known contaminant concentrations  in 200-UP-l
OU groundwater against pertinent federal and state groundwater standards.  The risk-based
screening was qualitative in nature and was designed to prioritize contaminant plumes for
potential remedial actions.  The screening concluded that uranium, technetium-99, and nitrate
present a high potential risk due  to their carcinogenic and or non-carcinogenic characteristics,
and that  these contaminants had been consistently detected in the groundwater at
concentrations that significantly exceeded MCLs and other human health risk-based .levels for
drinking water.  It should be noted that the contaminated 200-UP-l OU groundwater is not
currently used as a drinking water  source, nor is it considered to be used for drinking water
for the foreseeable future.
                                           11

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                              U  Plant
•    216-U-1. 2
         Crib5   Sjh.
       216-U-16
           Crib
                        216-U -12
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Well used lor plum* definition

Conccnlrolion isopltlh in pkoCuritt pci lilci (pCi/l)

UopKlht or* boicd on (he moil <*c«nl
onalylkol ittullt lor Iht period 3/93 lo 10/94.
Detection limit	IS pCi/l
Dunking Water Stondo'd	900 pCi/l
Uoiimum Cortcenliolion limit	900 pCi/l
Woshmqlon Woler Quality Stondoid	   N/A

     Derived Concenliolion Guide .        4000 pCi/l
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 •    216-U-1.  2
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     Inoptetht ore bated on the matt recent
     analytical results tor the period 3/9J to 10/94.
Detection Limit	
Drinking Water Standard	

Uottmurn Concentration Limit. . .  .

Woihinqlon Water Quality Standard

1/25 Derived Concentration Cuida
.  • 500 ppb
. 45.000 ppb
 45.0OO ppb

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  aoo-zr-i    '


OpvnDto Un« Boumtaiy
     200 West
Carbon Tetrachloride
    Grounciwuter
  Contamination
       1995
        MumluingWtl
      Conc«nbtUoni ki pyA.
      Itoplollii me lii i\
           -N-
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Table 1. Maximum Concentration of Contaminants in the 200-UP-l Operable Unit (1994-1995).
              Constituent

         1,1 -Dichlolroethene
         1,2-Dichlolroethene
         4,4'-DDD
         Arsenic
         Cadmium
         Carbon tetrachloride
         Chloromorm
         Chromium
         Fluoride
         Iodine-129
         Plutonium-238
         Potassium-40
         Selenium
         Strontium-90
         Technetium-99
         Trichloroethene
         Uranium
      Units
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
pCi/L
pCi/L
pCi/L
ug/L
pCi/L
pCi/L
ug/L
ug/L
   Maximum
 Concentration

3.2
5.5
0.008
17.1
54
1800
29
2400
2400
86.1
0.00415
 142
 8.6
 71.3
 21400
 33
 16400
         Ref: DOE/RL-96-33 Draft A, July 1996
                                        15

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The evaluation of 200-UP-l OU concluded uranium and technetium-99 present a relatively
high potential  risk for their carcinogenic characteristics.  The radioisotopes of uranium and
technetium-99 are known human carcinogens.  The uranium in chemical forms and nitrate
present potential risk for their non-carcinogenic health effects.  Nitrate is a contaminant with
a potential for causing methemoglobinemia, which may be life threatening to fetuses and
infants.

The maximum concentrations were approximately 2,000 ppb for uranium and 23,700 pCi/L
for technetium-99.   The Drinking Water Standards  maximum contaminant levels (MCL) for
technetium-99 is 900 pCi/L.  The Washington State Model Toxics Control Act (MTCA)
cleanup standard for uranium is 48 ppb.

7.1    Qualitative Risk Assessment Methodology

A qualitative risk analysis  of the 200-UP-l groundwater operable unit was prepared based on
the document titled, Risk-Based Decision Analysis for Groundwater Operable Units (BHI-
00161). That  analysis included the following evaluations:

•     Characterization  of potential risks to onsite workers via ingestion of contaminated
       drinking water under an industrial exposure  scenario.  The point of ingestion would
       be at the boundary  of the 200 Area plateau.

•     Estimation of downgradient concentrations at various potential receptor points while
       accounting for  natural attenuation and dispersion of contaminants, assuming no
       remediation of the groundwater from 200-UP-l OU.

7.2    Risk Characterization

For carcinogens, risks are estimated as  the likelihood of an individual developing cancer over
a lifetime as a result of exposure to a potential carcinogen.  These are expressed an
exponential ratio such as 1 x 10E-4 (one additional  cancer  for 10,000 members of an exposed
population). When potential  risks exceed 1 x 10E-4, remedial action is generally required to
reduce or eliminate the risk.  For non-carcinogens,  potential human health hazards are
evaluated separately from carcinogens.  The daily intake over a specified period of time is
compared to a reference dose to determine the hazard quotient.  A hazard quotient greater
than 1.0 may require evaluation of the need for remedial action.

Incremental cancer risks and noncancer hazard quotients were estimated from limited
groundwater sampling events undertaken between March 1993 and October 1994.  The
cancer and  non-cancer risks  were calculated assuming an industrial groundwater ingestion
scenario. The results  of those analyses indicated that under an industrial exposure scenario,
uranium and technetium-99 present a 2.6 x 10E-4 risk for  the high concentration area of the
plume.  For nitrate, the hazard  quotient at the high concentration area of the plume was
estimated to be 10.
                                           16

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                       8.0 REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) are site-specific goals that define the extent of cleanup
necessary to achieve the specified level of remediation at the site.  The RAOs are derived
from applicable or relevant and appropriate requirements (ARARs), points of compliance,
and the restoration timeframe for the remedial action.  The RAOs were formulated to meet
the overall goal of CERCLA, which is to provide protection of human health and the
environment. The RAOs have been identified for the contaminated groundwater in the 200-
UP-1 OU for this interim remedial action.  The interim remedial action selected by this
document has die following specific RAOs.

•      Reducing contamination in the area of highest concentrations of uranium and
       technetium-99 to below 10 times the cleanup level under the MTCA, and 10 times the
       MCL for technetium-99.

•      Reducing potential adverse human health risks through reduction of contaminant mass.

•      Preventing further movement of these contaminants from the highest concentration
       area.

•      Providing information that will lead to development and implementation of a final
       remedy that will be protective of human health and the environment.

Preliminary  studies have indicated diat about 2.5 to 3.0 years are required for the extraction
of one pore  volume of ground water from die capture zone at a pumping rate of 190
liters/min (50 gpm) from the existing well configuration.  Based on the results of the ongoing
pump and treat system, as well as modeling predictions, it is expected that removal and
treatment of one pore  volume of groundwater from the plume will meet the IRA objectives  as
defined above. Additional information will  be obtained during the  interim remedial action
prior to the  development and implementation of the final action.  Effectiveness of the IRA
will  be evaluated based on site specific data.  This evaluation should include: treatment cost,
efficiency, evaluation of other technologies, hydraulic impacts, and effectiveness of the
contaminant removal from die aquifer, and other related aspects.  The IRA will continue to
operate until such time U.S. DOE demonstrates to EPA and  Ecology that no further interim
action is required to protect human health and the environment. The goal of die IRA is to
reduce the uranium and technetium-99 at or below ten times  the cleanup level  and to reduce
contaminant mass such that potential downgradient risks are reduced.

Major applicable or relevant and appropriate requirements (ARARs) include drinking water
standards, state effluent discharge standards, solid  and hazardous waste designation and
management standards, and air emission  standards (e.g., for  venting releases  from tanks or
piping).  This action is an interim action designed  to reduce  risk through contaminant mass
reduction.  This action is an interim measure which will become part of a final remedial
                                          17

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action that will attain all applicable or relevant and appropriate requirements as provided for
in Section 121 of CERCLA.

                      9.0  DESCRIPTION OF ALTERNATIVES

The Engineering Evaluation/Conceptual Plan for the 200-UP-l Groundwater Operable Unit
Interim Remedial Measure identified two general response actions for the contaminated
groundwater.  A third alternative was identified during public comment in the fall of 1995.
The three alternatives evaluated for the interim remedial action include:

•    No Action
•    Groundwater Pump and Treat  Using  the Existing Onsite Treatment System
•    Groundwater Pump and Treat  Using  the Effluent Treatment Facility.

9.1   Alternative 1:  No Action

Evaluation of this alternative is required under CERCLA serves as "a reference against which
other alternatives can be compared.  Under this alternative, no action would be taken to
remove, treat, or restrict the further migration of contaminated groundwater.  Although the
U.S. DOE would retain control of the site throughout the interim period, no additional
institutional controls would be implemented, for  the no action alternative.  Additional
monitoring and restrictions would not be implemented, contaminants would continue to
migrate and  dissipate resulting in the expansion of the contaminant plume. This alternative
invokes no additional costs.

9.2   Alternative 2:  Groundwater Pump and Treat Using Onsite Treatment System

This alternative would consist of extracting groundwater; treating it to remove  uranium,
technetium-99 and carbon tetrachloride; and then returning the treated water to the same
aquifer up-gradient of the pumping location.  Carbon tetrachloride is a co-contaminant and a
listed waste.  The source of carbon tetrachloride is believed to be from the disposal sites
associated with Z Plant, upgradient and outside the 200-UP-l OU.   Under this alternative,
the pump and treat system is the continuation of the treatability study, which began on April
1994, as  a pilot-scale treatment system. The pilot-scale  system was upgraded from 57
liters/min (15 gal/min.) to 190 liters/min (50 gals/min.)  flow rate in September 1995.  Re-
analysis of the capture system by the  U.S. DOE, using aquifer parameters derived from the
site-specific aquifer tests and an up-to-date configuration of the water table, indicates that 190
liters/min (50 gals/min.) will contain  and capture uranium plume greater than 480 ppb and
technetium-99 plume greater than 9,000 pCi/L.   The existing treatment system uses an ion
exchange and granulated activated carbon (GAC) treatment.  Ion exchange is used to remove
uranium  and technetium-99 and GAC is used as  a polishing step  to remove carbon
tetrachloride.  During the IRA period, plume monitoring would continue and may include
installation of additional monitoring and backup production wells.
                                          18

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Table 2. Pump and Treat Cost Using 200-UP-l Operable Unit Onsite System.
(SxlOOO)
Operations and Maintenance*
Consumables'1
Waste Disposal'
Process Monitoring/Sampling'
Utilities
Performance Monitoring8
System Upgrades'*
Well Installation1
Data Management/ReportingJ
Escalation (2.3%/yr)
Total Cost to Treat
FY 1996*
586
145
3
326
50
279
836.2
277
57
—
2559.2
FY 1997"
586
145
•>
326
50
279
163.8
—
57
33
1642.8
FY 19986
586
145
3
326
50
279
—
—
57
67
1.513
'Fiscal year (FY) 1996 activities include 12 months of operating existing system at
SO gal/min; design, procurement and installation of system upgrades; installation/tie-in of
one extraction well.
bFY 1997 and 1998 activities include 12 months of operations at 50 gal/min.
•Operations and maintenance costs are based on actual FY 1996 cost accounts and include
process operations labor, engineering support, field support, radiological control, site safety,
quality assurance oversight, and associated overheads (G&A).
'Consumables include ion-exchange resin, granular activated carbon (GAC), process filters
and miscellaneous materials for maintenance.
'Waste disposal costs include materials (drums, labels, etc.), waste designation and disposal.
Disposal costs assume 1,065 fWyr of ion-exchange resin disposed of at the ERDF @
$55/yd3 and 75 ftVyr of GAC @ $55/yd3.
'Process monitoring/sampling includes two influent and two effluent samples per
SOO.OOO gal of groundwater treated (analyzed onsite), 2 monthly treatment system
efficiency/confirmatory samples analyzed by an independent laboratory (offsite), five
samples per month for waste designation (analyzed offsite) and supporting quality
assurance/quality control samples. Process monitoring costs also include sample disposal
costs.
'Performance monitoring includes monthly sampling of approximately 12 monitoring wells
to assess interim remedial measure (IRM) performance.
•"Upgrades include design, procurement of a resin/GAC slurry changeout system. Assumes
double-contained pipeline with leak detection is required.
'Well installation costs include design, procurement, installation, tie-in, and surveying costs
for one extraction well.
'Data interpretation/reporting includes preparation of quarterly IRM performance reports
summarizing process and groundwater data.
                                19

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The provision of Washington Administrative Code (WAC)  173-303, Dangerous Waste
Regulations, would- be applicable to the management and treatment of the groundwater at
200-UP-l OU because of the carbon tetrachloride in the groundwater is designated a listed
waste. The present treatment system does not meet the dangerous waste standard for
secondary containment for tank and piping systems (WAC  173-303-640).  Implementation of
the ROD using the current on site system would require the addition of secondary
containment or an ARAR waiver of this provision.

The secondary wastes, which include spent ion-exchange resins and GAC, would be managed
as dangerous  wastes.  The secondary wastes will be disposed at Environmental Restoration
Disposal Facility (ERDF) or transported to a RCRA-permitted facility for appropriate
treatment and final disposal based on the waste=s capability to meet the waste acceptance
criteria.  The total  cost of implementation of the IRA for three years (1996,  1997,  and
1998) is $5,715,000.  The details of construction, operation and maintenance are described  in
Table 2

9.3    Alternative 3: Groundwater Pump and Treat using Effluent Treatment Facility
       (ETF)

This alternative will consist of extracting groundwater, pumping the groundwater to the ETF
via an existing pipeline, and treating it to remove uranium  and technetium-99 to meet the
goals of the IRA.  Additionally, the co-contaminants of nitrate and carbon tetrachloride will
be removed at the ETF. The treated groundwater will then be returned to the soil column at
the State-Approved Land Disposal Site (SALDS) located north of 200 West Area. The
treatment process at the  ETF would involve transfer of contaminated groundwater, through
an existing single-walled PVC pipeline, from 200-UP-l OU to the Liquid Effluent Retention
Facility (LERF) surface impoundment for temporary storage before treatment at the ETF
(Figure 8). Groundwater monitoring of the contaminant plume would continue during the
IRA.

