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
Q.
I
•X).
rt
•8
o1
•1
S-
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3
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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
Crib
900-
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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
n
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-------
• 216-U-1. 2
Crib,
0,000 1,000,000
I
-N-
I
MCICRS
FCC!
3OO
1000
• WeHi tiled lor plum* definition
''Jj. Concenlrolion itoplelh in porlt per billion (ppb)
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
.... N/A
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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\
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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
$4,169,000. The details of construction, materials and maintenance are described in Table 3.
No additional labor cost is included for treatment at the ETF. The labor force necessary is
already present and funded due to the requirements for operation of the facility to treat
process condensate and other streams.
10.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
10.1 CERCLA Nine Criteria
This section summarizes the relative performance of each of the alternatives with respect to
the nine criteria identified in the National Contingency Plan (NCP). The nine criteria fall
into three categories. The first two criteria (overall protection of human health, and the
environment and compliance with ARARs) are considered threshold criteria and must be met.
The next five criteria are considered balancing criteria and are used to compare technical and
cost aspects of alternatives. The final two criteria (state and community acceptance) are
considered modifying criteria. Modifications to remedial actions may be made based upon
21
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Kl
200 West Area
a Pump Stations
— TEDF
... Spare Lino
— Tlo-ln
200 East Area
o
N)
O
O
C/3
O
n
n
i/>
I
•
£.
•^*
-------
($ 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
5
cx
H
n
o
r*
I/I
5'
00
m
n
5
Si
3
OJ
O
-------
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.
27
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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.
28
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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.
29
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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
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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.
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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.
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APPENDIX A
PUBLIC LETTERS
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APPENDIX A
PUBLIC LETTERS
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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
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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
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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
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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.
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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?
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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.
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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
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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.
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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
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NMWMP - Hanford RIP Name.
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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
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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
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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?
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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
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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
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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.
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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
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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.
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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
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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
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