PB98-964602
EPA 541-R98-035
September 1998
EPA Superfund
Record of Decision:
Idaho National Engineering Laboratory
(USDOE) OU 2-13
Idaho Falls, ID
12/17/1997
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DftTtnher 2:.
Idaho
National
Engineering
Laboratory
DIVISION OF
ENVIRONMENTAL QUALITY
Final Record of Decision
Test Reactor Area
Operable Unit 2-13
Idaho National Engineering and Environmental Laboratory
Idaho Falls. Idaho
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DOE/1D-10586
Record of Decision
Test Reactor Area
December 22,1997
Operable Unit 2-13
Idaho National Enqineering and Environmental Laboratory
Idaho Falls, Idaho
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DECLARATION OF THE RECORD OF DECISION
Site Name and Location
Test Reactor Area, Waste Area Group 2
Operable Unit 2-13
Idaho National Engineering and Environmental Laboratory
Idaho Falls. Idaho
Statement of Basis and Purpose
The Test Reactor Area (TRA) Waste Area Group (WAG) 2 is one of the ten Idaho National
Engineering and Environmental Laboratory (INEEL) WAGs identified in the Federal Facilities Agreement
and Consent Order (FFA/CO) by the U.S. Environmental Protection Agency (EPA) Region 10, the Idaho
Department of Health and Welfare (IDHW), and the U.S. Department of Energy (DOE). Operable Unit
(OU) 2-13 is listed as the "WAG 2 Comprehensive Remedial Investigation (RI)/Feasibility Study (FS).
including TRA Chemical Waste Pond" in the FFA/CO. The RI/FS task was to assemble the investigations
previously conducted for WAG 2, to thoroughly investigate the sites not previously evaluated, and to
determine the overall risk posed by the WAG. This resulting comprehensive Record of Decision (ROD)
document presents the selected remedial actions for eight contaminant release sites at the TRA of the
INEEL, Idaho Falls, Idaho. It provides information to support remedial actions for these eight sites where
contamination presents an unacceptable risk, and a "No Action" decision on 47 additional sites at the
TRA. These remedial actions have been chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1986, as amended by the Superfund
Amendments and Reauthorization Act, and to the extent practicable, with the National Oil and Hazardous
Substances Pollution Contingency Plan. It is also designed to satisfy the requirements of the FFA/CO.
This decision is based on the administrative record for the site.
The DOE is the lead agency for this decision. The EPA and the IDHW have participated in the
evaluation ot the final action alternatives. The EPA and IDHW both concur with the selection of the
preferred remedy for the TRA eight sites of concern and with the No Action determinations for the
remaining sites.
Assessment of the Site
Eight of the 55 identified release sites within TRA have actual or threatened releases of hazardous
substances, which, if not addressed by implementing the response actions selected in this ROD, may
present an imminent and substantial endangerment to public health, welfare, or the environment. These
sites include four disposal ponds (Warm Waste Pond1952. 1957. and 1964 cells (TRA-03). Chemical
Waste Pond (TRA-06). Cold Waste Pond (TRA-08). and the Sewage Leach Pond (TRA-I3)|. three
subsurface contaminant release sites (soil surrounding Hot Waste Tanks at Building 613 (TRA-15),
Tanks I and 2 at Building 630 ((TRA-19), and the Brass Cap Area|. and one area of surficial windblown
contamination (Sewage Leach Pond Berms and Soil Contamination Area). The response actions selected
in this ROD arc designed to reduce the potential threats t» human health and the eru;-\>nmen; to acceptable
levels. The remaining 47 sites as part of the following OL's either were determined not to present an
unacceptable risk to human health or the environment, and therefore require* no further action, or were part
in
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of a previous ROD. These OUs are: Rubble Piles (no OU specified). Paint Shop.Ditch (OU 2-01);
Inacdve Fuel Tanks (OU 2-02); Miscellaneous Spill Sites (OU 2-03); Petroleum and Polychlorinated
Biphenyl Sites and the North Storage Area including the North Storage Area, Soil Contamination Area
(OU 2-04); Hot Waste Tanks (OU 2-05); Rubble Sites (OU 2-06); Cooling Tower Sites (OU 2-07).
Materials Test Reactor Canal (OU 2-08); Sewage Treatment Plant (OU 2-09); Retention Basin, Injection
Well. Cold Waste Sampling Pit and Sump (OU 2-11); Perched Water (OU 2-12); and Hot Tree Site,
Engineering Test Reactor Stack, French Drain Associated with TRA-653 and Diesel Unloading Pit
(OU2-I3).
Description of the Selected Remedies
The selected remedy for the Warm Waste Pond (TRA-03), 1952 and 1957 cells, is containment of
the pond contents using an engineered cover consisting of several layers of geologic materials to reduce
potential exposure to contaminated pond sediments by human and environmental receptors. This remedy
also includes the following institutional controls that are assumed to remain in effect for at least 100 years:
long-term environmental monitoring, soil cover integrity monitoring and maintenance, surface water
diversions, and access restrictions (e.g., fencing and signage). Before cover construction, the Warm Waste
Pond 1957 cell may be filled to grade with bulk CERCLA-contaminated soils from the INEEL. For the
Warm Waste Pond 1964 cell, where an interim remedial action was previously completed, a riprap or
cobble gravel layer will be placed over the existing native soil cover to inhibit future intrusion or
excavation and to increase the degree of permanence of the remedy. In addition, institutional controls as
described above will be implemented for the Warm Waste Pond 1964 cell.
The major components of the selected remedy for the Warm Waste Pond are:
Containment by cover, with an engineered cover constructed primarily of native materials
Implementation may include consolidation of INEEL CERCLA-generated contaminated
materials similar to those already in the Warm Waste Pond for containment under the 1957 cell
engineered cover
Implementation will include consolidation of clean native soil from an appropriate borrow
source located at the INEEL
Contouring and grading of surrounding terrain to direct surface water runoff away from the
covers
Periodic aboveground radiological surveys following completion of the covers to assess the
effectiveness of the remedial action
Periodic inspection and maintenance following completion of the covers to ensure cover
integrity and surface drainage away from the covers
Access restrictions consisting of fences, posted signs, and permanent markers
Restriction* limiting land use for at least KM) years following completion of the covers
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Review of the remedy no less than every 5 years until determined by the regulatory agencies to
be unnecessary.
The selected remedy addresses the principal risks posed by the Warm Waste Pond by providing
shielding from ionizing radiation, a cover to inhibit ecological and human intrusion, and a long-lasting
cover to diminish the effects of wind and water erosion.
The selected remedy of the Chemical Waste Pond (TRA-06) is containment with a native soil cover
and institutional controls with possible excavation, treatment, and disposal after sampling. This remedy
will provide a sufficient thickness of soil to effectively reduce the potential for human and/or biological
intrusion or excavation into the contamination.
The EPA's preference for sites that pose relatively low long-term threats or where treatment is .
impractical (e.g., TRA radionuclide contamination) is engineering controls, such as containment. In the
case of low-level mercury contamination in the Chemical Waste Pond, containment is a protective and
cost-effective option to remediate the exposure pathway (homegrown food crop ingestion) determined to
pose an unacceptable risk. Based on sampling to be conducted during the remedial design phase to
determine the nature and extent of contamination, remediation of the Chemical Waste Pond may include
excavation, treatment, and disposal prior to containment with a native soil cover.
A revised cost comparison based on the above-identified sampling will be reviewed by the agencies
during the Remedial Design Phase.
The major components of the selected remedy for the Chemical Waste Pond are:
Containment with a soil cover constructed primarily of native materials
Implementation will include consolidation of clean native soil from the berms surrounding the
Chemical Waste Pond and from an appropriate borrow source located at the INEEL
Contouring and grading of surrounding terrain to direct surface water runoff away from the
cover
Final cover layer materials will be determined in the Remedial Design/Remedial Action Work
Plan but may include a vegetated crested wheatgrass and a gravel mulch layer
Periodic inspection and maintenance following completion of the cover to ensure integrity and
surface drainage away from the cover
Access restrictions consisting of fences, posted signs, and permanent markers
Restrictions limiting land use for at least 100 years following completion of the cover
Review of the remedy no less than every 5 years until determined by the regulatory1 agencies to
he unnecessary.
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The selected remedy addresses the principal risks posed by the Chemical Waste Pond by isolating the
contaminants, providing institutional controls to inhibit human intrusion, and a long-lasting cover to inhibit
the effects of wind and water erosion.
The selected remedy for the Sewage Leach Pond is containment using a native soil cover and
institutional controls as described above. This remedy will provide a sufficient thickness of soil to
effectively reduce the potential for intrusion or excavation into the contaminated area and will provide
shielding against exposure to radionuclide.contamination. Prior to placement of the final clean soil cover.
contaminated soil will be removed from the sewage leach pond berms for placement in the bottom of the
Sewage Leach Pond. The berms of the pond will then be placed into the pond to ensure that any
contaminated soil is contained. Additional fill material will be used, as needed, to bring the ponds to
grade.
The major components of the selected remedy for the Sewage Leach Pond are:
Containment by capping with a native soil cover constructed primarily of native materials
Contaminated soil from the berms will be placed in the bottom of the Sewage Leach Pond cells
Implementation will include consolidation of soil from the berms surrounding the Sewage
Leach Pond and from an appropriate borrow source located at the INEEL
Contouring and grading of surrounding terrain to direct surface water runoff away from the
cover
Final cover layer materials will be determined in the Remedial Design/Remedial Action Work
Plan but may include a vegetated crested wheatgrass and a gravel mulch layer
Periodic aboveground radiological surveys following completion of the cover to assess the
effectiveness of the remedial action
Periodic inspection and maintenance following completion of the cover to ensure cover
integrity and surface drainage away from the cover
Access restrictions consisting of fences, posted signs, and permanent markers
Restrictions limiting land use for at least KM) years following completion of the cover
Review of the remedy no less than every 5 years until determined by the regulatory agencies to
be unnecessary.
The selected remedy addresses the principal risks posed by the Sewage Leach Pond by providing
shielding from inni/ing radiation, institutional controls to inhibit human intrusion, and a long-lasting cover
to diminish the effects of \\ ind and water erosion.
For the Cold Waste Pond (TRA-08). the selected alternative is excavation followed by disposal at an
appropriate facility Additional field and laboratory data will be obtained beforehand to optimi/e
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excavation activities. Current administrative controls designed to protect worker health and safety will be
maintained.
The major components of the selected remedy for the Cold Waste Pond are:
Sampling to identify hot spots
Excavation of hot spots that are above acceptable levels
Disposal at an appropriate location (e.g.. Warm Waste Pond, 1957 cell).
The selected remedy addresses the principal risks posed by the Cold Waste Pond by effectively
removing the source of contamination and thus breaking the pathway by which a future receptor may be
exposed.
The selected remedy for the Soil Surrounding Hot Waste Tanks at Building 613 (TRA-15) is Limited
Action, consisting of continued use of existing administrative controls and implementation of long-term
environmental monitoring for a period of at least 100 years to protect current and future occupational
receptors. On the basis of predicted radioactive decay, no further action is expected at the end of
KM) years. Five-year reviews would be conducted to ensure that the remedy remains protective for the
entire period of administrative controls.
Major components of the selected remedy for TRA-15 are:
Inspection of existing operational controls to assess the adequacy and need for additional
institutional controls
Access restrictions (e.g., fences, posted signs, and permanent markers)
Restrictions limiting land use for at least 100 years
Periodic inspection and maintenance to ensure integrity of institutional controls
Review of the remedy no less than every 5 years until determined by the regulatory agencies to
be unnecessary.
The selected remedy addresses the principal risks posed by the Soil Surrounding Hot Waste Tanks at
Building 613 by effectively preventing access to the area and exposure to contaminated media.
Forthe Soil Surrounding Tanks 1 and 2 at Building 630 (TRA-19) and the Brass Cap Area, the
selected alternative is Limited Action, with the contingency that, when controls established under the
Limited Action are not maintained, then an excavation and disposal option would be implemented (to a
maximum of 10 ft). This Limited Action alternative is preferred because the contamination associated
with these two sites is located under the ground surface in and around active radioactive waste piping and
tank systems and buildings where access is physically limited. Therefore, excavation alternatives arc not
fully implementable at this time, because it cannot be ensured that adequate contamination could be
removed lo eliminate the need for the controls that would be in place under the Limited Action alternative.
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If during 5-year reviews it is determined that the controls established under the Limited Action alternative
could not be maintained or do not continue to be protective, then the contingency of excavation and
disposal would be implemented. Seleciion of the Limited Action alternative requires that existing
administrative controls, such as access restrictions and worker protection programs, be maintained to
prevent exposure 10 workers or future inhabitants above acceptable levels and long-term environmental
monitoring to be implemented.
Major components of the selected remedy for TRA-19 and the EJrass Cap Area are:
Inspection of existing operational controls to assess the adequacy and need for additional
institutional controls
Access restrictions (e.g., fences, posted signs, and permanent markers)
Restrictions limiting land use for at least 100 years
Periodic inspection and maintenance to ensure integrity of institutional controls
Review of the remedy no less than every 5 years, until determined by the agencies to be
unnecessary
Once controls established under the limited action are not maintained (no longer than
100 years) or do not continue to be protective, then excavation and disposal of contaminated
soil will be implemented.
The selected remedy addresses the principal risks posed by the Soil Surrounding Tanks I and 2 at
Building 630 (TRA-19) and the Brass Cap Area by effectively preventing access to the area so that
exposure to contaminated media resulting in an unacceptable risk to human health and the environment
would not be possible. In addition, if controls established under the Limited Action were not maintained,
then excavation and removal of contaminated media would effectively remove the source of contamination
and thus break the pathway by which future receptors may be exposed.
The identification of Limited Action as the preferred alternative with an excavation and disposal
contingency is based on the 100-year industrial land use assumption torTRA. The validity of this
assumption will be evaluated during the 5-year review process. How :ver. the maximum duration of time
for which this assumption may be considered valid is up to 100 years from the signing of this ROD.
For the Sewage Leach Pond Berms and Soil Contamination Area, the selected remedy is Limited
Action (existing administrative/institutional controls, including implementation of long-term
environmental monitoring) for a period of at least 100 years to protect current and future occupational
receptors. However, through radioactive decay, it is estimated that no further action would be needed at
the end of the 100-year period. Consistent with the Sewage Leach Pond remedy, however, the windblown
radionuclide-contammated soil berms will be placed in the bottom of the pond as part of the native soil
cover This remedv will continue to prevent or reduce potential occupational exposure to acceptable levels
tor the l()0-\ear period that institutional control;, are in place. T'v 5-year review process would be used to
en MI re- that the remedv remains effective.
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Major components of the selected remedy for Sewage Leach Pond Berms and Soil Contamination
Area are:
Inspection of existing operational controls to assess the adequacy and need for additional
institutional controls
Access restrictions (e.g., fences, posted signs, and permanent markers)
Restrictions limiting land use for at least 100 years
Periodic inspection and maintenance to ensure integrity of institutional controls
Review of the remedy no less than every 5 years until determined by the agencies to be .
unnecessary.
The selected remedy addresses the principal risks posed by the Sewage Leach Pond Berms and Soil
Contamination Area by effectively preventing access to the area so that exposure to contaminated media
would result in an unacceptable risk to human health and the environment while radioactive decay occurs.
For the Snake River Plain Aquifer and the Deep Perched Water System, the OU 2-12 ROD remains
in place. The Warm Waste Pond, which was the major source of contamination in the perched
groundwater, has been replaced by a new lined pond. A monitoring plan will be developed in accordance
with the OU 2-13 Remedial Design/Remedial Action Scope of Work, which integrates the monitoring
needs of both OU 2-12 and OU 2-13. Until that time, monitoring will continue to be performed as
prescribed in the OU 2-12 monitoring plan. Groundwater monitoring will be conducted to verify that
contaminant concentration trends follow those predicted by the groundwater model. Computer modeling
shows that through natural radioactive decay, natural attenuation, and dispersion, contaminants in the
groundwater will steadily decrease to acceptable levels within the next 20 years, which is consistent with
the time of continued operations at the TRA. Existing institutional controls, which include land use and
property access restrictions, will continue to be maintained. The CERCLA 5-year review process will be
used to verify that this recommendation remains protective.
The No Action alternative is reaffirmed and selected as the appropriate alternative for the remaining
47 sites at the TRA on the basis of risks being at an acceptable level or due to the lack of known or
suspected contaminant releases to the environment.
The possibility exists that contaminated environmental media not identified by the INEEL FFA/CO
or in this comprehensive investigation will be discovered in the future as a result of routine operations.
maintenance activities, and decontamination and dismantlement activities at TRA. Upon discovery of a
new contaminant source by DOE, IDHW. or EPA, that contaminant source will be evaluated and
appropriate response action taken in accordance with the FFA/CO. In addition, legacy waste that has been
generated as a result of previous sampling activities at WAG 2 (i.e.. investigation derived waste) will be
appropriately characterized, assessed, and dispositioned in accordance with regulatory requirements to
achieve remediation souls consistent with remedies established for sites under this ROD.
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Statutory Determination
The selected remedy for each site has been determined to be protective of human health and the
environment, to comply with federal and state requirements that are legally applicable or relevant and
appropriate (applicable or relevant and appropriate requirements to the remedial actions), and to be cost
effective.
These remedies-use permanent solutions and alternative treatment technologies to the maximum
extent practicable. However, because treatment of radionuclide-contaminated soil is not found to be
practical, these remedies do not satisfy the statutory preference for treatment as a principal element of the
remedy. The EPA's preference for sites that pose relatively low long-term threats or where treatment is
impractical is engineering controls, such as containment. In the case of mercury contamination at the
Chemical Waste Pond, the preference for treatment will be fulfilled if the post-ROD sampling indicates
that excavation, treatment, and disposal are necessary.
For those sites where contaminants are to be left in place (containment and Limited Action) in excess
of health-based levels, a review will be conducted every 5 years after ROD signature (statutory 5-year
review) to ensure that the remedy is still effective in protecting human health and the environment and to
assess the need for future long-term environmental monitoring and administrative/institutional controls.
These comprehensive statutory 5-year reviews will be conducted to evaluate factors such as contaminant
migration from sites where contamination has been left in place, effectiveness of institutional controls, and
overall effectiveness of the remedial actions. For the Limited Action remedy, it is assumed that the
institutional controls will remain in place for at least 100 years. The identification of Limited Action with
an excavation and disposal option contingency as the selected alternative for TRA-19 and Brass Cap Area
is based on the 100-year industrial land use assumption for the TRA. However, the maximum duration of
time for which this assumption may be considered valid for purposes of this ROD is up to 100 years from
the signing of this ROD.
The agencies agree that no action be taken at 47 additional sites. For those sites for which no action
is being taken based on land use assumptions, those assumptions will be reviewed as part of the 5-year
review.
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Signature Sheet
Signature sheet for the Record of Decision for OU 2-13, located in Waste Area Group 2, Test
Reactor Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho
Department of Health and Welfare.
Chuck Clarke, Regional Administrator Date
Region 10
U.S. Environmental Protection Agency
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XII
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Signature Sheet
Signature sheet for the Record of Decision for OLJ 2-13, located in Waste Area Group 2, Test
Reactor Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho
Department of Health and Welfare.
^\
r //
^
Wallace N. Cory, Administrator / Date
Division of Environmental Quality
Idaho Department of Health and Welfare
XIII
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Signature Sheet
Signature sheet for the Record of Decision for OU 2-13, located in Waste Area Group 2, Test
Reactor Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho
Department of Health and Welfare.
hn Wilcynski, Managbr Date
.S. Department of Energy Idaho Operations Office
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XVI
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CONTENTS
DECLARATION OF THE RECORD OF DECISION iii
ACRONYMS xxiii
I. DECISION SUMMARY 1-1
1.1 Site Name, Location, and Description 1-1
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3-1
4. SCOPE AND ROLE OF OPERABLE UNITS AND RESPONSE ACTIONS 4-1
5. SUMMARY OF SITE CHARACTERISTICS 5-1
5.1 Physiography, Geology, and Hydrology 5-1
5.2 Nature and Extent of Contamination 5-4
5.2.1 Disposal Pond Sites 5-4
5.2.2 Subsurface Release Sites : 5-8
5.2.3 Windblown Surficial Contamination Site 5-13
5.2.4 Snake River Plain Aquifer and Deep Perched Water System 5-16
5.2.5 No Action Sites 5-17
6. SUMMARY OF SITE RISKS 6-1
6.1 Human Health Risk Evaluation 6-1
6.
6.
6.
6.
6.
. 1 Contaminant Identification 6-1
.2 Exposure Assessment 6-1
.3 Toxicity Assessment 6-3
.4 Human Health Risk Characterization 6-3
.5 Human Health Risk Uncertainty 6-17
6.2 Ecological Evaluation 6-17
6.2.1 Species of Concern 6-17
6.2.2 Exposure Assessment 6-21
6.2.3 Ecological Risk Evaluation . . 6-21
6.2.4 Ecological Risk Uncertainty 6-22
6.3 Groundwatcr Fate and Transport 6-22
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6.4 Basis for Response 6-24
7. DESCRIPTION OF ALTERNATIVES 7-1
7.1 Remedial Action Objectives 7-1
7.2 Summary of Alternatives 7-2
7.2.1 Alternative 1: No Action (With Monitoring) 7-2
7.2.2 Alternative 2: Limited Action 7-4
7.2.3 Alternatives 3a and 3b: Containment Alternatives and Institutional Controls .... 7-6
7.2.4 Alternative 4: Excavation, Treatment, and Disposal 7-8
7.2.5 Alternative 5: Excavation and Disposal 7-9
7.3 Summary of Comparative Analysis of Alternatives 7-9
7.3.1 Threshold Criteria 7-10
7.3.2 Balancing Criteria 7-18
7.4 Modifying Criteria 7-21
7.4.1 State Acceptance 7-21
7.4.2 Community Acceptance 7-21
8. SELECTED REMEDY '. . . 8-1
8.1 Description of Selected Remedy 8-1
8.1.1 Warm Waste Pond (TRA-03) 8-1
8.1.2 Chemical Waste Pond (TRA-06) 8-3
8. .3 Cold Waste Pond (TRA-08) 8-3
8. .4 Sewage Leach Pond (TRA-13) 8-4
8. .5 Soil Surrounding Hot Waste Tanks at Building 613 (TRA-15) 8-4
8. .6 Soil Surrounding Tanks I and 2 at Building 630 (TRA-19) 8-4
8. .7 Brass Cap Area 8-5
8. .8 Sewage Leach Pond Berm and Soil Contamination Area 8-6
8. .9 No Action Site 8-6
8.2 Remediation Goals 8-8
8.2.1 Containment System Performance Standards 8-8
S.2.2 Excavation and Disposal Performance Standards 8-9
8.2.3 Limited Action Performance Standards 8-9
S.2.4 Treatment Performance Standards 8-10
S.3 Estimated COM Detail for the Selected Remed\ 8-10
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9. STATUTORY DETERMINATION 9-1
9.1 Protection of Human Health and the Environment 9-1
9.1.1 Alternative I: No Action 9-1
9.1.2 Alternative 2: Limited Action 9-1
9.1.3 Alternatives 3a and 3b: Containment with Engineered Cover or Native
Soil Cover 9-1
9.1.4 Alternative 4: Excavation, Treatment, and Disposal 9-2
9.1.5 Alternative 5: Excavation and Disposal 9-2
9.2 Compliance with ARARs 9-2
9.2.1 Additional ARARs : 9-10
9.2.2 To Be Considered 9-10
9.3 Cost Effectiveness 9-11
9.4 Preference for Treatment as a Principal Element 9-13
10. DOCUMENTATION OF SIGNIFICANT CHANGES 10-1
II. RESPONSIVENESS SUMMARY I l-l
Appendix AResponsiveness Summary A-l
Appendix BAdministrative Record File Index B-l
FIGURES
I -1. Location of the Test Reactor Area 1-2
1 -2. Location of Test Reactor Area sites of concern 1-3
I -3. Land ownership distribution in the vicinity of the INEEL and onsite areas open for
permit grazing 1-4
5-1. Warm Waste Pond (TRA-03) location 5-5
5-2. Chemical Waste Pond (TRA-06) showing 1990 sample locations with maximum average
data for PCBs and metals 5-7
5-3. Cold Waste Pond (TRA-08) showing 1990 soil sample location, organic compound and
metal data, and composite gamma data 5-9
5-4. Hot Waste Tanks at Building ftl 3 (TRA-15) showing 1993 soil boring locations and soil
sample data 5-11
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5-5. Radioactive Tanks at Building 630 (TRA-19) and Brass Cap Area showing 1985 y data
in pCi/g 5-12
5-6. Sewage Leach Pond soil contamination area showing 1995 sampling locations and data 5-14
5-7. Sewage Leach Pond berms showing 1995 sampling locations and data 5-15
7-1. Cross-sectional schematic typical of the engineered cover and the native soil cover 7-7
10-1. Chemical Waste Pond logic diagram 10-2
TABLES
4-1. List of WAG 2 sites 4-2
6-1. Summary of sites and exposure routes with calculated risks greater than or equal to 1E-04 6-4
6-2. Summary of sites and exposure routes with calculated risks greater than or equal to 1E-06 6-5
6-3. Summary of sites and exposure routes with calculated hazard index greater than or
equal to one 6-7
6-4. Summary of the sites that have the potential to pose an unacceptable risk to ecological
receptors 6-8
6-5. WAG 2 contaminants of concern 6-9
6-6 Contaminants and exposure pathways of concern for OU 2-13 sites with risks >1E-06 and
cumulative risks >IE-04 6-10
6-7. Contaminants and exposure pathways of concern for OU 2-13 sites with hazard
indexes >1.0 6-15
6-8. Human health assessment uncertainty factors 6-18
7-1. Final remediation goals for OU 2-13 sites of concern 7-3
7-2. Estimated area and volume of contaminated media requiring remedial action 7-4
7-3. Comparative analysis summary ol remedial alternatives for OU 2-13 sites of concern 7-11
7-4 Relative ranking of alternatives evaluated tor the eight OU 2-13 sites ol concern 7-16
8-1. Selective remedial alternatives for sites of concern in OU 2-13 8-2
S-2. Warm Waste Pond engineered barrier detailed cost estimate 8-11
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8-3. Chemical Waste Pond detailed cost estimate 8-12
8-4. Cold Waste Pond excavate and dispose detailed cost estimate 8-13
8-5. Sewage Leach Pond native soil cover detailed cost estimate 8-14
8-6. TRA-15, TRA-19, Brass Cap Area limited action detailed cost estimate 8-15
8-7. Sewage Leach Pond Berm and Soil Contamination Area limited action detailed
cost estimate 8-16
8-8. Brass Cap Area excavation and disposal contingent remedy detailed cost estimate 8-17
8-9. TRA-19 excavation and disposal contingent remedy detailed cost estimate 8-18
9-1'. Summary of ARARs met by selected alternatives for OU 2-13 sites of concern 9-3
9-2. Summary of alternative cost estimates for the eight sites of concern 9-12
XXI
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XXII
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ACRONYMS
ARAR applicable or relevant and appropriate requirement
ATR Advanced Test Reactor
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COC contaminant of concern
COCA Consent Order and Compliance Agreement
COPC contaminant of potential concern
DOE U.S. Department of Energy
DOE-ID U.S. Department of Energy Idaho Operations Office
EMS Environmental Management System
EPA U.S. Environmental Protection Agency
ERA ecological risk assessment
ETR Engineering Test Reactor
FFA/CO Federal Facility Agreement and Consent Order
FRG final remediation goal
FS feasibility study
HQ hazard quotient
IDHW Idaho Department of Health and Welfare
INEEL Idaho National Engineering and Environmental Laboratory
IRIS (EPA) Integrated Risk Information System
LMITCO Lockheed Martin Idaho Technologies Company
MCL maximum contaminant level
MTR Materials Test Reactor
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NCP National Oil and Hazardous Substances Pollution Contingency Plan
NESHAP National Emission Standards for Hazardous Air Pollutants
NPL National Priorities List
OU operable unit
PCB polychlorinated biphenyl
PRO preliminary remediation goals
RAO remedial action objective
RCRA Resource Conservation and Recovery Act
Rl remedial investigation
ROD Record of Decision
SRPA Snake River Plain Aquifer
SVOC semivolatile organic compound
TBC to be considered
TCLP toxicity characteristic leaching procedure
TRA Test Reactor Area
TSCA Toxic Substances Control Act
UCL upper confidence level
USGS United States Geological Survey
VOC volatile organic compound
WAG Waste Area Group
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Waste Area Group 2
Record of Decision
1. DECISION SUMMARY
1.1 Site Name, Location, and Description
The Idaho National Engineering and Environmental Laboratory (INEEL) is a government facility
managed by the U.S. Department of Energy (DOE), located 32 mi (51.5 km) west of Idaho Falls, Idaho,
and occupies 890 mi: (2,305 km2) of the northeastern portion of the Eastern Snake River Plain. The Test
Reactor Area (TRA) is located in the west-central portion of the INEEL, as shown in Figure I-I. To better
manage environmental investigations, the INEEL is divided into ten Waste Area Groups (WAGs).
Identified contaminant release sites in each WAG were in turn divided into operable units (OUs) to
expedite the investigations and any required remedial actions. Waste Area Group 2 covers the TRA and
contains. 13 OUs that were investigated for contaminant releases to environmental pathways. Within these
13 OUs, 55 known or suspected contaminant release sites have been identified. This Record of Decision
(ROD) applies to these 55 sites, which, on the basis of the comprehensive remedial
investigation(RI)/feasibility study (FS) for WAG 2, were identified as posing a potential risk to human
health and/or the environment. Of those 55 sites, 47 are being recommended for "No Action." The
locations of the eight sites where remedial action is proposed are shown in Figure 1-2.
Facilities at the INEEL are primarily dedicated to nuclear research, development, and waste
management. Surrounding areas are managed by the Bureau of Land Management for multipurpose use.
The developed area within the INEEL is surrounded by a 500-mr (1,295-knr) buffer zone used for cattle
and sheep grazing. Communities nearest to the TRA are Atomic City (south), Arco (west), Butte City
(west), Howe (northwest). Mud Lake (northeast), and Terreton (northeast). In the counties surrounding the
INEEL, approximately 45% is agricultural land, 45% is open land, and \()c/r is urban. Sheep, cattle, hogs,
poultry, and dairy cattle are produced; and potatoes, sugar beets, wheat, barley, oats, forage, and seed crops
are cultivated. Most of the land surrounding the INEEL is owned by private individuals or the U.S.
Government, as shown in Figure 1-3.
Public access to the INEEL is strictly controlled by fences and security personnel. State
Highways 22, 28, and 33 cross the northeastern portion of the INEEL approximately 20 mi (32.2 km)
away, and U.S. Highways 20 and 26 cross the southern portion approximately 5 mi (8 km) away. A total
of 90 mi (145 km) of paved highways pass through the INEEL and are used by the general public.
The TRA was established in the early 1950s for studying the effects of radiation on materials, fuels,
and equipment. Three major reactors have been built at the TRA, including the Materials Test Reactor
(MTR). the Engineering Test Reactor (ETR), and the Advanced Test Reactor (ATR). The ATR is
currently the only major operating reactor at the TRA. Approximately 420 people are employed at the
TRA.
1-1
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Legend
Mountains and Buttes
U.S. and State Roads
INEEL Roads
Streams
INEEL Boundary
Railroad Tracks
Key To Facilities
ANL-W - Argonne National Laboratory-West
ARA - Auxiliary Reactor Area
ARVFS - Army Reentry Vehicle Facility Site
BORAX Boiling Water Reactor Experiment
CFA - Central Facilities Area
EBR-I - Experimental Breeder Reactor-1
LOFT - Loss ol Fluid Test Facility
ICPP - Idaho Chemical Processing Plant
IET Initial Engine Test
MWSF - Mixed Waste Storage Facility
NOTF - Navel Ordnance Test Facility
NRF - Navel Reactor Facility
PBF - Power Burst Facility
RWMC - Radioactive Waste Management Complex
SPERT - Special Power Excursion Reactor Test
STF - Security Training Facility
TAN - Test Area North
TRA - Test Reactor Area
WEHF - Waste Experimental Reduction Facility
WRRTF - Water Reactor Research Test Facility
To Arco
/ ^'y? Experimental Field
Station
To BlacKlool
8 10 MILES
RED V97 0181
Figure 1-1. Locution of the Test Reactor Area.
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TRA-06
SLP-SCA
TRA-13
TRA-19
TRA-15
Release Sites of Concern
Operjbk I nil No.
2-05
M>S
2-O'>
2-0<)
2-lu
FF.VCO Reference No.
TRA-I5
TRA-I'J
TRA-OS
TRA-M
None
TRA-03
TRA-(K,
None
Site Description
Sml SurrnunJini! Hot W.IMC Tanks .11 TRA-613
Soil Surroundmj; T.ln^;^ I -2 ;il TRA-630
Cold W.IMC Pond 'TRA-702i
Soxvajii: l-cach Ponds «2i by TRA-7.»2
Sc»:ij;c I.cjch Pond Borm ;md Soil Conciiiiinniion Area i SLP-SCA i
NV;irm \V;iNk' Pond Scdimcnis iColK I'J?2. MJ57. and I'JW)
("homii.i: \\jNii: Pond iTRA-701 i
Brass Cap Arc.i ilK'A-
Figure 1-2. Location of Test Reactor Area .sites of concern.
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Bureau of Land Management
National Forest Service
Private Land - Noncultivated
Private Land - Cultivated
State Land
Under Grazing Permits
Mountains and Buttes
U.S. and State Roads
INEEL Roads
Streams
INEEL Boundary
Key To Facilities
ANL-W Argonne National Laboratory-West
ARA Auxiliary Reactor Area
ARVFS Army Reentry Vehicle Facility Site
BORAX - Baling Water Reactor Experiment
CFA Central Facilities Area
EBR-I Experimental Breeder Reactor-l
LOFT - Loss of Fluid Tesl Facility
ICPP - Idaho Chemical Processing Plant
IET - Initial Engine Test
MWSF - Mixed Waste Storage Facility
NOTF - Navel Ordnance Tesl Facility
NRF Navel Reactor Facility
PBF - Power Burst Facility
RWMC - Radioactive Waste Management Complex
SPERT - Special Power Excursion Reactor Tesl
STF Security Training Facility
TAN - Test Area North
TRA Test Reactor Area
WERF Waste Experimental Reduction Facility
WRRTF - Water Reactor Research Test Facility
To Dubois
N
Lost River,-'
Range
ToArco
ANL-W
I Expenmentai Field ^
Station
02465 10 MILES
Figure 1-3 Land ownership distribution in the \icinil> of ilie INHHl. and onsiie areas open for permit
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The Snake River Plain Aquifer (SRPA), the largest potable aquifer in Idaho, underlies the Eastern
Snake River Plain and the INEEL. The aquifer is approximately 200 mi (322 km) long, 20 to 60 mi (32.2
to 96.5 km) wide, and covers an area of approximately 9,600 mi: (24,853 knr). The depth to the SRPA
varies from approximately 200 ft (61 m) in the northeastern comer of the INEEL to approximately 900 ft
(274 m) in the southeastern corner, a distance of 42 mi (67.6 km). Depth to groundwater is approximately
480 ft (146.3 m) below TRA. Drinking water for employees at TRA is obtained from production wells in
the northeastern part of the facility.
1-5
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2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The TRA was established in the 1950s as a testing area for studving the effects of radiation on
materials, fuels, and equipment. In July 1989, the Environmental Protection Agency (EPA) proposed
listing the INEEL on the National Priorities List (NPL) of the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). The EPA issued a final ruling that listed INEEL as an NPL site in
November 1989. The Federal Facility Agreement and Consent Order (FFA/CO) was developed to
establish the procedural framework and schedule for developing, prioritizing, implementing, and
monitoring response actions at the INEEL in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), Resource Conservation and Recovery' Act
(RCRA), and the Idaho Hazardous Waste Management Act. The FFA/CO identified 13 OUs within TRA
WAG 2 that required further study under the CERCLA process. An additional 10 sites were determined to
need no further action at the time the FFA/CO was signed.
The DOE, EPA, and Idaho Department of Health and Welfare (IDHW) decided that hazardous waste
release sites at TRA would be remediated through the CERCLA process, as defined in the FFA/CO, which
superseded the existing RCRA-driven Consent Order and Compliance Agreement requirements. An
investigation was conducted in 1990 at the TRA Warm Waste Pond to support a remedial decision
required under CERCLA. An Interim Action ROD was signed in 1991, and an interim action was
conducted at the Warm Waste Pond in 1993. The interim action consisted of (I) consolidating sediments
contaminated above the action level of 690 pCi/g cesium (Cs)-137 for the Warm Waste Pond 1964 cell and
backfilling the 1964 cell with clean material; (2) placing the contaminated Warm Waste Pond 1964 cell
sediments into the Warm Waste Pond 1952 cell; (3) collapsing the contaminated sidewalls into the base of
the Warm Waste Pond 1957 cell; and (4) covering the contaminated Warm Waste Pond 1957 cell
sediments with clean material.
In December 1992, the ROD was issued forOU 2-12, the TRA Perched Water System. The selected
remedy was "No Action" with continued groundwater monitoring and a 3-year review of the monitoring
system. After 3 years of post-ROD monitoring, chromium and tritium concentrations in two of the SRPA
monitoring wells remain above drinking water standards. Overall, good agreement between actual and
expected concentrations for other contaminants exists on the basis of the 3 years of study since the
OU 2-12 ROD was signed. The deep perched water system wells show that removing the Warm Waste
Pond from service has reduced concentrations with time. In general, all monitoring wells show a
decreasing contaminant concentration trend, with the exception of one well with chromium and one well
with tritium, which show a statistical increase with time. The objectives of the monitoring program are to
verify contaminant concentration trends in the SRPA, as predicted by computer modeling, and to evaluate
the effect that discontinuing discharge to the Warm Waste Pond has had on contaminant concentrations in
the SRPA and the deep perched water system. Since July 1993, groundwater monitoring has been
conducted at a network of SRPA wells in the vicinity of the TRA and for selected deep perched water zone
wells. This monitoring, currently conducted semiannually, is anticipated to continue until January 1998. at
which time ihe scope of continued future monitoring under the OU 2-13 ROD is anticipated to have been
established and implemented.
Locali/cd areas of radionuclide-contaminated soil were located in the North Storage Area and north
<>! the Nonh Storage Area fence at TRA. This soil contamination was removed in the summer of 1995 and
1996 ;i.s part of an INHHL-uide cleanup of nidioactively contaminated surface soil. Confirmation samples
slum that removal of this contamination was effective.
2-1
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The OU 2-13 comprehensive RI/FS conducted at the TRA resulted in the identification of eight sites
with potential risk to human health and requiring some type of remedial action (DOE/ID-10531, February
1997). The Proposed Plan (March 1997) identified the agencies' preferred alternative for each site of
concern.
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3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
In accordance with CERCLA §113(k)(2)(B)(i-v) and §117, a series of opportunities for public
information and participation in the RI and decision process for the WAG 2, TRA. was provided to the
public from September 1995 through May 1997. The opportunities to obtain information and provide
input included "kick-off and "update" fact sheets, which briefly discussed the status of the comprehensive
investigation, numerous INEEL Reporter newsletter articles (a publication of the INEEL's Environmental
Restoration Program), two Citizens' Guide supplemental updates, a proposed plan, and focus group
interactions, which included teleconference calls, briefings and presentations to interest groups, and public
meetings. In addition, many public involvement activities were conducted during two previous
investigations and RODs at the TRA. The RODs for the Warm Waste Pond Interim Action (1991) and the
Perched Water Remedial Investigation (1992) contain summaries of the public involvement activities that
were associated with these two former investigations at TRA.
In September 1994, a kick-off fact sheet concerning the WAG 2, TRA comprehensive RI/FS was
sent to about 6,700 individuals of the general public and to 60 ENEEL employees on the Community
Relations Plan mailing list. Included in the fact sheet was a postage-paid return mailer comment form. A
total of five comments were received from the public. These comments were evaluated and considered in
the preparation stage of the project workplan. In fall of 1994, three public open houses, held in Idaho
Falls. Boise, and Moscow allowed citizens an opportunity ta interact with DOE Idaho Operations Office
(DOE-ID) and Lockheed Martin Idaho Technologies Company employees concerning the nature and
extent of the investigation. It was the initial opportunity for the public to be involved in how the
investigation would be conducted.
The project was discussed at an informal availability session in Twin Falls (October 11, 1994) and in
Pocatello (October 13, 1994). The same opportunity for informal interactions with agency and INEEL
representatives was provided for Moscow (October 18. 1994), Boise (October 19, 1994), and Idaho Falls
(October 20, 1994). During these briefings, representatives from the DOE and the INEEL discussed the
project, answered questions, and listened to public comments and concerns.
Regular reports concerning the status of the project were included in bimonthly issues of the INEEL
Reporter and were mailed to those on the mailing list. Reports also appeared in two issues of a Citizens'
Guide to environmental restoration at the INEEL (a supplement to the INEEL Reporter) in early 1996 and
1997.
In March 1997, another update fact sheet concerning the project was sent to about 6,700 people on
the INEEL Community Relations Plan mailing list. On March 10, 1997, DOE-ID issued a news release to
more than 100 media contacts concerning the beginning of a 30-day public comment period pertaining to
the WAG 2 TRA proposed plan. This period began March 10, 1997. In response to a request from the
public, the comment period was extended 30 days and ended May 9. 1997. Many of the news releases
resulted in a short note in community calendar sections of newspapers and in public service
announcements on radio stations. Both the fact sheet and news release gave notice to the public that
\VAG 2 TRA investigation documents would be available before the beginning of the commeni period.
These documents were available in the Administrative Record section of the INEEL Information
Repositories located in the INEEL Technical Library in Idaho Falls, in the 1NF.EL Boise Office, and in
public libraries in Fon Hall. Pocatello. and Moscow.
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Opportunities tor public involvement in the decision-making process concerning the WAG 2 TRA
proposed plan began in September 1996 with the establishment of a citizens "focus group" to review the
INEEL's Community Relations Plan. The focus group of eight citizens was convened to critique the
adequacy of the Community Relations Plan in meeting the public's need for information on the
"comprehensive" investigations for an entire WAG. As a result of group interaction with DOE-ID, the
State of Idaho, and EPA Region X project managers, it was decided that, for the first time, draft documents
being prepared for the upcoming public involvement activities could be reviewed by focus group members.
Two teleconference calls to review and discuss the layout and user-friendliness of the information
contained in the WAG 2 documents were held in early January for the draft fact sheet and in early
February for the draft proposed plan. As a result of focus group recommendations, many of the
suggestions identified by the focus group were incorporated into the documents prior to their release to the
general public.
For the general public, the activities associated with participating in the decision-making process
included receiving the proposed plan, receiving telephone calls, attending the availability sessions one-half
hour before the public meetings to informally discuss the issues, and submitting verbal and written
comments to the agencies during the 60-day public comment period. At the request of the Shoshone-
Bannock Tribes, the three agencies met at Fort Hall in January and March 1997 to give Tribal members
and their technical staff a briefing on this proposed plan, as well as on other RIs underway at the INEEL.
It was during the second briefing that the Tribes submitted a request for the 30-day extension of the
comment period.