Prior to transfer of the groundwater to the ETF, and during construction of the connecting
pipelines, the U.S. DOE will continue  operating the existing on-site treatability test.  This
current treatability test will continue until startup (approximately 12 months) without
secondary containment for tank systems, as compliance with those requirements would
interrupt treatment and is not practicable considering the exigencies of the situation.

Once the connections  to the  ETF are completed, and groundwater  from 200-UP-l OU is
being treated  successfully at the ETF facility, this remedy would be considered to be in place
and the onsite treatability test equipment would be shutdown and dismantled.

The main treatment train at ETF consists of several treatment steps for the removal  and
destruction of contaminants in the contaminated groundwater.  The major components of this
system are:
                                          20

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•     Degassification:  Removes dissolved gases such as carbon dioxide and oxygen from
       the ground water.  The system is equipped with high-efficiency particulate air and
       charcoal filtration prior to discharge.

•     Reverse osmosis:  Removes the majority of dissolved solids including: uranium and
       the co-contaminant nitrate.

•     Ultraviolet oxidation:  Destroys organics including the co-contaminant carbon
       tetrachloride.

•     Ion exchange:  Provides a final polishing step for dissolved solids removal and is
       typically necessary to meet U.S. DOE limits for radionuclide releases. Details will
       be provided  in the Remedial Design Report/Remedial Action Work Plan
       (RDR/RAWP).

Secondary waste resulting from processing the 200-UP-l OU groundwater may be disposed
in the ERDF, or a RCRA-permitted facility, provided that waste acceptance criteria are met.
The treated liquid effluent will be discharged at the SALDS upon verification that the
concentration of nitrate is at or below 3,800 ppb and the concentration of carbon
tetrachloride is at or below 5 ppb.  The removal efficiency of the ETF for radionuclides is
typically 99 percent.  Therefore, the effluent concentrations of uranium and technetium-99
are expected to be verified as at or below 16.4 ppb and 30 pCi/L, respectively.

Because of the presence of carbon tetrachloride as a listed  waste in the groundwater, the
provisions of WAC 173-303-650 for surface impoundment would be applicable to the
management of the groundwater from 200-UP-l OU at the LERF.  The State of Washington
dangerous waste rules apply to the ETF operations and the disposal of secondary wastes.
The total cost of  implementation of the IRA for three years (1996, 1997, and 1998) is
$4,169,000. The details  of construction, materials and maintenance are described in Table 3.
No additional labor cost is included for treatment at the ETF.  The labor force necessary is
already present and funded due to the requirements for operation of the facility to treat
process condensate and other streams.

       10.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

10.1   CERCLA Nine Criteria

This section summarizes  the relative performance of each of the alternatives with respect to
the nine criteria identified in the National Contingency  Plan (NCP).  The nine criteria fall
into three categories.  The first two criteria (overall protection of human health, and the
environment and compliance with ARARs) are considered  threshold criteria and must be met.
The next five criteria  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 upon
                                          21

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Kl
              200 West Area
 a   Pump Stations

— TEDF

... Spare Lino

— Tlo-ln
                                                                  200 East Area
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                                                                                                                        •
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($ x 1000)
Operations & Maintenance Labor''2
Consumables (Chemicals. IX Resin)1
Waste Disposal4
Sampling1
Electrical6
Modify ETF Process7
Connect UP- 1 to Transfer Line9'10
Connect Transfer Line to LERF910
Phase 1 Onsite Treatment*
Pump Groundwaler"
Monitor Aquifer Cleanup11
Well Installation*
Data Management/Reporting*
Escalation (2.3%)
Total Cost to Treat Groundwatcr
FY 1996





250
365
262
1059
50
279
277
57

2599
FY 1997
0
35
8
130
200




50
279

57
17
776
FY 1998
0
35
8
130
200




50
279

57
35
794
Assumes ground water is pumped continuously at 50 gpm through September 1998. The water would be treated by the UP-1 pilot-scale system until transfer lo the
ETF/LERF begins. Groundwater would be processed by the ETF at an average of 80 gpm. This Table assumes 24 months of 50 gpm (low (52,560,000 gal total) arc treated
•I Ihc ETF. Phase I Onsite treatment costs and ETF costs can be pro-rated as appropriate for different schedule scenarios.
No additional labor force is required to support UP-1  ground water treatment at the ETF. The labor force necessary is already present and funded due to the requirements for
operation of the ETF to treat evaporator condensale and other streams such as the N-Uasin water.  The FY98 5-ycar Plan Target Budget assumes u $2 5M cost efficiency is
acheived due to merger of 200 Area Liquid Effluent Operations with the 242-A Evaporator operation.
Includes $25K/ycar for sulfuric acid, sodium hydroxide, and hydrogen peroxide; and $IOK/year fur ion exchange resin.
Groundwaler at 50 gpm and 1000 ppm TDS average produces 3510 R3/year solid waste; disposal in EKDF @ $53/cy (unit cost provided by LRC)
Groundwaler at 50 gpm Tills 43.8 verification tanks at 600,000 gal/verification lank; sampling for environmental compliance costs $3000/vcrificalion tank.
Electrical cost is energy and demand charges of $30K/monlh when ETF is operating, minus energy and demand charges of $ I OK/month if ETF is noi operating.  Assessment
to maintain site electrical system is not included as this would be paid by the site regardless of whether groundwalcr is treated in the LIT.
Includes design/engineering, piping changes, control system rcprogramming, procedure updates, and training.
Estimate provided by ER.
Assumes flow monitoring with leak detection arc acceptable alternatives lo double-containment.
Includes construction, design, engineering/inspection, construction management, quality support, project management, general support, and conlingency.
Same as Utilities cost for ER pilot-scale system.
Same as Performance Monitoring cost for ER pilot-scale system
                                                                                                                                                              cr
                                                                                                                                                              re*
                                                                                                                                                              Ul
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A description of the nine evaluation criteria contained in the NCP, and a brief analysis of each
alternative against the criteria is presented in the box below.
             EXPLANATION OF CERCLA EVALVATION CRITERIA

             Threshold Criteria:

             1. Overall Protection of Human health and the Environment - How well does
             the alternative protect human health and the environment, both during and
             after construction?

             2. Compliance with Applicable or Relevant and Appropriate Requirements -
             Does the alternative meet all Federal and state applicable or relevant and
             appropriate requirements (ARARs)?

             Ba[anciny Criteria:

             3. Long-Term Effectiveness and Permanence • How well does the alternative
             protect human health and the environment after completion ofcleanupWhat,
             if any, risks  will remain at the site?

             4. Reduction ofToxicity, Mobility, or Volume Through Treatment - Does the
             alternative effectively treat the contamination to significantly reduce the
             toxicity, mobility, and plume of the hazardous substances?

             5.  Short-Term Effectiveness - Are there potential adverse effects to either
             human health of the  environment during construction implementation of the
             alternative.  How quickly does  the alternative reach the cleanup goals?

             6. Implementability - Is the alternative both technically and administratively
            feasible? Has the technology been used successfully on other similar sites?

             7. Cost - What are the estimated costs of the alternative?

             Modifying Criteria:

             8. State Acceptance - What are the state's comments or concerns about the
             alternatives considered and about EPA 's preferred alternative? Does the sta
             support or oppose the preferred alternative?

             9. Community Acceptance - What arethe community's comments or concerns
             about the preferred alternative?  Does  the community generally support or
             oppose the preferred alternative?
                                              24

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state and local comments and concerns.  These were evaluated after all public comments
were received.

10.1.1       Overall Protection of Human Health and the Environment

Alternative 1, the no-action alternative, will not protect human health and the environment.
The contaminated groundwater would continue to migrate from the 200 Area and have
adverse impacts on downgradient groundwater, and eventually the Columbia River.

Alternative 2, continue to use the existing onsite system, would remove contaminant mass
from the aquifer and contain the high concentration area of the plumes for uranium  and
technetium-99.  Carbon tetrachloride associated within the high concentrated portion of
uranium and technetium-99 plumes will also be removed.  Nitrate would  not be treated by
this alternative.

Alternative 3, treatment at the ETF, would remove uranium and technetium-99 from the
aquifer and contain the high concentration portion of the plumes.   Carbon tetrachloride and
nitrate associated within the highly concentrated portion of uranium and  technetium-99
plumes will also be treated.  Therefore, it will  achieve a greater degree of overall protection
of human health and  the environment than the other alternatives, since the co-contaminants of
nitrate and carbon tetrachloride  are removed and destroyed,  respectively.

10.1.2       Compliance with ARARs

Major ARARs for this IRA include state underground injection standards, state drinking
water and groundwater quality standards, state  dangerous waste designation and management
standards (for extracted groundwater and secondary wastes that might have contacted the
groundwater), Federal land disposal restrictions, and air emission standards (e.g., for venting
releases from tanks or piping).  The MTCA is  a chemical-specific ARAR that establishes
requirements (one of which is meeting drinking water standards) for groundwater cleanup.
Final  remediation goals must attain MTCA requirements.  This IRA is an interim action
designed to reduce risk until a final remedy is selected, but is not  in itself a final remedy for
groundwater.

Alternative 1 would not meet ARARs and would not satisfy  this criteria.

Alternative 2 is intended to meet the state underground injection program standards, which
prohibits injecting fluid into groundwater that would cause the groundwater to exceed
drinking water standards or otherwise affect beneficial uses.  Extracted groundwater would
be treated at the onsite system to reduce concentrations of technetium-99  and carbon
tetrachloride to below drinking  water standards, and concentrations of uranium to below
MTCA groundwater  cleanup standards.  The treated groundwater would  be injected to the
existing contaminant plume, so  there would be no reduction in beneficial uses.  Dangerous
waste requirements would be met by upgrading the onsite system to provide secondary
                                          25

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containment for all tank systems and piping and disposing of secondary wastes at either the
ERDF or a RCRA-permitted facility.  Radioactive air emissions from the system would be
monitored as appropriate to ensure that releases do not have the potential to cause significant
offsite doses as defined by the Notice of Construction.  Non-radiological (toxic) air emissions
have been estimated to be below regulatory limits.

Alternative 3 is intended to satisfy state drinking water standards and state groundwater
quality standards.  Extracted groundwater would be treated  at the ETF to reduce
concentrations of all constituents as discussed in Section VIII.  Dangerous waste management
requirements would be met by the current design of the LERF and the ETF, which meet
RCRA standards for a treatment facility, and by treating the extracted groundwater to reduce
concentrations of carbon tetrachloride to levels below health-based limits, such that the
agencies can determine it no longer contains a hazardous waste. Radioactive and
nonradioactive air emissions will be controlled and monitored in accordance with the Notice
of Construction approvals previously granted to the ETF.

10.1.3       Long-Term Effectiveness and Permanence

The no-action alternative provides no long-term effectiveness or permanence.  Alternative 2
and Alternative 3 may not, by themselves, achieve  long-term effectiveness and permanence.
However, contaminant removal and containment through pump-and-treat would provide a
long-term and permanent reduction in risk and in contaminant migration.  At the same time,
Alternative 2 and Alternative  3 would improve the potential for future final remedies to be
implemented that will achieve  long-term effectiveness and" permanence.  Furthermore, by
utilizing the ETF, Alternative  3 addresses more contaminants and permanently destroys
carbon tetrachloride.

10.1.4       Reduction of Toxicity, Mobility,  or Volume

The no-action alternative provides no reduction of toxicity,  mobility, or volume through
treatment.  Alternative 2 and Alternative 3 would provide treatment of the groundwater
co-contaminants, thereby reducing the volume of contaminants that are migrating and reduce
the overall toxicity risk of the  groundwater.  Furthermore, by using the ETF, Alternative 3
reduces the concentration of a greater number of contaminants through treatment.

10.1.5       Short-Term Effectiveness

The no-action alternative has no short-term  effect on the contamination.  Alternative 2 and
Alternative 3 would offer short-term effectiveness by limiting the migration of the
contamination and by reducing the most significant contamination in the areas of highest
concentration.  Short  term risk due to workers can be easily managed through standard
remedial action and construction procedures.  Mitigation measures will include actions to
minimize dust,  use of protective equipment to minimize worker exposures, minimize
disturbance to wildlife, and revegetation of the site as appropriate.
                                           26

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10.1.6        Implementability

The no-action alternative can be easily implemented, because no changes would be made to
the site.  Alternative 2 started as a pilot project in 1994 and was successful in removing
uranium, technetium-99 and carbon tetrachloride. The existing onsite system uses ion
exchange resins to remove radionuclides and GAC to remove carbon tetrachloride.  A
modification required for implementing Alternative 2 would be to provide double
containment of the treatment system, which is implementable.  Alternative 3 could be easily
implemented using the existing available ETF.  The ETF is a state-of-the-art treatment
facility which  can treat a wide range of contaminants of radionuclides, organics and
inorganics.  The system has been tested for a range  of contaminants and can be used to treat
200-UP-l OU groundwater. An existing pipeline will be used  to transfer the 200-UP-l OU
water to the LERF basins.  Transfer pipelines will be constructed  to connect the 200-UP-l
OU groundwater  wells to the transfer line in the 200 West Area, and another will be
constructed to tie the transfer line to the LERF  basins in the 200 East Area.

10.1.7        Cost

The no-action alternative has essentially no added cost. The detailed cost estimates for
Alternative 2 are  presented in Table 2. The total estimated cost for the Alternative 2  is
$5,715,000 for three years (i.e. 1996,  1997, and 1998). This  cost includes the cost for
installing the double containment of the system  in addition to other costs (e.g., operation,
maintenance, waste disposal, monitoring, etc.).  The detailed cost  of Alternative 3 are
presented  in Table 3.  The total estimated cost for Alternative 3 is $4,169,000 during the
same time period of three years.  This cost includes construction of connecting pipelines,
process  monitoring, and waste disposal.  No additional labor cost is included for treatment at
the ETF.  The labor force necessary is already  present and funded due to the requirements
for operations of  the facility to treat process  condensate and other  streams.

10.1.8        State Acceptance

The State of Washington concurs with the selection of the  interim  remedial action described
in this ROD.

10.1.9        Community Acceptance

This action was first proposed as part of the fourth amendment to  the Tri-Party Agreement
and received favorable comments from the public.  Community acceptance of the alternatives
was evaluated during two public comment periods as described in  Section III of this ROD.
The identification of the selected alternative that utilizes the ETF for treatment was based on
public comment.  A summary of public comments on the IRA  is provided in the
Responsiveness Summary attached to this interim action ROD.
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10.2   Evaluation of Potential Environmental Impacts

Impacts are expected to be limited to potential exposure of remediation workers to hazardous
or radioactive substances,  short-term indirect impact to wildlife from construction noise, and
disturbance of the land area designated to wells, equipment and facilities.  Removal of
groundwater contamination is expected to improve rather than degrade the ecological
conditions of the area.

The cumulative impacts of implementing reasonable foreseeable remedial actions in the
200 West Areas are generally expected to improve ecological conditions in the 200 Areas in
the long term.  The sites to be impacted by the interim remedial actions are located within
the 200 Areas, previously  disturbed  by the operations at the Hanford Site.  Because of the
previous disturbance,  ecological or cultural resources are not expected to be impacted by the
interim remedial action.
11.0  SELECTED REMEDY

The components of the selected remedy achieve the best balance of the nine evaluation
criteria described in Section IX.  The total estimate cost of the remedy is approximately $4.2
million.

The selected remedy uses groundwater pumping by extraction wells to capture the
contaminant plume for mass removal and treatment at the ETF.  It is intended to minimize
the migration of uranium and the technetium-99 from the 200 West Area.  In addition, the
concentrations of nitrate and carbon tetrachloride will be reduced in the groundwater.  The
IRA  is intended to stabilize and reduce contaminant mass in the high concentration area of
the plume. In general, th^e high concentration portion of the plume corresponds to the area
greater than ten times cleanup levels for of uranium (48 ppb) and technetium-99 (900 pCi/L).
The selected remedy for the interim actions at the 200-UP-l OU will include, at a minimum,
the following activities.

11.1   Groundwater Extraction

Groundwater from the 200 West Area will be pumped from the existing extraction well(s) at
a rate of 190 liters/min (50 gpm).  The extraction rates and the well locations may be
modified upon the approval of the lead regulatory agency based on the future behavior of the
aquifer, the response of the contaminant plume to further pump and treat activities, the rate
of removal of the mass of contaminants, and other considerations of the long-term operations
and maintenance of the extraction and treatment system.  The groundwater extraction rate of
190 liters/min (50 gpm) is expected to be sufficient to meet the remedial action objectives.
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11.2   Construction Requirements

Under the ETF treatment option, water from the 200-UP-l OU extraction wells will be
pumped directly via an existing underground single walled pipeline to the surface
impoundment known as the LERF, where it would be temporarily stored for treatment at the
ETF.  The LERF is a double contained, RCRA-permitted facility.

Several enhancements will be necessary to the groundwater transfer system prior to
operations.  These include additional piping in the 200 West area to connect the groundwater
transfer system to the 200-UP-l OU groundwater well(s). In the 200 East Area, piping will
be installed to connect the system to the LERF.  Engineering evaluations for pipeline
connections were completed in November 1996.

Appropriate instrumentation and other required controls and monitoring devices, as needed
during the course of operations, will be installed in the transfer system.  Prior to placing the
transfer system into  operation it will undergo an operational test, which will test the system
under operating conditions.

Details of the construction, design and monitoring and other detailed requirements will be
described in the RDR/RAWP and approved by Ecology, the lead regulatory agency.  In
addition, this plan shall include at least the following elements:

•     Construction  will comply with appropriate worker safety requirements.

•     U.S. DOE will consult with the Department of Fish and Wildlife and other resource
       management agencies, to ensure that the activities should avoid or minimize
       disruption to  local wildlife and other natural resources to the extent practicable.

•     For areas that are disturbed during construction and operation, U.S. DOE plans to
       revegetate following construction in those areas that are not needed for operation and
       maintenance of the treatment system and  where the land is not expected to be
       redisturbed within the next few years by other site activities.

•     To the extent practicable,  facilities are to be designed and located in a manner that
       minimizes interference with and  interference by remedial actions for the source waste
       sites or other planned activities.

•     Sites with cultural resource significance should be avoided during remedial activities,
       if avoidance is possible.  To date, no sites of cultural resource significance have been
       identified. Where avoidance is not possible, U.S. DOE has agreed to prepare a data
       recovery/mitigation plan in consultation with the affected resource trustee and carried
       out for each site impacted by remedial activities.
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•     Prior to transfer of the groundwater to the ETF, and during construction of the
       connecting pipelines, the U.S. DOE will continue operating the onsite treatment
       system. This current treatability test will be allowed to continue without secondary
       containment for tank systems (it would not be practicable to install the secondary
       containment considering exigencies of the situation because it would interrupt
       treatment).  Once the connections to the ETF are~completed, and groundwater  from
       200-UP-l  OU is being treated successfully at the ETF, this remedy would be
       considered to be in place and the onsite treatability test equipment would be shutdown
       and dismantled.

11.3   Groundwater Treatment

The contaminants of concern that ETF will treat as a part of the IRA are uranium and
technetium-99. In addition, the ETF will remove the nitrate co-contaminant and destroy the
co-contaminant of carbon tetrachloride. A complete discussion of the treatment components
is presented under Section 9, Description of the Alternatives.  The following two subsections
(Sections 11.3.1 and 11.3.2) describes several unique considerations of the treatment of the
contaminated groundwater and the subsequent handling requirements of the treated effluent
discharge, as well as secondary waste streams.

11.3.1    Treatment Modification

The groundwater  extracted  from 200-UP-l OU is not a characteristic hazardous waste, but
contains carbon tetrachloride as a listed hazardous waste.  The waste wuTbe treated in the
ETF to meet the current discharge standards contained  in the State Waste Discharge Permit
ST-4500.  During the  treatment of 200-UP-l  OU groundwater, the limits for carbon
tetrachloride and  nitrate are 5 ppb and 3,800 ppb, respectively.  Because these discharge
standards are below the MCLs and other health-based levels, the regulatory agencies have
determined that, after treatment and verification analyses, the groundwater will no longer
contain any listed RCRA hazardous waste.  The treated groundwater will satisfy the LDRs
since the discharge  standards in the State Waste Discharge Permit, which are incorporated
herein  by reference, are below the applicable 40 CFR 268.40 treatment standards.
The LERF and the ETF will need to segregate the storage and treatment of this contaminated
groundwater (media) from the storage and treatment of the listed waste currently  using these
facilities.  Any contaminated groundwater that is mixed with the 242-A process condensate
listed waste at the LERF and/or ETF, either accidentally or in the process of cleaning or
emptying the surface impoundments and the ETF may be disposed only if the treated water
meets the de-listing criteria in 40 CFR 261, Appendix IX, Table 2, and as part of the
maximum allowable volume of de-listed material under that rulemaking.  Because the 200-
UP-l OU  groundwater will no longer contain listed waste after treatment and because  it  will
be segregated  from other listed hazardous waste treated at ETF,  the volume of this
groundwater being treated will not be applied toward the volume limit under the RCRA de-
listing  rule.  This operational requirement to segregate  these waste streams will be eliminated
if the contaminated groundwater is  included in a future RCRA de-listing modification.
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11.3.2    Effluent and Waste Disposal

The ETF process consists of a main treatment train and a secondary train. The main train
discharges treated water and the secondary train results in drums of concentrated
contaminants in the form of dry powder.  The treated effluent from the 200-UP-l OU will be
temporarily stored in the ETF verification tanks until compliance with the discharge limits is
verified. The treated water is then discharged to the state-approved land disposal site
(SALDS) north of the 200 West Area.  The location of the  SALDS was chosen because of its
slow local groundwater migration rate. The secondary derived solid waste from the ETF
operation, including spent ion exchange resin, is a hazardous  waste and will be managed in
accordance with RCRA ARARs.  This waste will be disposed of in the ERDF or other
approved facility after meeting RCRA ARARs and other waste acceptance criteria.

11.4   Compliance Monitoring - Effluent Discharge

The data collection, analysis, and  evaluation procedures used  to determine compliance with
cleanup levels and liquid effluent disposal limits shall be as  defined in the State Waste
Discharge Permit ST-4500.

11.5   Human Access Institutional Controls

Institutional controls are required to prevent human exposure  to groundwater.  The U.S.
DOE is responsible for establishing and maintaining land use  and access restrictions until the
final remedy is selected and implemented.  Institutional controls include placing written
notification of the remedial action in the facility land use master plan. The U.S. DOE will
prohibit any activities  that would interfere with the remedial activity without the lead
agency=s concurrence.  In addition, measures necessary to ensure the continuation of this
restriction will be taken  in the event of any transfer or  lease of the property before the final
remedy is selected.  A copy of the notification in a land use plan will be given to any
prospective purchaser/transfer before any transfer or lease.  U.S. DOE will provide Ecology
and EPA within written verification that these restrictions have been put in place.

11.6   Shutdown and Decommissioning of the Onsite System

The 200-UP-l OU RCRA-permitted system will be deactivated and placed in stand down
condition when water is  sent to  the LERF. Decommissioning of the onsite system will take
place only after satisfactory treatment and disposal of 200-UP-1 OU groundwater at the ETF
has been demonstrated.

11.7   Schedule

U.S. DOE will  start pumping groundwater to LERF by March 30, 1997,  and  will continue to
pump at an average rate of 190 liters/min (50 gpm) to exchange one pore volume of
groundwater. It is estimated that pumping at 190 liters/min (50 gpm) for 2.5  to 3 years to
                                          31

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treat one pore volume. A detailed schedule of construction, testing, etc. will be provided in
the RDR/RAWP and associated documents. The goals of the  IRA are to reduce the uranium
and technetium-99 concentrations in the groundwater to 10 times the cleanup level, and to
remove the mass of these contaminants in order to contain the contaminant plume and reduce
potential downgradient risks.
12.0  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
practicable.  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.

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 to the public health or welfare
of the environment, the  President may, at his discretion, treat these related facilities as one
for the purpose of this section.

The preamble to the NCP clarifies the s'ated EPA=s interpretation that when noncontiguous
facilities are reasonable  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 tead agency
to treat these related facilities as one site for response purposes and, therefore, allows the
lead agency  to manage waste transferred between such facilities without having to obtain a
permit. Therefore, the ETF, ERDF and the 200-UP-l OU are considered to be a single site
for response purposes under this interim action ROD.

12.1   Protection of Human Health  and the Environment

The selected remedy protects human health and the environment through groundwater
remediation.  This action will reduce the highest concentration area of the contaminated
plume of uranium and technetium-99, thereby reducing potential adverse impacts to
downgradient areas. Implementation of this remedial action will not pose unacceptable short-
term risks to site workers.  The selected remedy is the best alternative as it uses the state of
art technology and will remove, not only the contaminants of concern, but also additional
contaminants such as nitrate and carbon tetrachloride.

12.2   Compliance with ARARS

The following state and  federal ARARs have been identified  for this interim remedial
measure:
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12.2.1    Chemical-Specific ARARs

Safe Drinking Water Act (SDWA), 40 CFR 141, Maximum Contaminant Levels, for public
drinking water supplies are relevant and appropriate for setting groundwater treatment levels.
The treatment train will meet MCLs for carbon tetrachloride, technetium-99, nitrate and the
estimated MCL for uranium  (20 ppb).

The Model Toxic Control Act regulation (WAC 173-340) is applicable for setting
groundwater treatment levels for uranium.

The groundwater removed  will be treated to achieve these levels before discharge. However,
the underlying groundwater will not be treated to achieve these levels.  This interim action is
only part of a total remedial  action and is cost effective. Therefore these ARAR requirements
at this time is being waived pursuant to Section 121(d)(4)(A) of CERCLA.

12.2.2    Action-Specific ARARs

LDRs (40 CFR 268) are applicable for the extracted groundwater as well as for secondary
waste (protective clothing,  sampling equipment, etc.) that comes in contact with the
contaminated water.

RCRA Subtitle C (40 CFR 264) hazardous waste treatment,  storage, and disposal
requirements are applicable to design and operation of the treatment system.

"Surface Impoundments" (WAC 173-303-650) provides guidance for surface impoundment
which are  applicable to the management of the groundwater  from the 200-UP-l OU  at  the
LERF and subsequent treatment at the ETF.