Copies of the proposed plan were mailed to 6,700 members of the public on the INEEL Community
Relations Plan mailing list on March 7, 1997, urging citizens to comment on the proposed plan and to
attend public meetings. Display advertisements announcing the same information concerning the
availability of the proposed plan and the locations of public meetings, and the comment period extension,
appeared in six regional newspapers during the weeks of March 9, 16, and 23 in Idaho Falls. Boise,
Moscow, Fort Hall, Pocatello, and Twin Falls. Large display advertisements appeared in the following
newspapers: the Post Register (Idaho Falls); the Sho-Ban News (Fort Hall); the Idaho State Journal
(Pocatello); the Times News (Twin Falls); the Idaho Statesman (Boise); and the Daily News (Moscow).
The update fact sheet was mailed on March 21, 1997. to about 6.700 members of the public on the
INEEL Community Relations Plan mailing list to encourage them to attend the public meetings and to
provide verbal or written comments. Notice was provided in the fact sheet and on its back cover,
explaining that the comment period had been extended to May 9, ll>97. A scries of three news releases
and newspaper advertisements, including the notice of the extension of the comment period, provided
public notice of these public involvement activities. Offerings for briefings and the 30-day public
comment period (including the 30-day extension of the comment period) that was to begin March 10 and
end May 9. 1997. were also announced. Personal calls were made to stakeholders in the Idaho Falls.
Pocatello. Ketchum. Boise, and Moscow areas the weeks of March 10. 17. and 24 to remind individuals
about (he meetings and to see it a briefing was desired.
Written comment forms available at the meeting locations (including a postage-paid business-reply
formi were available to those attending the public meetings. The forms were used to submit written
comments either at the meeting or bv mail. The reverse side o1 the meeting agenda contained a form for
the public u> use in evaluating the effectiveness of the meetings. A court reporter was present at each
meeting lo keep transcripts of discussions and public comments. The meeting transcripts were placed in
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the Administrative Record section for the WAG 2. TRA. OU 2-13 in five INEEL Information
Repositories. For those who could not attend the public meetings, but wanted to make formal written
comments, a postage-paid written comment form was attached to the proposed plan.
A Responsiveness Summary has been prepared as part of the ROD. All formal verbal comments
presented at the public meetings and all written comments are included in Appendix A and in the
Administrative Record for the ROD. Those comments are annotated to indicate which response in the
Responsiveness Sijmmary addresses each comment.
A total of about 20 people not associated with the project attended the public meetings. Overall.
twenty citizens provided formal comments; of these, six citizens provided verbal comments, and fourteen
provided written comments. All comments received on the proposed plan were considered during the
development of this ROD. The decision for this action is based on the information in the Administrative
Record for these OUs.
On March 19, 1997, project managers from DOE-ID gave a brief presentation on the projects to the
INEEL Environmental Management Site-Specific Advisory Board. The advisory board is a group of
15 individuals, representing the citizens of Idaho, who make recommendations to DOE, EPA. and the State
of Idaho regarding environmental restoration activities at the INEEL.
3-3
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4. SCOPE AND ROLE OF OPERABLE UNITS
AND RESPONSE ACTIONS
The primary source of contamination at WAG 2 is past discharges and releases associated with the
TRA warm waste system. For example, radiologically contaminated wastewater was discharged to the
Warm Waste Pond. Discharges to the Warm Waste Pond caused contamination of the sediments in the
cells of the unit. The Warm Waste Pond was taken out of service and an interim remedial action has been
completed (OU 2-10). Infiltration of water from the cells caused the migration of contaminants to the TRA
Deep Perched Water System, and ultimately to the SRPA beneath TRA. A ROD has been signed for the
Perched Water System (OU 2-12), and post-ROD monitoring is in progress. Windblown contamination,
spread principally from the Warm Waste Pond, is the suspected source of contaminations at the Sewage
Leach Pond Berm and Soil Contamination Area. In addition, minor areas of contamination are associated
with waste lines and storage tanks in the warm waste system. The tanks in OU 2-05 are, or were, pan of
the warm waste system, and they have associated releases of contamination (TRA-15 and TRA-19).
Radiological contamination at the Brass Cap Area is attributed to leaks from the warm waste lines. Waste
Area Group 2 also includes sites that have been contaminated as a result of other operational processes
such as the Chemical Waste Pond, Sewage Leach Pond, and Cold Waste Pond. Contaminated sediments
remain in these unlined disposal ponds.
The TRA is designated as WAG 2 at the INEEL. Each of these OUs contains a number of
contaminant release sites. A total of 13 OUs were investigated under a comprehensive RI/FS to evaluate
contamination of environmental pathways (soil, air, and groundwater) and the potential risks to human
health and the environment from exposure to contaminated media. Each site has been evaluated
comprehensively in relation to the other sites to determine the overall risk posed to human health and the
environment. A total of 55 known or suspected contaminant release sites were identified. In order to
satisfy the broader objective of INEEL comprehensive risk assessments, an analysis of risk produced
through the air and groundwater exposure pathways is evaluated in a cumulative manner. A cumulative
analysis of these two exposure pathways involves calculating one WAG-wide risk number for each
contaminant of potential concern (COPC) in each air and groundwater exposure route. Analyzing the air
and groundwater pathways in a cumulative manner is necessary because contaminations from all release
sites within a WAG are typically isolated from one another with respect to the soil pathway exposure
routes. Therefore, the soil pathway exposure route is analyzed on a release site specific or
"noncumulative" basis in the INEEL comprehensive risk assessments. Monitoring data, process
knowledge, written correspondence, interviews with current and previous employees, previous agency
investigations and decisions, and site characterization data were used to determine the nature and extent of
contamination at each site and to evaluate potential risks to human health and the environment. Eight of
the 55 sites were found to pose risks to human health that exceed acceptable risk levels and were therefore
evaluated for remedial action. The screening, development, and detailed analysis of remedial alternatives
resulted in the selection of preferred alternatives for each of the eight sites. These alternatives met the
goals established for reducing or eliminating risks to human health and the environment and for complying
with applicable or relevant and appropriate requirements (ARARs).
In addition to the eight sites that require some type of remedial action, this comprehensive ROD also
addresses 47 sites that do not pose an unacceptable risk to human health or the environment, based on
evidence compiled durin«: the comprehensive RI/FS. These >iies are being recommended for No Action
.ind. uiih approval of this ROD. the No Action decision is formal i/ed. Table 4-1 contains a complete
listing nt the sites at WAG 2: Section 5.2.5 provides a description of the proposed No Action sites.
4-1
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Table 4-1. List of WAG 2 sites.
Operable
Unit
None
Site
Number
TRA-IO
TRA-23
TRA-24
TRA-25
TRA-26
TRA-27
TRA-28
TRA-29
TRA-32
TRA-33
Site Name
TRA MTR Construction Excavation Pile
TRA ETR Excavation Site Rubble Pile
TRA Guardhouse Construction Rubble Pile
TRA Sewer Plant Settling Pond Rubble Pile
TRA Rubble Site by U.S. Geological Survey Observation Well
TRA North Storage Area Rubble Pile
TRA North (Landfill) Rubble Site
TRA ATR Construction Rubble
TRA West Road Rubble Pile
TRA West Staging Area/Drainage Ditch Rubble Site
OU 2-01
OU 2-02
OU 2-03
Of 2-04
TRA-02
TRA-14
TRA-17
TRA-18
TRA-21
TRA-22
None
TRA-01
TRA-11
TRA-12
TRA-20
TRA-40
None
None
None
None
None
None
TRA-09
TRA-34
TRA Paint Shop Ditch (TRA-606)
TRA Inactive Gasoline Tank at TRA-605
TRA Inactive Gasoline Tank at TRA-616
TRA Inactive Gasoline Tank at TRA-619
TRA Inactive Tank, North Side of MTR-643
TRA Inactive Diesel Fuel Tank at ETR-648
TRA-614 Oil Storage North
TRA Acid Spill Disposal Pit
TRA French Drain at TRA-645
TRA Fuel Oil Tank Spill (TRA-727B)
TRA Brine Tank (TRA-731) at TRA-631
TRA Tunnel French Drain (TRA-731)
TRA PCB Spill at TRA-619
TRA PCB Spill at TRA-626
TRA-627 No. .5 Oil Spill
TRA PCB Spill at TRA-653
TRA-670 Petroleum Product Spill
TRA PW 13 Diesel Fuel Contamination
TRA Spills at TRA Loading Dock (TRA-722)
TRA North Storase Area
4-2
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Table 4-1. (continued).
Operable
Unit
Site
Number
Site
Name
OU 2-05
OU 2-06
OU 2-07
OU 2-08
OU 2-09
OU2-IO
OL'2-11
OU2-I2
OL'2-13
None
TRA-15
TRA-16
TRA-19
TRA-30
TRA-31
TRA-35
None
TRA-36
TRA-38
TRA-39
TRA-37
TRA-07
TRA-08
TRA-13
TRA-03B
TRA-03A
TRA-04
TRA-05
None
TRA-06
TRA-41
TRA-42
None
None
None
TRA-603/605 Tank
TRA Hot Waste Tanks Nos. 2. 3, and 4 at TRA-613
TRA Inactive Radioactive Contaminated Tank at TRA-614
TRA Radioactive Tanks 1 and 4 at TRA-630, replaced by
Tanks 1,2, 3, and 4
TRA Beta Building Rubble Site
TRA West Rubble Site
TRA Rubble Site East of West Road near Beta Building Rubble
Pile
TRA-653 Chromium-Contaminated Soil
TRA ETR Cooling Tower Basin (TRA-751)
TRA ATR Cooling Tower (TRA-771)
TRA MTR Cooling Tower North of TRA-607
TRA MTR Canal in basement of TRA-603
TRA Sewage Treatment Plant (TRA-624) and Sludge Pit
(TRA-07)
TRA Cold Waste Disposal Pond (TRA-702)
TRA Final Sewage Leach Ponds (2) by TRA-732, including
SLP-Berm and Soil Contamination Area
TRA Warm Waste Pond (sediments)
TRA Warm Waste Leach Pond (TRA-758)
TRA Warm Waste Retention Basin (TRA-712)
TRA Waste Disposal Well, Sampling Pit (764) and Sump (703)
Perched Water Rl/FS
WAG 2 Comprehensive RI/FS including:
TRA Chemical Waste Pond (TRA-701)
French Drain Site
Diesel Unloading Pit
Brass Cap Area
Hot Tree Site
ETR Stack Area
4-3
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5. SUMMARY OF SITE CHARACTERISTICS
5.1 Physiography, Geology, and Hydrology
The ENEEL is located on the northeastern portion of the Eastern Snake River Plain, a volcanic
plateau that is composed primarily of silicic and basaltic volcanic rocks and relatively minor amounts of
sediment. Underlying the INEEL is a series of basaltic flows with sedimentary rock interbeds. The basalts
beneath the TRA are relatively flat and are covered by 30 to 75 ft (9 to 23 m) of alluvial materials and
loess. The alluvial materials are composed primarily of well to poorly graded gravel and contain minor
amounts of fine-grained materials.
The depth to the SRPA varies from 200 ft (61 m) in the northern portion to 900 ft (274 m) in the
southern portion of the INEEL. At TRA, the depth to the SRPA is approximately 450 ft (137 m).
Regional groundwater flow is to the southwest. Above the main aquifer, there are both shallow and deep
zones of perched water created by lenses of low permeability sediments (containing silts and clays) within
an interbedded basalt-sediment sequence overlying the primary basalt flows. These perched zones are
discontinuous and are found at varying depths throughout the TRA.
The climate of the INEEL region is characterized as semidesert with hot summers and cold winters.
Normal annual precipitation is 8.71 in. (22.1 cm). The only natural sources of surface water present at the
INEEL are Birch Creek, the Little Lost River, and the Big Lost River, which is approximately I mi
(1.6 km) southeast of the TRA. However, the Big Lost River is typically dry because of the arid climate
and high infiltration rates of the alluvium. The only other natural source of surface water at the TRA is
occasional heavy precipitation, which results in surface water runoff in natural drainage areas, usually
during the period of January through April of each year.
Fifteen distinctive vegetative cover types have been identified at the INEEL, with sagebrush being
the dominant species. There are five vegetation types surrounding the TRA: sagebrush-steppe on lava,
sagebrush/rabbitbrush, grassland, playa-bareground/disturbed, and juniper. The variety of habitats on the
INEEL supports numerous species of reptiles, birds, and mammals. Several bird species warrant special
concern because of their threatened status or sensitivity to disturbance. These species include the
ferruginous hawk (Buteo regalis), bald eagle (Haliaeetus leucocephalus), prairie falcon (Falco mexicanus),
merlin (Falco columbarius), long-billed curlew (Numenius americanus), and the burrowing owl (Athlene
cunicularia). The ringneck snake, whose occurrence is considered to be INEEL-wide, is listed by the
Idaho Department of Fish and Game as a Category C sensitive species. It should be noted, however, that
the TRA is a highly disturbed industrial area with almost continuous human activity that contains little
suitable habitat for most of these species. No areas of critical habitat, as defined in 40 Code of Federal
Regulations (CFR) Part 300. are known to exist in or around the TRA.
The TRA is located in (he south-central portion of the INEEL. The land surface at TRA is relatively
flat, with elevations ranging from 4,945 ft (1.507 m) on top of a rubble pile near the Cold Waste Pond to
4.908 ft (1.496 m) at the bottom of the Chemical Waste Pond. Generally, the land surface gently slopes
from the west-southwest corner |4,930 ft (1,503 m)l to the east-northeast corner |4,915 ft (1,498 m)|.
Much of the INEF.L's surface is covered by Pleistocene and Holocene basalt Hows. The second most
prominent geologic feature is the Hood plain ol'ihc Big Lost River. Alluvial sediments ol Quaternary age
occur in a hand ihat extends across the INEEL from the southwest to the northeast. The alluvial deposits
5-1
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grade into lacustrine deposits in the northern portion of the INEEL. where the Big Lost River enters a
series of playa lakes. Paleozoic sedimentary rocks make up a very small area of the INEEL along the
northwest boundary. Three large silicic domes and a number of smaller basalt cinder cones occur on the
INEEL and along the southern boundary.
A complex sequence of basalt flows and sedimentary interbeds underlie TRA. From basalt flow
samples collected, peirographically similar basalt flows were correlated into 23 flow groups that erupted
from related source areas. Known source vents occur to the southwest, along what is referred to as the
Arco volcanic rift zone, to the southeast along the axial volcanic zone, and to the north at Atomic Energy
Commission Butte. Surficial material at TRA consists of alluvial and terrace deposits of the Big Lost
River and is composed of unconsolidated fluvial deposits of silt. sand, and pebble-sized gravel. The
uneven alluvial thickness and undulating basalt surface at TRA are common of basalt flow morphology.
The basalt flows that underlie the surficial alluvium are separated by sedimentary interbeds that vary in
thickness and lateral extent.
The TRA is located on the alluvial plain of the Big Lost River. The thickness of surtlcial sediment in
the vicinity of TRA ranges from 30 to 75 ft (9 to 23 m) and is greatest south of the facility. The surficial
sediments at TRA are primarily composed of well to pooriy graded gravel and contain minor amounts of
fine-grained materials. Most of the soil textures are sandy loams and the primary soil type is mapped as
Bannock sandy loam. The TRA is not located in a 100-year flood plain. An extensive flood control
system has been built at the INEEL that uses a diversion gate and a series of spreading areas to control
high flows from the Big Lost River, which typically occur in the late spring or early summer.
An area north of TRA where surface runoff accumulates contains some damp areas with sedges and
wetland grasses; however, the area is not mapped by the INEEL wetland inventory. It is not expected that
any remedial activities would impact these potentially sensitive areas.
The area surrounding TRA has been surveyed in the past, and no sites of archaeological or historical
value were found. All potential remedial areas within the fenced area of TRA are considered disturbed
areas that do not contain material of archaeological or historic significance. Therefore, the regulatory
requirements associated with the preservation of antiquities and archaeological materials/sites are not a
concern.
The TRA is not known to be located within a critical habitat of an endangered or threatened species.
including bald and golden eagles, nor are such species known to frequent the TRA proximity. However,
bald eagles, golden eagles, and American perigrin falcons have been observed at the INEEL. In addition.
eight species of concern to the Idaho Department of Fish and Game and Bureau of Land Management have
been obserxed at the INEEL. Remedial activities at WAG 2 are not expected to affect any endangered
species because activities are anticipated to be conducted entirely in previously disturbed areas, and limited
in both duration and affected area.
No fish or wildlife addressed by the Threatened Fish and Wildlife Act are found at WAG 2. nor do
the planned activities at WAG 2 involve the modification of a stream because no streams arc located on the
silo. Occasionally, migratory waterfowl are observed at WAG 2. However, the area contains no critical
habitat, and remedial acti\ it\ docs not appear to lia\c a potent! 'I for adverse impacts to migratory
waterfowl.
-------
Several sites located within the WAG 2 area have been deemed potentially eligible for the National
Register of Historic Places by the Idaho State Historical Society. The sites include the MTR, the ETR, and
the ATR. These sites must be accorded the same protection under the National Historic Preservation Act
as if they were listed sites under the Act. Remedial activities within WAG 2 are not expected to adversely
affect the sites; however, should future planning identify activities that would potentially impact the sites,
proper mitigative measures would be identified through discussion with the Idaho State Historical
Preservation Office.
The SRPA occurs approximately 450 ft (137 m) below TRA and consists of a series of saturated
basalt flows and interlayered pyroclastic and sedimentary materials. The EPA designated the SRPA as a
sole-source aquifer under the Safe Drinking Water Act on October 7. 1991. The aquifer is relatively
permeable because of the presence of fractures, fissures, and voids such as lava tubes in the basalt.
Groundwater flow in the SRPA is to the south-southwest at rates between 5 and 20 ft (1.5 and 6 m) per
day.
Two perched water zones have been recognized below TRA. In the vicinity of the ponds and
retention basin, a shallow perched water zone is formed at a depth of approximately 50 ft (15.2 m). Finer
grained sediments and fracture infilling at the alluvium and basalt interface areas impede the downward
movement of water, resulting in perched conditions. The shallow perched water eventually percolates
through the underlying basalt to a deeper perched water zone. The deep perched water is also caused by
low-permeability sediments within the interbedded basalt-sediment sequence and occurs at a depth of
approximately 140 to 200 ft (43 to 61 m). These sediments include silt, clay, cinders, and gravel and
appear to be laterally continuous in the vicinity of TRA. The shallow and deep perched waters are two
separate zones, with the possible exception of the area of the ponds where they may become one zone
depending on the volume of wastewater discharge to the ponds. The perched water bodies are present
because approximately 200 million gal (757 million L) per year of water have been sent to the TRA
disposal ponds over the past several decades. A major contributor to contamination in the perched water
bodies resulted from discharges to the old Warm Waste Pond. Low-level radioactive waste discharges
were discontinued on August 12, 1993, when the former Warm Waste Ponds were replaced with a lined
evaporation pond. The Cold Waste Pond currently receives an average of approximately 300 gal (1,135 L)
per minute of uncontaminated wastewater. There appears to be a strong correlation between hydraulic head
patterns in the Perched Water System and the discharge rates to the Cold Waste Pond, In addition,
discharges to the Chemical Waste Pond, an unlined surface impoundment designed as an infiltration pond
to receive chemical waste from the demineralization plant, average approximately 15 gal (57 L) per
minute.
Waste Area Group 2 encompasses approximately 74 acres (30 hectares), with the majority of the
acreage associated with extensive facilities consisting of buildings, graveled parking areas, roads, and
cleared fence lines. Surrounding the TRA, however, are several pond areas that were used for the
conveyance and discharge of wastewater from facility operations as shown in Figure 1-2. These ponds
contain a variety of potentially hazardous contaminants with the primary contaminants being radionuclides.
After several of the ponds were removed from service, exposed sediments were subjected to winds
resulting in the surrounding surficial soils being contaminated with low levels of radionuclides. An
interim cleanup action occurred at the former warm waste disposal pond.
In addition lo the disposal ponds and associated windblown contamination, several other tvpes of
potentially contaminated MICN were identified at the TRA. These sites include: rubble piles, a paint shop
-------
ditch, petroleum tanks, u disposal pit. french drains, brine tank, petroleum and polychlorinated biphenyl
(PCB) spills, radiological tanks, cooling towers, a reactor canal, sewage treatment facility, a retention
basin, disposal well, and a sampling pit and sump. Possible contaminants consist of organic compounds
including petroleum hydrocarbons and PCBs, acids, bases, heavy metals, and radionuclides.
5.2 Nature and Extent of Contamination
The following sections describe the nature and extent of contamination at the eight sites that have
been determined to pose an unacceptable risk to human health or the environment. These eight sites within
TRA have actual or threatened releases of hazardous substances, which, if not addressed by implementing
the response actions selected in this ROD. may present an imminent and substantial endangerment to
public health, welfare, or the environment.
5.2.1 Disposal Pond Sites
5.2.1.1 Warm Waste Pond (TRA-03). The source of contamination in sediments of the three
cells 11952, 1957, and 1964, (Figure 5-1)] was low-level radionuclide contaminated wastewater discharged
to the three cells from TRA reactor operations. The wastewater included cooling tower effluent.
wastewater from hot cell drains, laboratory solutions, and floor drainage from the ATR and other test
reactors. The resulting contamination consisted primarily of radionuclide-contaminated sediments in the
pond bottoms and sidewalls to depths of approximately 2 ft (0.6 m). The primary contaminants of concern
(COCs) are Cs-l37, cobalt (Co)-60, and chromium (Cr). Concentrations of Cs-l37 range from 2.9 to
39,400 pCi/g and of Co-60 range from 0.2 to 27,100 pCi/g. Concentrations of chromium in the sediments
ranged from 0 to 222 mg/kg. Data indicate that both chromium and radionuclides were strongly adsorbed
into the surficial sediments and that soil contamination generally did not extend beyond a depth of 2 ft
(0.6 m) below the base of each cell.
In 1993, the Warm Waste Pond was replaced by a lined evaporation pond. An interim remedial
action was subsequently conducted to provide immediate risk reduction by removing approximately 4 ft
(1.2 m) of sediment from the sidewall and 3 ft (0.9 m) of sediment from the base of the 1964 cell and
placing of these excavated materials into the 1952 cell. Previously stockpiled materials from cleanup of
Warm Waste Pond windblown contamination was also placed in the 1952 cell. The 1964 cell was then
backfilled with approximately 10 ft (3 m) of clean soil, and the 1952 cell was covered with a 1.0-ft
i(l.3 1 -mi la\er of clean till and then revegelated. The balance of the stockpiled material was distributed on
the sidewalls of the 1957 cell as shielding. The 1957 cell sidewull sediment was then scraped into the base
of the 1957 cell followed by disposal of materials from a demolished contaminated wooden structure. The
1957 cell was then covered with a 0.5-ft (0.1 5-m) layer of clean fill. The 1957 cell was not capped
because appropriate fill material was being identified and evaluated. In 1995 and 1996, material from OU
10-06 removal actions was also placed in the 1957 cell, including soil contaminated with Cs-137 from the
Argonne National Laboratory stockpile, soil contaminated with Cs-137 from the Boiling Water Reactor
Hxperimeiu. soil contaminated with Cs-137 from the H.xperimentul Breeder Reactor, soil contaminated
with several radionuclides including strontium (Sr)-90. europium (Hin-1 52. amcricium (Am)-241. Cs-1 37.
lui-154. and Co-60 from the TRA North Storage Area, soil contaminated with Cs-137 and Sr-90 from Test
Area North Area B. and soil contaminated with Cs-137 and Sr-9O from the Technical Support Facility.
. (1.5 ll (0.15 in) of clean fill was placed over these materials. This soil uas analyzed for
poUchlorinated bipheinls iPCBsi; however, none were detected. The maximum detection limit of the data
sei was 0.220 ppm. The agencies have determined that these soils need not ho managed as PCB-
5-4
-------
Legend
Buildings
| Original 1952 Cell
(Original 1957 Cell
(Original 1964 Cell
1952
1957
N
1964
,
100 200 300 Feet
RED K970042
Figure 5-1. Warm Waste Pond (TRA-03) location.
-------
contaminated soil since the residual PCB levels are below the Office of Solid Waste and Emergency
Response directive guidance level of 25 ppm at Superfund Sites.
Additionally, recent investigations have determined that RCRA-listed waste may have been present
in the TRA Warm Waste System when discharges from the warm waste system to the pond occurred. Soil
placed in the warm waste pond from Test Area North may be contaminated with RCRA-listed waste.
Information regarding releases of RCRA-listed waste can be found in the "RCRA-listed Waste
Determination Report for the INEEL Test Reactor Area. October 30,1997," which has been placed in the
Administrative Record. Pages 3-21 through 3-23 of the OU 2-13 comprehensive RI/FS report provide
more detailed information on the COC concentrations and volumes of soil consolidated in the OU 2-10
Warm Waste Pond.
5.2.1.2 Chemical Waste Pond (TRA-06). The Chemical Waste Pond was excavated and put
into operation in 1962 as an unlined infiltration pond designed to receive chemical waste from a
demineralization plant at the TRA. The pond currently receives effluent containing mineral salts, with
average discharge to the pond being 15 gal (57 L) per minute. In addition, until 1982, solid and liquid
wastes were disposed directly into the pond from a support structure .constructed for waste disposal. This
disposal included corrosives and other waste. A tank containing battery acid from the vehicle storage
facility at the Central Facilities Area was drained into the Chemical Waste Pond in 1992. Possible
disposals into the pond, including pesticides, solvents, PCBs, methylene chloride, and biocides, are
suspected, but not documented. However, the Track I document for this site indicates that these reports
are unsubstantiated. Samples collected from the pond in 1990 (Figure 5-2) were analyzed for metals
known to be associated with the demineralization process (i.e., silver, arsenic, barium, cadmium,
chromium, copper, mercury, nickel, selenium, and zinc), volatile organic compounds (VOCs), semivolatile
organic compounds (SVOCs), and PCBs. The sample results indicate that only barium and mercury
exceed background levels presented in the OU 10-06 soil background document. The Chemical Waste
Pond is identified in the FFA/CO as a land disposal unit. Application materials for a wastewater land
application permit were submitted to the State of Idaho for review in late January 1997.
Maximum total concentrations of the metals were 3,830 mg/kg for barium and 133 mg/kg for
mercury in an area where standing water occurs within the pond. The two metals have the highest
concentrations in surface sediments, with concentrations decreasing with depth to background
concentrations from 10 to 16 ft (3 to 5 m) below the surface. In the 1990 sampling event, PCBs were
detected in 20 surface samples, with a maximum concentration of 0.33 mg/kg. they were not detected in
subsurface samples. Volatile organic compounds and SVOC concentrations were either undetectable or
below regulatory concern.
The most recent release of ha/ardous materials occurred in May and June 1995. when approximately
2X7,100 gal (1.068.788 L) of liquid used to neutralize and flush out-of-ser\icc acid and caustic tanks were
disposed to the pond. Alter disposal it was determined that the liquids contained 0.3 ppm of mercury.
which exceeds the toxicity characteristic leaching procedure (TCLP) limit of 0.2 ppm for D009 mercury
ha/ardous waste. The total mass of mercury contained in the Chemical Pond from all past disposal
operations is estimated to be approximately 8.0H+07 ing. The mercury contribution from the 1995 release
is relatively small and is not expected to increase human health or ecological risk at the site.
-------
L~~3
Legend
Roads and Buildings
Fences
Approximate Sample Locations
Gravel/Main Pond
Precipitate/Main Pond
Gravel Fan
Drainpipe Outlet
Truck Ramp
N
Notes:
Metal data are reported in mg/kg.
The PCB (Aroclor-1260) data are reported in u.g/l<9
I Analyte Max. Avg.
PCBs 57
As 5.3 3.1
Ba 1920 794
Cd 0.8 0.7
Cr 41.4 15.0
Co 3.6 2.7
Cu 6.9 2.6
Pb 28.7 14.9
Hg 30 12
Ni 18.6 10.4
Sr 171 73
:Zn 33.4 11.0
Analyte Max. Avg.
\
PCBs 330 -
Ba 3830 2292
Cr 17.8 14.8
Cu 2.5 2.1
Pb 33.2 23.3
Hg 86.7 53.0
Ni 11.2 8.5
Sr 186 125
Zn 7.8 5.0
\
i
\ ..
(.
1
\
Drai
\
ipipe
\
\
\
-------
5.2.1.3 Cold Waste Pond (TRA-08). The Cold Waste Pond has been continually managed as a
disposal site for nonradiologically contaminated wastewater since its construction in 1982. The pond
consists of two cells, which are used for cold waste disposal, primarily from cooling tower effluent and
from air conditioning units, secondary system drains, floor drains, and other nonradioactive drains
throughout TRA. Historically, only one of the two cells is used at a time, and flow of wastewater is
alternated from one cell to another on an annual basis. Wastewater that is discharged into the Cold Waste
Pond percolates through the soil to form the perched water zones beneath TRA. Effluent routed to the
pond has been monitored for metals, organic compounds, and radionuclides since 1986. Soil samples were
collected from the bottom of the two cells in 1990 (Figure 5-3) and analyzed for gamma-emitting
radioisotopes. TCLP metals, and VOCs. Radionuclides, including Co-60. Cs-134, Cs-137. and Eu-154.
were detected at concentrations slightly above INEEL background levels in several samples. These low
levels of radionuclides were found in samples collected from the pond berms and are thought to be the
result of windblown soil contamination from the Warm Waste Pond rather than from effluents discharged
to the Cold Waste Pond. Low levels of VOCs (carbon tetrachloride. tetrachloroethylene, tetrahydrofuran.
l.l.l-trichloroethane, and xylene) and metals (arsenic, barium, cadmium, chromium, copper, lead,
mercury, selenium, and silver) were also detected in the pond sediments.
In addition, in May 1996. sediment samples were collected from the Cold Waste Pond.
Radionuclides. including Co-60, Cs-137. and Am-241, were detected at background or slightly above
background concentrations. The results of this sampling effort can be found in the Administrative Record
under the OU 2-13 Comprehensive RI/FS. Currently, a wastewater land application permit was submitted
to the State of Idaho for review and approval in late January 1997.
5.2.1.4 Sewage Leach Pond (TRA-13). The Sewage Leach Pond is located outside the TRA
facility fence and consists of two cells where effluent was discharged from sanitary sewer drains
throughout TRA. The first cell (southern) was constructed in 1950 and the second (northern) in 1965.
The system was routinely monitored by the Environmental Monitoring Unit beginning in 1986. Process
knowledge indicates that effluent is limited to sewage. However, low-level gamma-emitting radionuclides
were detected in the bottom of the 1950 cell, and alpha and gamma-emitting radionuclides were detected in
a sludge pit located south of the Sewage Treatment Plant. The source of the contamination has been
attributed to windblown sediments from the Warm Waste Pond. After a preliminary investigation,
DOE-ID recommended that the bottom of the pond be backfilled when it was removed from service.
IDH W and EPA concurred. Construction of a new sewage treatment facility, including a lined evaporation
pond, was completed in December 1995, and the former Sewage Leach Pond and Sewage Treatment Plant
were removed from service.
5.2.2 Subsurface Release Sites
Recent investigations have determined that RCRA-listed waste may have been present in the TRA
warm and hot waste systems when leaks from the systems to the environment occurred. Therefore, soils at
those sites associated with releases from the warm waste system or hot waste system will be managed in a
manner consistent uiih (he ha/.ardous waste determination to be performed at the time of the remedial
action.
5-S
-------
Legend
Roads and Buildings
Fences
Approximate Sample Locations
Co-60
Cs-134
Cs-137
Eu-154
0.84
0.39
23.7
0.60
Notes:
Because samples exceeded laboratory
holding times, organic compound
concentrations are biased low.
Because samples were ?xtracted by TCLP prior
to metals' analyses, the data are reported in
mg/L.
Five subsamples from each cell of the CWP were
composited prior to 7 analyses.
The radionuclide data are reported in pCi/g.
CCI4 = carbon tetrachlonde
PCE = letrachloroethene
TCA = 1.1.1 trichloroethane
'Ba
0.49
.TCA 380
'PCE 7 I
; CCI4 6 I
Xylenes 20 j
i Co-60 ! 0.97 .
Cs-134 0.066;
Cs-137: 6.3 I
50 100
150
200 Feet
BED K97 0038
Figure 5-3. Cold Waste Pond (TRA-08) showing 1990 soil sample location, organic compound and
metal data, and composite gamma data.
5-9
-------
5.2.2.1 Soil Surrounding Hot Waste Tanks at Building TRA-613 (TRA-15). The TRA-15
site is the location of underground Tanks I and 2 that leaked radiologically contaminated and possibly
hazardous waste to surrounding soil. Four underground tanks are located at this site. Leaks from Tank I
were determined to be the source of subsurface contamination identified in the 1993-1994 time frame.
Four borings were drilled from the surface to basalt to depths of 30 to 31 ft (-9.5 m), as shown in
Figure 5-4. Samples collected from these borings show soil is contaminated with Sr-90 and Cs-l37 at or
below a depth of 20 ft (6 m). Surface spills and leaks were also reported, but a surface soil contamination
assessment conducted in 1994 showed that only low levels of Cs-l37 to a maximum of 8.3 pCi/g were
detected. However, surface samples collected in 1993 from borehole No. 3 showed Cs-l37 concentrations
as high as 33 pCi/gm.
Lead was detected in all the samples and ranged from 4.9 to 225 mg/kg. Chromium was detected
from 4.45 to 31 mg/kg, and arsenic was detected from 2.1 to 10 mg/kg. Sampling results indicate that
volatile and semivolatile constituents were not detected at the site.
5.2.2.2 Soil Surrounding Tanks 1 and 2 at Building TRA-630 (TRA-19). The TRA-19 site
(Figure 5-5) consists of subsurface soil contamination suspected of resulting from leaks from the
radiologically contaminated waste drain line that originates at the Gamma Facility Building (TRA-641) or
from possible releases from four underground catch tanks associated with the MTR. The original four
catch tanks from the MTR were contained in a concrete vault. The tanks and vault were removed and
replaced with new ones in 1985 and 1986. The original tanks were found to be intact upon removal and
although the outside surface appeared to be degrading, the fiberglass liners had not been breached.
Therefore, no releases from the tanks were suspected. Several spills inside the vault, however, had been
reported as a result of pipe-cutting operations during tank removal, from reconnecting pipelines to the new
tanks, and from a damaged waste drain line from Building TRA-641, but nothing was released to the soil
that remained after the tank upgrade. Recently it has been determined that hazardous waste has been and
are being contained in the hot waste catch tanks near the TRA-19 release site. This raises the concern
regarding whether releases associated with the hot waste system (i.e., TRA-I9, TRA-I5. and the Brass Cap
Site) were appropriately characterized given the probability of nonradionuclide hazardous constituents
having been released and only radionuclide sampling analysis performed. To address this issue, the
agencies agreed that TRA-15 could serve as a corollary for release sites associated with the Hot Waste
System because more complete characterization was performed at TRA-15 (radionuclides, metals, volatile.
and semivolatile organic compounds). However, the data collected would not be sufficient to fully support
a ha/ardous waste determination at TRA-15. TRA-19. and Brass Cap Area given the present knowledge of
other listed ha/ardous wastes that were not sampled/analyzed as pan of the general investigation at
TRA-15. Therefore, a hazardous waste determination will need to be'completed when excavation and
disposal occur and the soil managed accordingly.
Limited sampling conducted at TRA-19. information from field screening data collected during tank
removal, and information from Health Physics Technician logs indicate that COCs in soil resulting from
pipeline leaks are likely to include Co-dO. Cs-l 34. Cs-1 37. and Sr-90. The contamination is suspected to
he the result of a leak from the radiologically contaminated waste drain line thai originates at the Gamma
Facility Building
-------
Legend
Roads and Buildings
Fences
Approximate Sample Locations
Approximate Tank Locations
N
Notes:
The radionuclide data are recorded in pCi/g.
Metal data are recorded in mg/kg.
The average and maximum data include surface data
Drilling in BH-2 was refused at 20 ft: therefore.
BH-2A was drilled.
BH-3 surface samples were collected from 0 - 0.5 ft.
French Drain
: Radionuclide Avg. Max.
Billf sh Ave.
a
.0
Co-60
Cs-137
Sr-90
i U-234
I U-238
21
1587
0.2
22
.
583
0.8
40 : NX
6640 i \^
0.3
50
0.3
N
2000 .^
1.11 ^
f !
I Metal
As
Ba
Cd
Cr
Co
Cu
Pb
Ni
Zn
Avg.
3
99
1
16
5
14
37
17
52
Radionuclide Surface Avg
« 24
3 67
Am-241
i 22
30
. ..
I Co-60 : 0.9 0.5
i Cs-137 i 33
5
: Sr-90 i 7.8 . --
U-234 0.9 1
Max.
4.1
131
1.3
22.1
7.2
17
225
21.2
5
/
/,
/
98.8 / ,
Max.
/
28 >
67 :
0.2 i
0.9 '
. 33 : >
I 7.8 j
^BH-2 W-J^M *""""
N^l!~713>
/"? 'l_ji
Sjlfylafc"; !
j*i j 'i j '
BH-2A'^H:^""
' / i
/
/
' /
/
1
K
'/
/
1
1
\
~-'
i
1
! 1.1 | *
. f
\
\
^_
\ ' x\
*
* *-'
706
>
.
\
\
\
Metal
;As
.Ba
;Cd
'Cr
Cu
Ni
Zn
Surface
3.1
129
1 14.9
16.1
14.6
50.7
Avg.
4
121
15
15
. 17
49
Max. i
s :
<212 '.
; 1.4
; 19.1
18.9
i 21.21
66.1
20
j Radionuclide Avg. Max. :
ia
f3
21
1587
Am-241 i 0.2
40
6640
0.3
Co-60 ; 22 50 '
Cs-134 - - : 0.3
'Cs-137
iEu-154
\
Pu-238
P-239/240
Sr-90
U-234
U-23B
583 , 2000
0.8
0.2
0.3
1245
1
1
1.1
0.3
0.4
2280
1.4
1.3
Metal
As
Ba
Cd
Cr
Co
Cu
Pb
Ni
^Zn
Avg.
5
132
1
18
6
13
8
18
47
Max.
10
241
1.5 i
31 !
7.8
16.6
12.2
22
55.1
40
60
80 Feet
REDK970040
Figure 5-4. Hot Waste Tanks at Building 613 (TRA-I.V) showing 1993 soil boring locations and soil
sample data.
5-1 I
-------
Legend
Roads and Buildings
== Underground Hot Waste Line
"=» Underground Warm Waste Line
Approximate Underground Tank Locations
Q 1985 Surface Soil Sample Locations
and Brass Cap Area Marker
1985 Surface Soil Sample Locations
Notes:
One 2-inch hot waste line and six 2- to 4-inch warm
waste lines are buried within 5 feet of each other
south of 611/654 extending north to 603 and east of 630.
N
........
Sample*
1
2
3
4
5
Total"
1.300.000 0
54.0
26.000.0
190
3.3
4.000 0
Brass
Cap Area
20 40 60 80 100 Feet
RED vp? 0179
Figure 5-5. Radioactive Tanks at Hiiikiiny 6.>0 (TRA-I1)) and Brasx Cap Area showing IW -{ data in
5-12
-------
5.2.2.3 Brass Cap Area. The Brass Cap Area is located in the center of TRA, near building
TRA-630, and is southeast of site TRA-19 (see Figure 5-5). The contamination at this site is attributed to
leaking warm waste lines. Following discovery of the contamination, the leaking waste line was repaired
and contaminated soil associated with waste line repairs was removed. During removal of the
contaminated soil, water collected in the bottom of the excavation. Actions included removing the soil and
concrete in the area, identifying the leak, and repairing a pipeline elbow. The highest radiation levels were
present directly above the elbow in the wasteline. Following the repair, the excavation was backfilled with
clean soil and then resurfaced with concrete. The source of the water was determined to be a leaking warm
waste line, located 5 ft (1.5 m) south and 5 to 6 ft (1.5 to 1.8 m) below the level of the excavation. The
extent of migration of the radiological contamination under the concrete surface was characterized by
boring six 8-inch-diameter holes through the concrete, followed by measurements using field screening
instruments (intrinsic Germanium detector, multichannel analyzer, and tungsten collimator).
The extent of contamination in the excavation was determined by driving a hollow-pointed pipe into
the ground at the bottom of the excavation and measuring the radiation inside the pipe. This survey
indicated that the soil was contaminated to a depth of approximately 10 ft (3 m). Soil sample results from
the excavation indicated that the radionuclide contaminants consist primarily of Cs-137 and Cs-134, with
lesser amounts of Sr-90 and Co-60. Contaminant estimates at the Brass Cap Area are based on radiation
measurements rather than direct soil sampling results. It is not known whether chemical contaminants
exist at this site. Following the soil removal and leak repair, the excavation was backfilled with clean soil
and resurfaced with new concrete. A brass marker (hence, the name Brass Cap Area) was placed in the
concrete to designate the area of subsurface contamination.
5.2.3 Windblown Surficial Contamination Site
5.2.3.1 Sewage Leach Pond Berms and Soil Contamination Area. The soil
contamination area (Figure 5-6) is a fence-enclosed radiation control area on the north and south sides of
the Sewage Leach Pond. The fenced area is approximately 475 x 480 ft (145 x 147 m). Radiological
contamination on the south side of the southern berm (Figure 5-7) is attributed to Warm Waste Pond
sediments. However, radiological contamination on the north side of the southern berm may have resulted
from windblown Sewage Leach Pond sediments and/or the Warm Waste Pond windblown sediments.
A sampling investigation was conducted in the summer of 1994 to characterize the radionuclide
contamination in surface soil northeast and southwest of the Warm Waste Pond. Fifty samples were
collected along transects, which included the area adjacent to the Sewage Leach Pond. The most
frequently detected radionuclides were Cs-l37, Co-60. and Sr-90. Interim action at Warm Waste Pond in
1993 included excavation and consolidation of the contaminated pond sediments, which were then covered
with clean soil, thus eliminating the suspected source of the windblown surface soil contamination. During
this interim action, a front-end loader was used to remove contaminated surface soil with instrument
reading of over 100 counts per minute. No verification samples, however, were collected to confirm the
effectiveness of this contamination removal activity at that time.
In 1995. additional sampling was conducted to characterize the surface soil contamination near the
Sewage Leach Pond: this sampling confirmed a reduction in contamination. Surface soil samples were
randomly collected from 18 locations on the southern berm :nd from IS locations in 'he remainder of the
soil contamination area. Cesium-137 was detected in all samples collected on the southern berm and is the
C'OC that causes an unacceptable risk. Other isotopes detected in henn samples were Co-nO. Ag-IOXm.
5-13
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Legend
Roads and Buildings
Berm Boundaries
Depressions
Approximate Berm Ridgeline
Fences
Berm Soil Sample Locations
Notes:
All data are recorded in pCi/g.
Grid #253 was a duplicate sample
and analysis location.
Isotopes are identified in text.
N
ICs iCo |Ag
8.1
2.7 ,0.1
Sr
2.0i
Cs
J14.0
Co
5.3
Aq
0.2
Sr .
2.4,
.Cs
; 24.0
Co
10.2
ASL
Sr
0.511.1;
Cs ICo.|Ag|Sr
6'.9'[2~4iO.V9.0, ..-
50 100 150 200 Feel
«EO K970035
Figure 5-6. Senate Leach Pond soil contamination area showing lc>95 sampling locations and data.
5-14
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Legend
Roads and Buildings
- - Berm Boundaries
Depressions
Approximate Berm Ridgefine
.. , Fences
Berm Soil Sample Locations
Notes:
All data are recorded in pCi/g
Berm #7 was a duplicate sample
and analysis location.