"Minimum Standards for Construction and Maintenance of Wells" (WAC 173-160 and
WAC 162) are applicable for the location, design, construction, and abandonment of water
supply and resource protection wells.

"Dangerous Waste Regulations" (WAC 173-303) establish the standards for persons  who
generate, transport, treat, store, or dispose dangerous wastes.  This regulation is applicable
to the management and transportation of groundwater contaminated with carbon tetrachloride,
the design and operation of the ETF,  and the  management and disposal of secondary waste
from treating the groundwater at ETF.

"National Emission Standards for Hazardous Air Pollutants" (40 CFR 61, Subpart H), and
"Radiation  Protection, Air  Emissions" (WAC 246-247) are applicable to potential radioactive
air emissions resulting from transfer and treatment of contaminated groundwater.

"Air Pollution Regulations, New and  Modified Emission Units" (WAC 173-460) establishes
acceptable source impact levels for carcinogenic and acutely toxic air pollutants.  This is
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applicable to carbon tetrachloride emissions resulting from groundwater transfer and
treatment.  The IRA will achieve the air emission criteria by destruction of the carbon
tetrachloride through ultraviolet oxidation.

12.2.3    Location-Specific ARARs

•     National Historic Preservation Act (16 U.S.C. 470, et. seq.)  Is relevant and
       appropriate to actions in order to preserve historic properties controlled by a federal
       agency.

•     Endangered Species Act (16 U.S.C. 1531, et. seq.) Applicable for activities that
       threaten the continued existence of listed species or destroy critical habitat.

•     National Archeological and Historic Preservation  Act (16 U.S.C. 469)   Requires
       action to recover and preserve artifacts in areas where activity might cause irreparable
       harm, loss, or destruction of significant artifacts.

12.2.4    Other Criteria, Advisories,  or Guidance to be Considered for this Remedial
          Action

•     The Future for Hanford:  Uses and Cleanup, the Final Report of the Hanford Future
       Site Uses Working Group, December 1992.

The ERDF waste acceptance criteria establishes chemical, radiological, and physicar
standards for disposal of wastes to ERDF.  It is applicable to any secondary waste from ETF
or waste from shutdown of the existing  site treatment system proposal for disposal at ERDF.

12.3   Cost Effectiveness

The selected remedy provides overall effectiveness proportional to its cost.  Costs are
summarized on Table 1. While  the costs of treatment at  the ETF are similar to those of
continued use of the existing onsite treatability system, additional contaminants will be
treated.  This will have significant additional environmental benefit.

12.4   Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Possible

Because this action does not constitute the final remedy for this OU,  the statutory preference
for remedies that employ treatment that  reduces toxicity,  mobility, or volume as a principal
element, although partially addressed in this remedy, will be addressed by the  final response
action.  Subsequent actions are planned  to address fully the threats posed by conditions at
diis OU.  The  selected remedy does rely on state  of the art treatment technologies at the ETF
that will result in permanent destruction of carbon tetrachloride.
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12.5   Preference for Treatment as a Principal Element

The selected remedy utilizes an effective treatment process for the removal of uranium,
technetium-99, and nitrate, and permanently destroys carbon tetrachloride.
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES

Ecology reviewed all written and verbal comments submitted during the original public
comment period.  As a result of these comments, the three parties considered the use of the
Effluent Treatment Facility for treatment of the 200-UP-l OU groundwater.  Based on the
comparison of the RCRA-permirted treatment system to the ETF, the selected remedy was
revised to consider the ETF for treatment of the 200-UP-l OU groundwater.  A second
public comment period was held to describe the proposed change to the selected remedy.
Subsequently, public comments  were received during the second comment period.
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            U.S. DOE HANFORD 200 WEST AREA 200-UP-l OPERABLE
                 -                     UNIT

                          RESPONSIVENESS SUMMARY
The U.S. Department of Energy (U.S. DOE), the U.S. Environmental Protection Agency
(EPA), and the Washington State Department of Ecology (Ecology) held a public comment
period from August 8, 1995, to October 6, 1995, and from August 5, 1996, to October 4,
1996, for interested parties to comment on the 200-UP-l Proposed Plan and Focus Sheet,
respectively.  These documents present the preferred alternative for the groundwater located
in the 200-UP-l Operable Unit of the Hanford Site=s 200 West Area. The primary support
documents for this action are the 200 West Groundwater Aggregate Area Management Report
and the Engineering Evaluation/Conceptual Plan for the 200-UP-l Operable Unit Interim
Remedial Measure with an accompanying transmittal letter dated April 24, 1996.

This action was presented and discussed at the April 1996 and September 1996 Hanford
Advisory Board meetings. These meetings were open to the public and the public was
encouraged to comment on issues. The public was informed of the opportunity to comment
on the Proposed Plan and Focus Sheet by publication in the Seattle Post-Intelligence*'Seattle
Times, the Spokane Spokesman Review-Chronicle, the Tri-City Herald, and the Oregonian on
August 8,  1995, and August 5, 1996; and  by mailing a fact sheet to approximately 2,000
people.  A public meeting was also held on September 1995.

A responsive  summary is required by the Comprehensive Response 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

The Hanford Site was established in 1943 to produce plutonium for nuclear weapons using
nuclear reactors and chemical processing plants.  Operations at the Hanford Site are now
focused on environmental restoration and waste management.

The 200 West Area is an operational area of approximately 3.2 square miles where spent
nuclear fuel was processed  in four main facilities: U Plant (primarily uranium recovery);
Plutonium Finishing Plant (primarily plutonium separation and recovery); and S and T Plants
(primarily uranium and plutonium separation-from irradiated fuel rods).  The 200-UP-l OU
is located within the 200 West Area of the Hanford Site, and was included on the NPL in
July  1989.
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Contamination in the 200-UP-l OU resulted from historic discharges to five primary liquid
waste disposal sites.  These five sites are at cribs 216-U-l, 216-U-2, 216-U-8, 216-U-12,
and 216-U-16.  The predominant contaminants in the waste stream were uranium and
technetium-99.  It is estimated that 4,000 kg (8,800 Ib) of process waste from Uranium
Oxide (UO3) Plant, consisting primarily of dilute nitric acid containing uranium, technetium-
99 and small quantities of other fission products, was discharged  to the soil columns via two
cribs (216-U-l and 216-U-2) between 1951 and 1968.  Most of these contaminants were
initially retained in the upper 20 m (65 ft) of soil.  During the final years of Crib  operation
(1966 through 1968), highly acidic wastes were disposed, which resulted in mobilizing the
contaminants.  The mobile uranium was transported to groundwater when large volumes of
cooling  water was discharged to the adjacent 216-U-16 Crib in 1984.  A pump and treat
action was initiated in 1985 that removed 680 kg (1,500 Ib) of uranium, reduced contaminant
levels resulting in the concentrations present today  (DOE-RL 1993).

During  1993, DOE-RL completed AAMS that compiled  and evaluated information about
source and groundwater contamination in the 200 West Area.  Recommendations generated
from the AAMS included interim actions to accelerate removal and" limit the potential spread
of contamination where information is sufficient to successfully plan and implement the
actions.   For the 200-UP-l OU, the area containing the highest concentration of uranium,
technetium-99 and nitrate was recommended for an IRA.  Subsequently, it was determined
that nitrate should be removed from consideration as a contaminant of concern for this
remedial action because the nitrate plume emanating from the 200 West Area  is so extensive.
Treatment of the portion of the nitrate plume within 200-UP-l OU will not result in a
significant reduction in the overall nitrate plume.
n.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

The public has been involved in the cleanup of the Hanford Site since the Hanford Federal
Facility Agreement and Consent Order was signed in 1989.  Over the past several years a
number of stakeholder work groups and task forces have been used to enhance decision
making at the Hanford Site.  In January 1994, the Hanford Advisory Board was established
to provide informed advice to the U.S. DOE, EPA, and Ecology.

A consistent message delivered by interested citizens and affected Indian Nations is to take
early action on groundwater contamination and protect the Columbia River.  Taking this
action will help support these desires.
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m.    SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
       DURING THE PUBLIC COMMENT PERIOD AND THE AGENCIES
       RESPONSE TO THOSE COMMENTS

Comments received during the public comment period are presented in this section.
Responses to the comments follow each comment.  Copies of all comment letters received
are attached to this responsiveness summary as Appendix A.

Question .  The Hanford Advisory Board endorses  remediation of uranium and technetium-99
plume of the 200-UP-I using the Effluent Treatment Facility.

Response:  The agencies agree that this action should proceed.

Question.  During the first public comment period  of the proposed plan in 1995, public
comments  reflect ovenvhelming support for taking an active action to consider use ofETFfor
the treatment of extracted contaminated groundwater from the 200-UP-l Operable Unit.
Public is of the opinion that the ETF is a state-of-art facility capable of treating and
removing various contaminants, including organics, inorganics and metals, it minimizes
waste and must be used.

Response:  The three parties agreed to consider the use of the ETF and recommended the
U.S. DOE to carry out a detailed engineering evaluation of the proposal.  The U.S. DOE
prepared an Engineering Evaluation and Cost Analysis Plan which provides details of the use
of  ETF.  The transmittal letter of this document provides detatts of the Record of Decision
to use the  ETF for the treatment of groundwater from the 200-UP-l OU.

Question:  Please provide the budget basis or estimate for maintenance and operations in
full time equivalent employees  including operators,  engineers, health physics, management,
safety, QA, maintenance crafts and support for the  200-UP-l onsite system.

Response:  Approximately 3 full time equivalent employees  will  be required to safely and
efficiently operate the  treatment system. Additional cost details are available in the
"Engineering Evaluation/Conceptual Plan for the 200-UP-l Groundwater Operable Unit
Interim Remedial Measure"  report, BHI-00187.

Question:  What is the cost for a cubic ft of resin ?

Response:  Approximately $180 per cubic foot.

Question:  What is the cost for disposal of a drum  of waste?

Response: Waste  disposal, as estimated, will cost  approximately $55 per cubic yard.
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 Question:  Since the source has been halted, what changes over time might be expected to
 the constituents of this plume? What is the half-life for technetium-99?  How fast does the
 plume move?  What dilutions are expected?

 Response:  The primary constituents of this plume, uranium and technetium-99 will move
 with the groundwater and will decay.  Nitrate concentrations are likely to be reduced to some
 extent by bacteriologically driven denitrification, but will remain well above drinking water
 standards for an extended period of time (no calculations of the rate of natural denitrification
 have been made). The half-life of technetium-99 is 212,000 years.  Under the hydraulic
 conditions present today the plume  is moving at a rate of about 120 ft/year. Dilution of the
 plume under unaltered flow would be due to dispersion and advection and would amount to
 about 10 percent year.

 Question:  Is the land on the Hanford Reservation currently under government ownership?

 Response:  Yes.

 Question:  Couldn 't the land do\vngradient of any plumes or potential plumes from Hanford
 Remain in government ownership in order to restrict uses  (such as drilling drinking wells)
 that could result in exposures? Wouldn 't this  in fact also preserve it as wild open space,
 which is an ecologically desirable objective?

 Response:  Retention of federal ownership is indeed an option. Sale of the land with deed
 restrictions is also an option.  Maintenance of the land as open desert is an option-.

 Question:  If the objective of the cleanup is for the government to later sell the land for
future residential development, does the cost for this development opportunity make any
 economic sense at all when compared to the cost of keeping the area undeveloped?

 Response:  Contamination in the  groundwater will eventually reach the Columbia River even
 if the land is left undeveloped.  The Hanford Future Site Users Group recommended that  the
 long-term uses of the site should include unrestricted use or access to the area away from the
 200 Area Plateau. The land use recommendations by that group were considered in the
 development of the Proposed Plan.

 Question:  Is there any logical basis to assume that future site uses will be thrown open to
 the public to flock to homesites and to drink well water from Hanford? My thoughts are that
 no matter how good a cleanup is ever achieved, the public really isn 't going to be willing to
 do this anyway.

 Response:  Current federal and state laws require remediation of contaminated groundwater
 which is a potential drinking water source.   Hanford groundwater is considered a potential
 drinking water source.  Furthermore, contamination in the groundwater will eventually reach
 the Columbia River, even if the land is left undeveloped.
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 Comment: The Public is concerned regarding the possible loss of jobs ifETF is not used.

 Response: it is the responsibility of the Tri-Parties to select the most cost effective and
 environmentally acceptable means to address the 200-UP-l groundwater contamination. In
 that regard, all treatment options will be assessed, including use of the ETF.

 Question: Public is concerned regarding loss of jobs if ETF is not used.

 Response: It is the responsibility of Ecology to select the most cost effective and
 environmentally acceptable means to address the 200-UP-l groundwater contamination. In
 that regard, all treatment options will be assessed, including use of the ETF.

 Question. If the Effluent Treatment Facility (ETF) has the capacity to handle 180 gallons
 per minute of waste water, and the  UP-1 were to provide a base load of 50 gallons per
 minute, would the effective cost of treatment equal 50/180 of the operating cost of the ETF?

 Response: The costs for treating the UP-1 groundwater in the ETF have been evaluated and
 are discussed in the Record of Decision. The costs for implementation of the JR44^|y||for
 three years at the ETF is $4.2  million.  The cost of implementation of the 4RM-|3p||ror
 three years at the onsite system is $5.7 million.  Both estimates include facility modification
 costs, operation cost and maintenance costs.  The labor force necessary to operate  the ETF is
 already present and funded due to the requirements for operation of the facility to treat other
 waste waters on the Hanford Site, therefore there are no additional labor costs for  treatment
 of the UP-1 groundwater at the ETF.