Isotopes are identified in text.
Cs
8.5
Co
3.3
Ag
0.2
Sr
1.0
|Cs
29.0
Co
11.6
Ag
0.6
Sr j
4.9 1
Cs
10.8
Co
4.3
Ag
0.2
Sr :
3.3
Cs jCo
1 16.8|6.7
Ag
0.3
Sr
3.4.
50 100 150 200 Feel
Cs
'28.0
Co
9.1
Ag
0.4
Sr :
2.0 ;
Cs
i14.0
Co
6.7
Ag
0.3
Sr
0.9 i
Cs
23.0
24.3
Co
9.5
9.6
Ag
0.5
0.5
Sr
2.0
14.1'
;Cs
:'18.0
Co
8.0
Ag
0.3
Sr
5.9
:Cs |Co [Ag]Sr :
"25.0! 10.2
'Am
0.1
Cs
19.2
ColAq
7.3l 0.3
Sr|
1.3!
\
Cs
13.8
Cs
i'26
.4
Co
9.9
Co
5.3
Aq
[O3
Ag
0.5
Sr ,
4.7'
Sr '
1.8!
CslCo
Cs
13.7
Co
5.3
AqlSr
0.3i4.7-
11.5 14.6
[Co AglSf
[4.6|0.2|l'6
RED K970036
Figure 5-7. Sewage Leach Pond berms showing 1995 sampling locations and data.
5-1 5
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and Am-241. Also delected were the metals silver, barium, beryllium, cadmium, chromium, copper,
mercury, nickel, lead, and zinc. The SVOCs pyrene, fluoranthene, phthalates, chrysene.
benzo(b)fluoranlhene, and 4-chloroanaline were also present. All metals were detected at or below
background concentrations. All SVOCs were nondetectable.
Samples from the remainder of the area had the same radionuclide contaminants, but at lower levels
than found in the berm samples. The primary COCs are Co-60 and Cs-137. Levels of contamination,
however, are below the preliminary remediation goal concentrations for radionuclides.
5.2.4 Snake River Plain Aquifer and Deep Perched Water System
Infiltration of water from the pond system at TRA has caused contaminant migration to the SRPA. A
chromium plume with concentrations currently above maximum contaminant levels (100 ug/L) extends
both south and southwest of TRA. A tritium-contaminated plume with concentrations currently above
maximum contaminant level (MCLs) also exists, extending both south and southwest of TRA. Semiannual
monitoring of these plumes continues. Computer modeling was conducted to determine the predicted
contaminant levels in the future. Through radioactive decay (tritium), natural attenuation, and dispersion
processes, contaminant levels in the SRPA are expected to be reduced to less than MCLs (100 ug/L)
between the years 2004 and 2016. In order to evaluate the possibility of overlapping groundwater
contaminant plumes with other areas, contaminant source terms from the TRA modeling effort are
included in the OU 3-13 groundwater modeling effort at the Idaho Chemical Processing Plant.
The perched water zones underlying TRA are contaminated from infiltration of wastewaters from the
system of ponds. An investigation of the two perched zones (shallow and deep) was conducted. The ROD
for the TRA Perched Water System, OU 2-12, was issued in December 1992. It was determined in the
ROD that no remedial action was necessary to ensure protection of human health and the environment.
That decision was based on the results of human health and ecological risk assessments (ERAs). which
determined that conditions at the site pose no unacceptable risks to human health or the environment for
expected or future use of the SRPA beneath the deep perched water system at TRA. One of the
assumptions tor the no-remedial-action decision was that groundwater monitoring would be conducted to
verify that contaminant concentration trends follow those predicted by a groundwater computer model. It
was further stated that a statutory review of (his decision would be conducted by the agencies within
3 years to ensure that adequate protection of human health and the environment continues to be provided.
A technical memorandum was prepared in August 1996 that presents the 3 years of post-ROD
monitoring data and provides an evaluation of hydrologic and groundwater contaminant conditions for the
TRA deep perched water system and the underlying aquifer (refer to Section 5.2.5.12 for more information
regarding the results of the 3-year post-ROD monitoring). The agencies agree that the remedy selected tor
OU 2-12 continues to provide adequate protection of human health and the environment. Specific
recommendations in the Ol' 2-12 3-year review include continued sampling at SRPA wells TRA-06 and
TRA-OS. replacement of positive displacement pumps in \\ells TRA-06 and -OS by submersible pumps.
and sampling on a semiannual basis for both deep perched water system and SRPA wells. The SRPA
welN \\ill he sampled for total dissolved chromium and tritium semiannually and cadmium, Co-60, and
Sr-90 annually: deep perched water system wells will he sampled tor total dissolved chromium, tritium,
cadmium. Co-N). and Sr-90 semiannuullv. The Ol' 2-12 ROD is a final ROD and stand-alone document.
5-16
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A required monitoring plan will be developed following signature of this ROD. Monitoring
performed in accordance with the OU 2-12 ROD will be integrated into the OU 2-13 post-ROD
groundwater monitoring plan. The Warm Waste Pond and the Sewage Leach Pond have also been
replaced by lined ponds, resulting in the elimination of a previous large source of contaminated effluent
impacting the perched water zones. The impact of this source reduction will continue to be monitored.
5.2.5 No Action Sites
The agencies agree that no action will be taken under CERCLA at the sites discussed in the
following sections. For those sites for which no action is being taken based on land use assumptions, those
assumptions will be reviewed as part of the 5-year review.
5.2.5.1 Rubble Piles. Ten sites consisting of uncontaminated rubble piles were examined in the
initial review of the TRA site. Because they contain no hazardous substances that would pose an
unacceptable risk, they were given a No Action status in the FFA/CO and were not considered further in
the RI/FS. Miscellaneous asbestos tiles were discovered and cleaned up from the rubble piles in 1996.
5.2.5.2 Paint Shop Ditch (OU 2-01). The Paint Shop Ditch is an open ditch that was used for
disposal of paint-shop waste until 1982. The site has been characterized; concentrations of contaminants
are below risk-based levels of concern. A determination of No Further Action for the site was approved by
the agencies in December 1991.
5.2.5.3 Inactive Fuel Tank Sites (OU 2-02). This OU 2-02 site includes five underground
storage tanks that contained petroleum products. All five of the tanks have been removed from the ground;
the initial site characterizations found that either no, or minimal, contamination remained at the sites. The
sites were all recommended and approved for No Further Action by the agencies in 1992 and 1993.
5.2.5.4 Miscellaneous (OU 2-03). This OU includes six miscellaneous sites where sources of
contamination no longer exist. All sites in this OU received No Further Action determinations from the
agencies in 1993. Following are summaries of those sites.
TRA-OI is a burial site containing excavated soil from a I983 sulfuric acid spill. The acid in the soil
was immediately neutralized at the spill site before excavation and burial. Bounding calculations show
that the calcite content of the soil would be sufficient to neutralize more than I'D times the estimated release
volume. As no source exists at the site, no further action is appropriate.
TRA-11 is a french drain connected to the overflow vent of a I .()()()-gal (3,875-L) sulfuric acid tank.
No documented overflows or evidence of spills is associated with the site. Risk-based calculations
demonstrate that the threshold quantity of acid necessary to generate an unacceptable risk would have been
appropriately documented. As no source likely exists at the site, no further action is appropriate.
TRA-l 2 is a site where, in I983, an estimated 110 gal (416 L) of No. 5 fuel oil overflowed from a
20().(MM)-gal (75,708-L) aboveground tank. Two independent eyewitnesses report that the flow never
reached the ground (because of the high viscosity of the oil), and no ground staining was observed.
Hounding calculations show that VOCs \vould not be present even if the spill volume was increased by a
factor of ton. As no source exists at the sjie. no further action is appropriate.
5-17
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TRA-20 is the site of a 15,0(X)-gal (56.781 -L) aboveground concrete tank used for processing sodium
chloride solution, sodium hydroxide, and sulfuric acid. Before using the sodium hydroxide and sulfuric
acid in the tank, it was lined with epoxy. The tank lining was found to he intact during a 1992 inspection.
Bounding calculations show that the calcite present in 10 yd1 of soil would be sufficient to neutralize at
least 315 gal (1,192 L) of the acid. Risk-based calculations indicate that the threshold quantity of sulfuric
acid 1315 gal (1.192 L)] is greater than the amount likely to have been spilled. No further action is
appropriate.
TRA-40 is the site of a 45-ft (13.7-m) concrete-lined trench containing piping for demineralizer
solutions. A portion of the trench was unlined prior to 1989. Releases before 1984 would have involved
nonhazardous substances. Subsequently, the system transferred sulfuric acid and sodium hydroxide.
There are no documented releases from the site, and an inspection performed in 1992 indicated that the
system was in a well maintained condition. Had a leak occurred, approximately equal volumes of acid and
base would have been released. As no source exists at the site, no further action is appropriate.
TRA-614 is a site consisting of an earthen berm where small quantities of oii may have been
disposed. There is no documentation or evidence of oil disposal at the site. The site is currently beneath
Building TRA-628. With excavation of the berm, there is no known source. No further action is
appropriate.
Based on these results, no further action is appropriate for all OU 2-03 sites.
5.2.5.5 Petroleum and PCB Spill Sites and North Storage Area, Including the Soil
Contamination Area (OU 2-04). Sites recommended for No Further Action include seven sites of
mainly petroleum products, including three with PCB-contaminated areas. The other four sites include
diesel fuel contamination in a perched water well, contamination beneath an old loading dock, and two
areas of fuel oil contamination. Also included in OU 2-04 is the North Storage Area, including the North
Storage Area Soil Contamination Area where localized areas of radionuclide-conlaminated soils exist. The
agencies recommend no further action because potential concentration of contaminants and associated
risks are below levels that would justify cleanup action or further investigation.
TRA-653 is the site of a PCB transformer spill. After excavation of 8 yd' of contaminated soil and
backfilling with clean soil in 1990, the highest PCB concentration was found to be 16 ppm under 4 ft
(1.2 nu of clean soil. The maximum surface concentration was 2 ppm located in a 2 x 8 ft (0.6 x 2.4 m)
area that was not excavated. The use of a conservative computer screening model demonstrated thai the
concentration of PCB is below that necessary to pose a risk to' groundwater. Although the concentration of
PCB for the soil ingestiun pathway is above the 1 in 1.000.000 concentration of 0.08 ppm for carcinogenic
risk, ii is below the 25 ppm cleanup level established under the Toxic Substances Control Act (TSCA) for
restricted industrial areas. No further action is appropriate.
TKA-M9 is the site of a PCB transformer spill. Approximately 10 to I 2 yd' of soil were removed
from around the transformer. The site was backfilled with approximately 2 ft il).6 m) of clean soil. The
highest PCB concentration of 22 ppm is belou the 2 ft (0.6 m) of contaminated soil and (he concrete pad.
which uas left in place. Although the concentration of PCB for the soil ingestion pathway is above the I
in 1 .(H)O.OO(l concentration of I).OS ppm for carcinogenic risk, il - well helovs the 25 ppm cleanup level
established under TSCA for restricted industrial areas, and is under at least 2 It i0.6 m) ol clean soil. No
5-IS
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further action is appropriate for this site. Note that this site description was inadvertently left out of the list
of No Action site descriptions in the Proposed Plan.
TRA-626 is the site of a PCB transformer spill. Approximately 36 yd' of soil and concrete were
excavated from the site, followed by backfilling with clean soil. The highest PCB concentration is 24 ppm
under 4 ft (1.2 m) of clean soil. Computer model results demonstrate that the concentration of PCB is
below that necessary to pose a risk to groundwater. Although the concentration of PCB for the soil
ingestion pathway is above the 1 in 1,000,000 concentration of 0.08 ppm for carcinogenic risk, it is below
the 25 ppm cleanup level established under TSCA for restricted industrial areas, and is under 4 ft (1.2 m)
of clean soil. No further action is appropriate.
PW-13 is a monitoring well site where diesel fuel was discovered at a depth of 65 to 75 ft (20 to
23 m) during drilling operations. After removing approximately 20 gal (76 L) of diesel fuel, the borehole
was observed for several days without additional influx of fuel being noted. The well was subsequently
completed at a depth of 90 ft (27 m). The well has been sampled four times (July 1993, October 1993,
January 1994. and April 1994) and analyzed for total petroleum hydrocarbons. The well was sampled and
analyzed twice for benzene, toluene, ethylbenzene, and xylene. All analyses were reported as nondetects,
with the exception of ethylbenzene, which was detected in samples at concentrations ranging from
nondetect (April 1994) to a high of 5.41 ppb (July 1993). These levels are well below the allowable
drinking water MCL of 700 ppb.
TRA-09 is the site of a former loading dock used to store petroleum products and solvents where, as
a result of transfer operations, small quantities of this material may have been spilled. Bounding
calculations performed demonstrated that the hazardous constituents from small incidental spills would
have volatilized in the 8 years since the dock was removed. Soil staining observed in 1985 when the dock
was removed is no longer visible, qualitatively indicating natural degradation of the spill constituents.
TRA-670 is the site of surficial oil staining at the former location of two 500-gal (1,893-L)
aboveground waste oil storage tanks. Anecdotal information indicates that the tanks had been overfilled on
at least one occasion and that small incidental spills would occur during routine transfer operations. The
tanks and stained soil were removed from the site in 1987, and the area was backfilled with clean soil. It is
unlikely that sufficient contamination remains at this location to pose an unacceptable risk.
TRA-627 is the site of oil-stained soils at an oil transfer pump house. The pump house was used to
transfer No. 5 fuel oil from trucks to storage tanks. Incidental spills occurred during the transfer as lines
were connected and disconnected. Whenever these spills occurred, however, it was standard practice to
use a sand absorbent on the spill. The sand was then put into a "sand box" before disposal at the Central
Facilities Area landfill. The only hazardous constituents of No. 5 fuel oil are low levels of polycyclic
aromatic hydrocarbons. The high viscosity of No. 5 fuel oil would have prevented significant infiltration
prior to removal of the spills.
The North Storage Area, including North Storage Area Soil Contamination Area located north of the
North Storage Area fence, contained localized radionuclide-contaminated soil. This soil contamination
arcu wa> removed in the summers of 1995 and 1996 as part of an INEEL-wide cleanup of radioactively
v 'illuminated surface soil. f\irr:r-^ ' .pies show that rein >val of this contamination was effective.
No further cleanup action i> necessary, and the No Action option is appropriate.
5-19
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5.2.5.6 Hot Waste Tanks (OU 2-05). This OU contains two tank sites (TRA-16 and TRA-603/
605) used for hot waste disposal. Site TRA-16 was an underground hot waste storage tank. The contents
of the tank were sampled in April 1993 and found to be an ignitable waste contaminated with low levels of
radionuclides, primarily uranium isotopes. The tank contents were removed, and the tank was excavated in
August 1993. Note that no leaks were detected and the tank was intact upon inspection when it was
removed. The risk evaluation of the site found no unacceptable risk from exposure through any complete
pathway. At the TRA 603/605 tank, there had been no evidence of leaks. It is unlikely that a source of
contamination remains at the site. The process water pipe loop is constructed of 0.25-in. (0.64-cm)
stainless steel and is unlikely to have lost sufficient integrity to allow leakage. In addition, any leaks would
he collected in a sump within the building where the portion of the loop being used for storage is located.
There have been no reports of leaks. It is unlikely that there is a source of contamination at this site. The
agencies concurred in 1994 that no further action is necessary for these two tank sites.
5.2.5.7 Rubble Sites (OU 2-06). This OU 2-06 site consists of three separate rubble piles, which
were generated as a result of previous construction activities at the TRA. These piles are located outside
the existing fenced perimeter and were used intermittently from 1952 through 1971. No source of
hazardous waste contamination exists at any of the three sites; therefore, no complete pathways were
identified. After a limited investigation, the agencies concurred in October 1993 that no further action is
necessary at these three sites. Historical data, including photographs, information from operations
personnel, and field screening data obtained during site visits provided the basis for this evaluation.
5.2.5.8 Cooling Tower Sites (OU 2-07). This OU consists of areas surrounding the cooling
tower basins and cooling towers associated with the ETR, MTR, and ATR. The sites were suspected of
being contaminated with hexavalent chromium. However, the majority of chromium detected in the soil
had been reduced to the less toxic trivalent state and is in the elemental state. Risk evaluations conducted
for current occupational and future residential scenarios indicated that the potential risk for all pathways
and all scenarios does not exceed 1 chance in 1,000.000. Based on these results. DOE-ID recommended.
and the EPA and IDHW concurred, that no further action is appropriate.
5.2.5.9 Materials Test Reactor Canal (OU 2-08). For approximately 8 years, the canal.
installed in 1952, leaked significant quantities of water contaminated with radionuclides. During an
investigation in 1994, historical data (including operating procedures), monitoring data, and information
from site personnel were collected and evaluated. Potential contaminants in the subsurface are available
for release only to the grounds ater pathway, as the base of the canal is 14 to 32 ft (4 to l()m) below
ground level.
The groundwater pathway was evaluated using a conservative computer screening model. The
results of the modeling indicate that the COCs (cadmium, beryllium, cesium, and cobalt) are relatively
immobile, based on their respective computed travel times to the underlying aquifer. In addition, the
potential for contaminant migration from moisture infiltration is limited h\ the fact that the major portion
of the canal is located below the MTR building and the portion that extends beyond the building is under
pavement. Based on this information, the risk to human health and the environment to exposure by
contaminants in the canal is considered low. DOE-ID recommended, and EPA and IDHW concurred, that
no further action is appropriate for this site.
5.2.5.10 Sewage Treatment Plant (OU 2-09). Because there is no c\ idcnce of a release of a
ha/ardoiis material, this siiL- \\;is determined to require no further action.
5-20
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5.2.5. /1 Retention Basin, Injection Well, Cold Waste Sump and Pit (OU 2-11). The
warm waste retention basin is a large underground concrete basin. The retention basin received the waste
routed to the Warm Waste Pond. It was originally designed to hold radioactive wastewater long enough
for short-lived radionuclides to decay. The disposal well sampling pit. and sump system located south of
the retention basin, were used for the disposal of uncontaminated cooling tower effluent water between
I964 and 1982. The site was evaluated in 1992, and it was determined that the well (TRA-05) sump and
sampling pit do not pose an unacceptable risk. Radiological and chemical soil contamination was
identified surrounding the warm waste retention basin from releases associated with the basin, piping, and
sumps. The results of the OU 2-13 comprehensive baseline risk assessment indicate that the risks
associated with the site are within allowable levels. The recommendation from the agencies for these sites
is that no further action is appropriate.
5.2.5.12 Perched Water (OU 2-12). This OU comprises the perched water zones underlying the
TRA. These zones are a result of water from the Cold Waste Pond, Warm Waste Pond, Chemical Waste
Pond, and Sewage Leach Pond infiltrating the ground and perching on low permeability layers (i.e., silts
and clays) in the underlying basalt. The investigation of the shallow and deep perched water zones was
completed in 1992, and a ROD was signed in December 1992, recommending long-term monitoring and
evaluation of monitoring results. After 3 years of post-ROD monitoring, chromium and tritium
concentrations in two of the SRPA monitoring wells remain above drinking water standards. However,
insufficient data have been collected to determine the statistical significance of these results. Overall, good
agreement between actual and expected concentrations for other contaminants exists on the basis of the
3 years of study since the OU 2-12 ROD was signed. The Deep Perched Water System wells show that
removing the Warm Waste Pond from service has reduced contaminant concentrations with time. In
general, all monitoring wells show a decreasing contaminant concentration trend, with the exception of one
well with chromium (USGS-53) and one well with tritium (USGS-58) that shows an increasing trend with
time. The extent of detectable contaminant plumes originating at TRA appears to be less than 5 km, based
on United States Geological Survey (USGS) monitoring of the public rest stop well on U.S. Highway 20.
Continued monitoring of the SRPA and the perched water below the TRA is recommended.
5.2.5.13 New Sites (OU 2-13). Hot Tree SiteThe Hot Tree Site is located in the center of
TRA. Screening of the branches of a spruce tree indicated it was contaminated with gamma-emitting
radionuclides. The tree was removed, boxed, and disposed in May 1994. Subsequent to the removal of
the tree, ten shallow soil boring samples were collected for field screening. The samples were collected
approximately 2 ft (0.6 m) below land surface in the immediate area surrounding the former tree location,
and the tree's root system was surveyed. In addition, three surface soil samples were collected and
submitted for analysis. The highest radiologically contaminated areas were located west of the Hot Tree
Site, suggesting that a nearby abandoned warm waste line was the contamination source. Adjacent trees
were surface screened in August 1994. The surface screening of adjacent trees did not indicate
contamination. Surface radiation surveys of the Hot Tree Site indicated a radiation dose rate of 30 to
40 urem/hr at waist height (i.e., TRA background levels). This suggests that the contamination was
confined to the Hot Tree Site.
The warm waste line, which is the suspected contamination source, is located approximately ID ft
(3 m) west and 6 ft (1.8 m) below land surface of the removed tree. The waste transferred through this line
uas low-pressure, dcmineralizcd acidic water. The acidic condition of the waste coi.li' have contributed to
the deterioration of the line, which could lead to potential release*. The line was cut and capped in 1983.
so it is not suspected to he a potential source of continuing releases.
5-21
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Because only Cs-137 was detected in two 1994 surface soil samples, it is the only COPC. Based on
the Hot Tree Site, sampling information by TRA facility personnel, and process knowledge of the warm
waste line, only gamma-emitting radionuclides Cs-l 37 and Co-60. and the beta-emitting radionuclide
Sr-90. were identified as COPCs at the Hot Tree Site.
Additional sampling was conducted to better characterize the subsurface contamination profile. The
results o! this sampling effort were evaluated in the baseline risk assessment. The baseline risk assessment
showed that an unacceptable risk does not exist at this site because of low contaminant concentrations in
the soil. No further action is necessary for this site.
Engineering Test Reactor StackThe Engineering Test Reactor Stack is located outside and east
of the TRA perimeter fence and west of the Warm Waste Pond. The site was suspected to have PCB
contamination because tar-containing PCBs were used to coat the inside of the stack. This tar coating had
deteriorated since 1957. when the stack was put in operation, and started to leak out the north access door
at the base of the stack. Because of this process knowledge, no other COPCs are associated with this site.
In addition, samples collected by the facility indicated low levels of PCBs in the soil immediately adjacent
to (he concrete pad where the slack was located.
Three soil/concrete samples and one duplicate were collected from the soil at the base of the stack.
Analysis of the samples indicates that very low levels of PCB contamination are present at this site. The
maximum concentration was 2.3 ppm of the Aroclor-1260 PCB in one sample. The TSCA requires
cleanup of PCB-contaminated soils at an industrial site if the PCB concentration is 25 ppm or higher.
Because the maximum concentration detected was 2.3 ppm, cleanup is not required. No further action is
necessary.
French Drain Associated with TRA-653 (TRA-41)The French Drain is located in the south
central portion of TRA. The French Drain comprises an 8-in. (20-cm) conduit extending from ground
surface to approximately 2 ft (0.6 m) below land surface. This French Drain is still in place and
operational. It is reported to the State of Idaho on the active injection well inventory. Process knowledge
indicates that VOCs and SVOCs are the only COCs. Sampling was conducted at the French Drain in
August 1993 during a Site-wide assessment of shallow injection wells. The material sampled was a sludge
with a black tar-like appearance. The analytical data indicated that this new site had probably been
contaminated by the TRA-653 mechanical shop operations. The wastes suspected are solvents, fuel
residues, and oilv wastes. The composite sample result was sufficient to characteri/.e the sludge material.
A TRA facility maintenance action was completed in 1995 to remove sludge inside the drain.
Approximately two 55-gal (208-Li drums of material were removed from the drain during the maintenance
action. Confirmation sampling was conducted following removal of the sludge lo verify total
contamination removal. This material was characterized in August 1995 and was determined to be
nonhu/ardous. Following this determination, the drums were dispositioned at the Central Facilities Area
landfill. The results of the baseline risk assessment indicate that an unacceptable risk is not posed by this
Nile. Nii further action is recommended.
Diesel I nlouding I'it lTRA-42)The diesel unloading pit is located in the northeast corner of the
Test Reactor Area. The unloading pit for No. ?. diesel consists of a 4-in. ( Hi-cm) flow line encased in an
approximate!) 3- x 3- x >s-tt i I - x 1- x 2.4-mi concrete vault. The connection has been used since the late
I l)5i»s. ()\ er the \carv the unloading operation-- have resulted in minor releases mlo the bottom of the pit.
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When the pit was cleaned, it was discovered that the pit had an unlined soil and sand floor, not a concrete
floor as expected. Any diesel spills may have penetrated the surface soil of the pit surrounding the
connection.
No additional field characterization was conducted. A conservative estimate of the volume of diesel
fuel that may have been spilled at the site indicates that the volume is insufficient to migrate to
groundwater using the computer model. In addition, the computer model indicated that the potential
residual concentration of benzene that might be leached into the groundwater is insufficient to pose a risk
for groundwater consumption. This site was eliminated from further evaluation on the basis that a source
of contamination is no longer present that would pose an unacceptable risk. No further action is necessary.
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6. SUMMARY OF SITE RISKS
6.1 Human Health Risk Evaluation
The human health risk assessment consists of two broad phases of analysis: (I) a site and
contaminant screening that identified COPCs at retained sites, and (2) an exposure route analysis for each
COPC. The exposure route analysis includes an exposure assessment, a toxicity assessment, and a risk
characterization discussion. The OU 2-13 baseline risk assessment includes an evaluation of human health
risks associated with exposure to contaminants through soil ingestion, fugitive dust inhalation, volatile
inhalation, external radiation exposure, groundwater ingestion, ingestion of homegrown produce, dermal
absorption of groundwater, and inhalation of water vapors because of indoor water use.
6.1.1 Contaminant Identification
Historical sampling data were used to identify contaminants present in surface soils at the WAG 2
sites. The list of contaminants was screened based on comparison with background concentrations
determined for the INEEL, detection frequency of less than 5% and no evidence that the contaminant was
released at the site, and whether the contaminant is routinely considered to be an essential nutrient.
Because substances that are essential nutrients can be toxic at high concentrations, this screening step
applied only at sites where essential nutrient concentrations are less than 10 times the background
concentration.
In addition, an evaluation of groundwater concentrations was conducted to ensure that contaminants
that have been detected above MCLs or risk-based concentrations were not eliminated from evaluation.
6.1.2 Exposure Assessment
»
The human health exposure assessment quantifies the receptor intake of COCs for select pathways.
The assessment consists of estimating the magnitude, frequency, duration, and exposure route of chemicals
to humans.
6.1.2.1 Exposure Scenarios. Only those exposure pathways deemed to be complete, or where a
plausible route of exposure can be demonstrated from the site to an individual, were quantitatively
evaluated in the risk assessment. The populations at risk because of the exposure from waste at the TRA
were identified by considering both the current and future land use scenarios.
The residential scenarios model a person living on the site 350 days u year for 30 years, beginning in
2097 (100 years from 1997), and 2997 (1,000 years from 1997). The 100-year residential scenario was
selected for analysis because the INEEL institutional control is currently expected to last for at least
100 years. The 1.000-year residential scenario was evaluated because 1.000 years is a sufficient period of
time to allow for decay of the short half-life radionuclides at WAG 2. For purposes of the baseline risk
assessment, the assumption was made that future residents will construct 10-ft basements beneath their
homes, and so could he exposed to contaminants down to that depth.
The occupational scenarios model nonintrusive daily industrial use without restrictions. The two
occupational scenarios thai wore anals/.ed include a current occupational scenario thai lasts for 25 years
from the present and a future occupational scenario that starts in 30 years and lasts for 25 years.
6-1
-------
6.1.2.2 Quantification of Exposure. The following exposure pathways were considered
applicable to the evaluation of human exposure to contaminants at the TRA sites: ingestion of soil,
inhalation of fugitive dust, inhalation of volatiles, external radiation exposure, groundwater ingestion
(residential scenario only), ingestion of homegrown produce (residential scenario only), and inhalation of
volatiles from indoor use of groundwater (residential use only). Dermal absorption risks and hazard
quotients for organic contaminants contained in WAG 2 soils were calculated at all of the retained release
sites evaluated in the baseline risk assessment. It was determined that dermal exposure did not contribute
significantly to risk based on these calculations and combined with the knowledge that the predominant
contaminants of concern at TRA (i.e., radionuclides) are not dermally absorbed to any great extent.
Adult exposures were evaluated for all scenarios and pathways (external exposure; inhalation of dust;
and ingestion of soil, groundwater, and foods); child exposures (0 to 6 years old) were considered
separately only for the soils ingestion pathways in the residential scenarios. Children were included
because children ingest more soil than adults, significantly increasing their exposure rate.
The exposure parameters used in the risk assessment were obtained from EPA and DOE guidance.
The exposure parameter default values used in the risk assessment are designed to estimate the reasonable
maximum exposure at a site. Use of this approach makes under-estimation of the actual cancer risk highly
unlikely. The exposure parameters used in the risk assessment wore:
All pathways
- Exposure frequency, residential
- Exposure frequency, occupational, current
- Exposure duration, occupational, current
External exposure pathway
- Exposure time, residential
- Exposure time, occupational
- Exposure duration, residential
Soil ingestion pathway
- Soil ingestion rate, residential, adult
- Soil ingestion rate, residential, child
- Soil ingestion rate, occupational
- Exposure duration, residential, adult
- Exposure duration, residential, child
Dust inhalation pathway
- Inhalation rate
- Exposure duration, residential
Gromuluater ingestion pathway
- Gnnuuluater ingestion rate, residential
- Exposure duration, residential
350 days/yr
250 days/yr
25 yr
24 hr/day
8 hr/day
30 vr
lOOmg/day
200 mg/day
50 mg/day
24 yr
6vr
20 m' of air/day
30 \r
2 L/da>
30 sr
Tlie contaminant exposure point concentrations evaluated in the Baseline Risk Assessment were
developed from site-specific sampling information. Ninet\-fi\e percent upper confidence level il'CL)
-------
(95% UCL) of the mean concentrations were calculated from these sampling data, and either the 95c/c UCL
or maximum detected concentration at a given site was used as the exposure point concentration in the
site's risk calculations. This analysis method was also designed to produce reasonable maximum exposure
estimates for the WAG.
6.1.3 Toxicity Assessment
A toxicity assessment was conducted to identify potential adverse effects to humans from
contaminants at the TRA. A toxicity value is the numerical expression of the substance dose-response
relationship used in the risk assessment. Toxicity values (slope factors and reference doses) for the sites
were obtained from EPA's Integrated Risk Information System (IRIS) database and EPA's Health Effects
Assessment Summan,- Tables: Annual FY-93, ECAO-CIN-909, 1993.
6.1.4 Human Health Risk Characterization
Excess lifetime cancer risks are estimated by multiplying the intake level, developed using the
exposure assumptions, by the slope factor. These risks are probabilities that are generally expressed in
either scientific notation (I x 10") or exponential notation (lE-06). An excess lifetime cancer risk of
IE-06 indicates that, a plausible upper bound, an individual has a one in one million chance of developing
cancer over a lifetime as a result of site-related exposure to a carcinogen under the specific exposure
conditions at a site. Excess cancer risks estimated below IE-06 typically indicate that no further action is
appropriate. Risks estimated in the range of lE-04 to I E-06 indicate that further investigation or
remediation may be needed, and risks estimated above the lE-04 typically indicate that further action is
appropriate. However, the upper boundary of the risk range is not a discrete line at IE-04, although EPA
generally uses I E-04 in making risk management decisions. A specific risk estimate around lE-04 may be
considered acceptable if justified based on site-specific conditions.
Tables 6-1 and 6-2 summarize the results of the human health evaluation with respect to the
evaluated exposure routes. Table 6-1 indicates which release sites evaluated in the baseline risk
assessment have predicted risks in excess of I E-04 during the occupational 0-year or 30-year time periods,
or the residential 100-year or 1,000-year time periods. Risk results are time dependent because of
radioactive decay without physical source depletion. The results from the 30-year residential time period
are not included because TRA is not expected to be released for residential development any sooner than
100 years in the future. Finally. Table 6-3 indicates the three sites (Chemical Waste Pond, Cold Waste
Pond. :md Sewage Leach Pond) with a predicted hazard index greater than one. As shown in these tables.
the exposure routes that could produce unacceptable risks and hazard indexes are external radiation
exposure, ingestion of soil, ingestion of homegrown produce, and inhalation of fugitive dust. Table 6-4
provides a summary of sites that pose an unacceptable risk to ecological receptors.
The contaminants with the greatest potential for causing adverse human health effects at WAG 2
(i.e.. risks greater than IF-04 or hazard index greater than 1.0) include lour radionuclides and four metals.
In general, radionuclide contamination in shallow soils represents the greatest health risk identified at the
WAG. The contaminants with calculated risks greater than IE-06 and/or calculated hazard indexes greater
than 1.0 are considered to be COCs for WAG 2. These are shown in Table 6-5. Tables 6-6 and 6-7 list
M' :s determined to present ;
-------
Tab|e
5-1 Summary of sites aiul exposure routes with calculated risks greater than or equal to I K-04.
( kciipanonal Scenario Kesulenlial Seenano
Soil A,, ^d Au_
Inycslniri ol
l-vii-,,,.,1 Inhalaliiin Kxternal Hume Inhalation
lifvsiinii R.idiaiiuii ol Fuuilne Inhalation Cumulative Injiesiion Radiation Grown ol l-U(!ill\e Inhalation <'nimil.iii\c
,,l vi,,,l l-xpusdK- I'"'I of Volaides Total of Sod l:\posuie 1'nxlucc Dust ol Volatdes Total'
I K \ I >
IK \ I'1
11< \ ' is 11 AM' I
IK \ i iiM.r i
SI I' Hi-mi .ul S<'A
IK \ |'»
i\\\M' I-Hi I .
. i-viiuii di-iinal ahsoiplion. and inlialaiion of \apois from mdooi usi-i
.1 liu li- li's nsks loi i;i"iinil^.iii ^«.i-ii. t-
11 (AM' Cold \\asti- I't'iitl
, SI I' Sexv.ife Ivaili I'oml
.1 SC \ Soil Contamination Aiea
t. U\M' - \\aini Waste I'ond
i II- ll I I" evposiiii- loule lor Ihe nceupalUMiiil sn-nano (holh the piesenl lime and .1(1 yeais in (he Inline) and lor Ihe residential MViiaiiu llxilli HH) yeais and I.IKKI \eais
i II- tU Ini I In-1- ii In.'' ""»' |vin»ls dn.-i.-iipaiii>nal sccnaimal Ihc present lime or residential scenario I (Ml \eais in ihe 1'iiiinei. and less lhan Ili-dd Ini the lalei |Vin»l
V|ii..iih.n.il ai Ml \cai MI.I.I tin-mime '" I .QHH >eais iiilo Ihe Inline)
-------
Table 6-2
()""P; mil Scciiaiu- Kcsnlcnnal .Su-iiaru.
t-:\icrnal Inhalation K.xivrnul Inticslion n| Inhalation
IIIJ.YSIIOII ol lailialion nl liiyiliu- Inhalation Cumulative Ingcslion ladialiun homegrown lit'lu{!ili\c Inhalaiinn Cumulaliu-
""I expoviiie ilu-J nl vnlalilcs Tulal of Mill cxptisiirc produce tlusi ol vulalilcs Ttilal'
I-1 K Slav-k
.i liuluilcx iixk- lot >jiomul«.ilci MCIUIION (iiij-'cxlion. ilcimal ah-DipUoii. ami inhalation ol sapors from intlooi u»c)
li \S \ Ninth Sloi;i;.v Ale.i
> C\\l' - t'i'lil \\,i>k- I'mitl
.1 SI I' Scxvayc I each 1'oinl
i- S( A - Soil ('iiiilaiinn.ilioii Area
I \V\\I1 - Waiin \Va-le I'oml
j ('!' Cheinu-al \\axle I'lUiil
lk ;jie.ili-| than »i ci|u:il In II-. IH> lot Mh expoMiic M.-ciiaiiotiine (vnikN (nceiipalninal 0-ycar anil (0-seai. or lesiilennal lOO-vear anil 1.0(1(1 scan
j Kixk yie.itei ih.m ol equal In II: 0(» Im cailiei lime pcnotl (OLLiip.iiioiial ll-seai or icsidcnlial KHI-yeai I. ami less lhan IH-Ofi I'nr laid periixl (oecupalional XI seiu or loiilcnlial I (KH)-ycai)
-------
Table 6-2. SUIMIIKII \ ol' sites ami exposure routes with calculated risks greater than or equal to I F.-06.
( )caip;ilion;il Sn'iu
Sccilunn
Soil
Soil
All
l:\iimil
lii^vslinii nl I'adiiiiinn
Vtiiluinii MII| cxpoMm1
IKA Jl< il'< II M'lHl
IK A
IKA I1' *
IKA IIS l(A\l" i *
IKA 1 < I.SCH.II.V *
If.llll l''>lllll
SI.I' Huiii.iiid.SC'A-
IKA OliWWI' !')>:
|n|K ,1.111,1,, Btternal Ingcsdnn ol Inh.ihiiicm
ol IU^IIIM- Inhalalion Cumulative Inycsiioii radiation hoincsioun ollugilivc Inhalation Cuinulutivi-
,lusi ol volatiles Total ol MII! cxptisute produce duvl of'volaliles Total'
o
'
0
I) C.I O
0
o
.iml l')V?ivllM
IKA4
ivll I
IK A-(14 iKi-t H.IMIII
TKA-(KH('l"i
HI.I-.S < '.ip Aii'a
IKA 41 (l-icia-h
Plain I
II fS
-------
Table 6-3. Summary of sites and exposure routes with calculated hazard index greater than or equal to one.
(>cciipalion;il Scenario Residential Sccnano
S> ill ' Air Soil Air
Inhalation Injieslion ol
l:\icmal of External Home Inhalation Inhalation
hi}!csiioii Radiation t:ngilive Inhalation Cumulative Ingeslion Radiation Ciioun of Fugitive of Cumulative
ol Soil F.vposme Dust of Volaliles Total of Soil Kxposuie Produce Dust Volalilcs Tola!'
IKA OX K'VAI1')
IKA I ((SUM
IRA IKHCI"1)
.1 IIK Index nAs lor t!ioiniilualei xcenanox iint:e>lii>M. ileinial ahsorplion. and inhalation of vapors from indixir use)
l> I \VI' --Colil Waste I'onil
i SI I1 Sewage Ix'ach I'otul
.1 I'I' - Chemical Waste I'oiul
ll.i/.iul intlc\ (!iejiei il<:ni one h\ cvpoxtne louie loi the occupational scenario (both the present and 30 years into the future), and tor (he residential scenario
iliiitliihc IIH) \eais and I .mid vcais into (he Inline I
-------
Table 6-4. Summary of the sites that have the potential to pose an unacceptable risk to ecological
receptors.
Nonrudionuclides Radionuclides
Organic-
Site Metal Compound Internal External
TRA-()2J " "
TRA-03 ' -
TRA-()4/()5J «J »d
TRA-06 ''
TRA-08' '
TRA-13' <
TRA-I.V «h
TRA-I6J '
TRA-I9J ' >
TRA-36 "
TRA-38" '
Brass Cap AreaJ ' '
a. Co-located facilities that are currently in use and/or near areas of industrial activity.
h. At TRA-02. the metals are antimony, lead, selenium, silver, thallium, and tin. The organic compound is
b'en/ot h )fluroanthene.
c. At TRA-03. the metal is mercury and the rudionuclides are amencmm-241. cunum-244. pluionium-238.
plutomum-2?y/24<). and strontium-90.
d. At TRA-04/05. the metals are arsenic, copper, lead, mercury, selenium, and thallium: the organic compound is
.icrylomtnle.
L1 At TRA-Utv the metaU .ire antimony, arsenic, barium, lead, mercury, selenium, ^ll\er. strontium, thallium, and
mi
t. At TRA-OS. ilic metals are arsenic, barium, cadmium, copper, lead, mercury, selenium, and silver.
u. At TRA-1 .v the metals are copper, lead, mercury, selenium, silver, and /inc.
h. At TRA-1 5. the metals are arsenic, fluoride, and mercury.
i. At 1'RA-16. the metal is mercury.
I At 1'RA-11' .nid the Urass Cap Area, the internal and external radionuclules are cesium-1 34 and cesium-1 3"?.
k. Ai TRA-3l: however, these
contaminants uoukl po\c risk at background levels anil are not considered a problem at this site.)
I At IRA- ;v. the metaK are antimony, arsenic, lead, mercurv. selenium, and thallium.
fi-S
-------
Table 6-5. WAG 2 contaminants of concern.
Exposure
Scenario
Occupational
As- 1 08m.
Radionuclides Metals
Co-60. Cs- 1 34. Cs- 1 37. Arsenic
Organic
Contaminants
None
Other
PCBs
Eu-152. Eu-154. Sr-90
Residential As-108m. Am-241. Cs-134. Cs-137. Arsenic, beryllium.
Co-60. Pu-238. Pu-239. Sr-90. chromium, mercury
Th-228, U-238
Acrvlonitrile
PCBs
6-9
-------
Table 6-6. Contaminants and exposure pathways of concern forOU 2-13 sites with risks >IE-06 and
cumulative risks >1E-04.J
Site/Exposure Contaminants
Scenario Pathway of Concern
TRA-03 ( Warm Waste Pond)
Occupational O-year Soil mgestion Am-241
Cs- 1 37
Pu-23X
Pu-239/240
Sr-90
External radiation exposure Ag-l()8m
Am-24 1
Co-60
Cs-137
Eu-152
Eu-154
Exposure scenario total
Occupational 30-year Soil mtiestion Am-241
Cs- 1 37
Pu-238
Pu- 239/240
Sr-90
External radiation exposure Ag-l()8m
Am-241
Co-M)
Cs- 1 37
Eu-152
Eu-154
Exposure scenario total
Residential I00-\e.ir Soil msiestion As
A in- 241
Cs-i3">
Pu-23S
Pu-239/240
Sr-90
Homegrown produce iniiestion C\- 1 37
1'u- 2 39/241)
Sr-W
Ii\temal radiation exposure Ag-IOSm
Am-241
(\-!37
I-.U-152
I -23s
Excess
Cancer Risk
2-E-05
2E-05
IE-06
2E-05
4E-05
3E-05
4E-06 '
9E-04
2E-02
2E-03
5E-04
2E-02
2E-05
8E-06
1 E-06
2E-05
2E-05
2E-05
4E-06
2J--05
1 1--02
5E-04
4E-05
1E-02
5E-()f>
5!:-()5
hl'i-Oh
2li-0h
7E-05
2E-05
2l-:-()f>
3I-1-05
2I:-05
7E-05
21- -us
9l-:-03
M--D.-S
21 -.-(ih
-------
Table 6-6. (continued).
Site/Exposure
Scenario
Residential 1 .000-year
TRA-06 (Chemical Waste Pond)
Occupational 0-year
Occupational 30-year
Residential 100-year
Residential 1 .(KX)-year
TRA-08 (Cold Waste Pond)
Occupational 0-year
Occupational 30-year
Residential 1 Oil-sear
Pathway
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
External radiation exposure
Exposure scenario total
Soil ingestion
Exposure scenario total
Soil ingestion
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
Soil inyestion
External radiation exposure
Exposure scenario total
Soil ingestion
l-.xternal radiation exposure
!>!" - nario total
Soil inuestum
Contaminants
of Concern
As
Am-241
Pu-239/240
Pu-239/240
Am-241
U-238
As
As
Aroclor-1260
As
As
Aroclor-1260
As
As
As
Co-M)
Cs-137
Eu-154
As
Cs-137
As
Excess
Cancer Risk
9E-03
5E-06
IE-05
7E-05
3E-05
4E-06
2E-06
1E-04
2E-06
2E-06
2E-06
2E-06
1E-06
2E-05
2E-06
2E-05
1 E-06
2E-05
2E-06
2E-05
IE-05
IE-05
1 E-04
7E-06
1E-04
IE-05
7E-05
SE-05
ll-:-04
6-11
-------
Table 6-6. (continued).
Site/Exposure
Scenario
Residential 1. 000-year
TR A- 13 (Sewage Leach Pond)
Occupational ()-\ear
Occupational 30-year
Residential lOO-year
Residential I.O(Mi-\ear
TRA-15
Occupational 0-\ear
( Vcupational ;'>-\c.n
Residential l(id-\ear
Pathway
Homegrown produce mgestiun
External radiation exposure
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
External radiation exposure
Exposure scenario total
External radiation exposure
Exposure scenario total
External radiation exposure
Exposure scenario total
External radiation exposure
Exposure scenario total
External radiation exposure
Exposure scenario total
External radiaiion exposure
Exposure scenario total
S.,:l inL-estion
Contaminants
of Concern
As
Cs-137
As
As
As
Ag-I08m
Co-60
Cs-134
Cs- 1 37
Eu-152
Eu-154
Ag-I08m
Co-60
Cs- 1 37
Eu-152
Ag-I08m
Cs- 1 37
Ag- lOXm
Co-60
Cs- 1 34
Cs- 1 37
Cs- 1 37
As
Excess
Cancer Risk
1 E-05
7E-05
1 E-05
2E-04
IE-04
1 E-05
IE-04
5E-05
4E-04
1 E-06
7E-04
2 E-05
1 E-05
1E-03
4 E-05
8E-06
4E-04
5 E-06
4E-04
IE-04
4E-04
5E-04
IE-06
i E-06
1E-05
3E.-04
3E-04
2i-:-o4
2E-04
1E-05
-------
Table 6-6. (continued).
Site/Exposure
Scenario
Residential l.(XX)-year
TRA-19
Occupational 0-year
Occupational 30-year
Residential l(X)-year
Sewage Leach Pond-Soil
Occupational 0-vear
Occupational 30- v ear
Pathway
Homegrown produce ingestion
External radiation exposure
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
Soil ingestion
External radiation exposure
Exposure scenario total
Soil ingestion
External radiation exposure
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
External radiation exposure
Exposure scenario total.
Contamination Area and Berms
External radiation exposure
Exposure scenario total
External radiation exposure
Contaminants
of Concern
As
Cs-137
As
As
Cs-134
Cs-137
Sr-90
Co-60
Cs-134
Cs-137
Cs-137
Sr-90
Co-60
Cs-137
Cs-137
Sr-90
Cs- 1 37
Sr-90
Cs- 1 37
A»-UWm
Co-60.
. C.s-137
As.'- 1 08m
Co-60
CVI37
Excess
Cancer Risk
1 E-06
IE-04
IE-04
1 E-05
1 E-06
1 E-05
6E-06
1 E-04
1 E-05
1 E-04
IE-02
2E-OI
2E-01
7E-05
5E-06
3E-06
8E-02
8E-02
6E-05
4E-06
IE-05
6E-06
8E-02
8E-02
1 E-05
IE-04
IE-04
2E-IM
IE-05
2H-06
7H-05
A-13
-------
Table 6-6. (continued).
Site/Exposure
Scenario Pathway
Exposure scenario total
Residential 100-vear External radiation exposure
Exposure scenario total
Brass Cap Area
Occupational ()-\ear SIM! inyestion
External radiation exposure
Exposure scenario total
Occupational 30-year Soil ingestion
External radiation exposure
Exposure scenario total
Residential 100-year Soil mgestion
, Homegrown produce m^cstion
F.xternal radiation exposure
Exposure scenario total
Contaminants
ot' Concern
Ag-I08m
Cs- 1 37
Cs- 1 34
Cs- 1 37
Sr-90
Co-60
Cs- 1 34
Cs- 1 37
Cs- 1 37
Sr-W
Co-60
Cs-137
Cs- 1 37
Sr-W
Cs-137
Sr-90
Cs- i 37
Excess
Cancer Risk
8 E-05 '
3E-05
ftE-05
-9E-05
6E-06
1 E-04
1 E-05
1E-04
1E-02
2E-OI
2E-01
7 E-05
5E-06
3E-06
8E-02
8E-02
6K-05
4E-Of>
1 E-05
XK-02
8E-02
>II:-O4 .Hi- shinvn Ml hold.
h-14
-------
Table 6-7. Contaminants and exposure pathways of concern for OU 2-13 sites with hazard indexes >l .0.J
Site/Exposure
Scenario
TRA-03 (Warm Waste Pond)
Residential l(X)-year
TRA-06 (Chemical Waste Pond)
Occupational 0-year
Occupational 30-year
Residential 100-year
Residential 1.000-year
TRA-08 (Cold Waste Pond)
Residential 100-year
Residential 1. 000-year
Pathway
Homegrown produce ingestion
Exposure scenario total
Soil ingestion
Exposure scenario total
Soil ingestion
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Exposure scenario total
Soil ingestion
Homegrown produce ingestion
Contaminants
of Concern
Hg
Hg
Hg
Hg
Sb
Ba
Hg
Mn
Zn
Hg
Sb
Ba
Hg
Mn
Zn
As
Ba
Cd
Hg
As
Ba
Cd
H-J
Hazard Index
.6E-OI
6E-OI
2E-OJ
2E-01
2E-OI
2E-OI
2E+00
IE-01
5E-01
7E+01
3E-01
3E-OI
7E+OI
2E+00
1E-OI
5E-OI
7E+OI
3E-OI
3E-OI
7E+01
5E-OI
IE-01
2E-01
3E-01
1E+00
5E-OI
IE-01
2E-OI
3F.-01
Exposure scenario total
IF.-t-(K)
6-15
-------
Table 6-7. (continued).
Site/Exposure
Scenario
Pathway
Contaminants
of Concern
Ha/ard Index
TRA-13 (Sewage Leach Pond)
Residential HM)-year Homegrown produce ingestion
Residential l.(K)()-vear
TRA-15
Residential 100-year
Residential 1.000-vear
Exposure scenario total
Homegrown produce mgestion
Exposure scenario total
Soil mgestion
Exposure scenario total
Soil ingestion
Exposure scenario total
Hg
Zn
Hg
Zn
j. Total site ha/ard indexes are shown in hold.
2E+00
2E+00
4E+00
2E-MX)
2E-t-(M)
4E+00
IE-01
IE-01
1E-OI
IE-01
Additional exposure routes that have calculated 100-year future residential risks within or above the
National Contingency Plan (NCP) target risk range (one in ten thousand to one in one million excess
cancer risk) at WAG 2 are ingestion of soil, ingestion of homegrown produce, and ingestion of
groundwaier. Hstimated risks for ingestion of soil are within or above the target risk range at the
TRA-M9. TRA-u26. TRA-653 PCB Spill Sites, the TRA-15 soil surrounding the Hot Waste Storage
Tanks at TRA-613. the TRA-19 soil surrounding the Rad Tanks at TRA-630. the TRA-08 Cold Waste
Pond, the TRA-03 Warm Waste Pond 1952 and 1957 cells, the TRA-04/05 soil between 0 and 10 ft below
land surface surrounding the Retention Basin, the TRA-0(> Chemical Waste Pond, the Brass Cap Area, and
the Hxperimental Test Reactor Stack. Hstimated risks for ingestion of homegrown produce are within or
above the target risk range at the TRA-619. TRA-626. TRA-653 PCB Spill Sites, the TRA-15 soil
surrounding the Hot Waste Storage Tanks at TRA-613, the TRA-19 soil surrounding the Rad Tanks at
TRA-630. the TRA-08 Cold Waste Pond, the TRA-03 Warm Waste Pond 1952 and 1957 cells, the
TRA-04/05 soil between 0 and 10 ft below land surface surrounding.the Retention Basin, the TRA-06
Chemical Waste Pond, the Brass Cap Area, and the Experimental Test Reactor Stack. Hstimated risk for
external radiation exposure is within or above the target risk range at the North Storage Area, the TRA-15
soil surrounding Hot Waste Storage Tanks at TRA-613. the TRA-19 soil surrounding Rad Tank at
TRA-630. the TRA-OS Cold Waste Pond, the TRA-04/05 soil between 0 and 10 ft below land surface
surrounding the Retention Basin and the Cold Waste Sampling Pit and Sump. SLP-Berm and Soil
Contamination Area, the Brass Cap Area, and the Hm Tree Site, in addition lo the Sewage Leach Pond and
the Warm Waste Pond ll'52 and 1957 cells.
6-16
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Recent investigations have determined that RCRA-listed waste may have been present in the TRA
warm and hot waste systems when leaks to the environment occurred. Therefore, if excavation occurs,
soils will be managed in a manner consistent with the hazardous waste determination to be performed at
the time of the remedial action.
6.1.5 Human Health Risk Uncertainty
Many of the parameter uncertainty values used to calculate risks in the WAG 2 Baseline Risk
Assessment and Ecological Risk Assessment (ERA) are uncertain. For example, limitations in site
sampling produce some uncertainty associated with the extent of contamination at most of the WAG 2
sites. Limitations in the characterization of the WAG 2 physical environment produce some uncertainty
associated with fate and transport properties of WAG 2 contaminants. To offset these uncertainties,
parameter values were selected for use in the Baseline Risk Assessment and ERA so that the assessment's
results would present an upper bound, and yet reasonable, estimate of WAG 2 risks. Assumptions and
supporting rationale, along with potential impacts on the uncertainty, are included in Table 6-8.
6.2 Ecological Evaluation
The ecological assessment of the TRA is a qualitative evaluation of the potential effects of the sites
on plants and animals other than people and domesticated species. A quantitative ecological assessment is
planned in conjunction with the INEEL-wide comprehensive RI/FS scheduled for 1998. This INEEL-wide
ecological assessment will provide an indication of the affect of INEEL releases in the ecology at a
population level. There are no critical or sensitive habitats on or near TRA. Based on the present
contaminant and ecological information and the qualitative eco-evaluation performed for this ROD, the
remedies selected to address human health risks will serve to reduce the ecological risk posed at seven sites
where both human health and potential ecological risk have been identified. The need for remedial action
will be reconsidered at these sites as well as the remaining five sites if the INEEL-wide ecological risk
assessment suggests that these conclusions are not well founded. However, it is unlikely that the INEEL-
wide comprehensive RI/FS ecological assessment will identify the need for any additional actions at these
sites.
Table 6-4 summarizes the results of the ERA evaluation for those sites that have potential to pose an
unacceptable risk to ecological receptors.
6.2.1 Species of Concern
The only federally listed endangered species known lo frequent the INEEL is the peregrin falcon.
The status of the bald eagle in the lower 48 United States was changed from endangered to threatened in
July 1995. Several other species observed on the INEEL are the focus of varying levels of concern by
either federal or state agencies. Animal and avian species include the ferruginous huwk. the northern
goshawk, the sharp-tailed grouse, the loggerhead shrike, the Townsend's big-eared bat. the pygmy rabbit,
the gyrfalcon. the boreal owl. the flammulated owl, the Swainson's hawk, the merlin, and the burrowing
owl. Plant species classified as sensitive include Lemhi milkvetch, plains milkvctch, wing-seed evening
primrose, nipple cactus, and oxytheca.
6-17
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Table 6-8. Minium lu-
uncertainty factorv
et of uncertainly
Comment
Sollll I' k'llll .isslimpllnli
\.lllll.ll IlllllllallOII MlC
MillsllllC lOlltCMl
M;is Dvcicslimatc risk
May ovcicslmulc tisk
M,i\ oveiestimatc in underestimate risk
\\.ik-i lahlc tliiilu.ilioiis
Mav slighily overestimate or
undeiesiimate risk
Ma- ,.| cnnlammants in soils estimated Mav oveieslimale 01 undcrosi imale risk
In ,,vsii it; ;i umloim coni.iiiiinalion
11 MiicMli. il ion in ilk' si in ice /one
All contaminants aie assumed lo he completely available lor tiaiispoilaliou away from
ihe source /one In leahiy. some contaminants may he chemically or physically hound
to the source /one and unavailable for transport
A conservative value ol 10 cm/yr was used for this paiamelei
Soil moisture contents vaiy seasonally in the upper vadose /one and may he subject lo
measurement error
The average value used is expected to he representative ol the depth over ihe 30-year
exposure period
There is a possibility that most of the mass ol a given contaminant at a given site may
exist in a holspol ihal was not delecled hy sampling. If this condition existed, ihe mass
ol the contaminant used in the analysis might he underestimated. However. 'J.V/i
UCLs or maximum delected contamination were used for all mass calculations, and
these concentrations are assumed to exist at every point in each waste site, so ihe mass
of contaminants used in the analysis is probably overestimated
MICIII in L'loundvsatei Could overestimate or underestimate risk Plug How models aie conservative with respect lo concentrations because dispersion is
neglected, and mass lluxcs from the source to ihe aquifer differ only hy ihe lime delay
in the unsaturaled /one (Ihe magnilude of ihe llux remains unchanged). Tor
nonradiological contaminants. Ihe plug How assumption is conservative because
dispersion is not allowed lo dilute ihe contaminant groundw'ater concentrations. l:or
radionuclides. the plug How assumption may or may not he conservative Rased on
actual travel time, the radionuclide groundvvuler concentrations could be over or
underestimated because a longer travel time allows for more decay. II (he
concentration decrease due lo the Havel lime delay is larger than Ihe neglected dilution
due lo dispersion, ihe model v. ill not he conservative
HI ni coni-iniin mts fiom the Could oveieslimale 01 underestimate risk The effect of not modeling contaminant migration from the soil before IW4 is
dependent on ihe contaminant half-life, radioactive ingrowth, and mobility
characteristics.
I overestimate or underestimate risk In general, the methods and inputs used in contaminant migration calculations.
including assumptions made regarding chemical forms ol contaminants were chosen in
order lo err On the proleclive side All contaminant concentration and mass are
assumed available lor transport This assumption results in a probable overestimate of
risk
Mill MllllfC
Cliciiik-.il liirin ;isMinipiiiiiis
-------
Table 6-8. (continued).
I iKcil.nnlv l.iclor
l-Jieci ol uncertainly
Comment
|-.\pnslllc sccltallO assumptions
Mav overestimate risk
The likelihood of future scenarios has been qualitatively evaluated as follows:
residentimprobable
industrialcredible.
i'c paiaineler a.sMilllplions
Kcicp i locations
May overestimate risk
Mav overestimate risk
May overestimate or underestimate risk
l-oi the L'loiuulwaler pathway analysis.
.ill contaminants were assumed to be
hoinoL'cncously distributed in a large
Ml,|ss |i| soil.
The entile inventory ol each Ma> overestimate risk
contaminant is assumed to he available
for transpori along each pathway
l-.xposurc duration May overestimated
Nonconiaininani-spei-ilic constants (not May overestimate risk
dependent on contaminant properties)
liulnsioii of some hypothetical Ma) underestimate risk
pathways from the exposure scenarios
Model does not considei biolic decay Mav overestimate risk
The likelihood of future onsite residential devvlopnient is small. If future residential
use of this site does not occur, then the risk estimates calculated for lutuie onsile
residents arc likely to overestimate the true risk associated with future use of this site.
Assumptions regarding media intake, population characteristics, and exposure patterns
may not churacteri/e actual exposures.
Groundwaler ingeslion risks are calculated for a point at the downgradiem edge of an
equivalent rectangular area. The groundwaler risk at (his point is assumed to be the
risk from groundwaler ingeslion at every point within the TRA boundaries. Changing
the receptor location will only affect the risks calculated for the groundwaler pathway
since all other risks are site-specific or assumed constant at every point within ihe TRA
boundaries.
The total mass of each COPC is assumed lo he homogeneously distributed in the soil
volume beneath TRA. This assumption tends to maximize the estimated groundwatcr
concentrations produced by the contaminant inventories because homogeneously
distributed contaminants would not have to travel far lo reach a groundwaler well
drilled anywhere within the TRA boundary. However, groundwaler concentrations
may be underestimated for a large mass of contamination (located in a small area with
a groundwater well drilled directly downgiadienl).
In reality, only a portion of each contaminant's inventory will be transported by each
pathway.
The assumption that an individual will work or reside at the site for 25 or 30 years is
conservative. Short-term exposures involve comparison to suhchronic loxicity values.
which are generally less restrictive than chronic values.
Conservative or upper bound values were used for all parameters incorporated into
intake calculations.
Exposure pathways are considered for each scenario and eliminated only it the
pathway is cither incomplete or negligible compared to other evaluated pathways.
Biolic decay would tend lo reduce contamination over lime
-------
Table 6-8.
|:.IUvi ul unieriaiiiix
( Olllllienl
( >tl llp.llional llll.lkc xalllC I'M
lllll.ll.llli'll ! l onsCI \.lllU1
I
Slu'lillx oxcK-slimalcs risk
M.IX oxcreslllll.lle llsk
OVKIIX sallies denxi'd pnmaiilv liiini Max mcieshm.ilcor uiulciestimalcrisk
luxiriix x.ilucs.lciixcil pimianlx tniiii M.IS osi-icMim.iiiMir uiidiriv
ln;:h iliiM'- inosi rxiniMiif. ;in.' .il l"ss
Standard exposure laclors loi Hili.il.ilnm luxe the s.niii1 saluc Im iiccup.ilioii.il .is Im
residential sccn.nios allhotiL'h iiivupatiiiiial xxorkcrs xvould not he onsilc ;ill day
Slope laclors aic associated with uppci l)5\\t percenlile conndence lunils Tlies aie
considered unlikely to underestimate true risk
Extrapolation Irmn ,1111111.il to humans mas induce enoi due to dillerences in
absorption, pharmacokinelics. largel oiyatis. en/ymes. and population sanahilils
Assumes linearily al low dose. Tend to hase conservative exposure assumptions
..I M.IS .ui-rL-sliiiulc or iiiuicrcMini.ili: risk
M-'s niuU-ii-siiiiulc risk
Kisk.'IIOs sMiiuik-d .ii-niss |i.illiu;iss
Mas iiiKlcn.-siini.ili.- lisk
M.IS iixi-K-stiin.ik1 risk
Not all values represent the same degree ol certainly All are suhjecl in change as ness
evidence becomes available
COPC.s without slope laclors may or may not he carcinogenic through the oial
pathway
COPCs wilhoul KlDs may 01 may not have noncaicinnLieiiic adxeise ellecls.
Not all ol the COI'C inventory w'ill be available lor exposure through all applicable
exposure pathways ____________^__
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6.2.2 Exposure Assessment
Three primary media were identified to have the potential for posing risk to WAG 2 ecological
components: contaminated surface soil, contaminated subsurface soil, and contaminated surface water.
Ingestion of contaminated groundwater was not considered because groundwater is not accessible to
ecological receptors. For plants, the uptake of contaminants through root systems was considered.
The amount of exposure is directly related to the amount of time spent and the fraction of diet taken
on the sites. Therefore exposures are greatest for permanent ecological residents, particularly plants and
small burrowing animals. The small size of the sites of concern at WAG 2 is expected to minimize the
exposures received by migratory species, which include most avian and large mammal species that inhabit
the INEEL.
Table 6-4 summarizes the results of the ERA evaluation for those sites that pose an unacceptable risk
to ecological receptors.
6.2.3 Ecological Risk Evaluation
Of the sites and COPCs assessed, two sites were eliminated as posing no potential risk to ecological
receptors (TRA-39 and the ETR Stack). In addition. TRA-34, TRA-619, TRA-626, and TRA-653 were
determined to be highly unlikely to pose risk to ecological receptors and, therefore, were eliminated from
consideration. The PCB sites (TRA-619, 626, and 653) exceeded the target value for only one functional
group (avian insectivores). Given the size of these sites, it is highly unlikely that the member of this group
(swallows) would have an exposure that would result in adverse effects. The sites were therefore
eliminated. For site TRA-39, no contaminant exceeded the target value; therefore, this site was eliminated
from further consideration. The results of the assessment indicate risk at the remaining 12 sites as follows:
from internal and external exposure to radionuclides at the Brass Cap Area and TRA-19 soil surrounding
Rad Tanks I and 2 at TRA-630; from internal exposure to radionuclides at TRA-03 Warm Waste Pond, as
well as from a metal at TRA-03: and from both metals and organic compounds at the following sites:
TRA-02 TRA Paint Shop Ditch, TRA-04/05 Warm Waste Retention Basin and Sampling Pit, TRA-06
Chemical Waste Pond. TRA-08 Cold Waste Pond. TRA-13 Sewage Leach Ponds. TRA-I5 Hot Waste
Tanks at TRA-613, TRA-16 Inactive Radioactive Contaminated Tank at TRA-614, TRA-36 ETR Cooling
Tower Basin, and TRA-38 ATR Cooling Tower. These sites are all associated with ongoing TRA facility
operations. For a complete description of the ecological risk assessment process, please refer to the
WAG 2 Comprehensive Remedial Investigation/Feasibility Study Report located in the administrative
record. The TRA-02 Paint Shop Ditch. TRA-04/05 Warm Waste Retention Basin and Sampling Pit. TRA-
16 Inactive Radioactive Contaminated Tank at TRA-614. TRA-36 ETR Cooling Tower Basin, and TRA-
38 ATR Cooling Tower sites pose only a potential ecological risk.
A basic assumption of the ERA is that, under a future-use scenario, the contamination is present at an
abandoned site that will not he institutionally controlled. In actuality, co-located facilities are currently in
use. and institutional controls will remain in place until they are decommissioned. Because these sites are
at an industrial facility that is currently in use. they most likely do not contain desirable or valuable habitat.
The absence of habitat, the existence of facility activities, and institutional controls will minimize the
exposure of ecological receptors.
6-21
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The ERA determined that risks to ecological receptors may exist at 12 sites at WAG 2. Four sites
(TRA-03. TRA-06, TRA-08. and TRA-13) are outside the TRA facility fence. Human health risks
exceeding allowable levels exist at these sites, and some level of remediation ranging from institutional
controls to active remediation will be required. Any remedial alternative that reduces human health risks
would be expected to also reduce ecological risks. The remaining sites are inside the facility fence, where
ongoing facility operations result in limited ecological exposures, as discussed previously. The relatively
small size of these sites, including TRA-02. -16, and -38, would also likely result in little or no ecological
risks. The results of these studies can be found in the Environmental Science and Research Foundation
1996 Annual Technical Report, located in Idaho Falls, Idaho.
Recent D&D activities during the summer of 1996 at the TRA-645 building discovered radioactive
harn swallow nests. Bam swallows are common at most facilities on the INEEL and are know to nest near
many wastewater ponds found on the site. In a study conducted in 1976 through 1978. barn swallows
nesting at the TRA were found to build nests with radionuclide-contaminated materials and to accumulate
radionuclides internally by ingesting arthropods from radioactive leach ponds. The results of this study
indicate that no obvious direct effects to the barn swallows or their clutches were found. Recent studies
conducted in 199? showed that average radionuclide concentrations in adult barn swallows are about 54 to
314 times lower than those observed in the 1976 study.
6.2.4 Ecological Risk Uncertainty
Uncertainty is inherent in the risk process. Principal sources of uncertainty lie within the
development of an exposure assessment. Uncertainties inherent in the exposure assessment are associated
with estimation of receptor ingestion rates, selection of acceptable HQs, estimation of site usage, and
estimation of plant uptake factors and bioaccumulation factors. Additional uncertainties are associated
with the depiction of site characteristics, the determination of the nature and extent of contamination, and
the derivation of Threshold Limit Values. All of these uncertainties likely influence risk.
Overall, it is important to reiterate that it was anticipated that the conservative nature of the ERA at
the \VAG level would result in many sites and contaminants being indicative of potentially unacceptable
risk to ecological receptors. This is due to the exposure calculations using a very conservative approach
and is also compounded by the methods used to determine extent of contamination and characterize
exposure concentrations at each release site.
Because of these considerations, the relative small size of the sites, and the conservatism of the
ecological risk assessment, no significant ecological impact is anticipated from these sites. The need for
remedial action at sites posing a potentially unacceptable ecological risk will bo reconsidered if the INEEL-
wide ecological risk assessment suggests that these conclusions are not well founded.
6.3 Groundwater Fate and Transport
WAG 2 includes three potential sources of groundw-ater contamination: contamination contained in
perched waiter bodies beneath TRA. contamination injected into the aquifer by the TRA-0? disposal well.
and contamination that could leach from surface and near-surface soil. From 1964 until 1972. the TRA-05
disposal well v\.is used to dispose of the secondary reactor cooling water. This disposal well injected
directly into (he SRPA and did not contribute contaminants to the Perched Water S\ stem. Alter 1972.
he\as;ilem chromium was no longer used as a rust inhibitor in the coolinu s\stems and was no loivjcr
-------
discharged to the disposal well or to the ponds. Use of the disposal well ceased in 1982. Groundwater
contamination produced by perched water system infiltration and disposal well injection was evaluated as
part of the OU 2-12 perched water system RI, while contamination that could leach into the SRPA from
surface and near surface soil was evaluated using the computer code GWSCREEN in the baseline risk
assessment.
As discussed in the OU 2-12 perched water system RI, the principal groundwater COCs at WAG 2
are chromium and tritium (H-3). The Third Annual Technical Memorandum states that the MCLs for
chromium and H-3 have been exceeded in various wells throughout the OU 2-12 monitoring. Specifically.
the MCL for chromium is 100 ug/L, and the MCL for H-3 is 20 pCi/mL. To date, the monitoring indicates
the following about the TRA wells: (a) the long-term concentration trend (1988-present) is decreasing for
both contaminants in USGS-55, USGS-56. and USGS-65; (b) the short-term, post-ROD concentration
pattern (1993-present) is variable in USGS-55, increasing in USGS-56, and near stable in USGS-65;
(c) the concentration trend for chromium is increasing in USGS-53 but decreasing in USGS-64; and (d) the
concentration trend for H-3 is decreasing in USGS-53. In addition, there are insufficient TRA-7 data to
make contaminant trend determinations.
As discussed in the OU 2-12 ROD, H-3 is expected to fall below MCLs by the year 2004, and
chromium is expected to fall below MCLs by the year 2016. So neither contaminant is expected to
produce unacceptable risks from groundwater ingestion at WAG 2 if residential development occurs at
TRA in 100 years. The radiologically contaminated wastewater source to the Warm Waste Pond has been
removed. The groundwater modeling performed for the OU 2-12 RI/FS predicted that the H-3
contamination in the SRPA beneath TRA will naturally be reduced to concentrations that are less than
MCLs through radioactive decay and downgradient transport, and that most of the chromium
contamination will be reduced via dilution and dispersion.
The groundwater contamination below the TRA commingles with groundwater contamination below
the Idaho Chemical Processing Plant (ICPP). The groundwater contamination below the ICPP is being
evaluated as part of the OU 3-13 Comprehensive RI/FS. Because of the commingling nature of the plumes
below the TRA and ICPP, the chromium and H-3 contamination in the SRPA beneath TRA is being
evaluated in the draft OU 3-13 Rl/baseline risk assessment. To accomplish this evaluation, the
GWSCREEN fluxes derived in the OU 2-13 TRA Groundwater Flow and Contaminant Transport Model
were provided for input into the OU 3-13 flow and transport model. The flow and transport model being
used for the OU 3-13 baseline risk assessment is TETRAD, a proprietary three dimensional code. The
primary time frame of interest for the modeling is 100 years in the future. During this time frame,
concentration contours and peak concentrations in the aquifer are calculated for both H-3 and chromium.
In addition; the model simulates transport of each contaminant until its peak concentration falls below a
concentration equal to the 1E-06 risk concentration or the contaminant's MCL, whichever is lower.
The only other contaminant that is predicted to produce groundwater risks greater than 1 H-06 ai
WAG 2 is arsenic. No remedial action is recommended to lower arsenic groundwater risk because the risk
is less than the risk level of 1E-04 that has been agreed to by the agencies as the basis for groundwater
remedial action objectives (RAOs), and the predicted concentrations of arsenic are less than the MCL.
6-23
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6.4 Basis for Response
Eight sites within TRA have actual or threatened releases of hazardous substances, which, if not
addressed by implementing the response actions selected in this ROD. may present an imminent and
substantial endangerment to public health, welfare, or the environment. These sites include four disposal
ponds |Warm Waste Pond (TRA-03). Chemical Waste Pond (TRA-06). Cold Waste Pond (TRA-08). and
the Sewage Leach Pond (TRA-13)|, three subsurface contaminant release sites (Soil Surrounding Hot
Waste Tanks at Building 613 (TRA-15), Tanks 1 and 2 at Building 630 (TRA-19). and the Brass Cap
Area), and one area of surficial windblown contamination (Sewage Leach Pond Berrns and Soil
Contamination Area). The response actions selected in this ROD are designed to reduce the potential
threats to human health and the environment to acceptable levels.
The ERA for WAG 2 determined that potential risks to ecological receptors exist at 12 sites. Four of
these sites (the Warm Waste Pond, Chemical Waste Pond, Cold Waste Pond, and the Sewage Lagoons) are
outside the TRA facility fence. Human health risks exceeding allowable levels exist at these sites, and
some level of remediation will be required. The TRA-02 Paint Shop Ditch. TRA-04/05 Warm Waste
Retention Basin and Sampling Pit, TRA-16 Inactive Radioactive Contaminated Tank at TRA-614,
TRA-36 ETR Cooling Tower Basin, and TRA-38 ATR Cooling Tower sites pose only a potential
ecological risk. The need for remedial action at sites posing a potentially unacceptable ecological risk will
be reconsidered if the INEEL-wide ecological risk assessment suggests that these conclusions are not well
founded. Any remedial alternative that reduces human healtn risks would be expected to also reduce
ecological risks. The remaining sites are inside the facility fence, where ongoing facility operations result
in limited ecological exposure. The relatively small size of these sites would also likely result in little or no
ecological risk. The need for remedial action will be considered if the INEEL-wide ecological risk
assessment suggests that these conclusions are not well founded.
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7. DESCRIPTION OF ALTERNATIVES
7.1 Remedial Action Objectives
Remedial action objectives for TRA (OU 2-13) were developed in accordance with the NCR and
CERCLA RI/FS guidance. The RAOs were defined through discussions among agencies (IDHW, EPA,
and DOE). The RAOs are based on the results of the human health risk assessment and are specific to the
COCs and exposure pathways developed for OU 2-13. They are as follows:
For protection of human health
Inhibit direct exposure to radionuclide COCs that would result in a total excess cancer risk of
greater than I in 10,000 to 1,000,000 (1E-04 to 1E-06) to current and future workers and future
residents.
Inhibit ingestion of radionuclide and nonradionuclide COCs by all affected exposure routes
(including soil and groundwater ingestion, and ingestion of homegrown produce) that would
result in a total excess cancer risk of greater than 1 in 10,000 to 1,000,000 (I E-04 to lE-06)or
a hazard index greater than I to current and future workers and future residents.
Inhibit degradation of any low-level soil repository covers (e.g., Warm Waste Pond 1952 and
1957 cell covers) that would result in exposure to buried wastes or migration of contaminants to
the surface that would pose a total excess cancer risk (for all contaminants) of greater than 1 in
10,000 to 1,000,000 (1 E-04 to 1E-06) or a hazard index greater than 1 to current and future
workers and future residents.
For protection of the environment
Inhibit adverse effects to resident populations of flora and fauna, as determined by the
ecological risk evaluation, from soil, surface water, or air containing COCs.
Inhibit adverse effects to sites where COCs remain in place below ground surface that could
result in exposure to COCs or migration of COCs to the surface.
To meet these objectives, preliminary remediation goals (PRGs) were established. These goals are
quantitative cleanup levels based primarily on ARARs and risk-based doses. The PRGs are used in
remedial action planning and assessment of effectiveness of remedial alternatives. Final remediation goals
are based on the results of the baseline risk assessment and evaluation of expected exposures and risks for
selected alternatives.
The I chance in 10.000 risk (1 E-04) or hazard index of 1, whichever is more restrictive for a given
contaminant, is the primary basis for determining PRGs for the OU 2-13 sites of concern. The basis for
using the upper end of the 1 E-04 to I E-06 is justified based on the remoteness of the site, conservatism of
the risk assessments, the absence of current residents, and modeling 100 years in the future for tuture
residents, and as consist-in \\iui c.\|>usuie levels established 10 he acceptable by EPA tor radionuclides.
Preliminar> remediation goals for individual COCs were defined h\ calculating soil concentrations that
would result in excess- cancer risks equal to I E-04 or rui/urd indexes equal to I lor the 100-year future
7-1
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residential exposure scenario due. to exposure to all of a site's COCs. For example, if a given site
contained only one COC. the PRO basis for the COC was risk equal to 1E-04 and hazard index equal to I.
But it" the site contained two COCs, the PRO basis was risk equal to IE-0 I divided by 2 (or 5E-05) and a
hazard index equal to 1/2. The primary COCs for WAG 2 are radionuclides. Table 7-1 presents the final
remediation goals that have been established tor the eight sites of concern in OU 2-13. Remedial actions
will ensure that risk is mitigated to the point that exposure would not exceed these levels. On the basis of
these remediation goals, areas and volumes of contaminated media that would require some form of
remedial action were identified. These estimated areas, depths, and volumes are presented in Table 7-2.
7.2 Summary of Alternatives
In accordance with Section 121 of CERCLA. the FS identified alternatives that (a) achieve the stated
RAOs, ib) provide overall protection of human health and the environment, (c) meet ARARs, and (d) are
cost effective. These alternatives, used individually or in combination, can satisfy the RAOs through
reduction of contaminant levels, volume or toxicity, or by isolation of contaminants from potential
exposure and migration pathways. For OU 2-13 (TRA) sites, soil is the only medium of concern targeted
for remediation. Five alternative categories were identified to meet the RAOs for contaminated soil at
OU 2-13 sites:
1. No Action (with monitoring)
2. Limited Action
3. Containment and Institutional Controls
4 Excavation, Treatment, and Disposal
5. Excavation and Disposal.
Estimated present worth costs for the remedial alternatives for all sites are shown in Table 9-2 in
Section 9. Post-closure costs were estimated for the full duration of the 100-year period of monitoring.
7.2.1 Alternative 1: No Action {With Monitoring)
The NCP 140 CFR 300.430(e)<6)| requires consideration of a No Action alternative to serve as a
baseline for evaluation of other remedial alternatives. The No Action (with monitoring) alternative does
not involve active remedial actions but environmental monitoring may be warranted if contamination were
left in place under this alternative. Monitoring would enable identification of potential contaminant
migration within environmental media (air, groundwater, and soil) or other changes in site conditions that
may \\arrant future remedial actions. No land-use restriction, controls, or active remedial measures are
implemented at the she. If warranted, monitoring is an institutional action assumed to remain in effect for
at least 100 \ears. For the sites in this ROD. environmental monitoring would consist of radiological
sur\e\s in appropriate areas and groundwuter monitoring. Air monitoring uill he performed as part of the
air monitoring program. It is anticipated that monitoring will be conducted at least annually, but the
ienc\ v^ill he determined during the remedial design as well a- the appropriate areas.
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Table 7-1. Final remediation goals for OU 2-13 sites of concern.
Site
Warm Waste Pond (TRA-03)
Chemical Waste Pond (TRA-06)
Cold Waste Pond (TRA-08)
Sewage Leach Pond (TRA- 1 3)
Contaminant
of Concern
Ag-l()8m
Cs-137
Eu-152
Ba
Mn
Hg
Zn
As
Cs-137
Hg
Zn
Ag-I08m
Cs-137
Final Remediation Goals
(mg/kg for nonradionuclides
pCi/gm for radionuclides)J"'
0.39
7.78 .
90.9
92ft
146
0.47
43.3
18.3
11.7
0.94
86.6
0.58
11.7
Soil surrounding hot waste tanks at Cs-137 23.3
Building 613 (TRA-15)
Soil surrounding Tanks I and 2 at Cs-137 23.3
Building 630 (TRA-19) '
Brass Cap Area Cs-137 23.3
Sewage Leach Pond Berm and Soil Cs-137 23.3
Contamination Area
.1. Final remcdiaiion goals arc soil concentrations ol'COCs that would result in a cumulative excess cancer risk of I in lO.tXK)
or a ha/ard index greater than I for the 100-year residential exposure scenario. These may vary during the actual cleanup in
recognition of natural background levels as established in Rood. 1995. and in recognition thai cleanup 10 within (he
acceptable risk range could he achieved wrth a different mix of the COCs than was assumed in establishing these final
remediation goal generated during the RI/FS process.
-------
Table 7-2. Estimated area and volume of contaminated media requiring remedial action.
Sue
Surface Area
(fr)
Depth of
Contamination
(I'D
Soil Volume'1
(ft1)
Disposal Pond Sites
W;n in Waste Pond (TRA-03)
Chemical Waste Pond (TRA-06)
Cold Waste Pond (TRA-OS)
Sewage Leach Pond iTRA-13)
Subsurface Release Sites
Hot Waste Tanks at Building 613
(TRA-15)
Tanks I and 2 at Building 630
iTRA-19)
Brass Cap Area
Windblown Surficial
Contamination Site
Sewage Leach Pond Berm and Soil
Contamination Area (outside
fence)
5.88E+04
2.90E+04
1.58E+05
3.25E-t-04
6.24E+02
ft.lXIF.+Ol
2.83E+02
2.26E+05
I.23E+OI
5.(X)E-OI
5.(X)E-OI
f>.<)OE+00
3.83E+OI
I.OOE+OI
7.23E+05
I.45E+04
7.92E+04
1.95E+05
2.39E+04
6.00E+02
2.83E+03
I.13E+05
.1 liMimateil Miil volume lor remediation = 6.24E+03 !'»'
on I0-l'i excavation Jepth.
While the Nn Action alternative does not involve any construction or operational activities that
would result in disturbances ?> the surfaces ofthe Ol' 2-13 sites. IDAPA 16.01.01.650 could nonetheless
appK to an\ sites that were a source of fugitive dust and is, therefore, considered an ARAR that would not
he met. If metals and semivolatile organic compounds were present in fugitive dust, then IDAPA
I6.0I.OI.5X5-5S6 are ARARs that would not he met. 40 CHR I22.2h would similarly apply, and would
not he met. IDAPA 16.01.1 1.200 would he met hy ongoing groundwater monitoring. The No Action
alternative would not meet DOE orders hecause health risks to current workers and potential future
residents exceed allowable ranges. The estimated cost for implementing the No Action (with monitoring)
alternative is relatively low when compared to the other alternatives and ranges from S2.2M at the Brass
Cap site to S.V2M at the Warm Waste Pond.
7.2.2 Alternative 2: Limited Action
A Limited Action alternative was developed primarily for those sites posing an unacceptable risk 10
current and future workers and for which the radionuclidc contamination will decay to acceptable levels
within the next l'io \ears However, iliis alternative mav he implemented in conjunction with a contingent
7-4
-------
remedial alternative for those sites determined to pose an unacceptable risk and where access is physically
limited thereby inhibiting full implementation of the contingent remedy at this time. This alternative
essentially continues management practices and institutional controls currently in place at OU 2-13
disposal pond, surficial contaminated soil, and buried contaminated soil sites. Current management
practices and institutional controls are in place as a result of Department of Energy responsibilities and
authorities for maintaining security, control, and safety at DOE facilities. These responsibilities and
authorities have their basis in the Atomic Energy Act of 1954. For DOE facilities. Federal Regulation 10
CFR 835 implements the Radiation Protection Guidance to Federal Agencies for Occupational Workers.
recommended by the EPA and issued by the President on January 20, 1987. The requirements of this
regulation include standards for control of occupational radiation exposure, control of access to
radiological areas, personnel training, and record keeping.
In addition, the regulations specify limits for maintaining occupational radiation exposure as low as
reasonably achievable (ALARA), and requires that DOE activities be conducted in compliance with a
documented radiation protection program approved by DOE. At INEEL, the requirements of 10 CFR 835
are primarily implemented through DOE Order 5400.5. Regulations for the protection and security of
DOE facilities are included in. 10 CFR 860, which prohibits unauthorized entry. This regulation is
implemented through DOE Order 5632.1C. At the INEEL, the requirements of this order are primarily
implemented through DOE's Management and Operating Safeguards and Security manuals. The manuals
and associated control procedures define the programs and requirements for protecting INEEL property.
personnel, and sensitive information. The manuals include defining the processes for protecting controlled
property from theft, intentional acts of destruction and misuse, access controls for employees and offsite
visitors to the INEEL, and procedures for conducting investigations or security incidents.
A description of the areas where access will be restricted, the specific controls (e.g., fences, signs)
that will be used to ensure that access will be restricted, the types of activities that will be prohibited in
certain areas (e.g., excavation), and the anticipated duration of such controls will be placed in the "INEEL
Comprehensive Facility and Land Use Plan" maintained by the Office of Program Execution. DOE shall
also provide the Bureau of Land Management the detailed description of controls identified above. This
information will be submitted to the EPA and IDHW once it has been placed in the INEEL Comprehensive
Facility and Land Use Plan.
DOE-ID will submit a written evaluation of the effectiveness of the institutional controls at the TRA
as part of every 5-year review. This report, at a minimum, will include a description of a walk-through of
the areas subject to institutional controls conducted at the time of each 5-year review.
Short-term effectiveness of this alternative is considered high, as this alternative is already
implemented at the sites. Radiation control area fences and signs are maintained. No specialized
equipment, personnel, or services are required to continue to implement the Limited Action alternative.
Implementation of this alternative would have no physical effect or habitat alteration on the environment
beyond what is already there.
The estimated costs for implementing the Limited Action alternative are described in Sections 8
and 9 of this ROD.
-------
7.2.3 Alternatives 3a and 3b: Containment Alternatives and Institutional Controls
The two containment alternatives consist of the isolation of contaminated soil from potential
receptors (for the period of time that unacceptable cumulative exposure risks will be present) through the
use of a protective cover followed by institutional controls, including long-term environmental monitoring,
|as described above for the No Action (with monitoring) alternative) cover integrity monitoring and
maintenance, access restrictions, and surface water diversion. Institutional controls are assumed to remain
in effect for at least 100 years. These alternatives were considered for the Waste Disposal Ponds and
Subsurface Release Sites at TRA.
Alternative 3a consists of an engineered cover originally developed by the Uranium Mill Tailings
Reme.dial Action program for stabilization of abandoned uranium mill tailings. This design, based on
recent biointrusion research studies at the INEEL. was recently constructed at the INEEL stationary Low-
Power Reactor-I burial ground site (Figure 7-1). This cover
Requires minimal maintenance
Inhibits inadvertent human intrusion
Minimizes plant and animal intrusion
Inhibits contaminant migration.
The cover design consists of four layers of natural geologic materials, with the uppermost layer
consisting of rock riprap to inhibit intrusion and minimize erosion, a second layer of gravel overlying a
third layer of riprap or cobbles, and a fourth layer consisting of gravel. Deviation from this sequence of
materials and respective material thicknesses is not anticipated; however, the engineered cover design may
be refined during the remedial design phase.