 Question. Proposers of using  the Pilot-Scale Treatment plant offered information  on the
 treatment efficiency of their operation. As Ms.  Wanek stated the target operating efficiency
for FY-1996 is 80%.  Before any move is made to make ETF the sole or partial treater of the
 water, please provide similar operating data for that facility.

 Response: The ETF is designed to operate at an operating efficiency of 72 percent. During
 the first year of operation it has not been necessary for the ETF to operate at the design
 operating efficiency.  The first year of operation of the ETF are not representative of the
 ETF's capabilities. During this period the ETF has undergone testing, equipment
 modifications, and equipment problems that invalidate any determination of operating
 efficiency. The ETF is designed to treat 150 gallons per minute (78 million gal/yr).
 Groundwater will  be supplied to the ETF at a rate of 26 million gallons per year, other feeds
 to the ETF are anticipated to be less than 10 million gallons per year, for  a total of less than
 40  million gal/yr.  As a result, even with the UP-1 groundwater, the ETF still has excess
 capacity and  will only need to  operate at an efficiency of 51. percent during the IRA.
                                           40

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Question.  Proponents of the ETF made numerous mention of the facility being double
contained,  is the pipeline from 200 West Area to the ETF also double contained ?

Response:  The piping between 200 West and the Liquid Effluent Retention Facility (LERF)
is not double contained.  This transfer line was constructed of single wall PVC pipe in 1994.
The pipeline has been hydrotested, and is proposed to be equipped with flow monitoring
equipment  prior to the transfer of the UP-1 groundwater.

Question.  Please address the issue of listed waste, and how disposal of water which has
been in contact with the listed material (carbon tetrachloride) can be accomplished through
the ETF.

Response:  The ETF is  technically capable of treating the ground water containing carbon
tetrachloride and the treatment and disposal will be accomplished in accordance with all
applicable laws and permit conditions as discussed in section X of this document.

Question.  Operating history of the Pilot-Scale System has shown that there is a finite
probability of bacterial growth in the treatment system.   Backflushing has limited the negative
effects in the current system, please provide information on how the ETF, using
UV/Oxidation for removal of carbon tetrachloride, will prevent fouling of the UV lamps.
What will be the cost associated with system revisions to overcome these lamps.  What  will
be the cost associated with system revisions to overcome these difficulties?

Response:  While bacterial growth has also been observed in the first year of ETF operation,
it has not been associated with the UV/oxidation  unit. The high intensity UV light along
with the hydrogen peroxide have been shown to be very effective at controlling biological
growth.  Biological growth has been an operational problem with the ETF's filtration system.
Currently the  ETF's filtration systems are being modified to correct this operational problem.

Question.  / have additional concerns about the potential problems associated with  the
mixing of waste  streams in the LERF prior to the steams being treated in the ETF.   After the
streams are mixed, what element of the process has responsibility for the water? This
appears to  be analogous to the PRP questions facing  landfills around the country today.
Admittedly, the US Department of Energy is the ultimate responsible party, but contracting
changes on the pan of that agency are moving toward spreading the responsibility to
individual contractors working for them.

Response:  The DOE-RL is the owner of both the ETF and the LERF. Very recently,  a
contract for the  Project Hanford Management Contractor (PHMC) has been awarded to Fluor
Daniel Hanford, Inc (FDH).  The PHMC has awarded a contract for the operation of the
ETF and LERF  to Rust Federal Services of Hanford  Inc. (RFSH).  The mixing or
accumulation of wastes in LERF will continue to be in accordance with applicable permits,
regulations, and requirements. The DOE-RL will continue to be the owner of the facilities,
and manage the  facilities and waste in a manner that  is protective of the environment.
                                           41

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  APPENDIX A




PUBLIC LETTERS
       42

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  APPENDIX A




PUBLIC LETTERS
      A-i

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A-ii

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                                                       NMWMf
                           f.D
                                   antorc
                                                             MAY 2 2 1995

                                                            Kennewick
                 ENVIRONMENTAL RESTORATION,* WASTE MANAGEMENT
                   P.O. BOX 365 •  UkPWAI. IDAHO 83540-0365  • (208) 843-7375 / FAX: 843-7373
May 18, 1995
Dr. Dib Goswami
Washington State Department Of Ecology
1315 West Founh Avenue
Kennewick. Washington 99336
Dear Dr. Goswami:
File Name.
Integrated.
     RCRA.
     WQ
    CERCLA.
    AQ	
Administrative.
EFSEC.
Milestones
N-Reactor
                                     Cross-reference
The Nez Perce Tribe  Department of Environmental  Restoration and  Waste Management
(ERWM) has  received  and reviewed a  copy of INTERIM  REMEDIAL MEASURE
PROPOSED  PLAN   FOR   THE  200-UP-l   OPERABLE   UNIT,   HANFORD,
WASHINGTON,  DOE/RL-95-26 DRAFT A.   Enclosed, for your consideration, are  the
ERWM's specific comments and suggestions on that document.

The Nez Perce  Tribe  recognizes the  need  to lessen uranium,  technetium,  and  nitrate
concentrations in the 200 Area  groundwater.  ERWM acknowledges the complexity  of this
remediation and fully supports this plan. However, we have some concerns that may affect the
health and safety of members of our Tribe, the public, and the environment. Hereunder are our
general comments:

      a) The Nez Perce Tribe views this  IRM proposed plan as only one pro-active  step of
      many that are needed to prevent further degradation of the groundwater and eventually
      the Columbia River ecosystem by lessening the further spread of contaminants.

      b) This plan does not include plans for cultural surveys prior to construction of the pump
      and treat facilities and groundwater  wells or reference past cultural surveys.  The Plan
      should be revised to include bringing in Tribal cultural experts to monitor construction
      activities.

      c) Why is the carbon tetrachloride plume being ignored?  The health risk of carbon
      tetrachloride is not considered..  Eventually, the carbon tetrachloridn pollution must he
      remediated.  It is more economic and beneficial in the environment to treat all of the
      contaminants at once than to reinject carbon tetrachloride contaminated water and then
                                     A-1

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       treat  it at  a  later  date.   The  maximum  carbon  tetrachloride concentration  in the
       groundwater is 320 ppb which is  64 times the drinking water MCL of 5 ppb for carbon
       tetrachloride.  The  goal of this IRM proposed plan should be to contain elevated
       concentrations of uranium, tcchnetium-99, nitrate, and carbon tetracfaoride to the 200
       Area.

The  Nez  Perec ERWM Office  appreciates the opportunity  to  provide comments on the
INTERIM REMEDIAL MEASURE PROPOSED PLAN FOR THE 200-UP-l OPERABLE
UNIT, HANFORD,  WASHINGTON,  DOE/RL-9S-26 DRAFT A.   Specific comments are
included on pages 3 through 6.

If you wish to discuss Nez Perec ERWM's comments further, then please contact Dr. Stanley M.
Sobczyk. Dr. Rico O. Cruz, or Paul Danielsdn at 208-843-7375 or 208-843-7378 (rax).
Sincerely,
Donna L. Powaukee
ERWM Manager
In Concurrence:
               Samuel N. Penney
               Chairman
cc:  John Wagoner. DOE-RL, Site Manager
    Kevin Clarke, DOE-RL. Indian Programs Manager
    Steven Wisness, DOE-RL. Hanford Project Manager
    Douglas Sherwood, EPA, Hanford Project Manager
    J. Herman Reuben, Nez Perec ERWM. Cultural Specialist
                                       A-2

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                     RESPONSE TO
              INTERIM REMEDIAL MEASURE
     PROPOSED PLAN FOR THE 200-UP-l OPERABLE UNIT,
                HANFORD, WASHINGTON,
                 DOE/RL-95-26 DRAFT A
                  Comments Prepared By:

                     Nez Perce Tribe
Department of Environmental Restoration and Waste Management Staff

                      May 8, 1995
                             A-3

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A-4

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                              THE NEZ PERCE TRIBE
   DEPARTMENT OF ENVIRONMENTAL RESTORATION AND WASTE MANAGEMENT
                              COMMENTS ON THE
               INTERIM REMEDIAL MEASURE PROPOSED PLAN
                       FOR THE 200-UP-l OPERABLE UNIT
                           HANFORD, WASHINGTON
                            DOE/RL-95-26 DRAFT A.

Since  1855, reserved treaty rights of the Nez Perec  Tribe in the  Mid-Columbia have been
recognized and affirmed through a series of federal and state actions.  These actions protect the
interests of the Nez Perce to exploit their usual and accustomed resources and resource areas in
the Hanfcrd Reach of the Columbia River and elsewhere.  Accordingly, the Nez Perce Tribe
Department of Environmental Restoration and Waste Management (ERWM) has support from
the U.S. Department of Energy (DOE) to participate in and monitor certain DOE activities. The
Nez Perce Tribe Department of Environmental Restoration and Waste  Management  Program
responds to documents calling  for public comment from the U.S. Department of Energy. The
Program critically reviews and comments on papers in an objective and straight forward manner.
Each document review is usually provided in a format that lists the Page number. Column number.
Paragraph  number. Sentence number:  Comment.   Following are specific comments on the
INTERIM REMEDIAL MEASURE PROPOSED PLAN FOR THE 200-UP-I OPERABLE
UNIT, HANFORD, WASHINGTON, DOE/RL-9S-26 DRAFT A.

SPECIFIC COMMENTS

Page 1. Column 1, Paragraph 1

The most important goal of this IRM should be to contain elevated concentrations of uranium,
technetJum-99, nitrate, and carbon  tetrachoride to within the 200 Area.
                  v

Page 3, Figure 2

Figure 2 has an unacceptable lack of detail. All groundwater monitoring wells should be shown
along with measurements of the contaminants.  Additional figures should be shown to map each
of the plumes individually  The carbon tetrachloride plume is not shown on Figure 2.

Page 5. Column 2, Paragraph 5

The maximum concentrations for each of the contaminants are not specifically shown on Figure 2.

Page 6. Column I, Paragraph 2

This statement on risk evaluation is not detailed enough as the basic assumptions and pathways of
exposure are not clearly explained.  Studies supporting statements made are not referenced.
                                        A-5

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Page 6. Column-1. Paragraph 6, Last Sentence

If left unremediated, how long will it take for contaminants to migrate from the 200 Ares to the
Columbia River?

Page 7, Column i. Paragraph 1

Is the implicit soil to reduce contaminant TfltKH!mr*i'5H!* to less than 10 tunes the MCL?

Page 7, Column 2, Paragraph 1

Why are you not planning nitrate treatment during phase I?

Page S, Column 2, Paragraph 2, Last sentence

How does leaving long-lived radionucfides and other contaminants in the groundwater  satisfy
DOE Order 5820.2A (HIX2Xft)?  Thb order states that no legacy  requiring remedial  action
remains after operations have been terminated.

Pag* 8, Column 2, Paragraph 4

The Nez Perce Tribe believes RCRA regulations apply with regards, to the carbon temchloride
waste water. In tha document, a nuu) of the carbon tetnchlcflde phane u not shown, and there
are no plans for treating the carbon tetrachlcrid*.  U.S. DOE-RL is trying avoid compBancn with
RCRA regulations.

Page 9, Column I, Paragraph I, Last Sentence

How does leaving long-Bved radionucfides  and other contaminants in the groundwater  satisfy
DOE Order 5820.2A  (mX2X*)?  Tnk order states that no legacy requiring remedial  action
remains after operations have been termmateoV
                                                  i
Page 9, Coluoui 2, Last Paragraph, First Seateac*

DOE-RL claaatlthafr the no acdea ahernarive has no added cost.  DOE-RL conrinuea to be
oblivious of coatttath* environment created by its lack of foresight.
 Pag«10,TaMel

 The total estimated cost of the project should be shown.  What percentage of the total cost is
 contractor overhead?
                                             A-*

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Page 10. Column 2. Last paragraph. Last Sentence

The Nez Perce Tribe concurs that the continued migration of these groundwater plumes presents
a threat to public health, welfare, and the environment.
                                          A-7

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A-8

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                                       1168 Englewood Drive
                                       Richland, WA  99352

                                       August 8, 1995
Mr. Oib Goswaml
Washington State Department of Ecology
Nuclear Waste Program
1315 W. 4th Avenue
Kennewick, WA  99336

COMMENTS ON THE PROPOSED PLAN TO TREAT GROUNDWATER FROM THE 200-UP-l OPERABLE
UNIT ON THE HANFORD SITE

Ref.:  RL, 1995, Interim Remedial Measure Proposed Plan for the 200-UP-l
       Operable Unit, Hanford, Washington, DOE/RL-95-Z6, Rev. 0, U.S.
       Department of Energy, Richland Operations Office, Richland, Washington.

Dear Mr. Goswami:

I have reviewed the Proposed Plan to remediate the groundwater on the Hanford
Site at the 200-UP-l Operable Unit (Reference).  The Proposed Plan identifies
as the "preferred alternative" to upgrade the current pilot-scale system to
pump and treat the groundwater.  The only other alternative considered in the
Proposed Plan is to take no action.  Another alternative should be considered,
namely to use the 200 Area Effluent Treatment Facility (ETF) to treat the
groundwater.  The groundwater could be pumped to the ETF via a pipeline
installed earlier specifically for groundwater remediation.  This pipeline is
located in the same trench as the 200 Area Treated Effluent Disposal Facility
(TEDF).  The Liquid Effluent Retention Facility (LERF) could be used to
temporarily store the groundwater.