Alternative 3h consists of a native soil cover. This cover consists of a 10-ft (3-m) single layer of
lower permeability soil obtained on the INHEL. applied in lifts and compacted to 95% of optimum
moisture and density (see Hgure 7-1 ). The surface would be completed to promote runoff and may be
vegetated with a crested wheatgrass mixture that does not require supplemental water or nutrients once
established, or a gravel mulch/rock armor material to he determined during remedial design. Specific
design elements tor the native soil cover will be developed during the remedial design phase.
Hach capping technology is designed to prevent direct radiation exposures, resist erosion because of
wind and surface water runoff, and resist biointrusion that may penetrate the contamination zone or
facilitate erosion. The primary differences between capping technologies are (he length of time these
functions can he maintained and the effectiveness of the bioimrusion and erosion control components of
the designs. The dcMiMi life of the capping technologic'- specified for the containment alternatives will
depend on the construction materials specified, number and thickness of la\cis required, and sequence of
(hose lavers. The long-term effectiveness and permanence required at the Warm Waste Pond and the
Sewage Leach Pond is at least the dcca\ time required to reduce external exposure risks to acceptable
levels. The engineered harrier design is hkel\ (o provide a higher level of protection against biointrusion.
Thick soil will eliminate intrusion into waste rn most INI-HL species, but not all plants and invertebrates.
Root intrusion into contaminated soil-, could result m mohih/ation of radionuclidcs to environmental
-------
24" Nominal Riprap
-12" Cobble
4" Gravel
Approx 190'
Not to Scale
RED V97 0184
Crested Wheatgrass (INEEL Mix)
Native Soil Cover
^^^-r^^^m^i^m
rrTv^?-1 :'^mK^3&&23§?
Contaminated Soil
Clean Fill
Not to Scale
RED V97 0174
Figure 7-1. Cross-seciinnul schematic typical of" the engineered cover and the native soil cover.
-------
receptors. The engineered barrier is also likely to provide more effective control of wind erosion.
Vegetated surfaces are erosion resistant, but fire and other natural and human activities, including grazing,
could reduce or eliminate vegetation and allow wind erosion to occur.
Environmental impacts resulting from the excavation and construction activities would be minimal.
Materials would be excavated, transported, and placed entirely within previously disturbed areas.
Installation of surface water diversion controls at the OU 2-13 disposal pond sites might result in alteration
of the nearby terrain. However, the overall impact of these activities is not considered irreparable and
would be unnoticeable in the long run. The remoteness of the site would prevent any impact to the
surrounding communities during construction activities. No environmentally sensitive areas such as
archaeological or historical sites, wetlands, or critical habitat exist in the vicinity of the OU 2-13 sites,
because all are in previously disturbed areas.
Costs associated with the cover alternatives at each site are detailed in Sections 8 and 9 of this ROD.
7.2.4 Alternative 4: Excavation, Treatment, and Disposal
Standard treatment technologies have not been shown to be effective for the radionuclide-
contaminated soils at INEEL. Based on previous INEEL studies, no technology or combination of
technologies has been demonstrated to be able to achieve significant volume reduction of radionuclide-
contaminated TRA soils and sediments, primarily because of the binding of cesium in both surface
microfissures of large-grained soil fractions, and in the silicate lattices of clay materials of fine grained
fractions.
Technologies evaluated include physical separation using screening, flotation, attrition scrubbing,
monitor and gate systems, soil washing, chemical stabilization, and thermal treatment using plasma torch.
Therefore, this alternative was identified as being potentially applicable only to the sediments of the
Chemical Waste Pond (TRA-06) that are contaminated with mercury. Under this alternative, those
sediments with mercury concentrations exceeding 260 ppm would be excavated and treated with a mercury
retort process. These sediments would be heated, volatilizing mercury as a vapor. The vapor would be
subsequently cooled, and the liquid mercury would be recovered for recycling and disposal. Equipment
would include a feed conveyor, heating units, heat exchangers, condensers, and air pollution control
equipment, including a baghouse and granular activated carbon absorbers. This alternative would achieve
lohsi-term effectiveness because of the expected reduction in contaminant mobility, volume, and toxicily of
the treated sediments.
Implementation of the mercury retort process is dependent on mercur\ contamination being present
at concentrations exceeding 260 ppm and whether the mercury is in an elemental or ioni/.ed state. During
the remedial design phase, further consideration may also be given toother potentially appropriate
treatment .process options identified in the OU 2-13 comprehensive RI/FS such as stabilization of mercury-
contaminated soils. The determination as to whether this treatment technology is appropriate or not will be
dependent upon post-ROD sampling of the Chemical Waste Pond. The goals of the post-ROD sampling
will he to determine the nature and extent of contamination at the Chemical Waste Pond, although it is
anticipated that mercur\ will be the primary focus of the sampling effort. The costs associated \\ith
excavation, treatment, and disposal are estimated in Section S and *) of this ROD.
-------
7.2.5 Alternative 5: Excavation and Disposal
This alternative involves complete removal of material contaminated at unacceptable concentration
levels from a human health perspective, to levels of intrusion (maximum of 10 ft) or to the maximum depth
at which contaminant concentrations exceed preliminary remediation goals, whichever is less. This would
be followed by offsite transportation and disposal at a disposal facility licensed to receive low-level
radioactively contaminated soils. Verification samples would be collected to ensure that the final
remediation goals were met.
The license for a disposal facility will specify the radionuclide activity levels that can be accepted.
Transportation would involve a combination of onsite trucking to a railhead and offsite rail transportation
to the disposal facility.
This alternative provides long-term effectiveness because the contamination would be removed from
the site. Long-term monitoring would no longer be required, assuming removal of contaminated soils
achieve acceptable levels. Costs of excavation and disposal, which are high compared to other alternatives
considered, can be found in greater detail in Sections 8 and 9 of this ROD.
7.3 Summary of Comparative Analysis of Alternatives
The five alternatives discussed in Section 7.2 were evaluated using the nine evaluation criteria as
specified by CERCLA:
1. Overall protection of human health and the environmentaddresses whether a remedy
provides adequate protection of human health and the environment, and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled through treatment.
engineering controls, or institutional controls.
2. Compliance with ARARsaddresses whether a remedy will meet all of the ARARs under
federal and state environmental laws and/or justifies a waiver.
3. Umf>-term effectiveness and permanencerefers to expected residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time, once
cleanup goals have been met.
4. Reduction oftoxicity. mobility, or volume through treatmentaddresses the degree to which a
remedy employs recycling or treatment that reduces the toxicity, mobility, or volume of the
COCs. including how treatment is used to address the principal risks posed by the site.
5. Short-term effectivenessaddresses any adverse impacts on human health and the environment
that may he posed during the construction and implementation period, and the period of time
needed to achieve cleanup goals.
6. linph'nient
-------
8. Suite turcptanci'reflects aspects of the preferred alternative and other alternatives that the
state favors or objects to. and any specific comments regarding state ARARs or the proposed
use of waivers.
9. Community acceptancesummarizes the public's general response to the alternatives described
in the Proposed Plan and in the RI/FS. based on public comments received.
Table 7-3 presents the results of the comparative analysis of the five alternatives using a ranking
based on an alternative's ability to meet the nine evaluation criteria. Table 7-4 provides a ranking of
alternatives for each on the basis of the comparative analysis. The following sections describe how each
alternative either does or does not meet the criteria.
Each of the five alternatives subjected to the detailed analysis was evaluated against the nine
evaluation criteria identified under CERCLA. The criteria are subdivided into three categories:
(1) threshold criteria that mandate overall protection of human health and the environment and compliance
with ARARs, (2) primary balancing criteria that include long- and short-term effectiveness,
implementability, reduction in toxicity. mobility or volume through treatment, and cost; and (3) modifying
criteria that measure the acceptability of alternatives to state agencies and the community. The following
sections summarize the evaluation of the five alternatives against the nine evaluation criteria.
7.3.1 Threshold Criteria
The remedial alternatives were evaluated in relation to the two threshold criteria: overall protection of
human health and the environment, and compliance with ARARs. The selected remedial action must meet
the threshold criteria. Although the No Action alternative does not meet the threshold criteria, this
alternative was used in the detailed analysis as a baseline against which the other alternatives were
compared, as directed by EPA guidance.
7.3.1.1 Overall Protection of Human Health and the Environment. This criterion
addresses whether a remedy provides adequate protection of human health and the environment and
describes how risks posed through each exposure pathway are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
Alternatixe I (No Action With Monitoringi would not satisfy the criterion of overall protection of
human health and the environment because access to the site and contact with the waste are not presented.
Alternative 2 (Limited Action) would be effective for protecting human health and the environment.
Institutional controls, including access restrictions, are regarded as reliable for at least 100 years following
site closure. With the exception of mercury at the Chemical Waste Pond. COCs were determined to
degrade to risk levels less than IE-04 within KM) years. Therefore, no long-term human health risks will
exist alter that time. Institutional controls at the Chemical Waste Pond would have to be maintained
permanently as the COC. mercury, does not degrade.
Regarding both the engineered harrier (Alternative 3ai. and the native soil cover (Alternative 3hi.
each containment alternative involves the use of institutional controls (radiation surveys, cap integrity
" -""oring, and access restrictions) and surface water diversion controls. Surface water diversion controls
will he maintained at least until the 100-year institutional control period expires. Alternative 3a
i engineered harrieri is expected to he highly protective of human health and the environment tor at least
-------
Table 7-3. ('omparative analysis summary of remedial alternatives for OU 2-13 sites of concern.
Alternative 3a
Miciii.ilnc 1 No Aitinn Alternative J Containment v>/
Cnleiiii uviih imiiiilniiiigi Limited Action Hnginecred Cover
( >vcrall Protection of Human Health and Ihe
Hum. in Health Risks .iic nni icdmcd Is rllcuivc ten iluiaiion Inhibits direct exposure
1'ioitMioii ol nsk in eonlaminated soil for
duration of
unacceptable risk.
Minimal exposure risk
during cover
construction.
Alleinalive .'b
Containment u/Native
Soil Cover
Kmiinmncnl
Inhibits dnecl cxpnsuic
to contaminated soil I'm
duialion of unacceptable
risk. Minimal cxposuie
risks during cover
construction. Less
resistance to erosion than
engineered cover Less
effective than engineered
cover for inhibiting
bioinlrusion
Altcinalivc -1
Rxcavalion. Trcalmcm.
and Disposal
Eliminates potential
exposure fiom
contaminated soil al site
Protective-ness is based
on completely 'removing
contamination from Ihe
site. Short-term lisk is
moderate due to diiecl
exposure during
excavation.
Alleinalive 5
Kxcavalinn and Disposal
Llimmalcs potential
exposure horn
conlaininaled soil al site.
Proicclivcncss is based
completely on removing
contamination from ihe
site. Short-term risk i.s
moderate due to direct
exposure during
excavation.
Allow s micialiiin ot
itiiil.imin.ilctl suil.u'e
soil In \Miid and Mil I.ILL'
vv.tici eiosinn and
pi.>Mili-s little pinleclinn
linui expnsuie
Risk icdiiclinn ai
Provides effective
protection for duration
of unacceptable risk.
Minimal environmental
impacts during
construction. Inhibits
intrusion by burrowing
mammals and deep-
inoted plants.
('lovules uuxlerale
protection Inr duration of
unacceptable nsk
However, bioinlrusion
into contaminated soils
may result in exposure to
contaminants. Minimal
environmental impacts
during construction
Rliininaies
contamination linm SIR
and is therefore highly
protective
Eliminates
conlammation from ihe
site and is iheiefote
highly protective.
Compliance with ARARs
Would nnl meet AKAKs Meets AKAKs fur pcnod Meets ARARs
lot fugitive ilusi ol lime when
emissions management and
institutional cnniinls in
place
Would not meet AR AKs Meets AKAKs lor pcinul Meets ARARs
loi KHiliol nl sloimualci ol time \\hen
ilisihaij;c iiianaj.'emeni and
liislilulinii.il cnniinls in
place
Meets ARARs
Meeis ARARs
Meets AKAKs
Meets ARARs
Meets AKARs
Meels ARARs
-------
Table 7-3
Allcin.iluc 1 NoAiiuin Allcinatiu- :
,MUM., mill, monilotm:.'! 1 mined Action
Allei native }a
Containment w/
Ijifineeied ("over
Attein.tli\e *b
Containment w/Nali\c
Soil Covci
Allcmalive -4
tixcavalion. Tiealnieiil.
and Disposal
Alternative S
I'.xcavatinn and Dispr
,sal
I In Nil. .ll -I1' '
\\niiltl ii uvl AKAKs
tm poundvi.ilci
piolci.tion sl.nulaiil^ .ilnl
McclN AKAKx liu iviii
cled pimiilcs adequate
control o\et
coniaiiimateil soil and
sediment lollowing
evcuvulion liom ihc site
Not applu.il
-------
Table 7-3. (continued).
Alternative
-------
Table 7-3. I continued I.
Alternative .'a
Alternative 1 NnAvii'in Alicinaiive J Containment w/
r,,u-n. iuillim.niil.nuit: I l.iimk-il Ailion hnymecred Covci
A|,lhu ,M,,KI.,,,.| \oiappluahlc (mu-ntly implemented Involves available
construction
l.pl-l.lll1
technology
1 ,,,c ..I implementing lv.iMl.ihi> ximlv/u-,. ml l'..'"'l> implemented Additional remedial
...Umonal .MI..M .1 ' ,,| dcnx,o,i PMKCXX may actions would be
,., ,.,., need h. U- ic,valc.l dil-ficull because the
burner is intended to
prevent access to
contamination.
1 heiefore, the harrier
would require removal
Molitv loiiKimnx Mo" '1-'"' condition- M.nuloiingol londiiionx Hauler .performance
i-lli-,.iivciu-xx ixu-.i,lilv iiiiplcineiiiol ixu-adil> iiiiploim-niol can he monitored
Allciiulivc 'h
Conlainincnl u/Nali\t'
Soil Cover
Involves avjil.ihk
i.insiiviclion technology
Adilili.uial icmedial
actions would he difficult
Ivcauxc the hamci ix
inlemlcd to prevent
accesx to contamination.
Ihcicloic. the hauiei
would require removal
Hauler pciloimance can
tv moniloieil through
Allein.ilive -4
Kuavalion. Ticalinciil.
anil Dixpoxal
Dilliuill. mvoKcx
available excavation and
pnvexxinj! ti-cliiloln^y
Additional remedial
action would not he
necexsaiy hecauxe all
contaminated soil and
sediment au- lenioved
The elieclivenexs in
removing and lieatiii):
IIII^~-I1B 1 1
Alternative 5
l:\cavalion and Dixpoxal
Somewhat ilill'icull due
lo safely requireiuenix
Additional leinedial
action would not he
necessary because all
contaminated soil and
dehiis are removed
The cll'cclivcncss in
lemoving all
No appiovals leqm.e.l No appiovalx u-quuol
iluoiij;h radiation
suivcys. physical
integrity can be visually
asxcx.xeil.
No difficulties
identit'ied.
ladialion suiveys.
physical integrity can he
visuallv assessed
No difficulties identified
None u-quued
Han in design and
seivices exist within the
DOH and are
considcied readily
available to the INEF.I.
Hairier design and
si-ivtccs exist within the
DOC and aie considered
readily available lo the
INF.F.I.
all KCKA-ha/aid.uis
eonlaminaled iiiatenals
assiK-iated with the MIL-
IS easily determined
Difficult due to potential
requirements loi
environmental
assessments, safety
analyses, and AKAKs
compliance
Services available t-iihei
onsite or through
subcontractor, recycling
facility assumed
available based on pnor
INF.HI. actions
contaminated materials
associated with the site
is easily moniloieil
Difficult due lo potential
requirements tor
enviuiniiicntul
assessments, safety
analyses, and AKAKs
compliance
Set vices available eilhei
onsite or through
subcontractor
-------
Table 7-3. (continual).
Alternative .la
Allciiialive 1 No Action Alternative 2 Containment w/
("iilciia (with iiioiiiliinngi Limited Aclion Engineered C'over
\\.nlal>ilil\ 2 See Table 9-2 See Table 9-2
Alternative 'h
('onlainnienl w/Nalive
Soil ("ovci
Eqiiipmenl and maleiials
aic teadil) available al
the INEULoi wilhin the
suiioiinding
communities.
Easily accomplished
because operational
controls currently in
place. Materials and
services exist at the
INEEL to invoke
additional controls if
necessary
Technology is icadily
available al Ihc INEEL.
See Table 9-2
Alternative 4
Excavation, Treatment.
and Disposal
Equipment and
inatenals are eithci
available nnsile 01
thiongh subconlraciois
Easily accomplished
because operational
controls currently in
place Maleiials and
services exist at the
INEEL lo invoke
additional controls it
necessary
Technology is available
through subcontractors
See Table 9-2
Alletnativc 5
Excavation and Disposal
Equipment and
maleiials ate cither
available onsile. Ihiough
Mibcontiaclois. or will
be puichascd Trained
specialists arc available
wilhin the commiinilies
surrounding (he INEEI.
None iei|iiircd
Readily available al the
INEEL.
See Table 9-2
-------
Table 7-4 Kdalive ranking of alternatives evaluated lor the eight OU 2-13 sites of concern.
VAaini \VaMc
Pond
tTRA-03)
Chemical Waste Cold Waste Sewage
pond I'ond Leach Pond
ilKA-tHD (TRA-OH) (TRA-13)
Soil Surrounding
Hoi Waste Links
.ii Huilding 613
(TRA-I5I
Soil
Surrounding
Tanks I and 2
al Building f»3<>
(TRA-IVi
Brass Cap
Atea
Sewage Leach
Pond Ucrin and
Soil
Contamination
Area
-I
5. \.t. <|>. I X 4. 3a. Mi. I 5. 3a. 3h. I 5. 3a. 3b. I
I inn; leini cilci iivencsx
.Hill |>CMIlanCMCe
Reduction ol toMcilv.
inohilil). 01 volume
lIllollL'll lUMllllCMl
s. «.,. Mi. I 4. 5. la. . I. l'' 3a. X -4 1. 3h. 3a. 5 1. 3h. 3a. 5
I I,,. MI. 5 V I M\ 3a .4 5.1. 3h. 3a 1. 3h. 3a. 5
2. 3a. 5
2. 5. 3a. I
N/A
1. 2. 3a. 5
1.2. 3a. 5
1. 2. 3a. 5
5. 3a. I
N/A
1. 3u. 5
1. 3a. 5
5. 1. 3a
5. 3a. I
3a. 5
5. 3a. I
N/A
1. 3a. 5
1. 3a. 5
5. l.3a
S. 2. I
N/A
1.2.5
1.2.5
1.5.2
.. II | (|| ||u. ||>(Cl| jlii'inaiivcs. lor each Mie ol concein. is the relative ranking from best to worst in meeting the CbRCLA evaluation criteria (e.g.. when considering
I \\ i in W Me Pond lot "( hciall piolcciion ol hiiinan health and the environment" the highest ranked alternative is containment with an engineered cover" (3a). and the
i . i ..i ..i , ..,,.. iv sin .Vi-iion" I I I
lowest Linked altemalive is "No Action I I)
Alternative I
Alternative -
AlieiiMiive 'a
Mlein.itive Mi
\lleinative 4
No Action
Limited Action
Conlainmeni w/cnuinceicd cover
Containinent vv/native soil cover
l-\cavalioM. lic.ilinciil Imcrciirv retort) and disposal
I'Acavalion and Disposal
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the length of time an unacceptable risk is posed at the OU 2-13 buried soil and disposal sites. The
engineered cover ensures long-term protection because it uses natural construction materials approximately
4 ft thick. Functional requirements of this cover would include inhibiting human and biotic intrusion, as
well as meeting other RAOs. The thickness of this barrier would be more than sufficient to shield against
penetrating radiation above background levels. Furthermore, this barrier would be designed to inhibit
inadvertent human intrusion, and resist erosion from wind and surface water runoff. This barrier would
also inhibit biotic intrusion, thereby controlling exposure pathways to environmental receptors. The native
soil cover (Alternative 3b) is designed for long-term isolation of waste with minimal maintenance
requirements. The cover surface would provide erosion control, and the cover soil thickness would inhibit
biointrusion into contaminated soil. However, the potential would exist for deep-rooting vegetation or
burrowing invertebrates to mobilize radionuclides into the environment.
Alternative 4 (excavation, treatment, and disposal) involves excavation of mercury-contaminated
soils and pond sediments at the Chemical Waste Pond, treatment in a mercury retort, and return of clean
soils to the disposal pond. For the purposes of this evaluation, it is assumed that all pond sediments would
fail the TCLP and require treatment. This alternative provides highly effective, long-term protection of
human health and the environment. The removal of all mercury-contaminated soils from the Chemical
Waste Pond would eliminate potential long-term human health and environmental concerns associated
with future exposure of mercury migration from the pond. Recycling and/or reuse by an approved and
permitted industrial facility is assumed to ensure complete elimination of risks to human health and the
environment at this site.
Finally, excavation and disposal (alternative 5) provides highly effective, long-term protection of
human health and the environment. The removal of all contaminated soil from OU 2-13 sites of concern
would eliminate potential long-term human health and environmental concerns associated with future
exposure of contaminant migration from uncontrolled radioactive waste disposal sites. This alternative is
also environmentally protective during implementation, based on the contamination mitigation activities
that would be used to prevent contaminant migration during excavation activities. However, short-term
protection of human health is less effective because workers would receive direct exposure to contaminated
soil and debris during excavation.
7.3.1.2 Compliance with Applicable or Relevant and Appropriate Requirements. While
the No Action alternative does not involve any construction or operational activities that would result in
disturbances to the surfaces of the OU 2-13 sites, most ARARs and To Be Considered (TBC) requirements
for the eight sites identified as having unacceptable risks or adverse noncarcinogenic health effects would
not be met under this alternative. Table 7-3 shows which ARARs would not be met under this alternative.
Most ARARs and TBCs would be met under the Limited Action alternative, with the exception of Idaho
Fugitive Dust Emission (IDAPA 16.01.01.650 et seq) requirements and Storm Water Discharge
regulations (40 CFR 122.26). While the Limited Action alternative does not involve any construction or
operational activities that would result in disturbances to the surfaces of the OU 2-13 sites, IDAPA
16.01.01.650 could nonetheless apply to the existing Warm Waste Pond cells if they were a source of
tiigime diiM and is. therefore, considered an ARAR that would not be met. The ARARs pertaining to
current workers .ire met through administrative controls in place at TRA: these controls would remain in
effect during the institutional period (at least 100 years). If metals and SVOCs were present in fugitive
dust, then IDAPA 16.01 OI.5X>-5*r» :»r,- -\RARs that would not he met
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All ARARs and TBCs would be met under the containment alternatives (Alternatives 3a and 3b).
Containment actions, including the use of institutional controls, would reduce the external exposure risk
associated with contaminated soil left in place at disposal ponds and subsurface release sites.
Alternative 4 involves excavation, treatment, and disposal at the Chemical Waste Pond (TRA-06) only.
This alternative satisfies all ARARs and TBCs, provided proper engineering controls (i.e.. dust
suppression and retort emissions control) are followed during excavation and treatment. Excavation and
disposal (Alternative 5) would comply with all ARARs and TBCs. Compliance with the emissions control
ARARs would be ensured by performing excavation using water sprays and other techniques for dust
suppression, as needed.
Recent investigations have determined that RCRA-listed waste may have been present in the TRA
warm and hot waste systems when leaks from the systems to the environment occurred. Therefore, soils at
those sites associated with releases from the warm and hot waste systems will be managed in a manner
consistent with the hazardous waste determination to be performed at the time of the remedial action.
7.3.2 Balancing Criteria
Once an alternative satisfies the threshold criteria, five balancing criteria are used to evaluate other
aspects of the remedial alternatives and weigh major tradeoffs among alternatives. The balancing criteria
are used in refining the selection of the candidate alternatives for the site. The balancing criteria are:
(1) long-term effectiveness and permanence; (2) reduction in toxicity, mobility, or volume through
treatment; (3) short-term effectiveness; (4) implementability; and (5) cost.
7.3.2.1 Long-Term Effectiveness and Permanence. This criterion evaluates the long-term
effectiveness of alternatives in maintaining protection of human health and the environment after remedial
action objectives have been met.
Alternative I (No Action With Monitoring) provides the least possible level of long-term
effectiveness and permanence because unacceptable risks would remain at the sites. The long-term
effectiveness and permanence of the Limited Action alternative (Alternative 2) is considered high as long
as administrative and institutional controls are in place to prevent human exposure to contaminated surface
soil. Alternatives 3a and 3b (containment alternatives and institutional controls) involve the installation of
either an engineered barrier or a native soil cover. Cap integrity monitoring and survey programs would be
implemented annually for the first 5 years following completion of the cap. and additional monitoring
requirements would be evaluated during subsequent 5-year reviews. Therefore, the long-term effectiveness
and permanence requirements are met by these alternatives. Each capping technology is designed to resist
erosion because of wind and surface water runoff and to resist biointrusion into the contaminated soil. The
design of the engineered cover provides greater permanence and lower maintenance. The native soil cover
would he more susceptible to erosion and biointriision and would require more maintenance and
monitoring than the engineered cover. Based on direct exposure reduction requirements, the Warm Waste
Pond N52 and \(-)^l cells would require long-term effectiveness and permanence lor a period of at least
27O years. Both containment designs would meet this requirement.
Alternative 4 (excavation, treatment, and disposal) at the Chemical Waste Pond has a high potential
fur achieving long-term effectiveness and permanence because soil contaminated greater than TCLP levels
IN complete!) removed, treated, and used as clean backfill in the excavation. Alternative 5 (excavation and
Ji-.povili h'as the highest potential for achieving long-term effectiveness and permanence because
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contaminated soil is completely removed from the site. This would reduce or eliminate the need for long-
term monitoring and maintenance and would likely eliminate the need for other institutional controls such
as fencing and deed restrictions.
7.3.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment. This criterion
addresses the statutory preference for selecting remedial actions that employ treatment technologies that
permanently reduce toxicity, mobility, or volume of the hazardous substances as their principal elements.
Treatment to reduce the toxicity of radionuclides is presently not feasible. Therefore, none of the remedial
alternatives, with the exception of excavation, treatment, and disposal of mercury contaminated soil at the
Chemical Waste Pond, involves the use of treatment to reduce the toxicity, mobility, or volume of
contaminated materials. At the Chemical Waste Pond, it is expected that treatment would reduce the
toxicity, mobility, and volume to acceptable levels, if treatment were deemed necessary.
7.3.2.3 Short-Term Effectiveness. Short-term effectiveness addresses the time needed to
implement remediation methods to reduce any adverse impacts on human health and the environment that
may be posed during the construction and implementation period until cleanup goals are achieved.
The short-term effectiveness for any remedial action taken at the TRA would be enhanced to the
maximum extent practicable through adherence to strict health and safety protocols for worker protection
and use of engineering controls to prevent potential contaminant migration. However, the alternative that
provides the least amount of disturbance to contaminated materials ranks the highest in terms of short-term
effectiveness. As such. Alternative 1 (No Action With Monitoring) provides the highest degree of short-
term effectiveness because no additional onsite activities are required. The Limited Action (Alternative 2)
alternative is already implemented at TRA through radiation control and fences, signs, and radiation
monitoring; as a result, short-term effectiveness is considered high. No specialized equipment, personnel,
or services are required to continue this alternative. Natural decay of radionuclides over time would reduce
the environmental and human health risk. Short-term effectiveness criteria for the containment alternatives
(Alternatives 3a and 3b) are met because exposure to construction workers during installation of the cover
would be minimized. Inhalation and ingestion risks would be minimized by the use of appropriate
protective equipment, engineering controls, and adherence to health and safety protocol, including the
DOB as-low-as-reasonably-achievable approach to radiation protection.
Risks from transportation would be low because of the likelihood of obtaining construction materials
from local sources. Environmental impacts during construction activities would be minimal. The
activities would occur within previously disturbed areas. The remoteness of the TRA site would prevent
any impact to surrounding communities during construction activities. Short-term effectiveness of
Alternative 4 (excavation, treatment, and disposal) at the Chemical Waste Pond is considered relatively
high provided administrative and engineering controls are properly conducted. Equipment-operator
exposures would be minimized to the extent practicable. Environmental impacts for this alternative are
minimal and are similar to those for the excavation and disposal alternative. The RAOs would be achieved
hy this alternative once excavation, treatment, and disposal of treated soil is complete. Alternative 5
(excavation and disposal) offers the least short-term effectiveness because of direct contact with
contaminated materials during excavation and transportation of the disposal facility. However, radiation
controls and monitoring would be implemented to mitigate these risks.
Equipment-operator exposures would be mimmi/ed to the extent practicable through shielding, use
nf supplied air. air tillers, and other engineering controls (i.e.. dusl suppression). In addition, exposure
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could be reduced through reduction in the amount of time spent at the site by any one worker. Some
environmental disturbance is likely to occur in the area surrounding the excavation and haulage route.
However, these impacts would be temporary and restoration of disturbed areas would occur following
completion of construction activities. The RAOs would be achieved by this alternative once excavation
and disposal are complete.
7.3.2.4 Implementability. The implementability criterion has the following three factors
requiring evaluation: (I) technical feasibility, (2) administrative feasibility, and (3) the availability of
services and materials. Technical feasibility requires an evaluation of the ability to construct and operate
the technology, the reliability of the technology, the ease of undertaking additional remedial action (if
necessary), and monitoring considerations. The ability to coordinate actions with other agencies is one
factor for evaluating administrative feasibility, and the agencies have demonstrated this ability throughout
the project to date. Other administrative activities that would be readily implementable include planning,
use of administrative controls, and personnel training. In terms of services and materials, an evaluation of
the following availability factors is required: necessary equipment and personnel, prospective technologies,
and cover materials.
Alternative 1 (No Action With Monitoring) is the simplest remedial action to implement from a
technical perspective because environmental monitoring is all that may be required. If required,
monitoring would be performed until future reviews of the remedial action indicate that such activities are
no longer necessary. Environmental monitoring services and equipment are readily available. However,
Alternative I is administratively unacceptable because of the potential risks to human health and the
environment posed by the TRA sites of concern. Implementability for Alternative 2 (Limited Action) is
high because most administrative and institutional controls are already in place and access to contaminants
is currently restricted. The containment alternatives (Alternatives 3a and 3b) are readily implementable
based on local sources of materials, conventional construction equipment and methods, and easily
implemented institutional controls, including long-term monitoring, cap integrity monitoring, access
restrictions and surface water runoff control. Long-term activities following cover construction would
include radiation surveys, annual review of cover integrity, institutional controls for 5 years, and
subsequent 5-year reviews. Containment activities have been successfully implemented in other areas of
the INHEL. At the Chemical Waste Pond, Alternative 4 (excavation, treatment, and disposal) is readily
implementable.
Treatment of mercury-contaminated soils has been previously demonstrated to be effective at the
INEEL and at identified industrial facilities willing to take recovered mercury. Alternative 5 (excavation
and disposal) would be moderately difficult to implement because of the complexity of the retrieval system
with respect to safety considerations and containment requirements. Significant effort would be required
to perform environmental assessments, safety analyses, and equipment modifications (for operator safety).
as well as system testing and demonstration. Although the equipment and technology are available to
perform the activities specified in this alternative, increased risks to workers during excavation result in
lower implementability relative to other alternatives.
7.3.2.5 Cost. In evaluating project costs, an estimation of the direct and indirect costs in present
worth dollars is required. Present worth costs are estimated assuming variable annual inflation factors for
the first H> years, and a constant 5'J annual inflation rate after that. A constant 5rr discount rate is
assumed. Direct costs include the estimated dollars tor equipment, construction, and operation acli\itics to
conduct a remedial action. Indirect costs include the estimated dollars for activities thai support the
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remedial action (such as consiruction management, project management, and management reserve). In
accordance with the RI/FS study guidance, the costs presented in Table 9-2 are estimates (-30 to +50%).
Actual costs will vary based on the final design and detailed cost itemization.
The costs associated with Alternative 1 (No Action With Monitoring) involve only radiation surveys.
Post-closure costs were estimated for the full duration of the 100-year period of monitoring. The costs
associated with Alternative 2 (Limited Action) involve only radiation surveys and maintaining existing
fences, such as the one located at the Sewage Leach Pond Soil Contamination Area. For Alternatives 3a
(engineered barrier) and 3b (native soil cover) the cost estimate is based on constructing the engineered
and native soil cover, installing surface water diversion controls, using monitoring equipment, conducting
analyses, and post-closure maintenance and monitoring. Costs for the native soil cover are lower than for
the engineered cover because of the simple design. At the Chemical Waste Pond, costs associated with
excavation, treatment, and disposal are considered moderate. The estimated cost for Alternative 5 ,
(excavation and disposal) is relatively high. The implementation requirements significantly increase the
cost associated with this alternative. No post-closure monitoring or care is required because the
contaminants will be removed.
7.4 Modifying Criteria
The modifying criteria, state and community acceptance, are used in the final evaluation of remedial
alternatives. For both of these criteria, the factors include the elements of the alternatives that are
supported, the factors of the alternatives that are not supported, and the elements of the alternatives that
have strong opposition.
7.4.1 State Acceptance
The IDHW has been involved in the development and review of the RI/FS report, the Proposed Plan,
and this ROD. AH comments received from IDHW on these documents have been resolved and
incorporated into these documents accordingly. In addition, IDHW has participated in public meetings
where public comments and concerns have been received and responses offered.
The IDHW concurs with the selected remedial alternatives for the sites contained in this ROD and is
signatory to the ROD with DOE and EPA.
7.4.2 Community Acceptance
Community participation in the remedy selection process includes participation in the public
meetings held in March 1997 and review of the Proposed Plan during the public comment period of
March 10. I997 through May 9. I997. Community acceptance is summari/.ed in the Responsiveness
Summary presented as Appendix A of this document. The Responsiveness Summary includes comments
received either verbally or in writing from the public, and the agencies' responses to these comments.
A total o! about twenty people not associated with the project attended the Proposed Plan public
meetings. Overall, twenty citi/.ens provided formal comments: ot these, six citizens provided verbal
comments. ;mcl fourteen provided written comments. All comment* received on the proposed plan were
considered during (he development of this ROD.
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As can be seen in the Responsiveness Summary, the ROD was substantively modified and improved
in response to comments made by the public. Comments were often incorporated directly or were
modified and included in the decision. In other cases, the modifications were made to the document to add
greater explanation as to why a comment could not be incorporated.
In addition to their direct impact on the decision and the document, public comments triggered
focused leview of the sections highlighted by each commentor. The DOE. EPA, and the State review of
those sections and the document as a whole resulted in further modifications and improvements to the
decision. The agencies appreciate the public's participation in this process and acknowledge the value of
public comment.
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8. SELECTED REMEDY
The results of investigations at OU 2-13. WAG 2, TRA, at INEEL indicate that eight sites exceed a
1 in 10.000 risk or greater than 1.0 hazard index (indicates adverse noncarcenogenic health effects) to
human health and/or the environment and thus pose an unacceptable risk; 47 sites do not exceed a 1 in
10,000 risk and therefore require no action. Please note that there are no unacceptable cumulative effects
from the eight sites, and the remedial actions being recommended address individual risks as well as
preventing cumulative risks to a future residential receptor at WAG 2. Based on consideration of the
requirements of CERCLA, the detailed analysis of alternatives, and public comments, DOE-ID, EPA. and
IDHW have selected the following alternatives for the sites contained in this ROD (Table 8-1).
Table 7-3 provides a summary of how the selected remedy for each ranks relative to one another.
This comparative analysis provides a measure of the relative performance of alternatives against each
evaluation criterion. The purpose of this comparison is to identify the relative advantages and
disadvantages associated with each alternative.
8.1 Description of Selected Remedy
The selected remedies for each are described in the following sections.
8.1.1 Warm Waste Pond (TRA-03)
The selected remedy for the Warm Waste Pond 1952 and 1957 cells is Alternative 3a (containment
with an engineered cover and institutional controls). This alternative was found to provide the greatest
level of protectiveness to human health and the environment and had substantially lower costs than the
excavation and disposal alternative. Implementation of the engineered cover is slightly more difficult than
the native soil cover alternative, but the engineered cover provides greater permanence and requires less
maintenance. Because contaminants are being left in place, institutional controls will be required to
remain tor the length of time that the contaminants pose an unacceptable risk to human health or the
environment (at least 100 years). These institutional controls are to include soil cover integrity monitoring
and maintenance, surface water diversions, access restrictions, and long-term environmental monitoring.
Institutional controls are assumed to remain in effect for at least 100 years. Five-year reviews will be used
to ensure that the remedy remains protective and appropriate. Before placement of the final cover, the
1957 cell may be filled to grade with CERCLA-contaminated soils from surrounding INEEL sites. As
approved by the agencies, all soils used to fill the Warm Waste Pond to grade will have to be consistent
with what has been placed to date in the 1957 cell in terms of contaminant type and concentration.
This alternative will reduce human exposure by preventing direct contact with and exposure to
contaminants and will inhibit or eliminate potential intrusion of contaminated soils by both human and
ecological receptors (i.e., burrowing mammals and deep-rooted vegetation). Under this alternative.
groimdvvater monitoring will be continued to ensure that groundwater concentrations do not increase to
unacceptable levels and that modeling predictions remain valid.
For the 1964 cell, where previous interim remedial action has already been completed, a basalt riprap
or cobble gravel layer will be placed on top of the current native soil surface to inhibit intrusion or future
excavation at (he and to increase the permanence of the remedy.
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Table 8-1. Selective remedial alternatives for sites of concern in OU 2-13.
Selected Remedy
Warm Waste Pond (TRA-03) 1952
and 1957 cells
Warm Waste Pond 1964 cell
Chemical Waste Pond (TRA-06)
Cold Waste Pond (TRA-08)
Sewage Leach Pond (TRA-l 3)
Soil Surrounding Hot Waste Tanks at
Building TRA-613 (TRA-l5)
Soil Surrounding Tanks I and 2 at
Building TRA-630 (TRA-l9)
Brass Cap Area
Sewage Leach Pond Berms and Soil
Contamination Area
Containment with an engineered cover and
institutional controls
Final basalt riprap or cobble gravel layer on
existing native soil cover and institutional controls
Native soil cover and institutional controls, with
possible excavation, treatment, and disposal
Excavation and disposal
Containment with a native soil cover and
institutional controls
Limited Action for at least 100 vears
Limited Action with implementation of a
contingent excavation and disposal option
Limited Action with implementation of a
contingent excavation and disposal option
Limited Action for at least 100 years; berms will
be placed in the floor of the Sewage Leach Pond
Performance standards will be implemented to ensure that the engineered cover provides protection
against direct exposure to the contaminated waste. These standards are described in Section 8.2.
Recent investigations have determined that RCRA-listed waste may have been present in the TRA
warm waste system when discharges from the warm waste system to the pond occurred. In addition, soil
placed in the Warm Waste Pond from Test Area North (TAN) during the OU 10-06 removal action may
ha\e been contaminated with RCRA-listed waste. Therefore, the Warm Waste Pond soils will be managed
in a manner consistent with the hazardous waste determination to be performed at the time of the remedial
action. Any final determination to be made in regard to management of these soils will be pursued within
time frames capable of supporting the schedule to he established in the RD/RA Scope of Work.
The soil from TAN placed in the TRA Warm Waste Pond during the OU 10-06 removal action may
have been contaminated with low levels of PCBs. This soil was analyzed for PCBs: however, none were
delected. The maximum detection limit of the data set was 0.220 ppm. The agencies have determined that
these soils need not be managed as PCB-coniaminated soil since the residual PCB levels are below the
OSWHR directive guidance level of 25 ppm at superfund sites.
In summarv the containment remedy for the Warm Waste Pond is protective of human health and
the environment, complies with ARARs. provides short- and long-term effectiveness, is readilv
S-2.
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and is cost effective. The engineered cover design has been shown to be effective at other sites contaminated
with radionuclides. Institutional controls will be implemented as described in Section 7.2.2.
8.1.2 Chemical Waste Pond (TRA-06)
The selected remedy for the Chemical Waste Pond is Containment with a Native Soil Cover and
Institutional Controls with Possible Excavation, Treatment, and Disposal. The need for excavation, treatment
and disposal will be determined on the basis of additional sampling to be performed during the remedial
design phase. The agencies have concurred that excavating and disposing of contaminated sediments in the
bottom of the pond before filling the pond to grade or constructing a native soil cover will meet the cleanup
goals for the Chemical Waste Pond. However, it is not clear which is most cost effective. Cost effectiveness
is dependent on the amount of soil that would need to be excavated and the requirements for its management
as well as the design of the cover. If only small amounts of contaminated soil would need to be excavated and
disposed, and the level of mercury in that soil is below levels that would require treatment, then excavation
and disposal would likely be more cost effective. This is because the disposal cost would be low, the pond
could be filled to grade with minimal backfill specifications, and long-term monitoring and maintenance
needs would be eliminated. If larger amounts of soils would need to be excavated and disposed to meet
cleanup goals, and the levels of mercury in the soil would require treatment by stabilization or retorting to
meet hazardous waste regulations, then the soil cover would be the more cost-effective remedy. However, if
the contamination is left in place, the cover would require more strict specifications to enhance runoff and
reduce erosion. In order to make the final determination, further sampling and analysis needs to be completed
in the pond to define the amount of soils that would require excavation and how the soil would have to be
managed (i.e., soils contaminated with mercury above 260 mg/kg must be treated by retorting the soil if
excavated and thereby generated as hazardous waste). Therefore, the specific design of the remedy selected
in this ROD, native soil cover with possible excavation and disposal after sampling, will be dependent upon
the results of a sampling and analysis effort as a first step after signature of the ROD but before the final
design is completed.
If contaminants are left in place, the final cover design will consist of a sloped surface with a 1-ft peak
similar to that depicted in Figure 7-1. Environmental monitoring and institutional controls would be
maintained for at least 100 years. Institutional controls and access restrictions as described in Section 7.3.2
will be required. Five-year reviews will be used to evaluate the effectiveness and appropriateness of this
alternative.
Performance standards will be implemented to ensure that the native-soil cover provides protection
against direct exposure to the contaminated wastes. These standards are described in Section 8.2.
8.1.3 Cold Waste Pond (TRA-08)
The selected alternative for the Cold Waste Pond is Alternative 5, Excavation and Disposal. Costs for
this alternative were lower due to the estimated amount of contaminated sediment requiring removal [0 to 6
in. (0 to 15 cm)] versus the amount of fill materials that would be required under the two containment options
(Alternatives 3a and 3b). It is anticipated that a hot spot removal will be performed on the basis of field
measurements and laboratory data collected. This alternative provides the highest degree of long-term
effectiveness and permanence. Only sediments with contaminant concentrations exceeding risk-based
cleanup goals will be excavated and appropriately disposed.
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Performance standards will be implemented to ensure that the excavation and disposal of contaminated
soil provide protection against direct exposure to the contaminated wastes. These standards are described in
Section 8.2.
8.1.4 Sewage Leach Pond (TRA-13)
The selected alternative for the Sewage Leach Pond is Alternative 3b (containment with a native soil
cover and institutional controls, as described above). Institutional controls will be required to remain for the
length of time that the contaminants pose an unacceptable risk to human health or the environment (at least
100 years). Before the barrier is constructed, the pond will initially be backfilled with soils from the
contaminated berms, then filled with clean soil to grade. This will ensure that any contamination from the
berms is placed in the bottom of the pond. The final cover design will consist of a sloped surface with a 1-ft
peak. The cover surface'would be completed with a gravel mulch and vegetated with crested wheatgrass.
The slope surface would be used to divert surface water runoff and to promote evapotranspiration. This
alternative would effectively reduce risks to human health and the environment at relatively low
implementation costs compared to excavation and disposal. The native soil cover effectively reduces the
potential for human and environmental exposure to contaminants but requires long-term monitoring and
maintenance to ensure that migration of contaminants to receptor pathways does not occur. This alternative
was compared and selected based on remedy selection criteria as described in Section 7.3. Five-year reviews
will be used to evaluate the effectiveness and appropriateness of this alternative.
Performance standards will be implemented to ensure that the native-soil cover provides protection
against direct exposure to the contaminated wastes. These standards are described in Section 8.2.
8.1.5 Soil Surrounding Hot Waste Tanks at Building 613 (TRA-15)
The selected alternative for the soil surrounding Hot Waste Tanks at Building 613 is Alternative 2,
Limited Action, because risk estimates are only slightly above criteria for current and future workers.
Existing administrative and institutional controls will continue to be used to be protective of occupational
scenarios. These controls would be maintained for a period of 100 years. Performance standards will be
implemented to ensure protection against direct exposure to the contaminated wastes while the site is under
institutional control. At the end of 100 years, no other action will be required because radioactive decay of
contaminants will have occurred to levels that no longer represent an unacceptable risk to human health and
the environment.
8.1.6 Soil Surrounding Tanks 1 and 2 at Building 630 (TRA-19)
The selected alternative for the Soil Surrounding Tanks 1 and 2 at Building 630 is Alternative 2
(Limited Action), with the contingency that if controls established under the Limited Action are not
maintained then an Excavation and Disposal option would be implemented. Recent investigations have
determined that RCRA-usted waste may have been present in the TRA warm and hot waste systems when
leaks from the systems to the environment occurred. If soil is excavated for disposal, a hazardous waste
determination will be required. Therefore, the TRA-19 soils will be managed in a manner consistent with the
hazardous waste determination to be performed at the time of excavation and disposal. Excavation would
occur to a maximum depth of potential intrusion [10 ft (3 m) or the maximum depth at which contaminant
concentrations exceed PRGs, whichever is less]. The excavated soil will be transported to an approved
disposal facility. This alternative was selected on the basis of long-term effectiveness,
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permanence, and costs that are roughly equivalent to those for Alternative 3a. containment with an
engineered cover.
This alternative is selected because the contamination associated with these two sites is located under
the ground surface in and around active radioactive waste piping and tank systems and buildings where
access is physically limited. Therefore, excavation or containment alternatives are not fully implementable
at this time, because it cannot be ensured that adequate contamination could be removed to eliminate the
need for the controls that would be in place under the Limited Action alternative. If during 5-year reviews
it is determined that the controls established under the Limited Action alternative are not maintainable or
do not continue to be protective, the contingency of Excavation and Disposal would be implemented.
Selection of the Limited Action alternative in this ROD would require that existing controls such as access
restrictions and worker protection programs be maintained to prevent exposure above acceptable levels to
workers or future inhabitants.
The identification of Limited Action as the preferred alternative, with an Excavation and Disposal
option contingency, is based on the 100-year industrial land use assumption for TRA. The validity of this
assumption will be evaluated during the 5-year review process. However, the maximum duration of time
for which this assumption may be considered valid is up to 100 years from now.
Performance standards will be implemented to ensure protection against direct exposure to the
contaminated wastes while the site is under institutional control. When excavation and disposal take place
at some point in the future, the performance standards described in Section 8.2 will be implemented to
ensure that excavating and disposal activities provide protection against direct exposure to the
contaminated wastes.
8.1.7 Brass Cap Area
As with TRA-19, the selected alternative is Limited Action, with the contingency that, if controls
established under the Limited Action are not maintained then an Excavation and Disposal option would be
implemented. This alternative provides long-term effectiveness, permanence, and reasonable costs when
compared with the other remedies evaluated.
This consists of radioactively contaminated soil located below the ground surface inside the security
fence at TRA. The source of contamination is attributed to a leaking warm waste line: however, it is
acknowledged that possible releases from a nearby hot waste line may have occurred and that this
contamination may not be readily distinguishable from any warm waste line releases. Some contaminated
soil and concrete were excavated and removed during repair of the leaking line. The excavation was
backfilled with clean soil, and the concrete surface was replaced. Recent investigations have determined
that RCRA-listed waste may have been present in the TRA warm and hot waste systems when leaks from
the svstems to the 'environment occurred. If soil is excavated for disposal, a hazardous waste determination
will be required. Therefore, the Brass Cap Area soils will be managed in a manner consistent with the
ha/ardoiis waste determination to be performed at the time of excavation and disposal.
The identification of Limited Action as the preferred alternative, with an Excavation and Disposal
option contingency, is based on the 100-year, industrial land u.se assumption, for TRA. The validity of this
assumption will he evaluated during the 5-year review process. However, the maximum duration of tune
for which this assumption may be considered valid is up to 100 years from now.
8-5
-------
Performance standards will be implemented to ensure protection against direct exposure to the
contaminated wastes while the is under institutional control. When excavation and disposal take place at
some point in the future, the performance standards described in Section 8.2 will be implemented to ensure
that excavating and disposal activity provides protection against direct exposure to the contaminated
wastes.
8.1.8 Sewage Leach Pond Berm and Soil Contamination Area
The selected remedy for the Sewage Leach Pond Berms and Soil Contamination Area is
Alternative 2 (Limited Action), consisting of existing administrative and institutional controls. As
previously described in Section 8.1.4 for the Sewage Leach Pond (TRA-I3), the contaminated berms will
be placed in the bottom of the pond before completion of the final clean, native soil cover. The remaining
low-level radionuclide-contaminaled soils will be left in place, and exposure to these contaminants will be
minimized through the use of fences, signs, and monitoring (i.e., field measurement surveys). Institutional
controls will be maintained fora period of at least KM) years. This will be protective of occupational
scenarios while achieving acceptable risks within 100 years because of natural radioactive decay. A
CERCLA 5-year review will be conducted to ensure that the administrative controls are being properly
maintained and that the predicted decrease in contaminant concentrations does occur.
8.1.9 No Action Site
The No Action alternative was reaffirmed or selected as the appropriate alternative for the 47 sites at
TRA listed below. This alternative was chosen because there are no known or suspected contaminant
releases, contaminants exceeding acceptable levels, or previous cleanups resulting in unacceptable risks to
human health and the environment. For this reason, long-term environmental monitoring is not warranted
for these sites.. It should be noted that the eliminated No Action sites do not pose a risk in combination.
Operable UnitNone
TRA-K) TRA MRT Construction Excavation Pile
TRA-23 TRA ETR Excavation Rubble Pile
TRA-24 TRA Guardhouse Construction Rubble Pile
TRA-25 TRA Sewer Paint Settling Pond Rubble Pile
TRA-26 TRA Rubble by I'SGS Observation Well
TRA-27 TRA North Storage Area Rubble Pile
TRA-28 TRA North (Landfilli Rubble
TRA-29 TRA ATR Construction Pile
TRA-32 TRA West Road Rubble Pile
TRA-33 TRA West Staging Area/Drainage Ditch Rubble
Operable L'nit 2-01
TRA-02 TRA Paint Shop Ditch
Operable I nil 2-02
TRA-14 TRA Inactive Gasoline Tank at TR.WM)5
S-6
-------
TRA-17
TRA-18
TRA-21
TRA-22
Operable Unit 2-03
None
TRA-01
TRA-ll
TRA-12
TRA-20
TRA-40
Operable Unit 2-04
None
None
None
None
None
None
TRA-09
TRA-34
Operable Unit 2-05
None
TRA-16
Operable Unit 2-06
TRA Inactive Gasoline Tank at TRA-616
TRA Inactive Gasoline Tank at TRA-619
TRA Inactive Tank, North Side of MTR-643
TRA Inactive Diesel Fuel Tank at ETR-648
TRA-614 Oil Storage North
TRA Acid Spill Disposal Pit
TRA French Drain at TRA-645
TRA Fuel Oil Tank Spill (TRA-727B)
TRA Brine Tank (TRA-731) at TRA-631
TRA Tunnel French Drain (TRA-731)
TRA PCB Spill at TRA-619
TRA PCB Spill at TRA-626
TRA-627 #5 Oil Spili
TRA PCB Spill at TRA-653
TRA-670 Petroleum Product Spill
TRA PW 13 Diesel Fuel Contamination
TRA Spills at TRA Loading Dock (TRA-722)
TRA North Storage Area
TRA-603/605 Tank
TRA Inactive Radionuclide Contaminated Tank at TRA-614
TRA-30 TRA Beta Building Rubble
TRA-31 TRA West Rubble
TRA-35 TRA Rubble East of West Road near Beta Building Rubble Pile
Operable Unit 2-07
None TRA-653 Chromium-Contaminated Soil
Operable Unit 2-08
TRA-37 TRA MTR Canal in basement ofTRA-603
Operable Unit 2-09
TRA-07 TRA Scvvasic Treatment Plant (TRA-624) and Sludge Pit (TRA-07)
8-7
-------
Operable Unit 2-10
TRA-03B TRA Warm Waste Pond (Sediments)
Operable Unit 2-11
TRA-03A TRA Warm Waste Leach Pond (TRA-758)
TRA-04 TRA Warm Waste Retention Basin (TRA-712)
TRA-05 TRA Waste Disposal Well, Sampling Pit (764) and Sump (703)
Operable Unit 2-12
None Perched Water RI/FS
Operable Unit 2-13
TRA-41 French Drain
TRA-42 Diesel Unloading Pit
None Hot Tree
None ETR Stack Area
The agencies concur with the No Action alternative selected for the above-listed sites.
For those sites for which no action is being taken based on land use assumptions, those assumptions
will be reviewed as part of the 5-year review. In addition, legacy waste that has been generated as a result
of previous sampling activities at WAG 2 (i.e., investigation-derived waste) will be appropriately
characterized, assessed, and dispositioned in accordance with regulatory requirements to achieve
remediation goals consistent with remedies established for sites under this ROD.
8.2 Remediation Goals
The purpose of this response action is to inhibit potential exposure for human and environmental
receptors and to minimize the spread of contamination. For the majority of disposal pond sites, this will be
accomplished by constructing lone-term covers (caps) and restricting access to the sites. For the
subsurface release sites, this will be primarily accomplished by eventual excavation and disposal of the
contaminated soils. For the remaining sites, this will he accomplished through institutional controls.
8.2.1 Containment System Performance Standards
Performance standards will be implemented to ensure that the cover svstems provide protection
against direct exposure to the waste at the sites with native-soil covers or engineered covers. The
performance standards identified for the containment alternative include:
Installation of covers that arc designed to remain in existence for the length of time an
unacceptable risk is posed, in order to discourage any individual from inadvertently intruding
into the huried waste or from contacting the waste.
S-S
-------
Application of maintenance and surface monitoring programs for the containment systems
capable of providing early warning of releases of radionuclides and non-radionuclide
contaminants of concern from the disposal sites before they leave the site boundary
Institution of restrictions limiting land use for at least 100 years
Implementation of surface water controls to direct surface water away from the disposed waste
Elimination, to the extent practicable, of the need for ongoing active maintenance of the
disposal sites following closure so that only surveillance, monitoring, or minor custodial care
are required
Placement of adequate cover to inhibit erosion by natural processes for the specified design
lives of the covers
Incorporation of features to inhibit biotic intrusion into the Warm Waste Pond 1952 and 1957
cells.
The inspection and maintenance of the cover system will be conducted concurrent with the
radiological survey program. Implementation of the maintenance and survey programs will ensure
protection of human health and the environment from any unacceptable risks. These programs will be
implemented annually for the first 5 years following completion of the caps. The necessity for continued
monitoring will then be reevaluated and defined as determined appropriate by the agencies during
subsequent 5-year reviews.
8.2.2 Excavation and Disposal Performance Standards
Performance standards will be implemented to ensure that excavation and disposal activities will
result in protection against direct exposure to the contaminants during excavation and after disposal. The
performance standards identified for this alternative include:
Physically removing the source of contamination so that the pathway by which a future receptor
may be exposed is broken. This will he determined by confirmation soil sampling to ensure
that the cleanup meets or exceeds preliminary remediation goals.
8.2.3 Limited Action Performance Standards
Performance standards will be implemented to ensure that institutional controls will result in
protection against direct exposure to the contaminants for a period of at least 100 years (corresponding to
the point in time at which the contaminants have decayed to below levels of concern). The performance
standards identified for this alternative include:
Installation, where necessary, and maintenance of physical barriers to restrict unauthorized
access. This ma> include fences, ground surface cover, and/or posted warning signs.
8-9
-------
An evaluation of existing management and administrative controls to ensure that protection
against direct exposure to contaminants is effective. This evaluation will be performed as pan
of the remedial design.
Implementation of additional administrative controls as determined necessary by the evaluation
described in bullet 2 of this subsection.
8.2.4 Treatment Performance Standards
Performance standards will be implemented to ensure that treatment of contaminated soil at the
Chemical Waste Pond, if necessary, will achieve acceptable levels. The performance standards identified
for treatment include:
Treatment of contaminated soil to at least 0.2 mg/L TCLP for mercury.
8.3 Estimated Cost Details for the Selected Remedy
A summary of the costs for each of the remedial action alternatives evaluated is presented in
Table 9-2. Tables 8-2 through 8-7 provide detailed breakdowns of the estimated costs for the selected
remedies.
S-IO
-------
Table 8-2. Warm Waste Pond engineered barrier detailed cost estimate.
Cost Elements
Subtotal
Remedial Design
Title Design Construction Document Package
Remedial design documentation
Pre-final Inspection Report
Construction Subcontract
Mobilize/demobilize cap subcontractor
Construction of cap
Surface water control
Access restriction fencing
Contractor overhead and profit
Procurement and General and Administrative
Post-closure Costs
Post-closure management
Annual Operations and Management reports
WAG 5-year review
Remedial action report
Warm Waste Pond 100-year long-term total costs
Total in 1997 dollars'
Total in net present value dollars
Subtotal
Subtotal
Subtotal
Estimated Costs
(S)
Management and Documentation Costs
FFA/CO Management and Oversight
LMITCO Project Management and Title III Inspection
Construction Project Management (Parsons)
Remedial Design/Remedial Action Statement of Work and Remedial
Design/Remedial Action Work Plan
375,000
188,356
313.926
22.000
899,282
178,400
60,000
s;ooo
246,400
20.000
688,939
16.000
80.000
241,482
376,711
1,423,132
3,125.000
250,000
500.000
17,000
2.120.000
5,512,000
8,580,814
6,843,216
a. Costs shown are in IW7 dollars anil not present value dollars. SX.580.SI4 in 1SM7 dollars is equal (o
Sf..S43.2l(-> net present value dollars (not present value takes the IW7 dollar amount and assumes variable annual
inflation tailors lor the first 10 \ears. and a constant 5'* annual inflation rate alter that tor a total ol 100 years. A
constant 5'* discount rate - then ,ix«nm,-,l -vhich results in the net present value amount).
8-11
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Table 8-3. Chemical Waste Pond detailed cost estimate.
Estimated Costs
Cost Elements
Management and Documentation Costs
FFA/CO Management and Oversight
LM'ITCO Project Management and Title III Inspection
Construction Project Management (Parsons)
Remedial Design/Remedial Action Statement of Work and Remedial
Design/Remedial Action Work Plan
Remedial Design
Title Design Construction Document Package
Remedial design documentation
Pre-fmal Inspection Report
Construction Subcontract (Native Soil cover)
Mobilize/demobilize cap subcontractor
Construction of cap
Surface water control
Access restriction fencing
Contractor overhead and profit
Procurement and General and Administrative
Construction Subcontract (excavate, treat, dispose)
Excavate and haul to on treatment
On treatment
Transport concentrated waste off
Transport clean soils back to Chemical Pond
Mohili/.e/demobilize
Post-closure Costs (if contamination left in place)
Post-closure management
Annual Operations and Management report>
WAG 5->ear re\ ieu
Remedial action report
Chemical Waste Pond loivj-ierm maintenance costs
Total in 1997 dollars (Native Soil Cover only)
.....* in net present value dollars
Subtotal
Subtotal
Subtotal
Subtotal
Subtotal
375.000
23.166
38.610
22.000
458,776
65.600
60,000
8.000
133,600
10.000
59.000
5,000
25,000
29,700
46,332
175,032
26,850
859.200
3.200
4.136
10.000
903,386
3.125.000
250.00O
500.000
17.000
S22.000
4,714,000
5.481,408
3,904.959
s-i:
-------
Table 8-4. Cold Waste Pond excavate and dispose detailed cost estimate.
Estimated Costs
Cost Elements ($)
Management and Documentation Costs
FFA/CO Management and Oversight 375,000
LMITCO Project Management and Title III Inspection 28,548
Construction Project Management (Parsons) 47,580
Remedial Design/Remedial Action Statement of Work and Remedial 22,000
Design/Remedial Action Work Plan
Packaging, Shipping, Transportation Plan 25,000
Subtotal 498,128
Remedial Design
Title Design Construction Document Package 44,600
Remedial design documentation 60,000
Pre-final Inspection Report 8,000
Subtotal 112,600
Construction Subcontract
Excavate and haul costs 112,000
Disposal costs 896,000
Mobilize/demobilize cap subcontractor 10,000
Contractor overhead and profit 36,600
Procurement and General and Administrative 57.096
Subtotal 1,111,696
Post-closure Costs
Remedial action report 17,000
Subtotal 17,000
Total in 1997 dollars 1,739,424
Total in net present value dollars 1,592,818
X-13
-------
Table 8-5. Sewage Leach Pond native soil cover detailed cost estimate.
Estimated Costs
Cost Elements (S)
Management and Documentation Costs
FFA/CO Management and Oversight 375,000
LMITCO Project Management and Title 111 Inspection 28,080
Construction Project Management (Parsons) 46,800
Remedial Design/Remedial Action Statement of Work and Remedial 22,000
Design/Remedial Action Work Plan
Subtotal 471.880
Remedial Design
Title Design Construction Document Package 65,600
Remedial design documentation 60,000
Pre-tlnal Inspection Report 8,(X)()
Subtotal 133,600
Construction Subcontract
Mobilize/demobilize cap subcontractor 20.000
Construction of cap 70.000
Surface water control 5,000
Access restriction fencing 25,000
Contractor overhead and profit 36.000
Procurement and G&A 56,160
Subtotal 212,160
Post-closure Costs
Post-closure management 3,125,000
Annual Operations and Management reports 250.000
WAG 5-year review 500.000
Remedial action report 17.000
Sewage Leach Pond long-term maintenance costs 934.000
Subtotal 4,826,000
Total in 1997 dollars 5.643,640
Total in net present value dollars 4,028,832
8-14
-------
Table 8-6. TRA-15. TRA-19. Brass Cap Area limited action detailed cost estimate.
Cost Elements
Estimated Costs
(S)
Management and Documentation Costs
FFA/CO Management and Oversight
LMITCO Project Management and Title III Inspection
Construction Project Management (Parsons)
Remedial Design/Remedial Action Statement of Work and Remedial
Design/Remedial Action Work Plan
Subtotal
Remedial Design
Title Design Construction Document Package
Remedial design documentation
Pre-fmal Inspection Report
Inspection and Maintenance Costs
Access restriction fencing
Surface water diversion
Subcontractor overhead and profit
Procurement and General and Administrative fees
Post-closure Costs
Post-closure management
Annual Operations and Management reports
Remedial Action Report
WAG 5-year review
Lone-term maintenance costs
Total in 1997 dollars
Total in net present value dollars
Subtotal
Subtotal
Subtotal
125,000
983
1,638
22,000
149,621
18,800
60,000
8.000
86,800
35,000
700
1,260
1,966
7,426
3.093.750
247,500
17.000
500,000
570,000
4,428,250
4,672,099
2,312,337
S-15
-------
Table 8-7. Sewage Leach Pond Berm and Soil Coniamination Area limited action detailed cost estimate.
Cost Elements
Estimated Costs
(S)
Management and Documentation Costs
FFA/CO Management and Oversight
LMITCO Project Management and Title 111 Inspection
Construction Project Management (Parsons)
Remedial Design/Remedial Action Statement of Work and Remedial
Design/Remedial Action Work Plan
Subtotal
Remedial Design
Title Design Construction Document Package
Remedial Design Documentation
Pre-final Inspection Report
Inspection and Maintenance Costs
Access restriction fencing
Surface water diversion
Subcontractor overhead and profit
Procurement and General and Administrative fees
Post-closure Costs
Post-closure management
Annual Operations and Management reports
Remedial action report
WAG 5-year review
Lonu-ierm maintenance costs
Total in 1997. dollars
Total in net present value dollars
Subtotal
Subtotal
Subtotal
125.000
28.080
46.800
22.000
221,880
18.800
60.0(K)
8.000
86,800
100.000
20,000
36.000
56.160
212,160
3.093.750
247,500
17.000
500.000
570.000
4.428,250
4,949,090
3,497,155
S-16
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Table 8-8. Brass Cap Area excavation and disposal contingent remedy detailed cost estimate.
Estimated Costs
Cost Elements (S)
Management and Documentation Costs
FFA/CO Management and Oversight 375,000
LMITCO Project Management and Title III Inspection 6.578
Construction Project Management (Parsons) 10,963
Remedial Design/Remedial Action Statement of Work and Remedial 47,000
Design/Remedial Action Work Plan
Subtotal 439,541
Remedial Design
Title Design Construction Document Package 44,600
Remedial Design Documentation 60,000
Pre-fmal Inspection Report 8.000
Subtotal 112,600
Construction Subcontract
Excavate and haul 5,250
Transport and disposal costs 42,000
Refill borrowed and reseeding 5,420
Mobilize/demobilize 10,000
Contractor overhead and profit 6,201
Procurement and General and Administrative 9,674
Subtotal 78,545
Post-closure Costs
Remedial action report 17.000
Subtotal 17.000
Total in 1997 dollars 647,686
Total in net present value dollars 598,512
8-17
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Table 8-9. TRA-19 excavation and disposal contingent remedy detailed cost estimate.
Estimated Costs
Cost Elements (S)
Management and Documentation Costs
FFA/CO Management and Oversight 375,000
LMITCO Project Management and Title III Inspection 3,801
Construction Project Management (Parsons) 6.334
Remedial Design/Remedial Action Statement of Work and Remedial 47.000
Design/Remedial Action Work Plan
Subtotal 439,541
Remedial Design
Title Design Construction Document Package 44,600
Remedial Design Documentation 60,000
Pre-fmal Inspection Report 8,000
Subtotal 112,600
Construction Subcontract
Excavate and haul 1.150
Transport and disposal costs 9,200
Refill borrowed and reseeding 5,092
Mobilize/demobilize 10.000
Contractor overhead and profit 4.873
Procurement and General and Administrative 2.601
Subtotal 37,916
Post-closure Costs
Remedial action report 17.000
Subtotal 17.000
Total in 1997 dollars 599,651
Total in net present value dollars 549,110
s-is
-------
9. STATUTORY DETERMINATION
The selected remedy for each site meets the statutory requirements of CERCLA Section 121, the
regulations contained in the NCP, and the requirements of the FFA/CO for the INEEL. All remedies meet
the threshold criteria established in the NCP (i.e., protection of human health and the environment and
compliance with ARARs). CERCLA also requires that the remedy use permanent solutions and alternative
treatment technologies to the maximum extent practicable, and. that the implemented action be cost
effective. Finally, the statute includes a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal element.
For many of the sites contaminated with radionuclides, effective treatment technologies are currently
unavailable; therefore, the preference for permanent solutions cannot be met except through natural
radioactive decay processes over time. For those sites where contaminated soils and sediments will be left
in place at levels associated with a risk greater than 1E-04 and a hazard index greater than 1.0, a review
will be conducted within 5 years and at least every 5 years thereafter, until determined by the agencies to
be no longer necessary to ensure that the remedy continues to provide adequate protection of human health
and the environment.
9.1 Protection of Human Health and the Environment
As described in Section 8, the selected remedy for each site satisfies the criterion of overall
protection of human health and the environment.
9.1.1 Alternative 1: No Action
No remedial action is necessary to ensure continued protection of human health and the environment
at the 47 sites identified in Section 8.9. Because no unacceptable risks to human health and the
environment were identified, or those risks were mitigated during previous cleanups, the No Action
alternative has been selectedand environmental monitoring is not warranted.
9.1.2 Alternative 2: Limited Action
Protection of human health is achieved by this alternative through existing administrative and
institutional controls thai reduce the potential for exposure to site contaminants. The use of routine
maintenance, access restriction, long-term environmental monitoring, and surface water diversion are
included in this remedy. Protection of environmental receptors is not ensured under this alternative.
However, for TRA-15 19, Brass Cap Area, and Sewage Leach Pond Soil Contamination Area, for which
this remedy was selected, no unacceptable risks to environmental receptors have been identified.
9.1.3 Alternatives 3a and 3b: Containment with Engineered Cover or Native Soil Cover
The containment cover alternatives prevent direct contact with contaminants by all potential
receptors, reduce radiation external exposure through shielding, and reduce the likelihood of biointrusion
(enszinecrcd cover only).
9-1
-------
9.1.4 Alternative 4: Excavation, Treatment, and Disposal
This alternative provides maximum protection of human health and the environment by the reduction
of toxicity. mobility, and volume of mercury-contaminated sediments through excavation and treatment.
Following treatment, contaminated sediments would be disposed and would, therefore, no longer pose a
risk to human and environmental receptors at OU 2-13.
9.1.5 Alternative 5: Excavation and Disposal
The excavation and disposal alternative provides the best protection of human health and the
environment by removing contaminants that pose an unacceptable risk and placing them in a licensed
disposal facility designed to protect human health and the environment.
9.2 Compliance with ARARs
In general, sites identified during the OU 2-13 RI/FS as needing remedial action are the result of
releases to the environment that had little known potential to contain RCRA hazardous waste or PCBs.
The exception is the Chemical Waste Pond, which was known to have received corrosive hazardous waste,
and. more recently, wastewaters containing levels of mercury above the TCLP level. Recent evaluations
have determined that small quantities of RCRA-listed solvents and PCBs may also be associated with some
sites. RCRA-listed solvents may have been disposed to the warm wastewater and hot wastewater systems
at TRA. resulting from the use of small quantities of solvents in TRA laboratories, which may have
released small quantities of the solvent to drains that are connected to these systems. Trichloroethylene
(TCE). a RCRA-listed solvent, and PCBs are associated with soil from TAN, which was placed in the
57 cell of the Warm Waste Pond during an OU 10-06 removal action.
Of the eight sites needing remedial action under this ROD, four are associated with the warm
wastewater system, hot wastewater system, and/or OU 10-06 removal actions. The sites include the hot
waste tanks (TRA-15). the hot waste catch tanks (TRA-19). the Brass Cap Area, and the Warm Waste
Pond. Therefore, soils at these sites associated with releases from the warm waste system, hot waste
system, and/or 10-06 removal actions will be managed in a manner consistent with the hazardous waste
determination to be performed at the time of the remedial action. Any final determination to be made in
regard to management of the Warm Waste Pond soils will be pursued within time frames capable of
supporting the schedule to be established in the RD/RA SOW.
Soil from the Test Area North placed in the Warm Waste Pond during the OU 10-06 removal action
ma> have been contaminated with very low levels of PCBs. This soil was analy/ed for PCBs; however,
none were detected. The maximum detection limit of the data set was 0.220 ppm. The agencies have
determined that these soils need not be managed as PCB-contaminated soil since the residual PCB levels
are below ilie office of solid waste and emergency response directive guidance level of 25 ppni at
Superfund Sues. The data supporting this decision can be found in the OU 2-13 Administrative Record as
attachments to agencv comment responses to the OU 2-1 3 Draft ROD.
The selected remedies will be designed to compK with all chemical-specific, action-specific, and
liv.inon-specific federal and state ARARs. ;is described in Section 7.3 and presented in Table 9-1.
-------
Table 9-1. SummatA ol ARAKs met hy selected alteniaiives forOU 2-13 siles of concern.
(I) Warm Waste PondContainment with an engineered barrier
( 'hcmical-Specific A K A Ks
40CI-RM.42
4<)CI-'RM.o.J
4(KTRfil>J42
4()CI-Rftl.y3
4()CI;RM.94(a)
IDAPA Ih.OI.OI.. .5X5. and .5:
NESHAPS for Radionuclides from DOE Facilities
Emission Monitoring
Emission Compliance
Toxic Substances
Applicable
Applicable
Applicable
Applicable
-------
Table 9-1. (continued).
\cli"ii-Spi'cific AKAK.s
li is aniicipaicd ili.il the ici|iiircmcnls »l "I C'I-K 2MJIO
I.DI I) ;nul ^ could he met for ihe Chemical Waste Pond hy
dcmoiisiiaiiiii.1 ih.ii contaminant initiation in the aqmlci does
MM! pose .in unacceptable risk.
KICI k :) ( hi'itiiial \Viislv Pondcviavulion ;ind oft-site disposal
R& A
R& A
R& A
Chcitiicul-Spfcific AKAK.s
IDCI K M.'>2
IOCI-K 61 '^
lOCI-K (>l.»)4(a)
IDAI'A lh.OI.OI.5S5 - .5Kh
Aclion-Spccific AKARs
4(ICI;R Ihl II
i Note: Waste excavated from the Chemical Waste Pond will
be managed in accordance with the outcome ol the
ha/ardous waste determination)
(3) Cold \VusU> Pondl-Acuvutt- and dispose onsile
NRSHAPS Kadionuelide Emissions I'roin !)()!: f-acililies
Lmission Monitoring
Emission Complianee
Toxic Substances
Ha/ardous Waste Deierniinatii n
Applicable
Applicable
Applicable
Applicable
Applicable
Chemical-Specific AKAKs
-JKCI'Kd !.').(
-JUCl-KM.o.l(a)
IDAI'A Ki.ni.OI.. .'SSS. and 5S
NliSHAPS lor Radionuclidcs from DOf:. Facilities
limission Monitoring
limission Compliance
Toxic Substances
Applicable
Applicable
Applicable
Applicable
-------
Table 9-1. (continued).
Hazardous Waste Determination
( 'hcmical-Spccific AKAKS
40CFR6I.1J2
40CFR6l.yJ
40CFR6l.y4(a)
IDAI'A 16.01.01.. .585. and .586
Action-Specific AKARs
40CFR 262.11
Note: Waste excavated from 1 KA- I'J will be manured in
accordance with the outcome of the ha/ardous waste
determination.
NESHAPS for Radionuclides from DOK Facilities
Emission Monitoring
Emission Compliance
Toxic Substances
Hazardous Waste Determination
(5) Hrass Cap AreaInstitutional control with excavate and disposal contingency
Applicable
Action-Specific A RA Rs
4I1CI--R 2(12.11
Nine: W;isic excavated from the Cold Waste Pond will be
managed in accordance with the outcome of the ha/ardous
waste determination.
(4) Soil Siirrniindinn Tanks I and 2 at Huildin^ 630 (TRA-19)Institutional control with excavate and disposal contingency
Applicable
Applicable
Applicable
Applicable
Applicable
Chemical-Specific ARARs
4l)CTRol.l)2
40CI:Rol.l)4(a)
IDAPA Ih.OI.OI.. .585. and .5X6
Action-Specific ARARs
40CFR262.il
NESHAPS for Radionuclides from DOE Facilities
Emission Monitoring
Emission Compliance
Toxic Substances
Ha/ardous Waste Determination
Applicable
Applicable
Applicable
Applicable
Applicable
-------
Ha/.ardous Waste Determination
Table 9-1 (ounimiali.
\clitin-SptciHc A R ARs
IIICI-K 2<>2.l
I Note: Waste excavated I'rom the Hiass C'ap Area will he
ni.iii.iL'i'il in acouil.incc with the ha/,minus waste
ilekTininaimn)
((>) Soil Surrounding Hot Waste Tanks at litiilding 613 (TRA-15)Institutional Control
Applicable
Action-Specific ARARs
||,AI'Alh.ni.OI...5H.Vand.5Kh
NESHAPS for Radionuclides from DOE l-acilities
Emission Monitoring
Emission Compliance
Toxic Substances
(7, SpwaKt. |.,;.cl. I'oiul Bcrm anil Soil Contamination Area (SLP-SC A (-Institutional Control/use as backfill in the Sewage
( 'hcnm-al-Specific A R A Rs
Applicable
Applicable
Applicable
Applicable
Leach Pond
-411 ('I -KM. 42
ItKTRM.'M
4IK'l''Rol.lM(a)
IDAI'A UvOl.tll.. .5X5. and .5Xu
Attion-Specific ARARs
(8) Sewage I.each PondNative Soil Cover
Chemical-Specific A R A Rs
40CI:RM.l>2
40CI:Rhl.'M
KICI-K fil.'Mtai
IDAI'A KvOI.OI.. .5X5 .Hid .5Xd
NESHAPS for Radionuclides from DOli l-acilities
Emission Monitoring
Emission Compliance
Toxic Substances
Applicable
Applicable
Applicable
Applicable
NESHAPS for Radionuclides from DOE Facilities
Emission Monitoring
Emission Compliance
Toxic Substances
Applicable
Applicable
Applicable
Applicable
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Table 9-1. (continued).
l'» Additional AKAKs for all Actions ut all Sites
Action-Specific ARAKs
40CTR 2fO.II
IDAI'A UvOI.05.005-.OI I
Ha/arclous Waste Determination
Idaho Ha/ardous Waste Regulations, which
reference Federal regulations.
Applicable
Applicable
4UCI-K 2o8.7, .9. .40. .45. and .48
40 (TK 122.26
IDAI'A UvOI.OI.fi5l
Chemical Specific AKARs
IDAI'A I Ml 1.01.500.02
IDAI'A IM»l.02.299<5)(a)!: Older 54(MU
I )()! Order 5820.2A. Chapter
IX )!: Order 5400.5
Hazardous and Mixed Waste Program
Low-Level Radioactive Waste Management
Radiation Protection Sid.
-------
Chemical-specific ARARs are usually health- or risk-based numerical substantive requirements of
the values or methodologies that, when applied to site-specific conditions, result in the establishment of"
numerical values. These values establish the acceptable amounts or concentrations of a chemical that may
be found in. or discharged to. the ambient environment.
Action-specific ARARs are usually technology- or activity-based requirements for actions taken at a
site. Action-specific ARARs generally do not guide the development of remedial action alternatives, but
they indicate how the selected remedy must be implemented.
A number of statutes have requirements related to activities occurring in particular locations. For
instance, waste management activities in flood plains are restricted under RCRA. Location-speeific
ARARs are regulatory requirements placed on activities in specific locations that must be met by a given
remedial action. These location-specific ARARs are used in conjunction with chemical and action-specific
ARARs to ensure that remedial actions are protective of human health and the environment.
The following information provides a general discussion describing why a requirement is either
applicable or relevant and appropriate at each of the sites of concern.
Warm Waste PondNational Emissions Standards for Hazardous Air Pollutants (NESHAPS) for
radionuclide emissions from DOE facilities is applicable to this activity because radionuclides may be
suspended during soil movement and consolidation. The radiation dose to the public will be estimated and
included in the annual INEEL calculations and reports. If radionuclides associated with fugitive dust
releases exceed acceptable standards (10 mrem/yr to the public), then the need for additional measures will
be evaluated and implemented as appropriate.
The requirements of 40CFR 264.309 and 264.310, included in Table 9-1. are relevant and
appropriate because of recent information that shows RCRA-listed constituents were likely disposed to the
Warm Waste Pond. The requirements of 40 CFR 264.310 (a) (I) and (5) may be met by demonstrating
that no unacceptable risk is present via the groundwater pathway. It is anticipated that such a
determination could be made for the 1964 cell, but is not anticipated for the 1952 or 1957 cells.
Idaho rules for toxic air emissions are applicable because they also address releases or emissions of
radionuclides to the atmosphere, such as may occur during soil movement and consolidation.
Chemical Waste PondNESHAPS lor radionuclide emissions from DOE facilities is applicable to
this activity because radionuclides may he suspended during soil movment and consolidation. The
radiation dose to the public will be estimated and included in the annual INEEL calculations and reports.
It radionuclides associated with fugitive dust releases exceed acceptable standards (10 mrem/yr to the
public), then the need for additional measures will be evaluated and implemented as appropriate.
Idaho rules for toxic air emissions are applicable because they address mercury and radionuclides
emissions to the atmosphere, such as ma\ occur during soil movement and consolidation.
The Chemical Waste Pond is a land disposal unit. The agencies deem this risk-based CERCLA
remedial action to be functionally equivalent to RCRA corrective action requirements to eliminate
unacceptable risk. Administrative RCRA closure requirements v 'II occur separately from the ROD alter
ihc remedial action is completed. Houever. the requirements of 40 Cl R 264.309 and 264.310. as listed in
Table 9-1. would be appropriate performance standards and. therefore, can he considered relevant and
9-S
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appropriate for this action. If excavation and disposal were to occur, waste would be managed in
accordance with the outcome of a hazardous waste determination conducted at the time of the remedial
action (e.g., treatment of contaminated soil to at least 0.2 mg/L TCLP for mercury).
Cold Waste PondNESHAPS for radionuclide emissions from DOE facilities are applicable to this
activity because radionuclides may be suspended during soil movement and consolidation. The radiation
dose to the public will be estimated and included in the annual INEEL calculations and reports. If
radionuclides associated with fugitive dust releases exceed acceptable standards (10 mrem/yr to the
public), then the need for additional measures will be evaluated and implemented as appropriate.
Requirements for hazardous waste determinations and for management of hazardous waste are
applicable during excavation and disposal. While unlikely, sediments may exhibit a characteristic of a
hazardous waste. If so, sediments must be managed and disposed as hazardous waste.
Idaho rules for toxic air emissions are applicable because they address radionuclide emissions to the
atmosphere, such as may occur during soil movement and consolidation.
Soil Surrounding Tanks 1 and 2 at Building 639 (TRA-19)NESHAPS for radionuclide
emissions from DOE facilities are applicable to this activity because radionuclides may be suspended
during soil movement and consolidation. The radiation dose to the public will be estimated and included
in the annual INEEL calculations and reports. If radionuclides associated with fugitive dust releases
exceed acceptable standards (10 mrem/yr to the public), then the need for additional measures will be
evaluated and implemented as appropriate.
Requirements for hazardous waste determinations and for management of hazardous waste are
applicable during excavation and disposal. When contaminated soil is eventually excavated, then
requirements for hazardous waste management and disposal are applicable, because the soil may contain
RCRA-listed hazardous waste from warm and/or hot waste system leaks. If so, sediments must be
managed and disposed as hazardous waste.
Idaho rules for toxic air emissions are applicable because they address radionuclide emissions to the
atmosphere, such as may occur during soil movement and consolidation.
Brass Cap AreaNESHAPS for radionuclide emissions from DOE facilities are applicable to this
activity because radionuclides may be suspended during soil movement and consolidation. The radiation
dose m the public will be estimated and included in the annual INEEL calculations and reports. If
radionuclides associated with fugitive dust releases exceed acceptable standards < 10 mrem/yr to the public)
then the need for additional measures will be evaluated and implemented as appropriate.
Requirements for hazardous waste determinations and lor management of hazardous waste arc
applicable during excavation and disposal. When contaminated soil is eventually excavated, then
requirements tor ha/urdous waste management and disposal are applicable, because the soil may contain
RCRA-listed hazardous waste from warm and/or hot waste system leaks. If so. sediments must be
managed and disposed as hazardous waste.
Idaho rules for toxic -'r ei";«-'i- "-plicable because they address radionuclide emissions to the
atmosphere, such as ma\ occur during soil movement and consolidation.
y-y
-------
Soil Surrounding Hot Waste Tanks at Building 613 (TRA-15) NESHAPS for radionuclide
emissions from DOE facilities are applicable to this activity because radionuclides may be suspended. The
radiation dose to the public will be estimated and included in the annual INEEL calculations and reports.
If radionuclides associated with fugitive dust releases exceed acceptable standards ( 10 mrem/yr to the
public), then the need for additional measures will be evaluated and implemented as appropriate.
Idaho rules for toxic air emissions are applicable because they address radionuclide emissions to the
atmosphere, such as may occur during soil movement and consolidation.
Sewage Leach Pond Berm and Soil Contamination Area (SLP-SCA) NESHAPS for
radionuclide emissions from DOE facilities are applicable to this activity because radionuclides may be
suspended during soil movement and consolidation. The radiation dose to the public will be estimated and
included in the annual INEEL calculations and reports. If radionuclides associated with fugitive dust
releases exceed acceptable standards ( 10 mrem/yr to the public), then the need for additional measures will
be evaluated and implemented as appropriate.
Idaho rules for toxic air emissions are applicable because they address radionuclide emissions to the
atmosphere, such as may occur during soil movement and consolidation.
9.2.1 Additional ARARs
A hazardous waste determination is required for all waste generated during remedial activities. All
selected remedies at WAG 2 that result in generation of hazardous waste will be required to adhere to
pertinent substantive RCRA requirements (e.g., LDR standards) during excavation, storage, transportation,
treatment and disposal activities.
All selected remedies at WAG-2 that result in hazardous waste storage or soil movement or
excavation will be required to apply requirements to prevent contamination of storm water runoff into
waters of the United States.
Remedial actions taken at WAG 2 must protect groundwater and demonstrate that water quality
specifications found in the Idaho Water Quality standards and under the Idaho Groundwater Quality Rule
he met or achieved.
An\ remedial activities thai may result in generation of fugitive dust are subject to Idaho
requirements for preventing escape, suspension, or release of fugitive dust.
Remedial activities at WAG-2 may require various types of portable equipment. Portable equipment
and air emissions from portable equipment must meel requirements specified in Idaho Air Quality
regulations.
9.2.2 To Be Considered
DOH orders will be c\aluatcd as To-Be-Considered. especially in the absence of applicable state or
federal regulation. DOH Order 5400 3 requirements address programs tor managing ha/ardous and mixed
-------
DOE Order 5400.5 provides guidance on radiological environmental protection requirements and
guidelines for cleanup of residual radioactive material and management of the resulting waste and residue
and release'of property. This order shall be used in lieu of applicable state or federal groundwater
standards for radionuclides.
DOE Order 5820.2A provides guidance on disposal of low-level radioactive waste at DOE facilities.
9.3 Cost Effectiveness
Table 9-2 summarizes the estimated costs in net present value for the five alternatives at each site of
concern. These costs were estimated assuming annual inflation rate for the first 10 years and a constant
5c/c annual inflation rate after that. A constant 5% discount rate is assumed. Each remedial action selected
is cost effective because it provides overall effectiveness in meeting the remedial action objectives
proportionate to its costs. When compared to other potential remedial actions, the selected remedies
provide the best balance between cost and effectiveness in protecting human health and the environment.
Please note that the WAG 2 comprehensive feasibility study eliminated the Limited Action alternative on
the basis of effectiveness for all sites, except the Sewage Leach Pond Berms and Soil Contamination Area
and Soil Surrounding Hot Waste Tanks at Building 613 (TRA-15). Therefore, Limited Action costs are
presented only for these two sites in Table 9-2.
At the Warm Waste Pond, initial construction costs are higher than for the native soil cover.
However, the Engineered Cover provides greater protection for a longer period of time with less
maintenance required, thereby making this alternative more cost effective in the long run. The costs of
monitoring, access restrictions, and surface water diversion are nearly the same for the engineered barrier
and the native soil cover. Long-term air monitoring requirements are relatively low, assuming the air
monitoring would be performed as pan of INEEL-wide programs.