The Proposed Plan was issued for public comment.  Following are my comments:

1.   Existing Facilities Are Not Beino Utilized

     Confusion exists as to the origin of the equipment planned to be used to
     treat the groundwater in the preferred alternative.  Some testing was
     previously done using pilot-scale equipment which operated at 25 gpm.
     The Proposed Plan indicates a full-scale system operating at 50 gpm will
     be used.  Consideration is also being given to increasing the capacity to
     120 gpm in the future.  Ecology has said that this equipment was provided
     free-of-charge by the EPA.  What equipment was originally provided and
     may be modified at what cost is not clear.  Regardless, the ETF currently
     has available capacity to treat up to 150 gpm.  This would allow the
     pilot-scale pump and treat equipment to be used elsewhere for groundwater
     remediation, and would avoid the cost of future upgrades.

2.   Waste Minimization Is Hot Being Provided

     Carbon tetrachloride is planned to be adsorbed onto granular activated
     carbon (GAC) in the preferred alternative.  The spent carbon is a mixed
     waste that requires disposal unless it is regenerated.  The volume of
     waste produced could be considerable if the capacity of the existing pump

                                       1
                                        A-9

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     and treat equipment is increased.   The preferred alternative will also
     use ion exchange to remove uranium and technetium.  The spent ion
     exchange resin is similarly not  planned to be regenerated and will
     produce additional waste.   The ETF process includes an ultraviolet
     light/peroxide oxidation (UV/Ox)  system whereby organic compounds are
     totally destroyed, producing little or no residue.  Use of GAC was
     considered in the design of the  ETF,  but was eliminated because of the
     large volumes of waste that would be generated.  Flexibility was retained
     to include GAC in the ETF process at a later date if needed.  The ETF
     also has an ion exchange system  capable of removing uranium and
     technetium, and the spent resin  is regenerated so it can be reused.

3.   The Groundwater Is Onlv Being Partially Treated

     No treatment is provided for nitrate in the preferred alternative.  The
     treated water to be returned to  the aquifer will greatly exceed drinking
     water standards.  Granted,  the nitrate contamination in the groundwater
     beneath the Hanford Site is widespread and would be difficult to
     remediate.   However, that does not preclude responsibility for removing
     nitrate whenever possible to minimize the overall risk to the environment
     and the legacy we leave to future generations.   The ETF process is highly
     effective at removing nitrate from groundwater.

4.   The Preferred Alternative Will Cost Jobs

     The ETF is  a new $50 million facility intended to treat process
     condensate  from the 242-A Evaporator and wastewater from the PI/REX Plant.
     Startup of the ETF is planned for November.   The first campaign will
     treat approximately 10 million gallons of process condensate now being
     stored in the LERF.  When the next campaign  occurs is anyone's guess.
     The 242-A Evaporator is used to concentrate  the waste stored in the  tank
     farms to make storage space available and reduce the need for new tanks.
     However, the need for tank space  is now diminished and the PUREX Plant
     has also shut down.  As a  result,  the availability of feed to the ETF  is
     uncertain.   Without feed the ETF  will  most likely be placed on standby.
     This will  result in job losses that will  ripple through the Tri-Cities
     economy.  Even worse will  be the  perception  on Capitol Hill of Hanford
     using hard-fought tax dollars to  build facilities that have no apparent
     purpose. Using the ETF to treat  groundwater would provide a stable,
     long-term mission.

5.   Let The Stakeholders Hake the Decision

     Ecology has been advised several  times in the past of the suitability  of
     the ETF for treating groundwater.   Yet the ETF was still not considered
     as an alternative.  The Proposed  Plan invites the public to participate
     in the selection process,  but clearly the decision has already been made.
     Issuing the Proposed Plan  for public  comment without describing all the
     viable alternatives only gives the appearance of stakeholder involvement.
     The stakeholders cannot comment  on something they know nothing about.   An
     impartial panel of stakeholders  should review the options ana recommend  a
     path forward.   Persons knowledgeable  about the capabilities of the ETF
     should be asked to provide technical  input.
                                    A-IO

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I request-that  a public meeting be he1d_to discuss the Proposed Plan because
of the importance of the issuers I've'raised.^  Please Contact me at J/o-;ab9 if
you imtfU auUlliun.il  infuiffiltTorT   I  look forward to discussing this further.

                                       Very truly yours.
                                       Steven S. Lowe
                                     A-ll

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A-12

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A-13

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A-14

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             NMWMP  -  Hanford   RIP Name.

                           
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A-16

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Mr. Dib Goswami;                                  MIMIA/MD
Washington  State  Department of  Ecology            IMMWMr -
Nuclear Waste  Program
1315 W4th  Ave                                        AUG151995
Kennewick. Wa. 99336
                                                    •  Kennewick
Subject;   Comment on 200  Area  Ground Water;

The principal source of hazards to humans from  the carbontetrachloride
class of solvents is due to inhalation of the vapors.   Once solvent enters
the blood stream it can attack the vulnerable organs of the body. In1977,
the American Chemical Society issued a warning on the hazards of
exposures via the  respiratory track  could lead to cancer of the pancreas.
Several deaths  due to cancer of the pancreas did occur among the research
chemists at  Hanford.  two of which were friends. If  we pull these solvents
out into the  air and start  processing, we increase by some increment, the
chance  of exposing the respiratory tract of the employees.  My work with
relative toxicity of material  was in the  1970's for McDonnell Douglas,  if
my power of recall is accurate these solvents produce little if any hazard
to the  body  due to ingestion.  Since ingestion itself is  remote why not
leave the solvents  where they are now?
     The half lives of Uranium and  Technetium-99 are so great that the
number of disintegration per second are not significant.  The toxicity of
Uranium is related to its properties as  a heavy  metal and it's chemical
toxicity is far more limiting  than its radioactive properties.   Since  the
average amount of Uranium  present in the  earth's crust is in the .03 ppm
range,   and  natural deposits occur  in nature, that are  thousands of times
the average  concentration.  If the concentration  of  uranium  in the ground
water is less than  1% of the  deposits  found in  earth's  crust.  It should
considered in the same category  as natural occurring Uranium and no
action should be considered.  I submitted uranium ore  samples to Battelle
Northwest Laboratories for  analysis, these samples were from  a deposit
under Midwest Lake.in Canada.  The analysis done by BNWL in the 1970 's
indicated the  samples ran  from  15 to 22 % uranium.  These samples were
uranium nickel  arsenate. the arsenic had  the dominate toxicity  in the\
samples.  This   highly concentrated deposit was formed by a melting
glacier.  The  mounds  at Hanford were dropped by the receding glacier, who
know, what is present hundreds of feet below the surface?
     Prior to the start up of the -Tritium Producing  Reactors at Savanah
River test were  run to determine how far the discharge must travel to
                                     A-17

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obtain full lateral  dispersion of the tritium in the involved rivers. 1 It  was
shown that full lateral dispersion occurred within a few  miles of travel.
This means that complete dilution in the rivers  would also occur within
the few miles of the discharge point.  The Columbia River has an average
flow in excess of 180,000 cubic  feet per second over and thru McNary Oam.
This flow would provide dilution sufficient to dilute  a 50 cubic feet per
second of ground water flow by a factor of 3600.  This indicates that the
concentration in the ground water could be 3600 times the  EPA drinking
water standard and not exceed the EPA drinking water standard in  the
Columbia River.
     The ground water access within  the discharge  triangle  could  be
controlled by an  organization such as the Port of Benton or the County  of
Benton.   If the  selected entity were provided a  source of water for
sanitary  use and  irrigation,  it would eliminate the  need for access to the
ground water and  increase the ground water dilution and flow.

1.   AEC  Handbook,  'Source of Tritium',  by D. G. Jacobs. 1968

Submitted by    Marvin L  Smith  CHP

                      6408 W victoria Ave. Kennewick, Wa. 99336

                Phone  509-783-5523
                                  A-18

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NMWMP - Hanford                    i
                                            10508 W. Court
      AUG151995                           \—'Ei7^rficr-         CERCLA
     Kennewick                              WQ	„     AQ.
                                            Administrative
    Mr. 01b Goswami
    Washington State Department of Ecology    ppcpr   -"        N-Rpartnr
    Nuclear Waste Program                     crocv,	   n-noauiui
    1315 West 4th Avenue                      Milestones
    Kennewick, WA  99336                                , 	
                                            Cross reference
    Dear Mr. Goswani:
    REQUEST FOR A PUBLIC MEETING ON THE INTERIM REMEDIAL MEASURE PROPOSED PLAN FOR
    THE 200-UP-l OPERABLE UNIT AND COMMENTS ON THE PROPOSED PLAN

    With this letter,  I am requesting a Public Meeting be held on this IRM.   I am
    hopeful that Ecology will listen to public opinion and take the necessary
    action to change the proposed plan and do what is right for Hanford,  the
    taxpayers, and the environment—to utilize a state-of-the-art waste water
    treatment facility already available at Hanford to treat the ground water from
    200-UP-l.  A key concern, in addition to serious environmental issues,  is
    fiscal accountability in these times of reduced funding.

    The proposed plan endorses the S5M-10M dollar alternative to build a  50-120
    gallon per minute treatment facility, when an under utilized 150 gallon per
    minute facility already exists at Hanford—the new 200 Area Effluent  Treatment
    Facility.  If the IRM is necessary to prevent further movement of the nitrate,
    uranium, and technetium-99, the 200 Area Effluent Treatment Facility  is the
    best option available!

     The 200 Area Effluent Treatment Facility will provide:

         1)  Greater reduction of the contaminants.  The 200-UP-l plan proposes
         to proceed with the favored alternative even though not all  of  the
         site's contamination problems will be addressed.  But the 200 Area
         Effluent Treatment Facility can far exceed the contaminant reduction
         proposed.  Will Ecology continue to support the proposed inferior
         treatment, knowing that a superior treatment 1s available at Hanford?

         In addition, an uninterrupted flow of clean water for injection purposes
         could be made available from U-Plant—so why would Ecology and  EPA
         endorse reinjecting contaminated water?

         2)  Treatment for 150 gallons per minute.  If there is truly an
         environmental urgency requiring the IRM, please consider using  the  200
         Area Effluent Treatment Facility that can provide treatment  quickly--
         verses the eventual scale up to 120 gallons per minute your  plan
         proposes.  In light of your established need for an IRM, will Ecology
         support a more aggressive remedial action utilizing the available 150
         gallon per minute process?
                                     A-19

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      3)   Great Improvement to waste minimization.  The capability  alone  to
      regenerate the ion exchange beds can greatly reduce resin costs  and
      secondary waste volumes.  Similarly, UV/Oxidation destroys VOCs  rather
      than creating additional < irbon waste.  Does Ecology support  the
      production of unnecessary secondary waste when a treatment process  is
      available that will provide for waste minimization?

An additional point not considered in the proposed plan was the fact that the
Environmental Restoration Program has already installed .(and paid for) a
pipeline to carry the 200-UP-l ground water to the 200 Area Effluent Treatment
Facility.   The infrastructure is available, is Ecology willing to change  the
proposed plan and endorse utilizing that Infrastructure?

I am confident that Ecology can revisit the alternatives and see how using the
200 Area Effluent Treatment Facility is a far superior plan.  I am  requesting
that you take this opportunity to make a change— think out of the box — and do
what is right for Hanford.
Therefore,  in summary, I request that you hold a pnhiir p^etipff to take
further comments and initiate th» npr^sarv actions tn withdraw tht» nro
plan and endorse utilizing the 200 Area Effluent Treatment Facility for
treating ground water form the 200-UP-l Operable Unit.


                                    Sincerely,



                                    Janice Williams
cc:   Helodie Selby, Ecology
      Doug Sherwood, EPA
      Hanford Advisory Board
                                     A-20

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                                                            ivv.vir' - Hanforc

                                                              AUG211995

                                                             Kennewick
August 17,1995
Dib Goswami
Dept. of Ecology
Nuclear Waste Program
1315 W. 4th Ave.
Kennewick, Wa. 99336

Dear Mr. Goswami,

•though I live " down wind" from Hanford, I'm concerned about the long - range
effects Hanford could cause. We are still in the early stages of Hanford's  birth.
Though there are qualified people working their constantly learning and
developing new ways to improve storage, I don't believe there is yet a sure fire
system to completely protect the waste from contaminating the land and people.
The last couple of weeks I had the opportunity to fly over the facility. I was
shocked to see it situated so dose to the Columbia River. My immediate reaction
was "how stupid to build such a potentially deadly facility so dose to a major
waterway.  Yes, I have heard stones about the issues, but now visually seeing it
brings it doser to home. As delicate as Nudear energy is and how government
runs it is very important to our planet Every partide of being on the planet
induding the planet itself is a living organism. We don't have all the answers on
how to protect us. We haven't developed a perfect means of getting results of
damages to the planet The planet itself is being affected by our experiments and
needs. What guarantees are there that deaning the ground water with another
caustic material and returning it to the soil will not create another poisonous
problem to the planet.
      I'm sure my concerns aren't as vocal as  those that live next to the facility.
The balance of our earth depends on ail organism to fulfill their natural cyde of
existence.  We have created an imbalance in so many areas that the planet is
struggling to survive.
      Please respect the earth, look to the future of the planet. Create a balance
between all organisms so that we don't destroy ourselves even more.
      I live and breath each day not knowing how pollutants are affecting me. I
do know that the chemicals I've been around have caused damage to my health
and well-being.  The nations lives depend on your research and support.
      Your proposal stated is one alternative, what other alternatives do you
have? I assume there is no way to neutralize it. It seems that radioactive
material in its own form has natural substances that it works with that maybe
could be tapped and used to defuse the waste.
                                   Sincerely,
                                   Vicky Lyons
                                      A-21

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                                                             251 Green Meadows
                                                              Yakima.  WA 98908
                                                                (509)  966-9399
                                                               August  21, 1995

Mr. Dib Goswami
Washington State Department of Ecology
Nuclear Waste Program
1315 W. 4th Avenue
Kennewick, Wa 99336

COMMENTS ON THE PROPOSED PLAN TO TREAT  GROUNDWATER FROM THE 200-UP-l OPERABLE
UNIT ON THE HANFORD SITE

Ref:  RL, 1995, Interim Remedial  Measure  Proposed Plan for the 200-UP-l
      Operable Unit, Hanford, Washington, DOE/RL-95-26, Rev. 0,  U.S.
      Department of Energy, Richland Operations  Office, Rlchland,  Washington.