At the Sewage Leach Pond, where a Native Soil Cover will be employed, the cost is based on
constructing the native soil cover, installing surface-water diversion controls, using monitoring equipment,
conducting analyses, and post-closure monitoring and maintenance for at least 100 years. It is expected
that a higher level of maintenance will be required for the native soil covers when compared to the
engineered barrier.
At the Chemical Waste Pond, if a Native Soil Cover will be constructed, the cost is based on
constructing the native soil cover, installing surface-water diversion controls, using monitoring equipment.
conducting analsses, and post-closure monitoring and maintenance for at least 100 years. If excavation.
treatment, and disposal are selected as part of this alternative, the cost is based on the excavation of
mercury-contaminated soils below 260 ppm. treatment using a solidification process such as grouting or
chemical stabilization, and disposal offsite at an approved hazardous waste landfill.
For the Excavation and Disposal alternative at the Cold Waste Pond, initial implementation costs are
higher than the other alternatives considered. However, by removal of contaminants, the requirement for
lung-term maintenance and monitoring is eliminated, making this alternative cost effective proportional to
its effectiveness in protecting human health and the environment.
For the Sewage Leach Pond Soil Contamination Area. TRA-15. TRA-iy. and PK Brass Cap Area.
the overall COM of the LimilcJ Action renied> compared to effectiveness is low. The cost compared to
-------
9-2. SumiiKiiA ol iillcrnalivc cost c-Mimaics lor the eight sites of concern..
Alternative 3a Alternative 3h Alternative 4
Alternative 1 Alternative 2 Containment Containment Excavation.
N,, Action Limned Action w/Kmjinecred Cover w/Naiive Soil Cover Retort Disposal
Sll, ill <*) <*> <*> '*'
W,,,,iW.,su..'ond(.KA.54.54< N/A 4.352.457 3,904.959 5.768.466
riKA («' i
«,,. W.,M,l'»,K.,TKA.ns, 2.WJIK, N/A 5.800.7.2 4.411.567 N/A
S^c.vacli.'ond.lKAI.M :.W.54< N/A 4.475.562 4.028.832 N/A
. , , , >1(H8«7 2TI2317 .2.703.481 ' N/A N/A
Soil suiioiindni!! hot \\asle _.-Oi.n ''(IIS')? N/A 6.495.451 N/A N/A
Snil suiiouiHlmi! tanks 1 and- _._m.n" '"
.11 Iiinldin!l6*it( IRA-I'))
f ||ii(s% (.ipAu.i i:m.K,,7 N/A 2.7(X».998 N/A N/A
Si,,.i,...each.NMu.bi,n,s,nd 2.954.543 3,497.155 N/A N/A N/A
MM| conlainin.iiii'ii .uea
N/A - O'si coiisideted iiisienincai.i or noi .ipplic.ihk-
Ml costs in Net I'ICSCMI Value and incliuU- coiitinixncx Costs are based on cost estimate emiiled -Cost l-Mimates for OH 2-13 Remedial
\lk-inili\cs' loimd m Appendix l.ol tlieOl1 2 13 Comprehensive RI/I;S Report. Net present value costs were estimated assuming variable
Immal'inliatioi. lactors to, the first 10 sears, and a constant 5'.. annual inllalion rale alter thai. A constant 5V, discount rate is assumed
Slnded boxes indicate costs lor I lie selected remcd> lor each site.
Allernaiive 4a Allernative 5
Excavation. Excavation
Solidification. and Disposal
Disposal ($)
N/A 30.546.453
953.676 828.163
N/A 1.592.818
N/A 5.320.029
N/A 2.991.849
N/A 549,110
N/A 548.512
N/A 3.457.090
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effectiveness is further decreased for the TRA-19 and Brass Cap Area where eventual excavation and
disposal costs will be incurred. However, institutional and administrative costs associated with the Limited
Action alternative were based on the assumption that none of these measures are currently in place. On the
contrary, administrative and institutional controls are currently in place because TRA facility operations
are on-going. The added cost of invoking the Limited Action alternative recommended in this ROD is
expected to be minimal. However, a post-ROD evaluation will be conducted to determine what additional
administrative and institutional controls will be required as a result of this ROD.
9.4 Preference for Treatment as a Principal Element
For radionuclide-contaminated sites, effective treatment technologies that would satisfy this criterion
do not currently exist. However, natural radioactive decay will result in the reduction of contaminant
concentrations to acceptable levels within approximately 300 years. The EPA's preference for sites that
pose relatively low long-term threats, or where treatment is impracticable (e.g., TRA radionuclide
contamination) is engineering controls, such as containment.
In the case of mercury contamination at the Chemical Waste Pond, the preference for treatment as a
principal element of the remedy will not be fulfilled if the selected remedy is only containment with a
native soil cover. However, containment with a native soil cover is appropriately protective of human
health and the environment. If excavation, treatment, and disposal are chosen as part of the selected
remedy, then the preference for treatment as a principal element of the remedy will be fulfilled. The
specific design of the remedy selected, native soil cover with possible excavation, treatment, and disposal
after sampling, will depend upon the results of a sampling effort as a first step after the ROD and before
the final design is completed.
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10. DOCUMENTATION OF SIGNIFICANT CHANGES
CERCLA Section 117(b)-requires that an explanation of any significant changes from the preferred
alternative originally presented in the Proposed Plan be provided in the ROD.
Refinements have been made to the selected remedy for the Chemical Waste Pond. The Proposed
Plan recommended containment with native soil cover after excavation, treatment, and disposal of
contaminated sediments. A number of possible options for the excavation and disposal pan of the remedy
discussed in the Proposed Plan were dependent on the levels of mercury found in the pond sediments.
The approach presented in the Proposed Plan can be simplified because the native soil cover
alternative will meet cleanup objectives for the Chemical Waste Pond whether or not sediments are
excavated and disposed prior to filling the pond to grade. However, it is not clear whether the native soil
cover alternative is more cost effective with or without some excavation and disposal of contaminated
sediments. Cost effectiveness is dependent on the amount of soil that would need to be excavated, the
requirements for its management during and after excavation through disposal (e.g., RCRA requirements
for treatment and disposal), and on the rigor of the cover design and the need for long-term monitoring and
maintenance. If the amount of contaminated soil that would need to be excavated and the requirements for
its management are relatively minor, then excavation and disposal followed by filling the pond to grade
with clean backfill materials would likely be the most cost effective. This is because, with the majority of
contamination removed, the pond could be filled to grade with minimal backfill specifications, and long-
term monitoring and maintenance would not be needed. If larger amounts of soils needed to be excavated
and disposed and the levels of mercury in the soil required treatment prior to disposal, then it would likely
be more cost effective to design a cover with more strict specifications and to implement long-term
monitoring and maintenance of that cover. In order to make a final determination on the design of the
native soil cover, further sampling and analysis need to be completed in the pond to define the amount of
soil that would require excavation and how the soil would have to be managed and the associated cost.
Therefore, the specific design of the remedy selected in this ROD, native soil cover with possible
excavation and disposal after sampling, will be dependent upon the results of a sampling and analysis
effort as a first step after the ROD, but before the final design is completed. Figure 10-1 presents a flow
chart of this logic.
Recent investigations have determined that RCRA-listed waste may have been present in the TRA
warm and hot waste systems when leaks from the systems to the environment occurred. If soil is excavated
lor disposal, a hazardous waste determination will be required. Therefore, soils at those sites associated
with releases from the warm waste system and hot waste system will be managed in a manner consistent
with the hazardous waste determination to be performed at the time of the remedial action.
The primary elements of the preferred alternatives for the sites of concern at the TRA remained
relatively unchanged. For this reason, the agencies determined that a new proposed plan and public
comment period were unnecessary.
The Proposed Plan made the following statement in regards to no action sites: "The No Action status
of these sites will be verified on an annual basis to determine whether the status has changed. The concern
10-1
-------
Sample Chemical Waste Pond sediments
Determine amount of soil that would need to be excavated
from, the pond to minimize cover specifications and eliminate the need
for long-term monitoring and maintenance.
J
Determine requirements for and cost of managing the sediments to be excavated
both during excavation and through disposal
Compare the cost of the minimal specification cover including excavation and disposal of
pond sediments with the cost of a cover with more rigorous specifications
and long-term monitoring and maintenance.
Is cost of
minimal spec
'cover with management^
of sediments from
^excavation through disposal morej
than cost of greater spec
cover with cover
.maintenance and,,
monitoring?
Yes
No
Implement cover with greater
specifications and long term
monitoring and maintenance
_L
Design cover to include
management of sediments from
excavation through disposal
with minimal cover specifications
RED V970180
Figure 10-1. Chemical Waste Pond logic diagram.
-------
is that the continued operation of the Test Reactor Area may adversely impact these sites, and therefore.
such status verification is necessary." This language has been changed in the ROD to be consistent with
the NCP. The following language is incorporated in this ROD: "For those sites for which no action is
being taken based on land use assumptions, those assumptions will be reviewed as part of the 5-year
review."
In addition, the following statement regarding future discoveries of contamination was made in the
Proposed Plan: "The possibility exists that contaminated environmental media not identified by the INEL
Federal Facility Agreement and Consent Order (FFA/CO) or in this comprehensive investigation will be
discovered in the future as a result of routine operations, maintenance activities, and/or decontamination
and dismantlement activities at the Test Reactor Area. Future discoveries of radioaclively and chemically
contaminated environmental media will be evaluated as part of the CERCLA 5-year review process. The
5-year review process will ensure remedial actions and institutional controls are maintained. Five-year
reviews will also ensure that any changes in the physical configuration of any Test Reactor facility or site
where there is a suspicion of a release of hazardous substances (such as decontamination and
dismantlement or facility renovation/modification) will be managed to achieve remediation goals
consistent with remedies established for the sites in this proposed plan. Sufficient planning documentation
for such actions will be submitted to the agencies before implementation to ensure this consistency."
This language has been changed in the ROD to be consistent with the NCP as follows: "The
possibility exists that contaminated environmental media not identified by the INEEL FFA/CO or in this
comprehensive investigation will be discovered in the future as a result of routine operations, maintenance
activities, and decontamination and dismantlement activities at TRA." "Upon discovery of a new
contaminant source by DOE, IDHW. or EPA, that contaminant source will be evaluated and appropriate
response action taken in accordance with the FFA/CO."
The Proposed Plan described Alternative 1 as No Action (with monitoring) based on the presumption
that contamination would be left in place under this alternative. However, any contamination remaining in
place has been determined to not pose an unacceptable risk. Therefore, long-term environmental
monitoring is not warranted for the 47 no action sites.
10-3
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11. RESPONSIVENESS SUMMARY
The Responsiveness Summary is designed to provide the agencies with information about
community preferences regarding the selected remedial alternatives and general concerns about the site.
Secondly, it summarizes how public comments were evaluated and integrated into the decision-making
process and records how the agencies responded to each of the comments. Appendix A provides a
summary of community involvement in the CERCLA process for OLJ 2-13 and a summary of comments
received and corresponding agency responses.
-------
DOE/1D-106112
December 22,1997
Sources of Public Comment
Concerning the Proposed Plan for
Waste Area Group 2
at the Test Reactor Area
-------
Appendix A
Responsiveness Summary
-------
Appendix A
Responsiveness Summary
A Summary of Comments Received
During the Public Comment Period
A-1. OVERVIEW
Operable Unit(OU) 2-13 is within Waste Area Group (WAG) 2 of the Test Reactor Area (TRA) at
the Idaho National Engineering and Environmental Laboratory (INEEL). The unit contains 55 identified
release sites contained within 13 operable units. Eight of these sites were determined during the
comprehensive remedial investigation/feasibility study (RI/FS) to have contamination that poses a potential
risk to human health and the environment and that requires remedial action to reduce or eliminate those
risks. For the eight sites that include four disposal ponds, three subsurface soil contamination areas, and
one area of windblown surficial soil contamination, remedial alternatives were evaluated, and preferred
alternatives were selected. In addition to the eight sites of concern at OU 2-13, there were 47 sites that
were determined to pose no unacceptable risk to human health or the environment and were identified by
the agencies as recommended "No Action" alternative sites. A Proposed Plan that summarized the results
of the RI/FS and presented the preferred remedial alternatives was released by the agencies for public
review on March 10, 1997. Public review of this document took place between March 10, 1997, and
April 9, 1997. An additional 30-day review period (to May 9, 1997) was requested and used by the
Shoshone-Bannock Tribes. Public meetings were held in Idaho Falls, Boise, and Moscow, Idaho, on
March 25, 26, and 27, 1997, respectively.
This Responsiveness Summary responds to both written and verbal comments received during the
public comment period and meetings. Generally, support for the selected alternatives for each site was
mixed.
A-2. BACKGROUND ON COMMUNITY INVOLVEMENT
In accordance with Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) Sections 1 l3(k)(2)(B)(I-v) and 117, a series of opportunities was available for public
information and participation in the remedial investigation and decision process forOU 2-13, WAG 2 of
the TRA. from 1991 to the present. For the public, the activities included receiving fact sheets that briefly
discussed the status of investigations to date, INLEL Reporter articles and updates, a Proposed Plan, and
focus group interactions, including teleconference calls, briefings, presentations, and public meetings.
On March 10.1997. the L'.S. Department of Energy. Idaho Operations Office (DOE-ID) issued a
neu release to more than IOC -iici''. .icerning the beginning of a 30-day public comment
period pertaining to the WAG 2 TRA Proposed Plan, which began March 10. 1997. and was extended to
Ma> 9. 1997. In addition, a fact sheet was sent to approximate!) 6.700 people on the IN'EHL Community
A-1
-------
Relations Plan mailing list. Both the news release and fact sheet gave notice to the public that WAG 2
TRA investigation documents would be available before the beginning of the comment period in the
Administrative Record section of the INEEL Information Repositories located in the INEEL Technical
Library, the INEEL Boise Office, and public libraries in Fort Hall. Pocatello, and Moscow, Idaho.
Following the announcement of the public comment period, 6.700 copies of the Proposed Plan were
mailed to the public for their review and comment. In addition, public meetings were held at Idaho Falls,
Boise, and Moscow. Idaho, on March 25. 26, and 27. 1997. respectively. Written comment forms were
available at the meetings, and a court recorder was present at each meeting to record transcripts of
discussions and public comments. A total of about 20 people not associated with the project attended the
public meetings. Overall, 20 citizens provided formal comments: of these, 6 citizens provided verbal
comments and 14 provided written comments.
This Responsiveness Summary has been prepared as part of the Record of Decision (ROD). All
formal verbal comments, as given at the public meetings, and all written comments, as submitted, are
included in the Administrative Record for the ROD. Those comments are annotated to indicate which
response in this Responsiveness Summary addresses each comment. The ROD presents the preferred
alternative for each site of concern and the recommendation for No Action for the remaining sites. The
preferred alternatives were selected in accordance with CERCLA, as amended by the Superfund
Amendments and Reauthorization Act, and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (the National Contingency Plan). The decisions presented in the
ROD are based on information contained in the Administrative Record.
A-3. SUMMARY OF COMMENTS WITH RESPONSES
Comments and questions raised during the public comment period on the Proposed Plan for the
WAG 2 Comprehensive RI/FS for OU 2-13 at TRA are summarized below. The public meetings were
divided into an informal question-and-answer session and a formal public comment session. The meeting
format was described in published announcements, and meeting attendees were reminded of the format at
the beginning of the meeting. The informal question-and-answer session was designed to provide
immediate responses to the public's questions and concerns. Several questions were answered during the
informal period of" the public meetings on the Proposed Plan. This Responsiveness Summary does not
attempt to summuri/c or respond to issues and concerns raised during the informal part of the public
meetings. However, the Administrative Record contains complete transcripts of these meetings, which
include the agencies' responses to these informal questions.
Comments received during the formal comment session of the meetings are addressed by the
agencies in this Responsiveness Summary. The public was requested to provide their comments in
writing, \erbally during the public meetings, or by recording a message using INHHL's toll-free number.
Comments on the Remedial Investigation Process
I. Comment. One commentor expressed concern lhat the investigative process not only repeated
>. >>rk alread\ performed but ignored prior research, and felt lhat we should use all the results, not
liisi recent results. He aKo mentioned sonic concerns related to chromium and strontium-^) in the
aquifer and noted the studies should be as technical as possible. (T-ll. T-Ift. T-17. T-IK)
A-2
-------
Response: It is acknowledged that much of the groundwater investigative work is very similar to
work that has been conducted by the U.S. Geological Survey (USGS) for many years. All past and
present available sources of information, including USGS sources, have been used to evaluate the
site risks and extent of contamination at TRA. Sources of information used to evaluate site-
specific risks can be found in the technical site-specific summary reports (i.e.. Track I and Track 2
documents) for each site. Track 1 and Track 2 technical information can be found in the
Administrative Record for WAG 2.
2. Comment: Even though one commentor thought that the investigations were thorough and that
future monitoring would not be needed, another commentor brought up the "Hot Tree" incident
and hopes that 20 or 30 plants across the site would be sampled. (W-l I, W-30)
Response: The scope of site-wide ecological sampling is being established during the OU 10-04
Comprehensive RI/FS. Other trees in the vicinity of the Hot Tree Site were sampled and found not
to be contaminated. In addition, the CERCLA risk assessment process evaluates plant uptake
factors for exposure scenarios such as ingestion of homegrown produce at sites of concern. The
results of these risk evaluations help guide the type of remedial activity that is necessary to protect
human health and the environment.
There are several other entities that conduct ecological surveys across the site. They are the
Radiological and Environmental Sciences Laboratory at the Central Facilities Area and the
Environmental Research and Science Foundation in Idaho Falls. Copies of their survey reports
can be made available to the public by calling 1 -800-708-2680.
3. Comment: A commentor asked that audits and certification be conducted before remediation is
approved, and that the applicability of ISO 14001, 4.4.4 be addressed. (W-l)
Response: The CERCLA remedial action process requires pre-fmal and final inspections at
completion of construction activities for long-term remedial actions or at completion of
remediation for short-term remedial actions. The purpose of the inspection is to determine if all
aspects of the plans and specifications have been implemented at the site and are performed with
the U.S. Environmental Protection Agency's (EPA's) and State of Idaho's review, concurrence,
and resolution of outstanding issues.
In response to issues and needs identified in a recent DOE-ID and Lockheed Martin Idaho
Technologies Company (LMITCO) assessment, LMITCO is initiating efforts to develop a
LMITCO Environmental Management System (EMS). The objective of the EMS is to reinforce
accountability for compliance and provide the tools and systems to achieve compliance. The
framework for the system is based on ISO 14001. the international EMS standard.
4. Comment: One commentor stated that the cover's performance cannot be evaluated until it is
designed and demonstrated, all of which should take place before the ROD is signed, not after.
(W-42)
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Response: The CERCLA remedial action process provides that alternatives are generally
analyzed as part of the RI/FS process. However, resources are not spent developing specific
details and specifications until the remedy is actually selected in the ROD.
The general barrier design anticipated for the Warm Waste Pond, for example, was implemented
for the INEEL Stationary Low-Power Reactor (SL-I) closure cover. The long-term performance
of this alternative is considered to be highly effective for preventing external exposure to
contaminated surface soil. This basic design will be evaluated and modified as needed during the
post-ROD remedial design process. See Sections 7 through I I of the Comprehensive Remedial
Investigation/Feasibility Study for the Text Reactor Area Operable Unit 2-13 at the Idaho
National Engineering Laboratory (the OU 2-13 Comprehensive RI/FS) for additional supporting
. information.
5. Comment: One commentor noted that the Diesel Unloading Pit had an unlined soil and sand
floor, rather than a concrete floor as expected. The commentor wanted to know when this was
discovered and what other structures are constructed differently than expected. (W-28. W-29)
Response: The Diesel Unloading Pit is the only site of concern at TRA known to have been
constructed differently than expected. All other sites were found to be consistent with current
documented construction descriptions. If new information is discovered in the future regarding
these sites, this information will be considered and acted upon in the CERCLA 5-year review
process. If the new information demonstrates that the selected remedy is fundamentally no longer
valid to protect human health and the environment, then the CERCLA process provides that this
decision would be revisited through a ROD amendment.
6. Comment: One commentor felt that, because the maximum concentration of contaminants
detected was not reported simultaneously with the maximum contaminant levels (MCLs), it
showed a "trivialized characterization of the problem." (W-M9)
Response: It should be noted that MCLs only have meaning when compared to contaminant
levels in drinking water or the aquifer. It would be misleading to list an MCL for soil because
MCLs apply only to drinking water. Risk-based soil concentrations (which are analogous to
MCLs for waicn were thoroughly documented and listed in Appendix B of the OU 2-13
Comprehensive RI/FS.
7. Comment: A commentor fell that No Further Action for polychloi mated biphenyls (PCBs) was
insufficient because 24 ppm is 96^ of the limit of 25 ppm. (W-25)
Response: While the PCB level is 96'£ of the 25-ppm limit, it is still below the limit. The
25-ppm limit tor PCBs was established as part of the Toxic Substances Control Act (TSCA). The
limit has been used as the basis of remediation at industrial PCB release sites located across the
counirv. Because TRA is an industrial facility. 25 ppm is the standard to which cleanup would
have taken place. Because the limit is protective of human health and the environment and none
ol the PCBs detected at the TRA release sues exceed the limit, nu remediation of PCBs is
necessarv.
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8. Comment: A commentor noted that remedial actions were being delayed because operations were
ongoing. The commentor stated that the delays indicate that operations are more important than
remediation, which the commentor held was unacceptable. (W-M32)
Response: The commentor is correct in stating that remediation of two sites (the Brass Cap Site
and TRA-19) is being postponed until active operations in the vicinity are ended. The
postponement is due to these two sites current inaccessibility and the lack of assurance that
adequate cleanup could be achieved to eliminate the need for controls. Because the contamination
is in the subsurface, there is no exposure to workers as long as the institutional controls are
maintained. However, if the sites posed an immediate, unacceptable risk, remediation would not
be delayed in favor of operations^
Comments on the Remedial Investigation Process: Contaminants
9. Comment: Two commentors listed contaminants that they felt should have been included in the
iil/FS: tritium, carbon-14, uranium-234, neptunium-237, iodine-129, plutonium-238/239/240,
nickel, zinc, lead, copper, ammonium; cyanide; benzene, diesel oil, kerosene, xylene, nitrates,
nitrites, sulfates, and phosphates. (T-M1, W-M20)
Response: All contaminants that were detected during sampling at the TRA release sites were
included in the Rl/FS. These sampling investigations were conducted in a systematic manner that
begins with a complete listing of all contaminants suspected of being present or those that are
detected. This list is then screened on a site-by-site basis to determine the presence or absence of
the contaminant at each site. Once this is completed, risk calculations are made based on the
concentrations found. Contaminants that pose no risk are screened out. To be considered a
contaminant of concern, risk analysis must indicate a potential unacceptable level of risk posed by
the given contaminant. The contaminants identified by the commentor were given consideration
during the RI/FS and received detailed analysis in the Rl/FS, but they may not have been
identified as contaminants of concern in the Proposed Plan. Two of the contaminants listed by the
commentor (diesel fuel and kerosene) are not examined as such but are measured by their
constituent products (xylene. benzene, etc.).
10. Comment: One commentor noted a comment by the State during the perched water investigation,
OU 2-12. that the perched water zone may extend farther to the north than DOE recognized. In
addition, he said that because the plume is connected to the Big Lost River flood zone,
contaminants could be transported rapidly to the deep zone. (W-M14. W-M16, W-M17)
Response: These issues were evaluated during the previous OU 2-1 2 remedial investigation and
resolved with the State. Flooding of the Big Lost River was modeled as pan of that investigation.
Analysis indicated that the Big Lost River has a very minor impact, it any, on the edge of the TRA
perched water bodies compared to the volume of water being discharged as a result of routine
operations. The No Action (with monitoring) decision finding from the investigation and resulting
Record of Decision is still valid.
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Comments on Risk Assessment
11. Comment: One commentor questioned whether it is reasonable to assume that a receptor
(resident) would actually be exposed to contaminants at the site, and svhere that reasonableness is
taken into consideration during the risk assessment process. (T-I9. T-II6)
Response: It can be difficult to predict resident exposures MX) years into the future with certainty.
However, it is reasonable to expect that government control will be maintained for at least 100
years. At that point, it is assumed for purposes of a CERCLA baseline risk assessment that a
resident could live at TRA. The residential scenario, whether likely or not. is evaluated in the risk
assessment process based on guidance from the agencies, and this conservative assumption is
intended to ensure that cleanup alternatives are protective.
12. Comment: One commentor wanted to know which risks (by pathway) are current (during the
institutional control period) and which risks will only be present in the future (after the
institutional control period). Therefore, is the present construction of an engineered cover
justified, even though it will increase risk to the groundwater? (W-32. W-35. W-36)
Response: Table 1 of the Proposed Plan presents the calculated risks for workers and potential
future residents at the TRA release sites. These risks were calculated assuming that no remedial
actions would be taken at any of the TRA sites and that access controls to the sites would not be
left in place. The results presented in Table I are the sum of risks calculated for workers and
residents across all exposure pathways after an evaluation of contaminant ingestion, inhalation,
and external radiation exposure. Details of these individual pathway risks can be found in
Section 5 of the OU 2-13 Comprehensive RI/FS.
The plan for constructing an engineered barrier over the Warm Waste Pond was developed to
ensure (hat the pond's contamination would not be spread by wind erosion, and workers or
potential future residents at the site would not receive radiation exposures from the pond's
contamination. In addition, the barrier was developed to inhibit future excavation or intrusion into
the contamination.
It is true that the design will reduce evapolranspiration. which could result in more infiltration. In
response to the commentor's concern about the increased hydraulic load to the aquifer as a result
of an engineered cover. DOE re-ran the hydrologic models. The models increased the potential
amount of flow into groundwaier thai would result from the engineered cover. Even considering
the commentor's concern and a conservative doubling of infiltration, risk does not significantly
increase and remains within acceptable risk levels.
13. Comment: One commentor. noiing the graph of probable cancer per 10.000 exposed individuals.
stated during the public meeting that the rate of 1 in 10,000 is not determinable >n this population
and, therefore, should not be used as a goal or us a limit, since its attainment cannot be proven.
i \V-53)
Response: The I in IO.OOO Joes not mean I person in 10.000 would contract cancer. It is a
proh.ibiliiv thai ;in> person exposed ai those contaminant le\eN would contract cancer. As pail of
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the Comprehensive RI/FS described in the OU 2-13 Proposed Plan, DOE worked closely with
EPA and the State to ensure that risk assessment methods, including calculating risk probabilities,
are in accordance with EPA guidance. These methods have been used to consistently evaluate
risks associated with the TRA release sites and to identify the sites that have a potential for
producing risks that exceed the CERCLA acceptable risk range.
Comments on Risk Assessment: Ground water
14. Comment: A commentor cited the problem with cesium-137 levels in perched water:
176,000 times over the MCL. which will take 500 years to decay down to MCL levels, and will
migrate into the aquifer, which is already considerably over drinking water standards. (T-M5,
W-M12)
Response: The commentor's suggestion that cesium-137 levels in the perched water are
2,000,000 picocuries per liter (which is 176,000 times the MCL is incorrect. The highest level of
cesium-137 detected was 9,920 picocuries per liter (80 times the MCL) in one shallow well at
TRA in 1980. Cesium was last measured in this shallow well at 1,600 picocuries per liter
(13 times the MCL).
Cesium-137 quickly absorbs to the soil or rock medium through which it passes. Therefore, it is
not considered a threat to the aquifer because it will quickly become bound to subsurface material.
where it will remain until it decays. This is demonstrated by the lack of cesium-137 migrating to
the Snake River Plan Aquifer to date, including when discharge to the Warm Waste Pond was
taking place at over 2 million gallons per year. Although it is acknowledged that Cs-137 levels in
the shallow perched water are by no means trivial, models and historic monitoring indicate that
cesium levels in shallow and deep perched water will not reach the aquifer at levels that could pose
a risk. Therefore, this ROD does not alter the previous No Action with Monitoring decision for
OU2-12.
15. Comment: One commentor felt that residents would never need to inhabit the site, so the
residential scenario for risk assessment is not necessary. Conversely, another commentor
wondered how we would protect the residential use of the site after institutional controls are lifted
and felt that the No Action decision is risky. (W-l 3. T-M5)
Response: As stated in the response to Comment 11. the assumption that someone will someday
move to TRA is a conservative assumption that was made for risk assessment purposes. People
may never live at the site, but we can be reasonably assured that no resident would be adversely
impacted by the existing contamination if a potential future resident at the site in KM) years can be
protected.
The No Action decision was recommended for sites that do not pose unacceptable residential
exposure risks. Where contaminant releases have occurred, the risks were calculated in a
conservative manner, indicating it is unlikely that minor contamination left in place at the sites will
one day cause adverse health impacts to future residents. These decisions will be reevaluuted to
ensure that land use assumptions remain valid as pan of the CHRCLA 5-year review process.
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16. Comment: A commentor thought that the Proposed Plan was inadequately reviewed regarding
the effects of its preferred alternatives on the future groundwater pathway risk. (W-46)
Response: The OU 2-13 Comprehensive RI/FS Report and the Proposed Plan received numerous
technical reviews, including reviews internal to LMITCO followed by reviews by EPA and the
State. Areas of review include risk assessment, environmental compliance, quality assurance.
groundwater, and legal.
Comments on Risk Assessment: Groundwater Modeling
17. Comment: One commentor referred to findings that revealed the presence of lava tubes that move
water rapidly through the aquifer and exit at Thousand Springs. The commentor stated that it is
unjustified and unacceptable for DOE to contend that "there is no current use of the perched water
or contaminated Snake River Aquifer in the vicinity of TRA." The commentor questioned the
decision to consider the potential use of the area for only a 125-year period. (W-M23)
Response: Lava tubes have been identified in the Snake River Plain basalts, but they are localized
characteristics of the area's basalt flows. There is no evidence to suggest the possible presence of
intact, uncollapsed lava tubes that could transport groundwater over very large distances beyond
the INEEL to Thousand Springs.
DOE monitors drinking water wells at TRA to ensure that they are not producing contaminated
water. If contaminated water were to be detected at one of these wells, measures would be taken
to ensure that workers have clean drinking water. DOE also routinely monitors wells located off
the INEEL in an attempt to detect groundwater contamination before it could reach water users
downgradient of the site. Very little contamination has ever been detected in these off-site wells.
and contaminant concentrations detected have been well below drinking water standards.
Groundwater monitoring also is conducted independently by USGS and the State's INEEL
Oversight Program.
All of the action decisions recommended in the Proposed Plan were based on risks that are
expected within the next 100 years, but the OU 2-13 Comprehensive RI/FS evaluation was not
limited to this time frame. The RI/FS includes analysis of a residential exposure scenario in 1.000
vears. including computer modeling of groundwater. Remedial action objectives have been
established to ensure that remediation will remain protective of human health and the environment
until contaminant concentrations decrease to an acceptable level.
Comments on Risk Assessment: Ecology
18. Comment: Two commentors noted that the risk assessments consider occupational and residential
scenarios but include very little biological monitoring. They felt that other scenarios, including
Native American subsistence and recreation, should be considered. (T-M2. W-M26)
Response: In addition to the occupational and residential exposure scenarios. Native American
subsistence and recreation scenarios were also considered bin not evaluated individually. The
residential scenario that is evaluated is the most conservative scenario (i.e.. exposure to
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contaminants is greater, or more protective, under the residential scenario than under any other
scenario). For this reason, the residential scenario provides the highest degree of protection.
19. Comment: One commentor wanted to know why the Paint Shop Ditch, the Radioactive-
Contaminated Tank at TRA-614, and the Advanced Test Reactor Cooling Tower are not included
as sites with human health risks greater than allowable levels. (W-19)
Response: All of these sites were included in the WAG 2 Comprehensive RI/FS. They were each
evaluated in a manner that was consistent with the other sites in the RI/FS, and were found to have
risks below the 1 chance in 10,000 threshold. Details on the risk assessment for the sites can be
found in Section 5 of the OU 2-13 Comprehensive RI/FS.
Comments on Risk Assessment: Contaminants
20. Comment: Several commentors suggested that the actual values should be provided, rather than
stating that concentrations are above MCLs or making unquantified statements. Also, one
commentor wondered why tritium and chromium pose a health hazard even though they are below
MCLs. (T-I9. W-16, W-21. W-M25, W-54)
Response: The commentor's implication that a reader is better informed when actual contaminant
concentrations (values) detected are used in the Proposed Plan is well taken. In the future, greater
care will be given to providing actual concentrations (values) in the documents written for public
review. A complete description of the WAG 2 contaminant sampling investigations, including the
detected contaminant concentrations (the actual values) in groundwater, is available and can be
found in Section 4.4 of the OU 2-13 Comprehensive RI/FS.
With regard to the last concern noted above, tritium and chromium are the only two contaminants
that currently exceed MCLs in the groundwater beneath TRA. Groundwater modeling of these
contaminants predicts that they will be below MCLs before the end of the 100-year INEEL
institutional control period. As a result, no one is expected to be exposed to these contaminants at
concentrations that could cause adverse health effects.
21. Comment: One commentor asked if arsenic concentrations are currently below detection limits,
why will there be concentrations producing risks of 3 chances in 1.000.000 at approximately 1,000
years in the future? (W-18)
Response: Arsenic is naturally occurring in soils and groundwater at TRA. Groundwater
modeling predicts that the arsenic could migrate from surface soils down to the aquifer within
1.000 \cars. This migration would be caused by arsenic dissolving in rain and snowmelt moving
through the unsaturaied zone beneath TRA. The model predicts that the maximum risk from
drinking arsenic-contaminated groundwater would be 3 chances in 1,000,000. and that risk would
occur in 1.000 years. The fact that arsenic emerges as a contaminant of potential concern
demonstrates the conservative nntnp' (if the risk assessment process.
22. Comment: One commenlor stated that DOK should not eliminate from consideration those
isotopes with half-lives greater than 5 \eurs. especially cjsium. He wondered if DOH would walk
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away from sediments with high concentrations of cesium, and wanted to know which worst-case
conditions were used for cesium to approach National Contingency Plan limits. (W-M22, W-M27.
VV-M30)
Response: The WAG 2 Comprehensive RI/FS did not eliminate any radionuclides from
consideration based solely on radioactive half-life. All contaminants were evaluated for their
potential to cause adverse impacts to human health and the environment, and contaminants that
have the potential for producing adverse impacts were considered in the RI/FS. Cesium was one
of the many contaminants that was retained for evaluation in the RI/FS. and its presence is the
reason for many of the remedial action recommendations presented in the OU 2-13 Proposed Plan.
23. Comment: A commentor stated that the combined cancer risks for inhalation should be
considered. Because risk from radionuclides is close to the National Contingency Plan limit, will
the combined radionuclide and nonradionuclide risk be over the limit? (W-M24)
Response: The WAG 2 risk assessment considered the combined risks from multiple exposure
routes, including inhalation and ingestion. For any site where the combined risks are over the
acceptable limit, remedial action is being recommended. The "worst-case" conditions evaluated
for soil ingestion assume that, in 100 years, a resident lives on the contaminated site for 30 years.
350 days per year, 24 hours per day, and ingests 100 milligrams of dirt per day.
24. Comment: One commentor contended that the sediment contains hazardous waste despite DOE's
claims to the contrary. Also, even though DOE's tests show that the contaminants did not leach,
how did perched water become highly contaminated if not through leaching? (W-M31)
Response. It is acknowledged that hazardous substances are contained in the sediments and soils
at a number of release sites, hence, the need for investigation and cleanup. Hazardous wastes as
defined by the Resource Conservation and Recovery Act (RCRA) were not generally disposed of
at TRA with few exceptions. New information does suggest that, during its more than 40 years of
existence, the Warm Waste Pond received minute quantities of RCRA-listed hazardous wastes.
More information can be found in Section 9 of the ROD.
Direct infiltration of water that was disposed of in the Warm Waste Pond is the primary source of
the vast majority of contamination in the pond sediments und the TRA perched water. This water
contained contaminants that wore produced by operations at TRA, and (he discharge carried the
contaminants directly to the perched water bodies. Contaminants leaching from sediments are not
a significant continuing source of contamination. All discharges to the unlined Warm Waste Pond
wore discontinued in 1493. and there is no more contaminated water infiltrating to the perched
water bodies from the Warm Waste Pond. Contaminated discharges from the TRA reactors that
previously went to the Warm Waste Pond are now being sent to a lined disposal pond that docs not
allow water to infiltrate into the subsurface. All discharges to the disposal ponds will eventually
cease, at which lime the perched water bodies arc expected to begin to dissipate.
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Comments on Risk Assessment: Land Use
25. Comment: One person said that evaluation of risk at 100 years is not sufficient; it should be
evaluated for 1,000 years or more. (T-M3)
Response: The assumption that in 100 years someone will actually build a home and live at TRA
was made for the purpose of the comprehensive risk assessment. The evaluation was made
because it is conservative. If the site can be remediated to be protective of human health and the
environment in 100 years, it is anticipated to stay that way until contaminant concentrations
decrease to acceptable levels and farther into the future. Additionally, this assumption is
consistent with the Long-Term Land Use Future Scenarios for the Idaho National Engineering
Laboratory.
All of the action decisions recommended in the Proposed Plan were based on risks that are
expected within the next 100 years, but the WAG 2 Comprehensive RI/FS evaluation was not
limited to this time frame. The RI/FS includes analysis of a residential exposure scenario in 1,000
years, including computer modeling of groundwater.
Comments on Alternatives
26. Comment: Several commentors said that efforts should be concentrated on the Chemical Waste
Pond and the Warm Waste Pond to ensure that contaminants (especially mercury) are isolated and
do not pollute the aquifer anymore. Also, a commentor suggested that the engineered cover needs
to be demonstrated and reevaluated to see if it is really the best alternative for the long term as well
as short term. (T-I2, T-I3, T-I10, W-33)
Response: The primary contaminant of concern at the Chemical Waste Pond is mercury.
Contaminants of concern at the Warm Waste Pond include cesium-137. cobalt-60, and chromium.
Computer modeling using GWSCREEN shows that these contaminants do not migrate readily to
the aquifer. Annual average precipitation at the INEEL is approximately 10 cm per year.
Infiltration rates as high as 23 cm per year have been modeled and have shown that residual
contamination would not be expected to add to the cumulative risk in the aquifer. Essentially, the
model tells us that more than two times the average annual precipitation could fall on sites of
concern and the contaminants at the source still would not likely migrate to the aquifer.
The engineered cover is designed to isolate radioactive waste and to reduce surface exposures to
background levels. This barrier design was implemented for the INEEL Stationary Low-Power
Reactor (SL-1) closure cover. The long-term performance of this alternative is considered to be
highly effective for preventing external exposure to contaminated surface soil. This basic design
will he evaluated and modified as needed during the post-ROD remedial design process.
Sections 7 through 1 1 of the OU 2-13 Comprehensive RI/FS contain additional cover design
information.
27. Comment: One commentor wanted to know where excavated, contaminated materials (such as
those from the Cold Waste Pond) were to be emplaccd. Will they ho shuffled around the 1NHF.L
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to temporary locations, or when and where will they be permanently disposed of? (W-15, W-20.
W-23. W-24)
Response: The disposal location for these materials will be determined during remedial design. It
is reasonable to expect that soil excavated from the Cold Waste Pond will be placed in the adjacent
Warm Waste Pond cell to reduce the "footprint" of contaminated soil at the TRA facility and
because they contain the same contaminants. The Warm Waste Pond cells will then be.covered by
an engineered barrier that is designed for the length of time needed for radioactive contaminants in
soil to decay within acceptable levels.
28. Comment: One commentor thought that the publications were valid and informative and that
Alternative 3b is by far the best choice based on cost and the environment. (W-|(), W-l 2)
Response: The Agencies agree that Alternative 3b, containment by capping with a native soil
barrier is the preferred alternative at the Chemical Waste Pond and the Sewage Leach Pond based
on effectiveness, cost, and the other evaluation criteria discussed in the Proposed Plan. This
alternative appears in the ROD as the selected remedy for the Sewage Leach Pond and the
Chemical Waste Pond.
Comments on Alternatives: Evaluation
29. Comment: One commentor felt that the short-term effectiveness rating for the Containment with
Engineered Cover alternative was inaccurate because it rated the alternative as "good" for this
criterion. The commentor stated that the alternative increased risks to the aquifer and posed
additional worker risk in the short-terrn. Therefore, the alternative deserved to be ranked lower
than the other alternatives. For the same reasons, the commentor also questioned the selection of
the preferred alternative for the 1957 cell. (W-43, W-44)
Response: The plan for constructing an engineered barrier over the Warm Waste Pond was
developed to ensure that the contaminated pond sediments would not be spread by wind erosion.
This also ensures that workers at the site would not he exposed to radiation and that future
intrusion or excavation would be inhibited. The proposed design of the cap could allow a small
increase in the amount of water movement through the Warm Waste Pond sediments. Current
modeling suggests that the increased infiltration expected bv the design assumed in the Feasibility
Study and Proposed Plan would not alter overall risk results. The commentor's observations
concerning potential increased infiltration to the aquifer as a result of the cap and slight increases
in worker risks in the short-term are legitimate. However, these concerns are not significant
enough to adjust the relative rankings of the alternatives.
Comments on Alternatives: Cost
30. Comment: Commentors expressed concerns about the cost of covers and remedies with respect to
their adequacy Also. ihe\ slated that the public should know how much risk would be reduced
per million dollars spent, but wondered it the calculations of risk lo the public are reliable in the
first place considering the uncertainty of whether the public will ever live at the site. (T-II 2.
T-II7. T-IIXi
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Response: One of the purposes of soliciting public comment on a Proposed Plan is to provide an
opportunity for citizens to reflect their values concerning the expense of the proposed alternatives
in relation to the benefits gained. A cost/benefit analysis of the various remedial alternatives for
TRA releases was included as part of the WAG 2 Feasibility Study to illustrate the projected range
of construction costs. Although risk reduction per dollar spent is not evaluated, this analysis
considered the alternatives in terms of how well they met the nine CERCLA evaluation criteria
versus the amount of money that would be spent to implement each alternative. The alternatives
recommended in the OU 2-13 Proposed Plan produced the highest potential benefit-to-cost ratios
when compared to other alternatives that could be implemented at each site. Cleanup is being
recommended for sites that pose an unacceptable risk.
Comments on Alternatives: Design
31. Comment: One commentor wondered why we would use a native soil cover for the Warm Waste
Pond 1964 cell when three of the criteria for such a cover are rated as poor. Because the native
soil cover is combined with a riprap or cobble layer, it should really be called an "engineered
cover." (W-22)
Response: The 1964 cell of the Warm Waste Pond is different from the other two cells because
the majority of contamination was removed and approximately 10 feet of clean soil were placed in
the pond as backfill. Therefore, the criteria apply more directly to the other cells where higher
levels of contamination were placed nearer to the ground surface. In the case of the 1964 cell, the
existing soil cover is an effective remedy. However, consistent with the other two cells, a cobble
layer will inhibit future intrusion potential. The cover was not defined as an engineered cover
because there is no intent to engineer the cover design beyond the existing soil cover, with the
exception of the cobble layer.
Comments on Alternatives: Monitoring
32. Comment: One person stated that groundwater monitoring in fractured rock aquifers is very
difficult, expensive, and has a low probability of detecting ground water contamination until the
contamination is fairly widespread. He then asked. "Will there be vadose zone monitoring at any
of the sites to warn of contaminant movement to the aquifer before contaminants reach the
aquifer?" (W-51)
Response: Groundwater monitoring has been conducted in and around the TRA since the late
1950s. The groundwater system is well understood because of the long history of monitoring.