Dear Mr. Goswarai:

The proposed plan recommends a groundwater pump  and treat action to halt the
spread of the highly contaminated portion of  the 200-UP-l plume.  I agree with
this recommendation and support its  implementation.

However, I recommend that Ecology consider the 200 Area Effluent Treatment
Facility (ETF) rather than the continued use  of  the pilot-scale equipment for
the implementation of the preferred  alternative.   The ETF has several
potential advantages over the continued use and/or upgrade of the existing
pilot-scale treatment equipment.   These advantages include:

      o     Treatment Capability - The  ETF is a  state-of-the-art treatment
            facility that will provide  treatment  for contaminants  expected in
            the 20Q-UP-1 Plume (i.e.  nitrates, technetium-99, uranium  and
            carbon tetrachloride).

      o     Waste Minimization -  The ETF design  includes several steps  to
            reduce the amount of secondary waste  produced.  The ETF ion-
            exchange resins are regenerated, while in the pilot-scale  unit
            they are buried.  In  the ETF organics are destroyed, whereas,  in
            the pilot-scale unit, they  are adsorbed on activated carbon and
            then buried.

      o     Utilization of existing  facilities -  The ETF has available
            capacity and staff to treat 200-UP-l  groundwater.  There is an
            existing line to transfer the groundwater from 200 West to  200
            East.   The Liquid Effluent  Retention  Facility is available  to hold
            the groundwater prior to treatment in the ETF.

      o     Alternative application  of  pilot-scale equipment - The pilot-scale
            equipment could be relocated to other locations to collect
            engineering data on other plumes, or  to allow the remediation of
            sites which are not viable  candidates for treatment  in the  ETF.
                                      A-23

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Mr. 01b Goswami
Page 2
August 21, 1995


Again, I urge Ecology to consider the use of the ETF in the implementation of
the preferred alternative.   I  believe this evaluation will reveal the ETF is a
cost effective alternative  to  the one proposed in the Interim Remedial
Measure.  Additionally,  utilization of the ETF could serve as an example of
how two DOE sub-contractors  can work together to clean up the Hanford Site in
a cost-effective manner.
                               Sincerely,

                               &.  ~3(

                               Don Flyckt


cc: Melodic Selby,  Ecology
                                       A-24

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NMWMP-HanforcfjleNarTie-
                        Integrated.
          _
A|~      214 North Underwood
AU - fcmnewlck, WA 99336
      SEP • 6 1995 -.       RCRA _   CERCLA
                                                          14 N
                                                          mne
                  »                                       /cno\ T)K
                        Administrative _ (509) 73S-

        Mr. oib Goswami  EpSEC _   N-Reactor _
        Washington Statef0HWWWf\fe«f Ecology
        Nuclear Waste       5™63
        1315 w. 4th Aveniteross-reference
        Kennewick, Wa 99336
        COMMENTS ON THE PROPOSED PUN  TO  TREAT GROUNDWATER FROM THE  200-UP-l OPERABLE
        UNIT ON THE HANFORD SITE

        Ref:  RL,  1994, Hanford Sitevide  Groundwater Remediation Strategy,  DOE/RL-94-
              95,  Rev. 0, U.S.  Department of Energy. Richland operation  Office,
              Richland, Washington.

              RL,  1995, Interim Remedial Measure Proposed Plan for the 200-UP-l
              Operable Unit,  Hanford,  Washington, OOE/RL-95-26,  Rev. 0,  U.S.
              Department of Energy, Richland Operations Office,  Richland, Washington.


        Dear Mr. Goswami:

        The  proposed plan recommends a groundwater pump and treat action to  halt the
        spread  of  the highly  contaminated portion of the 200-UP-l plume.  I  agree with
        this recommendation and  support its implementation.

        I believe  that the recommended alternative of upgrading  the current  pilot-
        scale equipment has several disadvantages that must  be addressed before
        proceeding:

             Waste Minimization - The pilot-scale unit will  adsorb carbon
             tetrachloride into activated carbon.   When spent,  the activated carbon
             becomes a mixed waste that requires disposal.   This is  not following
             good waste minimization practices.   One method  that should be considered
             to destroy carbon tetrachloride and minimize waste is the process of
             organic destruction by ultraviolet  light/peroxide oxidation (UV/Ox).

             In addition,  the pilot-scale unit uses  ion exchange to  remove  uranium
             and technetium.  The spent ion exchange resin is not planned to be
             regenerated  and will produce additional  waste.   Ion exchange units that
             can be regenerated to minimize waste  should be considered.

             Ptrtlal  Treatment - The  pilot-scale unit  does not have  the  capability to
             treat the nitrate concentration down  to  below drinking  water standards.
             This  is  not  acceptable when  processes and facilities exist  to  remove
             nitrate  contamination.

             Utilization  of Existing  Facilities  -  The  200 Area Effluent  Treatment
             Facility (ETF) is a new  $50  million  facility built to treat process
             condensate from the 242-A Evaporator.   This facilities  feed source has
             significantly diminished  due to PUREX not being in continued operation.
                                            A-25

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       The HanTord Sitettide Groundwater Remediation  Strategy (RL 1994)  states
       that  "use of available  resources such as the  ETF will  be considered  in
       planning for groundwater  remediation".  This  facility must be considered
       in  the  remediation of groundwater at the 200-UP-l Operable Unit.

 The .ETF..facility mentioned above was designed to treat contaminants expected
 in the 200-UP-l  Plume (i.e. nitrates,  technetium-99,  uranium and carbon
 tetrachloride)  and has several  advantages that the  current  pilot-scale
 equipment does  not:

       Waste Minimization - The  ETF uses  the UV/Ox process described above  to
       destroy organic material  and Its ion exchange process  includes a
       regeneration cycle which  follows waste minimization policies.  In
       addition,  any secondary waste that is produced  is dried to a  powder  to
       further reduce waste generation.

       Partial Treatment - The ETF has  the ability to  lower nitrates  below  the
       drinking water standards.  In addition, organics  and radionuclides are
       reduced to minimum levels.

       Utilization of Existing Facilities - The ETF  has  available capacity  and
       staff to treat the 200-UP-l groundwater.  This  can be  accomplished via
       an  existing transfer line located  between the 200 West-and 200 East  Area
       in  the  same trench as the 200 Area Treated Effluent Disposal Facility
       line (200  Area TEDF).  Also, the Liquid Effluent  Retention Facility
       (LERF)  is  available to hold the  groundwater prior to treatment at the
       ETF.

This is not to say that the pilot-scale  facility cannot be further utilized.
It can be relocated  to collect engineering data and perform  small scale
treatment on  other plumes.

In summary,  due  to disadvantages in the current pilot-scale  equipment.  Ecology
must consider the use of the 200 Area  Effluent Treatment Facility in the
implementation of the preferred alternative to remediate the groundwater at
the 200-UP-l  Operable Unit.  I believe this evaluation  will  reveal the ETF is
a cost effective  alternative to the one proposed in the  Interim Remedial
Measure.   Additionally,  utilization of the ETF could  serve as a public example
of how DOE,  WDOE,  and two Hanford sub-contractors can work together  to clean
up the Hanford Site  in a cost-effective manner.

I look forward to  hearing your response on this matter  and am available if you
require clarification or any points or would like additional information.
Sincerely,
Oarrell Heimberger
                                        A-26

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    nduiuru                             Rle Name.
                                            Integrated.
 8EP:6*--.                                  RCRA	   CERCIA
,.    Hr. Olb Goswami                                         -  ~ 	
KeDffe8fWH&M State Department of Ecology           VVQ	     AQ	
     Nuclear Waste Program                                     .
     HIS w. 4th Avenue                          Administrative	
     Kennewick, WA  99336
                                            EFSEC	   N-Reacior
 RE: Comments on the Proposed Plan to Treat Graundwatecjfcon the 200-UP-l
 piume.                                      WflS?i'5hes	
 Dear Hr. Goswann:                            Cross reference.
 I  support the concept of groundwater pump and treatment in order to mitigate
 the spread of the 200-UP-l  plume. However, I do not support the concept of
 building another treatment  facility on the Hanford Site in order to accomplish
thli fliiaT.	"	'
 The 200 Area Effluent Treatment Facility (ETF) has the State-Of-The-Art
 treatment capability and capacity necessary to handle the planned groundwater
 treatment effort.  While it's  always nice to give design and construction
 engineers another  opportunity to practice there trade, building additional
 treatment capacity to handle  the 200-UP-l plume while the ETF goes into
 mothballs does  not speak of a wise expenditure of tax dollars. It is  important
 to remember that the Effluent Treatment Facility was originally built with the
 concept of treating flows from other sources. Toward this end a contingency
 pipeline was constructed that can be used to transport groundwater to the
 Liquid Effluent Retention Facility (LERF) where it can be stored prior to
 treatment at the ETF.

 Beyond the existing ''nfrastructure, the ETF facility will be able to  treat
 groundwater to  high Discharge standards, holds the necessary discharge
 permitting and  will  produce less secondary waste as a byproduct of treatment.
 Both from the standpoint of cost and treatment capability, it 1s difficult for
 me to envision  how' the construction of additional  capacity for a pilot plant
 would help further the environmental mission at Hanford.

 Should the option  of expanding the capacity of the pilot  scale facility
 continue to receive WOOE endorsement. I would ask that a  full and complete
 cost benefit analysis  be performed comparing upgrading the pilot facility to
 the use of the  EFT.  At a minimum I believe factors such as the capital, O&H,
 achievable treatment standards, production of secondary waste and facility
 permitting be evaluated in  comparing upgrading the pilot  scale equipment
 against the use of the ETF. Also, I would expect, that. this cost-benefjt
 evaluation be conducted with  public.input-into the process.

As a final  point,  I  would ask to be notified of any Water Board actions
 related to this matter.  I would like to discuss this issue with board members
 should it be placed  on their  agenda.
Sincerely
Oavid P.  Nelsen
3401 U.  1st Place #1
Kennewick WA.  99336    (509) 783-6866
                                      A-27

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A-28

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                                             12215 -  9th N.W.
                                             Seattle, WA 98275
                                             September  6,  1995


Dib Goswami
Washington Departnent of Ecology
Nuclear Waste Program
1315 West 4th Ave.
Kennewick, WA 99336

Dear Ms. or Mr. Goswani:

     I am writing to offer some comments concerning the Interim
Remedial Measure Proposed Plan for the 200-UP-l Operable Unit,
Hanford, Washington.  I will add that I do not know a lot  about
Hanford, but I fear that the public pressures for action are
probably not founded on* a good understanding of risks.  I  ask
that as studies at this Operable Unit, and other units  as  well,
progress, that considerations of several variations of  the "Do
Nothing" alternative be more thoroughly and objectively
evaluated.  The "do-nothing" alternative can include deed
restrictions to keep people out of harm's way (and preserve open
space) and monitoring.  Better understanding the possible  safety
of a "do-nothing" alternative is sorely needed.  Indeed, this is
crucial so if cleanup actions are actually taken, we can
understand what benefit has resulted.  From my reading  of  the
Interim Remedial Measure, I see nothing that supports the
position that the "do-nothing" alternative is not: the best
alternative.  Rather, it is just glossed over as unacceptable and
unprotective.

     The Summary of Site Risks indicates that uranium and
technetium-99 present a relatively high potential risk  for their
carcinogenic characteristics.  A level higher than 10**  was
stated.  However, this was called a "potential" risk because it
required a population to actually be exposed to these
contaminants by drinking well water from the plume, and this
consumption rate would persist for their life times, solely from
the plume.  A hazard index of 4 was also computed for a potential*
noncarcinogenic risk associated with uranium and nitrate.  Each
of these potential risks were based on the assumption that "the
land in this downgradient area were used for residences and
humans were to drink the groundwater" (pg 6).  I don't  believe
that the land is actually used for residences and the drinking of
groundwater.  I don't believe there is actually an exposed
population.  Therefore, I don't believe that the risk   ~
characterization is portrayed correctly.  I do believe  that the
opportunity' for deed restrictions to keep people from drinking
groundwater from the site can insure that risks will be avoided
in the future.  I believe the following questions need  to  be
honestly answered before we expend large amounts of money
cleaning things up.

     1.   Is there really any exposed population in the path of
                                A-29

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         .this plume now?

      2.   Since the source has been halted, what changes over
          time night be expected to tha constituents of this
          plume?  What is the h^if life for technetiun-99?  How
          fast does the plume move?  What dilutions are expected?

      3.   Is there any logical basis to assume that future site
          uses will be thrown open to the public to flock to
          homesites and to drink well water from Hanford?  My
          thoughts are that no matter how good a cleanup is ever
          achieved, the public really isn't going to be willing
          to do this anyway.

      4.   Is the land on the Hanford Reservation currently under
          government ownership?

      5.   Couldn't the land downgradient of any plumes or
          potential plumes from Hanford remain in government
          ownership in order to restrict uses (such as drilling
          drinking wells) that could result in exposures?
          Wouldn't this in fact also preserve it as wild open
          space, which is an ecologically desirable objective?)

      6.   If the objective of the cleanup is for the government
          to later sell the land for future residential
          development, does the cost for this development
          opportunity make any economic sense at all when
          compared to the cost of keeping the area undeveloped?

     A risk-risk analysis is needed.  This analysis needs to
examine the human health risks associated with the costs of
cleanup.  Costs (any costs) also carry risks.  They are currently
paid by present .and future taxpayers.  They are paid with deficit
dollars, meaning interest costs mount up as well.  These
expenditures come at the cost of preventing use of the sane money
for other needs, such as education, welfare, school loans,
housing, etc.  These expenditures make taxpayers incrementally
poorer, which in turn can equate to direct health and welfare
impacts on the population at large.  These risks are very real
and may b* roughly quantified.  These risks are more real than
the risks described in the Interim Remedial Measure document
because there is a population that will realize these costs,
whereas the risks that this action is seeking to reduce is
hypothetical, based on some future population living there and
drinking the groundwater.  The actual risks at present are
essentially non-existent, since there is no exposed population.

     The Interim Remedial Measure document shows that evaluation
criteria includes the following threshold criteria:

     "Overall Protection of Human Health and the Environment"

The document flippantly writes off the "no-action alternative"
stating that it "does not change the overall protection of human
                                A-30

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health and the environment" while alternative 2 "would serve to
contain the high-concentration area of the plume and remove
contaminant mass fron the aquifer" therefore reducing risks and
improving overall protection of human health and the environment.

     As part of objectively evaluating the do nothing
alternative, consider the following questions:

     1.   Assuming that nobody moves into the"area over where the
          plume is and where the plume may migrate to, and
          specifically, nobody drills wells and drinks most all
          of their water from those plumes for their life times,
          then how does alternative 2 reduce risks and improve
          the overall protection of human health and the
          environment?  Exposure was zero, and remains zero.

     2.   Assuming alternative 2 carries costs in the millions,
          and that further studies also carry costs, and further
          remedial actions may also be proposed later with even
          more costs, and that because of the deficit nature of
          federal spending, those costs will also carry
          substantial financing costs, what impact on human
          health is expected associated with those costs?  There
          is an impact.  This impact is not zero.

     There are other evaluating criteria based on long-term
effectiveness and short-term effectiveness.  If the no-action
alternative also considers restrictions on humans ever using the
downgradient area for drinking water wells, wouldn't that
restriction result in a high short and long-term effectiveness?

     I didn't see anywhere the concern of the plume reaching the
Columbia River.  I think that if it did, it would be a non-       '
problem because .the release rates would be slow, the dilution
high, and I do not believe it would present any more problem to
people drinking wate'r or eating fish from the Columbia than the
N-Springs seeps,  which was a classic example of__a_non-problem
that the Department of Ecology pushed for a needless cleanup     /
action on.                    	•	

     I am concerned about the objectivity of three different
governmental agencies acting in this process.  In all cases, it
is taxpayers money that will be spent.  The agencies will not be
good guardians of this money, since it is not their money.
Hence, a political decision to do something is easy to make,
whether it is truly of benefit to the taxpayers or not.  The
agencies need to recognize that public dollars will become
scarcer and scarcer, and they must assure that they are only
spent where they will accomplish the most.  I. wish that the state
Health Department had more involvement in this process, as they
are more inclined to examine real human health issues.

                              Sincerely your
                              Lincoln Loehr
ours,
-~£r- — C
                                A-31

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A-32

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                               MEMO

To        Dib Goswani, WaDOE

From      Lincoln Loehr

Date      9-9-95

Subject   correction to comments
     On September 6, 1995 I.mailed comments to you that had the
wrong return address.  I recently moved, and made the mistake of
putting my old street address in Seattle along with my new zip
code from Hukilteo.  Please note that my correct address is:

     Lincoln Loehr
     11500 West Oakmont Drive
     Hukilteo, WA 98275-4871

     For simplicity, I have attached a corrected set of my
comments.  The only change is the return address.. I am also on a
mailing list to receive information from Ecology on cleanup
matters at Hanford.  Could you please pass this memo on to
whoever maintains the mailing list so my address can be
corrected?

     Thanks for your assistance.
                                A-33

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A-34

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September 27, 1995
                                                          NMWMP  -
 Dib Goswami                                                    QCT - 4 1995
 Washington Depu of Ecology
 Nuclear Waste Programs Office                    '             .'  k prjfl
 1315 West 4th Ave.                  7
 Kennewick, WA 99356

 Dear Mr. Goswami:

 I attended last evenings public comment meeting on the Interim Remedial Measure Proposed
 Plan for the 200-UP-l Operable Unit I found the comments and questions offered by the
 audience to be informative, and at the same time troublesome.  To address the portions of the
 comments that were troublesome, I present the following questions:

 1 .     If the Effluent Treatment Facility (ETF) has the capacity to handle 1 80 gallons per minute
       of waste water, and the UP-1 were to provide a base load of 50 gallons per minute, would
       the effective cost of treannent equal 50/180 of the operating cost of the ETF?

       As noted at the meeting, ETF is a S50M facility, with a current budget of S18M per year.
       It would seem that the 200-UP-l share of that operating cost would be about S5M per
       year, a factor of 3 greater than that presented in the proposed plan.

2.     Proposers of using the Pilot-Scale Treannent plant offered information on the treatment
       efficiency of their operation. As Ms. Wanek stated the target operating efficiency for FY-
       1996 is 80%. Before any move is made to ""^ ETF the sole or partial treater of the
       water, please provide similar operating data for that facility.

3.     Proponents of the ETF made numerous mention of the facility being double contained, is
       the pipeline from 200  West Area to the ETF also double contained?

4.     Please address the issue of listed waste, and how disposal of water which has been in
       contact with the listed material (carbon tetxachloride) can be accomplished through the
       ETF.

5.     Operating history of the Pilot-Scale System has shown that there is a finite probability of
       bacterial growth in the treatment system. Backflushing  has limited the negative effects in
       the current system, please provide information on how the ETF, using UV/Oxidation for
       removal of carbon tetrachloride, will prevent fouling of the UV lamps. What will be the
       costs associated with system revisions to overcome these difficulties?

6.      I have additional concerns about the potential problems associated with the mixing of
       waste streams in the Liquid Effluent Retention Facility (LERF) prior to the streams being
       treated in the ETF. After the streams are mixed, what element of the process has
       responsibility for the water? This appears to be analogous to the PRP questions facing
                                           A-35

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       landfills around the country today.  Admittedly, the US Dept of Energy is the ultimate
       responsible parry, but contracting changes on the pan of that agency are moving toward
       spreading the responsibility to individual contractors working for them.

Thank you for considering these comments,
David A. Myers
2533 Davison
RichJand. WA 99352
                                             A-36

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                                                                         043623

                                                                 1400 Rimrock Avenue
                                               Rlchland, WA 99352
                                               October 5, 1995

Dr. D1b Goswaoi
Washington Department  of Ecology
1315 W.  4th Avenue
Kennewick, WA 99336

Re: 200-UP-l

Dear Or.  Goswaml:

       Two Issues must be resolved before a proper record of decision can be
.•nade regarding the  cleanup of 200-UP-l.  The first Issue Is multl-faceted,
dealing  with satisfying established stakeholder values, especially protecting
the Columbia River, protecting workers' safety and health, and reducing costs.

       You claimed  that you are not concerned with cleaning up the nitrate
:ontamination, which appears to directly violate the stakeholders' value of
protecting the Columbia River.  On the other hand, you insist on cleaning up
:he technetium and  uranium, which Donna Wanek claimed could be performed with
100* efficiency.  You  seen to have unilaterally decided that protecting the
:olumbia River means to not allow select contaminants to reach the river at
.oncentratlons greater than the HCLs.  I saw no evidence that this clenup
 ffort will  accomplish that goal.  The only modeling results presented dealt
/ith groundwater flow  and capture zone analyses 1n the area immediately
 unrounding the proposed Injection and extraction wells.  If the cleanup
.ffort will  not reduce the concentrations below the HCLs,. then why bother?

      Under all alternatives, the portion of the Columbia River that would
 xceed HCLs (or some other appropriate criteria) should be determined - 1s it 10
 quare  feet or 10 square miles.  Values do not require that they be completely
 atisfied regardless of the cost (as you have already declared by not cleaning
 p the  nitrate plume), so it is highly desirable to see the resulting damage
 one within the river  that is predicted for each alternative.

       I  would question the validity of the modeling results, because Bechtel's
 20hydrolog1st stated  that it is beyond the state-of-the-art of modeling to
 amonstrate "short-circuiting.*  All that a model has to contain are two highly
 Dntrastlng layers  in  terms of horizontal hydraulic conductivities to achieve
 riis effect.   This  leads me to wonder if all Bechtel modeling 1s accomplished
 sing only one soil type, even though we know that the Hanford and Rlngbld soils
 -e highly heterogeneous.

       I  have concerns about the capabilities of this cleanup approach to
 jntain  the plume and  thus ultimately protect the Columbia River.  Assume that
 ie natural  groundwater flow is say 20 gpra through the capture zone before
 imping.   If pumping is started at 20 gpm, then all the water will be captured.
 r all the extracted water is injected upstream, I.e. at 20 gpm, and the system
 : allowed to reach steady state conditions, then the combined flow rate must be
 i gpm  (or undesirable plume spreading occurs that pushes contaminants beyond
 .e original  capture zone lateral boundaries).  With water moving at 40 gpm and
 .•raps operating at  20  gpm, then water aiust escape the system at a rate of 20
 'in. If  the extraction rate is equal to the 'injection rate and steady state
 .nditions are achieved, then water must escape the system at the rate at which
  e water moved before pumping commenced.  In reality, transient conditions will
  cur, however, I saw  no indication at the public meeting that transient
  nditions were modeled, nor that the results presented were for a specific time
  ter the start of  operations.
                                           A-37

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       The second stakeholder value  that  was  not addressed was the workers'
safety and health.   Conducting these operations Imposes risks to workers from
both radiological and construction/operation  viewpoints and from travel to and
from the site.   Those risks  must  be  weighed against  the reduction in risk to the
public from conducting these cleanup efforts.  Without haveing analyses in hand
that clearly demonstrate that the benefits outweight the increased worker risks,
you do not have a proper basis for issuing a  ROD.

       The third stakeholder value that Is not properly considered is reducing
costs.   Disposal  costs obviously  have not been considered, because Bechtel could
not answer the  question of how disposal would be accomplished.  Consideration of
all costs involved  with building,  operating,  and deconnissioning a new facility
versus using the ETF must be considered.  You should get estimates with backup
calculations from both Bechtel  and WHC to perform a  bounding analysis.  If
Bechtel  has no  plans to use  the pipeline  that was built for their benefit, then
why were taxpayers'  dollars  spent building the pipeline and how does that
satisfy the stakeholder value of  reducing costs?

       You should express the benefit of  accomplishing this cleanup as dollars
jer death saved where the death saved is  the  reduction in public deaths less the
increase in workers'  deaths.   This approach will provide a means for
orioritizing cleanup activities across the site.  Prioritization will become
3Xtrenely important  as budgets are further reduced.

       The second issue deals with the absence of vital  information for the
}ublic meeting.   Costs for the ETF alternative were  not available for the public
neeting,  so you did  not receive all  the public input required to reach your
Jecision.   Modeling  results  were  woefully Inadequate to make any determination
ibout the validity  of claims by Bechtel on cleanup durations.  Absolutely
lothing was provided about modeling  assumptions, so  the public is not able to
>erform a reality check on the modeling.

       I  saw no modeling results  involving contaminant transport.  Reinjection
;hould show diminishing returns if properly modeled.   When the heterogeneous
lature of the aquifer is properly considered, the pump-and-treat should indicate
.hat the  highly conductive zones  will  be  cleaned first.   After that cleanup is
iccojRplished, further reinjection will likely result in only cleaning reinjected
,ater.   After turning off the pumps,  contaminants from within the less
 onductlve zone will  redistribute to the  more conductive zones and the
.oncentratlons  at the extraction  well  and monitoring wells will increase.   None
.f these  effects  is  captured with a  flow  model, nor  were any results of this
.ature  presented  at  the public meeting.

       In  conclusion,  I do not believe that you are  in position to render a
 efensible decision yet.   You have not adequately addressed stakeholder values
 or have you presented sufficient information for the public to fully, comment on
 hese cleanup activities.  I  recommend that you resolve  these issues, then hold
 nother public meeting.

 Incerely,
 eonard B. Col lard
                                         A-38

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                                                         043623
 This letter is in response to the Tri Parry Agreement ad in the
 Seattle Times dated 8-7-95:

     Back in the early 1970's,  the people at Hanford were wondering
 what to do about all the nuclear waste.   It's now 1995 and looks as
 if people are still asking the  same question.  This is after how
 many billions of dollars later?  I proposed back then that we take
 the waste, put it in rockets  and send it toward the sun.   Someone
wrote back and said it would be to  expensive.   I believe  one estimate
put it at 2 billion dollars.   I think  you've already spent that and
the waste is still here.   Seems like no  one  really wants  to clean
anything up since a lot of people are  making money at having career
jobs in moving stuff around,, lawyers in  court,  and endless committees.
Just thought I'd help out.

                                                  Gene Mallamo
                                 A'-39

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A-40

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