The groundwater monitoring network at the TRA under the OU 2-1 2 monitoring plan currently
consists of six deep perched and three aquifer wells. This continued monitoring effort provides the
necessary information for evaluation of contaminant migration trends between the perched water
system within the vadose zone and the aquifer below. Therefore, no additional vadose zone
monitoring will be performed at any of the sites.
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Comments on Alternatives: Available Alternatives
33. Comment: One commentor stated that the failure to build a vitrification treatment plant identified
in a 1977 EIS limited the RI/FS because fewer treatment alternatives were available. (T-M8)
Response: From a practical standpoint, existing treatment capabilities may be given special
consideration during an Rl/FS. However, the lack of an onsite treatment facility in no way limits
the technologies or alternatives considered during an Rl/FS. New treatment facilities have been
constructed to implement other INEEL RODs. Vitrification of contaminated soils was considered
and eliminated as a viable alternative in the Feasibility Study. For more information about this
proposed treatment, see Section 7.6 of the OU 2-13 Comprehensive RI/FS.
Comments on Groundwater
34. Comment: Several commentors stated that, because contamination in perched water will get into
the aquifer eventually, we should pump and treat the perched water immediately and that we
should monitor contamination levels after 20 years, then every 5 years after that. (T-M10. T-BI.
T-B4. W-MI3)
Response: Groundwater contamination produced by the perched water system infiltration and
disposal well injection was evaluated as part of the OU 2-12 perched water system remedial
investigation in 1992. A ROD was signed for the TRA Perched Water System in December 1992.
In that ROD, it was determined that no remedial action was necessary for the perched water system
at the TRA, and the agencies continue to support that decision. This decision was based on the
results of the human health and ecological risk assessments, which determined that conditions at
the site pose no unacceptable risks to human health or the environment for expected current or
future use of the Snake River Plain Aquifer beneath the perched water system at the TRA.
In addition, it was determined in the ROD that groundwater monitoring would be conducted to
verify that contaminant concentration trends follow those predicted by groundwater computer
modeling. Based on 3 years of monitoring, the expected contaminant concentration patterns have
been observed for most wells. In some cases, expected declines in tritium and chromium
concentrations have not occurred, but concentrations are well below predictions in the OU 2-12
Perched Water Rl/HS. Discontinuance of the discharges to the Warm Waste Pond appears to have
caused a reduction in most, hut not all. of the deep perched \\ater wells. There has been a decline
in hydraulic heads in the deep perched water system, but that decline appears to have been caused
primarily b\ reduced discharges to the Cold Waste Pond. Contaminant Hushing in the deep
perched water system varies widely with location because of variations in hydraulic properties and
the possible mixing and lateral spreading ol the infiltration water and contaminants in the shallow
perched \\ater system. Continued monitoring of the perched uater svstem and the aquifer is
recommended in this OL 2-13 ROD.
35. Comment. A commcmor stated that contaminated perched \\ater should he pumped and treated.
li v\as recommended that this he done using funds from nuclear material production. The
coinmemor noted that nroundv\aier contaminants bcha\e m a variei\ of \\a\s that raise
A-14
-------
environmental and public health concerns. To address this, contaminated groundwater should be
removed. (W-M18)
Response: The No Action (with monitoring) decision for the perched water below TRA was
officially adopted upon the signing of the OU 2-12 ROD in 1992. No new information was
developed during the OU 2-13 RI/FS to alter that decision or to justify expenditure of federal
funds, regardless of source.
With respect to contaminants in groundwater, each contaminant may behave differently. That is
why a remedial investigation seeks to identify the contaminants causing unacceptable risk. The
behavior of these contaminants is studied, modeled, and considered when developing alternatives
and selecting a preferred alternative (see the OU 2-12 Perched Water ROD for more information
on why the agencies determined they would monitor rather than remediate groundwater). Please
refer to the response to Comment No. 20 in regard to tritium and chromium concentrations in the
groundwater below the TRA. Contaminant concentrations are predicted to fall below MCLs
before the end of the 100-year INEEL institutional control period.
36. Comment: Three commentors felt that, because of the nature of the contamination (how the data
peaks and trails off) and the nature of the aquifer (as a natural filter), there is no need to be
concerned about the perched water because it will go away and the contamination will not get in
the springs if dumping is stopped now. (T-I11, T-I14, T-I20)
Response: Computer modeling and monitoring data support the comment. Contaminant levels in
the aquifer have steadily decreased since contaminant discharges ceased and are expected to
continue to decrease to within acceptable levels before reaching future residents on or off what is
now the INEEL. Please refer to the response to Comment No. 20 in regard to tritium and
chromium concentrations in the groundwater below the TRA. Contaminant concentrations are
predicted to fall below MCLs before the end of the 100-year INEEL institutional control period.
37. Comment: Commentors asked why strontium was not identified in addition to the cesium,
especially because strontium is more mobile than cesium and has been detected since 1964 in the
deep perched water zone. (T-I24, T-I25)
Response: Strontium-90 is identified as a contaminant of concern at the TRA surface sites and
was evaluated in the risk assessment to determine the risk associated with exposure to this
contaminant. As a contaminant of concern, strontium-90 contributes to the overall risk at the site.
Remedial action will be conducted at those sites where the cumulative risk, of which strontium-90
is a contributor, exceeds acceptable levels. Note that sampling and analysis of strontium-90 will
continue under the OU 2-12 ROD for both the deep perched water system and the aquifer.
Comments on Infiltration
38. Comment: Several commentors suggested the need for an infiltration barrier. Many commentors
felt that the existing native soils or a bentonite seal cover would contain contaminants better than
an engineered harrier, and that an engineered barrier would keep animals out but would increase
the infiltration rate into ihe aquifer. In addition, they asked for results of containment studies and
A-15
-------
comparisons. The commentors stated that, because the engineered barrier described in the.
Proposed Plan does not decrease infiltration, it is not really a containment barrier, so the name of
Alternative 3a should not have the word "containment" in it. Also, using the native soils as a
containment barrier should be a completely separate alternative. (T-I4. T-I5, T-113, T-115. T-I22.
W-5. W-6. VV-31, W-34, W-37, W-38, W-39, W-40, W-41. W-49, W-50. W-52)
Response: Based on computer modeling, in no case did the model predict that contaminants at the
surface sites would migrate to the aquifer at concentrations of concern. This was true even when
twice the annual average precipitation (23 cm/year) was input into the model. That was an
important consideration when evaluating the two cover designs. Because migration of
contaminants to the aquifer does not appear significant, the focus of the cover designs has been to
inhibit exposure of contaminants to current and future receptors, rather than to prevent migration
of those contaminants to the aquifer.
Though the use of an engineered barrier may increase the infiltration rate, computer modeling of
two times the average infiltration shows that the risk to groundwater does not increase
substantially. Both the engineered barrier and the native soil barrier were evaluated separately
during the Feasibility Study. Results of the study evaluating these two barriers can be found in the
OU 2-13 Comprehensive RI/FS Report contained in the Administrative Record.
39. Comment: Commentors asked what would happen if, after the engineered barrier is in place,
future information indicates the barrier is ineffective? Would the barrier be removed? Why not put
the engineered barrier in place in the future after institutional controls are removed? (W-45, W-47,
W-48)
Response: Leaving the cover off would require that limited actions (institutional controls) be
implemented. The Limited Action alternative was evaluated during the RI/FS and did not meet
remedial action objectives as effectively as installation of an engineered barrier. The CERCLA
process requires a review at least every 5 years after remedial action is completed to determine and
ensure that the remedial action continues to be protective of human health and the environment.
If, during that review, it is determined that the remedial action no longer is protective, then the
agencies could determine what appropriate action would be necessary. If a fundamental change in
the remedy were determined to be appropriate, a ROD amendment, including public comment,
would be initiated.
Comments on Public Involvement
40. Comment: Some commentors stated that the documents and meetings should better educate the
public. This should include providing specific numbers and facts. Mich as comparing contaminant
levels li> regulator) limits le.g.. drinking uater standards) that indicate the magnitude ol the
contamination relative to a baseline. Another commentor stated that presenters should be better
prepared and should not present conflicting information. Another commentor raised concerns
about communication needing to be clear and to avoid the "fear factor" (hat might affect
communication. Also, one commenlor felt that the focus nup did not reveal the true feelings of
the participants. (T-M4. T-B2. T-B3. T-B5. \V-M21. \V-4. T-MV)
A-16
-------
Response: As a result of a citizen's focus group held to review the draft Proposed Plan and
accompanying fact sheet, a number of statements were added to the text of the final documents to
add candor and acknowledge problems caused by the release of contaminants to the environment.
With reference to the need for providing specific facts and comparisons of contaminant levels
(such as drinking water standards) and not down-playing or trivializing the presence of
contaminants, the agencies will continue to pursue improved methods to communicate information
to the public. Because there are no legal standards dealing with or regulating concentrations of
contaminants in soil similar to those for drinking water, risk-based standards are used or
calculated. The DOE will reference established standards, when applicable, to aid citizens in
determining when contaminant levels exceed legal standards.
Presenters strive to be prepared and have facts at hand but are subject to unintentional mistakes.
When occasional contradictions arise during public presentations concerning proposed cleanup
plans, the agencies will make every effort to have the issue resolved during the discussion.
. Meeting facilitators are instructed to provide the attention necessary' to either resolve the conflict or
ask the agency representatives to provide a response to the interested parties.
In response to one commentor's request, focus group members were polled concerning their
feelings about the agencies' preferred alternative. Each focus group member was called and asked
their opinion of alternatives proposed by the agencies. One person opposed the agencies'
recommendation; three people would have liked more of an aggressive remedial action; one person
felt that even though they supported the alternative, the recommendation went farther than it
needed to; and three people agreed with the recommendation. (The original intent of focus group
review of the draft documents was to offer suggestions concerning readability, layout,
completeness, and user friendliness rather than concerning the remedies.)
41. Comment: One commentor stated that the information presented at the public meeting was
important and educational, and lamented the fact that only one citizen attended. The commentor
observed that some people spread the idea that the greater the fearthe greater the risk.. (T-B2,
T-B3.T-B5)
Response: The agencies would receive greater benefits if increasing numbers of citizens would
interact with project managers during the open public comment periods. Citizens are invited to
evaluate and suggest new methods of communicating and improving public participation.
42. Comment: While critical of aspects of the project, a commentor stated that it was good that the
environmental and public issues were being addressed. (T-I21)
Response: Comment noted.
43. Comment: One commentor representing a group wanted an extension for comments. (W-3)
Response: In response to the request for an extension, the agencies extended the public comment
period an additional .n) iiu\v
44. Comment: One commentor supported the plan and implementation, t\V-Si
A-17
-------
Response: Comment noted.
45. Comment: One comrnentor asked whether access to public comments was available on the
Internet. (W-2)
Response: All public comments received at the public meetings and compiled into meeting
transcripts are available on the Internet under the OU 2-13 Comprehensive RI/FS at
http://ar.inel.gov/home.html.
46. Comment: One commentor expressed frustration that public meeting dates were changed.
(T-M7)
Response: With regard to having published different meeting dates in the draft and final plans,
the DOE acknowledges and regrets the confusion that may have resulted from changes in meeting
dates. The original intent of the draft, which contained tentative dates, was to allow eight focus
group members an opportunity to review the user friendliness of the plan, and it was meant to be
draft information. Following the review of the draft plan, the meeting dates were confirmed in the
release of the final plan.
Comments on ER Programmatic Issues/DOE
47. Comment: A commentor noted that the contractor who operates the facility profits from
expenditures on remediation, creating an incentive to pollute. The commentor also expressed
concern about DOE self-regulation with respect to radioactive materials and called for an
independent agency to oversee DOE activities. (W-M34)
Response: While having responsibilities for operations and environmental remediation may
create a perception of an incentive to pollute, it is not believed to be true. Contractor incentives
and awards as well as fines and penalties are based on compliance with environmental
requirements. Deliberate actions of [his nature would constitute prosecutable criminal behavior.
The coinmentor's desire for independent oversight of DOE activities is achieved through State and
EPA oversight of remedial actions.
48. Comment: The Shoshone-Bannock Tribes commented that thev are primarily concerned that the
contamination that has accumulated at the INEEL over the past 50 years will be cleaned up or
mitigated to the maximum extent possible. In addition, all efforts should be made to alleviate
impacts to the health, welfare, safety, and cultural and treaty rights of the Tribes and others on the
Snake River Plain. The Tribes voiced the imperative need to respect and restore the environment.
i \V-l4i
Response: The restoration process at the INEEL is designed to alleviate adverse impacts i<>
human health and the environment. The long-term effects of accumulated contamination are
addressed in this process. ;md risk-based review and cleanup provide (he most effective means to
idcntifv. mitigate, and correct past practices.
A-IS
-------
Concerns With Previous Decisions
49. Comment: Several commentors expressed concerns about radionuclides (strontium-90 and
cesium-137) not being permanently isolated in the Warm Waste Ponds. The commentors also
expressed concerns about problems related to hot waste tanks TRA-15, TRA-16, TRA-19, and
TRA-603/605. They stated that DOE is ignoring its cleanup responsibilities and should pursue
containment strategies more aggressively. (T-M11. W-M10, W-MI I. W-MI5, W-MI9. W-M28,
W-M29. W-M3la, W-M33)
Response: It is recognized by DOE, EPA, and the State that there are a number of cleanup
technologies that could have been or could still be applied at contaminated sites and that there are
a number of opinions concerning what would be most effective. However, as stated in the Warm
Waste Pond and the Perched Water Proposed Plans and RODs, the agencies believe the '
alternatives proposed and the decisions made were appropriate. The agencies have no plans to
significantly alter the proposed alternatives contained in the Proposed Plan for the Comprehensive
TRAOU2-I3RI/FS.
At the time of the Interim Action ROD for Warm Waste Pond contaminated soils, the agencies
knew that containment could be implemented to achieve the cleanup objectives established for that
ROD. However, in the spirit of CERCLA and the National Contingency Plan (which has a
preference for treatment where reduction of toxicity, mobility, and volume can be achieved), a
treatment option was attempted. Because the treatment option was unproven, the first step was to
conduct treatability studies to determine whether the treatment would work and how it should be
implemented. A contingency remedy of a soil cover was included in the ROD in case the
treatment option was not successful.
As the commentor noted, the treatability study demonstrated that some contaminants could be
removed from the soil. However, insufficient contaminants could be removed to achieve the
cleanup goals. In addition, costs were high, safety issues were increasing, and the volume of
secondary wastes generated by the treatment was a concern. Thus, implementing the contingency
remedy of a soil cover was deemed to be the best option by the agencies. This was especially true
when considering that the contaminants of concern have relatively short decay rates (5 years half-
life for cobalt-60 and 33 years half-life for cesium-137). The decision to implement the
contingency remedy of emplacing a soil cover after consolidation of contaminated soil into a
smaller area was made through an Explanation of Significant Difference to the Interim Action
ROD for the Warm Waste Pond, as one of the commentor's noted.
Comments on Budget
50. Comment: A couple of commentors questioned the expense of cleanup considering the future
land use of the site being questionable and that too much money has been spent to date on the risk
assessment and characterization of these sites. (T-I19. W-53j
Response: The purpose of the CFRCLA risk assessment is to provide the ri>J. :.ianagers from the
agencies with the information needed to make decisions regarding remedial action at a site. The
risk assessment process has \ery specific guidance regarding the quantitative analysis of sile-
A-19
-------
specific information necessary to make a determination if contaminants at a site pose an
unacceptable or acceptable risk to human health and the environment. The question of whether a
site poses an acceptable risk must be answered. The National Contingency Plan defines an
acceptable risk range as I in 10.000 to I in 1,000,000. EPA uses this as a "target range" within
which the agency strives to reduce risks as part of a Superfund cleanup.
Cost estimates for the alternatives analyzed were developed for comparison purposes. The actual
cost of implementing the selected alternative will vary somewhat during actual design and
implementation. The cost estimates described in the Proposed Plan were developed on the basis of
a preliminary conceptual design. Many details are not well defined. These details are accounted
for within a contingency cost element that is included in each alternative.
51. Comment: One commentor was disappointed that DOE had eliminated funding for the Agency
for Toxic Substances and Disease Registry (ATSDR) fordoing health consultations and stated that
funding should be restored to allow health consultations on all RODs. (T-M6)
Response: DOE has just completed an interagency agreement with ATSDR to complete the
health assessments required by CERCLA. DOE is providing funding under the agreement so
ATSDR can meet its requirements under CERCLA. Health consultations are provided on DOE's
request as needed and as determined necessary.
Comments on the TRA Facility Interface
52. Comment: Several commentors wanted to know how the schedules for the Materials Test
Reactor, the Engineering Test Reactor, the Chemical Leach Pond, the Cold Waste Pond, and
continued operations of TRA would impact cleanup. (W-7. W-9, W-17)
Response: During the past 40 years, TRA has provided facilities, utilities, and support
capabilities for government and private agencies to conduct experiments associated with the
development, testing, and analysis used in nuclear and reactor applications. Because past and
present activities associated with TRA facilities and structures are "co-located" with TRA release
sites identified in the FFA/CO, an analysis was performed to address the potential for causing
current risk to 1/c underestimated (sec Appendix D of the OU 2-1 3 Comprehensive RI/FSt. The
analysis performed includes a review of past and present operational activities at TRA and
associated facilities and structures, and management control procedures to prevent and mitigate
releases. All facilities and structures that are operational, that arc no longer being used for their
original mission, or that are in standby or abandoned mode are included in this analysis. Based on
the analysis performed of co-located facilities and activities and management control to prevent
releases to the environment, only the Warm Waste Treatment System and the Engineering Test
Reactor stack are identified to have the potential to impact comprehensive risk at TRA. The
analysis does not identify any structures or facilities that posed an imminent threat of release.
However, live-year reviews will evaluate changing conditions that could result in unacceptable
risk.
A-20
-------
Except for the Brass Cap Area and TRA-19 (which are being addressed by limited action with a
contingent excavation and disposal option), it is not anticipated that current operations at TRA will
inhibit cleanup operations.
Editorial Comments
53. Comment: One commentor suggested changing "and" to "sand" in the last paragraph of page 30
of the Proposed Plan. A commentor noted editorial changes suggesting "North Storage Area
including North Storage Area Soil Contamination Area" (page 31, first paragraph) should be set
off as a heading or made into a complete sentence. (W-26, W-27)
Response: Comments noted.
A-21
-------
INDEX BY RESPONSE NUMBER
Response
1
1
1
1
>
->
3
4
5
5
fi
7
X
9
9
10
10
10
! 1
1 1
i:
i:
i:
13
14
14
15
\^
r
Last name
Barraclough
Barraclough
Barraclough
Barraclough
Capek
Tanner
Stonehill
McCarthy
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Broscious
Shoshone-Bannock Tribes
Broscious
Broscious
Cruz
Broscious
Broscious
Broscious
Barraclough
McCartlu
McCarths
McCarthy
McCarthy
Anonvmous
Hroscioux
Hroscioiis
H.impMin
McC.inln
Broscious
First name
Jack
Jack
Jack
Jack
John
John
L. George
James
Chuck
Chuck
Chuck
Rico
Chuck
Chuck
Chuck
Jack
Jamex
James
James
James
Chuck
Chuck
Walter
J.lllltfx
Chuck
Comment
number
T-ll
T-16
T-I7
T-IS
W- 1 1
.W-30
W-l
W-42
W-28
W-29
W-M9
W-25
W-M32
W-M20
T-M1
W-MI4
W-MI6
W-MI7
T-19
T-llh
W-32
W-35
W-36
W-53
T-M5
W-MI2
\V- 1 3
\V-4d
\\.\123
Page Number
A-2
A-2
A-2
A-2
A-3
A-3
A-3
A-3
A -4
A-4
A -4
A-4
A-5
A-5
A-5
A-5
A-5
A-5
A-o
A-fi
A-fi
A-fi
A-6
A-h
A-7
A -7
A-7
A-H
A-S
A-22
-------
INDEX BY RESPONSE NUMBER
Response
18
18
19
20
20
20
20
21
2"i
22
))
23
24
25
26
26
26
26
27
27
27
27
28
2S
2l>
29
30
30
3n
Lust name
Bruscious
Cruz
Shoshone-Bannock Tribes
Anonymous
Broscious
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Broscious
Broscious
Broscious
Broscious
Broscious
Cruz
Barraclough
Barraclough
Barraclough
McCarthy
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Capek
Capek
McCarthy
McCarthy
Anonymous
Anonvmous
Kiirraclouyh
First name
Chuck
Rico
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Rico
Jack
Jack
Jack
James
John
John
James
James
Jack
Comment
number
W-M26
T-M2
W-19
W-54
W-M25
W-16
W-21
W-18
W-M22
W-M27
W-M30
W-M24
W-M3I
T-M3
T-I2
T-13
T-IK)
W-33
W-15
W-20
W-23
W-24
W-IO
W-12
\V-43
W-44
T-II7
T-IIS
T-II2
Page Number
A-8
A-8
A-9
A-9
A-9
A-9
A-9
A-9
A- 10
A-IO
A-10
A-IO
A-IO
A-ll
A- II
A-ll
A-ll
A-ll
A- 12
A- 12
A- 12
A- 12
A- 12
A- 12
A- 12
A-12
A- 12
A-12
A- 1 2
A-23
-------
INDEX BY RESPONSE NUMBER
Response
31
32
33
34
34
34
34
35
36
36
36
37
37
38
38
38
38
38
38
38
38
38
38
38
38
38
?x
^s
3s
Last name
Shoshone-Bannock Tribes
Hubbell
Broscious
Broscious
Broscious
Howard
Howard
Broscious
Anonymous
Barraclough
White
Anonymous
Anonymous
Anonymous
Barraclough
Barraclough
Bingham
Hubbell
Hubbell
Huhhell
Kenney
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
White
First name
Joel
Chuck
Chuck
Chuck
Chuck
Jack
C.E.
Jack
Jack
G.E.
Joel
Joel
Joel
R.A.
James
James
James
James
James
James
James
C.I-.
Comment
number
W-22
W-51
T-M8
W-MI3
T-BI
T-B4
T-MK)
W-M 1 8
T-120
T-lll
T-II4
T-I24
T-I25
T-I22
T-I4
T-I5
W-5
W-49
W-50
\V-52
\V-d
\V-3I
W-34
W-37
\\-38
\v-3y
W-40
\\--il
T-II3
Page Number
A- 13
A- 13
A- 14
A-14
A-14
A-14
A-14
A- 15
A- 15
A- 15
A- 15
A- 15
A-15
A- 16
A- 16
A- 16
A-I6
A- 16
A- 16
A- 16
A- 16
A- 1 6
A- 16
A- 16
A- 16
A-16
A- 16
A-16
A-16
A -24
-------
INDEX BY RESPONSE NUMBER
Response
38
39
39
39
40
40
40
40
40
40
40
41
41
41
42
43
44
45
46
47
48
49
49
49
49
49
49
4*j
49
Last name
While
Hubbell
Hubbell
McCarthy
Bingham
Broscious
Broscious
Broscious
Howard
Howard
Howard
Howard
Howard
Howard
Anonymous
Bobo
Kenney
Bink
Broscious
Broscious
Shoshone-Bannock Tribes
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
First name
C.E.
Joel
Joel
James
G.E.
Chuck
Chuck
Chuck
Robert
R.A.
Lou
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Comment
number
T-II5
W-47
W-48
W-45
W-4
T-M4
T-M9
W-M2I
T-B3
T-B2
T-B5
T-B3
T-B2
T-B5
T-I2I
W-3
W-8
W-2
T-M7
W-M34
VV-14
T-M 1 1
W-MIO
W-M 1 1
W-M 15
W-M 19
W-M28
W-M 29
W-M33
Page Number
A-16
A-16
A-16
A-16
A-16
A-16
A-16
A-16
A-16. A-17
A-16, A- 17
A-16, A-17
A-16, A-17
A-16, A-17
A-16, A-17
A-17
A-17
A-17
A- IX
A- 1 8
A- 1 8
A- 1 8
A- 19
A- 19
A- 19
A- 19
A- 19
A- 19
A- 19
A- 14
A-25
-------
INDEX BY RESPONSE NUMBER
Response
49
50
50
51
52
52
52
53
53
Last name
Broscious
Anonymous
White
Broscious
Enckson
Kenney
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
First name
Chuck
C.E.
Chuck
Philip
R.A.
t
Comment
number
W-M31a
T-II9
W-53
T-M6
W-9
W-7
W-17
W-26
W-27
Page Number
A-19
A- 19
A-19
A-20
A-20
A-20
A-20
A-21
A-21
A-2(
-------
INDEX BY LAST NAME
Last name
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Bingham
Bingham
Bmk
Boho
Bniscious
Brn\cioux
Bni'o.'iiHiN
First name
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
G.E.
G.E.
Lou
Roheri
Chuck
Chuck
Chuck
Comment
number
W-53
W-54
T-I17
T-II8
T-120
T-124
T-I25
T-I22
T-I2I
W-53
T-I1
T-I6
T-17
T-I8
T-I9
T-I2
T-I3
T-IIO
T-II2
T-III
T-14
T-I5
W-5
W-4
VV-2
XV-3
\V-M9
\V-M32
\V-M:U
Response
number
13
20
30
30
36
37
37
38
42
50
1
1
1
1
II
26
26
26
30
36
3S
3S
38
40
45
43
6
S
y
Page Number
A-6
A-9
A- 12
A- 12
A-15
A- 15
A-15
A- 16
A-17
A-6
A-15
A-2
A-2
A-2
A-6
A-l 1
A- II
A- II
A- 12
A-15
A- 16
A- 16
A- 16
A- 16
A- IS
A-17
A -4
A -5
A -5
A-27
-------
INDEX BY LAST NAME
Last name
Broscious
Broscioi's
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Br"scious
Hr.iscious
First name
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Comment
number
\V-MI4
W-MI6
W-MI7
T-M5
W-MI2
W-M23
W-M26
W-M25
W-M22
W-M27
W-M30
W-M24
W-M3I
T-M8
W-MI3
T-MK)
W-M18
T-M4
T-M9
W-M2I
T-M7
\V-M34
r-M ii
W-MIO
\V-M1I
\V-MI5
\V-MI4
\\-M2S
W-M24
Response
number
10
10
10
14
14
17
IS
20
i i
11
11
23
24
33
34
34
35
41)
40
40
4d
47
44
44
44
44
44
44
44
Page Number
A-5
A-5
A-5
A -7
A-7
A-8
A-8
A-9
A-IO
A- 10
A-IO
A-IO
A-IO
A-14
A-14
A- 1 4
A- 1 5
A- 16
A- 16
A- 16
A- IX
A- IK
A-14
A- 1 4
A-14
A-14
A- 1 1>
A-14
A-14
A-2S
-------
INDEX BY LAST NAME
Last name
Broscious
Broscious
Broscious
Capek
Capek
Capek
Cru/
Cru/
Cru/,
Erickson
Hampson
Howard
Howard
Howard
Howard
Howard
Howard
Howard
Howard
Huhhell
Hubbell
Hubhell
Hubbell
Hubbell
Huhbell
Kcnnex
Kcnne>
Kcnncv
McOrilu
First name
Chuck
Chuck
Chuck
John
John
John
Rico
Rico
Rico
Philip
Walter
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr
Mr.
Joel
Joel
Joel
Joel
Joel
Joel
R.A.
R.A.
R.A.
James
Comment
number
W-M33
W-M31a
T-M6
W-ll
W-10
W-12
T-M1
T-M2
T-M3
W-9
W-13
T-BI
T-B4
T-B3
T-B2
T-B5
T-B3
T-B2
T-B5
W-51
\V-49
W-50
W-52
W-47
W-4S
W-6
W-8
\V-7
\\-42
Response
number
49
49
51
i
28
28
9
18
25
52
15
34
34
40
40
40
41
41
41
32
38
38
38
39
39
38
44
52
4
Page Number
A-19
A-19
A-20
A-3
A-12
A- II
A-5
A-8
A- II
A-20
A-7
A-14
A-14
A-16, A-17
A-16. A-17
A-16. A-17
A-16. A-17
A-16. A-17
A-16. A-17
A- 1 3
A-16
A-16
A-16
A-16
A-16
A-16
A-17
A-20
A-3
A-29
-------
INDEX BY LAST NAME
Last name
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
Shoshone-Bannock Tribes
Slioshone-Bannock Tribes
Shoshone-Bunnock Tribes
Shoshone-Bannock Tribes
Shothone-Bannock Tribes
Shoshone- Bannock Tribes
Shoshone- Bannock Tribes
S hi
-------
INDEX BY LAST NAME
Last name
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Stunehill
Tanner
White
White
White
White
First name
L. George
John
C.E.
C.E.
C.E.
C.E.
Comment
number
W-17
W-26
W-27
W-l
W-30
T-II4
T-II3
T-II5
T-II9
Response
number
52
53
53
3
2
36
38
38
50
Page Number
A- 20
A-21
A-2!
A-3
A-3
A- 15
A-16
A-16
A-19
A -31
-------
INDEX BY COMMENT NUMBER
Comment
number
W-53
W-54
T-II7
T-II8
T-I20
T-I24
T-125
T-I22
T-I21
W-53
T-ll
T-I6
T-I7
T-I8
T-I9
T-I2
T-I3
T-IIO
T-ll 2
T-III
T-14
T-15
W-5
\V-4
\V 2
W-3
\V-M4
W-M32
\V-M2n
Last name
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Anonymous
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Barraclough
Bmgham
Bmgham
Bink
Boho
BroscioiiN
Brnscii'iix
Broscious
First name
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
Jack
G.li.
C..H.
l.ou
Roheri
Chuck
Chuck
Chuck
Response
number
13
20
30
30
36
37
37
38
42
50
I
1
1
1
11
26
26
26
30
36
3s
38
38
40
45
43
(i
x
V
Page Number
A-6
A-9
A- 12
A- 12
A- 1 5
A- 1 5
A- 1 5
A-16
A- 17
A-6
A- 15
A-2
A-2
A-2
A-6
A- II
A- II
A-l 1
A- 12
A- 15
A- 1 6
A-16
A-16
A-16
A- 1 S
A- 17
A-4
A-5
A -5
-------
INDEX BY COMMENT NUMBER
Comment
number
W-MI4
W-M16
W-M17
T-M5
VV-MI2
W-M23
W-M26
W-M25
W-M22
W-M27
W-M30
W-M24
W-M3I
T-M8
W-MI3
T-MK)
VV-MI8
T-M4
T-M9
W-M2I
T-MV
W-M34
T-MI1
\V-MIO
\V-M 1 1
W-MI5
W-MI9
\V-M2.X
\V-M29
Last name
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
Broscious
BroM'iou.s
Brosciitus
First name
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck'
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Chuck
Response
number
10
10
10
14
14
17
18
20
22
22
22
23
24
33
34
34
35
40
40
40
46
47
49
49
49
49
49
44
44
Page Number
A-5
A-5
A-5
A-7
A-7
A-8
A-8
A-9
A- 10
A- 10
A- 10
A-IO
A- 10
A-14
A-14
A-14
A- 15
A- 16
A- 16
A- 16
A- 1 8
A- IS
A- 19
A-14
A- 19
A- 19
A- 19
A- 19
A-14
A-33
-------
INDEX BY COMMENT NUMBER
Comment
number
W-M33
W-M3la
T-M6
W-ll
W-IO
VV-12
T-MI
T-M2
T-M3
\V-9
W- 1 3
T-BI
T-B4
T-B3
T-B2
T-B5
T-B3
T-B:
T-B5
W-5 |
W-49
Won
W-52
W-47
W-4X
W-h
\V-X
\\
W-42
Last name
Broscious
Broscious
Broscious
Cupek
Capek
Capek
Cru/
Cru/.
Cru/.
Hrickson
Hampson
Howard
Howard
Howard
Howard
Howard
Howard
Howard
Howard
Huhbell
Huhhell
Huhbell
Hubholl
Hubhcll
Huhbell
Kenney
Kennev
Kenne\
Nkl'.ntln
First name
Chuck
Chuck
Chuck
John
John
John
Rico
Rico
Rico
Philip
Walter
Joel
Joel
Joel
Joe!
Joel
Joel
R.A.
R.A.
R.A.
JamcN
Response
number
49
49
51
T
2X
2S
9
IK
25
52
15
34
34
40
40
40
41
41
41
32
3X
3S
3S
39
39
3S
44
>2
4
Page Nuniber
A-19
A- 19
A-20
A-3
A- 12
A- 1 1
A-5
A-8
A- 11
A-20
A-7
A-14
A- 14
A-16. A-17
A- 1 6, A- 1 7
A-16. A-17
A-16. A-17
A-16. A-17
A-16. A-17
A- 13
A-16
A-16
A-16
A-16
A-16
A-16
A- 1 7
A-20
A-3
A-.M
-------
INDEX BY COMMENT NUMBER
Comment
number
T-II6
W-32
W-35
W-36
W-46
W-33
W-43
W-44
W-3 1
W-34
W-37
W-38
W-39
W-40
W-41
W-45
W-28
W-29
W-25
W-19
W-16
W-21
W-IH
W-IS
\V-20
\V-23
\V-24
\V-22
\V-I4
Last name
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
McCarthy
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone-Bannock Tribes
Shoshone- Bannock Tribes
Shoshone-Bannock Tribes
Shoihonc- Bannock Tribes
Shoshonc-Banmvk Tribes
First name
James
James
James
James
James
James
James
James
James
James
James
James
James
James
James
James
Response
number
11
12
12
12
16
26
29
29
38
38
38
38
38
38
38
39
5
5
7
19
20
20
21
27
27
27
27
31
4S
Page Number
A-6
A-6
A-6
A-6
A-8
A-ll
A-12
A- 12
A-16
A-16
A-16
A-16
A-16
A-16
A-16
A-16
A-4
A-4
A-4
A-9
A-9
A-9
A-9
A-12
A- 1 2
A- 1 2
A- 1 2
A- 1 3
A- IS
-------
INDEX BY COMMENT NUMBER
Comment
number
\V-I7
W-26
W-27
W-l
W-30
T-I14
T-II3
T-115
T-119
Last name
Shoshone-Bannock Tribes
Shoshone- Bannock Tribes
Shoshone-Bannock Tribes
Stonehill
Tanner
White
White
White
White
First name
L. George
John
C.E.
C.E.
C.E.
C.E.
Response
number
52
53
53
3
T
36
38
38
50
Page Number
A-20
A-21
A-21
A-3
A-3
A- 15
A- 16
A-16
A- 19
Aoh
-------
Appendix B
Administrative Record File Index
-------
Appendix B
Administrative Record File Index
This Administrative Record File index is a summary listing of documents arranged according to
operable unit within Waste Area Group (WAG) 2, Test Reactor Area (TRA). The following provides the
beginning page number for the administrative record for each individual operable unit:
Operable Unit
OU 2-01
OU 2-02
OU 2-03
OU 2-04
OU 2-05
OU 2-06
OU 2-07
OU 2-08
OU 2-09
OU2-IO
OU2-II
OU2-12
OU 2-13
No Action Sites
Page
Number
B-l
B-2
B-3
B-5
B-7
B-9
B-10
B-12
B-l 3
B-l 5
B-19
B-20
B-23
B-41
B-1. TRACK 1 INVESTIGATION OF TRA OU 2-01
File Number
AR 1 .7 INITIAL ASSESSMENTS
Document #: 2859
Title: TRA-02, TRA Paint Shop Ditch
Author: Alexander. T.G.
Recipient: Clark. C.
Date:
B-l
-------
AR3.5
TRACK 1 INVESTIGATIONS
Document #: 3601
Title: TRA 02 Paint Shop Ditch (TRA-606)
Author: N/A
Recipient: N/A
Date: 09/13/91
B-2. TRACK 1 INVESTIGATION OF TRA OU 2-02
File Number
ARl.7
INITIAL ASSESSMENTS
Document #: 2857
Title: TRA-21, TRA Inactive Tank North Side of MTR-643
Author: Alexander. T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2856
Title: TRA-22, TRA Inactive Diesel Fuel Tank at ETR-648
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2871
Title: TRA-14, TRA Inactive Gasoline Tank at TRA-605
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2873
Title: TRA-17. TRA Inactive Gasoline Tank at TRA-616
Author: Alexander. T.G.
Recipient. Clark. C.
Date: 10/03/86
Document #: 2875
Title: TRA-IS. TRA Inactive Gasoline Tank at TRA-M9
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 10/03/86
B-2
-------
AR3.5
TRACK I INVESTIGATIONS
Document #: 5206
Title: TRA 14 TRA Inactive Gasoline Tank at TRA-605
Author: N/A
Recipient: N/A
Date: 10/05/92
Document #: 5287
Title: TRA-22 TRA Diesel Fuel Tank at ETR-6-48
Author: N/A
Recipient: N/A
Date: 01/06/93
Document #: 5288
Title: TRA-21 TRA Inactive Tank North Side of MTR-643
Author: N/A
Recipient: N/A
Date: 01/06/93
Document #: 5289
Title. TRA-17 TRA Inactive Gasoline Tank at TRA-616
Author: N/A
Recipient: N/A
Date: 01/06/93
Document #: 5290
Title: TRA-18 TRA Inactive Gasoline Tank at TRA-619
Author: N/A
Recipient: N/A
Date: 01/06/93
B-3. TRACK 2 INVESTIGATION OF TRA OU 2-03
File Number
ARI.7
INITIAL ASSESSMENTS
Document #: 2858
Title: TRA-01, TRA Acid Spill Disposal Pit (TRA-608)
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 09/16/86
B-3
-------
Document #: 2868
Title: TRA-11. TRA French Drain at TRA-645
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2869
Title: TRA-12, TRA Fuel Oil Tank Spill (TRA-727B)
Author: Alexander. T.G.
Recipient: Clark, C.
Document #: 2879
Title: TRA-20. TRA Brine Tank < TRA-731) at TRA-631
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 10/03/86
Document #: 578
Title: TRA-40. TRA Tunnel French Drain (TRA-731)
Author: Pigon. W.R.
Recipient: Clark, C.
Date: 02/08/89
AR3.I4
TRACK 2 SUMMARY REPORT
Document #: EGG-ER-10736
Title: Preliminary Scoping Track 2 Summary Report lor
Operable Unit 2-03
Author: Sherwood. J.A.
Recipient: N/A
Date: 08/01/93
AR3.22
TRACK 2 DECISION STATEMENT
Document #: A.V1/HRWM-532-93
Title: Transmittal ol the Revised Track 2 Summary Reports
for Operable Units 2-03 and 2-06 and the DOK-1D
Track 2 Decision Statements
Author: Lyle. J.L.
Recipient: Pierre. W.; Nygard. D.
Dale: OS/13/93
B-4
-------
Document #: 5506
Title: EPA Recommendation on the Track 2 Summary
Report for the Test Reactor Area Operable Unit 2-03
Author: Meyer, L.
Recipient: Williams, A.C.
Date: 10/04/94
Summary Report
Document*: 5800
Title: IDHW Recommendation For OU 2-03 Track 2
Author: Koch, D.
Recipient: Williams, A.C.
Date: 10/13/93
Document #: 5855
Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit (OU) 2-03 Test Reactor Area
(TRA) including TRA-01. TRA-1 I, TRA-12, TRA-
20, TRA-40,andTRA-614
Author DOE, EPA, IDHW
Recipient: Not Specified
Date: 01/19/95
B-4. TRACK 2 INVESTIGATION OF TRA OU 2-04
File Number
AR1.7
INITIAL ASSESSMENTS
Document #: 2844
Title: TRA-34, TRA North Storage Area
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 07/08/87
Document #: 2866
Title: TRA-09, TRA Spills at TRA Loading Dock
(TRA-722)
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 09/11/86
B-5
-------
AR3.I4
TRACK 2 SUMMARY REPORT
Document #: EGG-ER- INK)
Title: Preliminary Scoping Track 2 Summary Report for the
Test Reactor Area Operable Unit 2-04 Fuel Spills
Author: Sherwood. J.A.
Recipient: N/A
Date: 03/01/94
AR3.22
TRACK 2 DECISION STATEMENT
Document #: OPE-ER-78-94
Title: Transmittal of the Revised Track 2 Summary Report
tor Operable Unit 2-04 at the TRA at the INEL and
the DOE-ID Decision Statement
Author: Green, L.
Recipient: Pierre, W.; Nygard, D.
Date: 04/01/94
Document #: 5790
Title: IDHW-DEQ Recommendations I'or OU 2-04 Track 2
Summary Report
Author: Koch, D.
Recipient: Green, L.
Date: 11/04/94
Document #: 5513
Title: EPA Recommendation on the Track 2 Summary
Report for Waste Area Group (WAG) 2. Operable
Unit(()U)2-()4
Author: Meyer. L.
Recipient: Green, L.
Date: 10/11/94
Document #:
Title:
Author:
Recipient:
Date:
5Sftl
DeciMon Statement lor the Track 2 Summary Report
tor the Operable Unit (OU) 2-04 Test Reactor Area
(TRA I TRA-h53. TRA-626. TRA-619. PW-I 3. TRA-
09. TRA-h70, and TRA-627
DOK. HPA. IDHW
Not Specified
K-h
-------
B-5. TRACK 2 INVESTIGATION OF OPERABLE UNIT 2-05
Administrative Record Volume I
File Number
AR1.7 INITIAL ASSESSMENTS
Document #: 2872
Title: TRA-15, TRA Hot Waste Tanks #2, #3, #4 at
TRA-613
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/16/86
Document #: 2874
Title: TRA-16, TRA Inactive Radioactive Contaminated
Tank at TRA-614
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2876
Title: TRA-19, TRA Rad Tanks 1 & 4 at TRA-630,
Replaced by Tanks 1,2,3, & 4
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/16/86
AR3 1 SAMPLING AND ANALYSIS PLAN
Document #: EGG-ER-10652. Rev. 1
Title: Track 2 Sampling and Analysis Plan for the
Characterization of Waste Area Group 2, Operable
Units TRA 2-05 and 2-07
Author: Jessmore, J.J.
Recipient: N/A
Date: 05/01/93
AR.V14 TRACK 2 SUMMARY REPORT
Document #: EGG-ER-1 1 114
Title: Preliminary Scoping Track 2 Summary Report for
Operable Unit 2-05
Author: Holdren. KJ.
Recipient: N/A
Date: 04/01/94
B-7
-------
Administrative Record Volume II
File Number
AR.VI5
HEALTH AND SAFETY PLAN
Document*: EGG-ER-10634, Rev. 2
Title: Health and Safety Plan tor Track 2 Characterization of
Operable Units 2-05 and 2-07 at the Test Reactor Area
Author: Rice. R.S.
Recipient: N/A
Date: 06/01/93
AR3.22
TRACK 2 DECISION STATEMENT
Document #: OPE-ER-1 10-94
Title: Transmittal of the Revised Track 2 Summary Report
for Operable Unit 2-07 at the Test Reactor Area
(TRA) at the 1NEL
Author: Lyle, J.L.
Recipient: Pierre W.;Nygard, W.
Date: 05/04/94
Document #: 5789
Title: IDHW-DEQ Recommendations for OU 2-05 Track 2
Summary Report
Author: Koch, D.
Recipient: Green, L.
Date: 11/04/94
Document #:
Title:
Author:
Recipient:
Date:
5796
EPA Recommendations for Track 2 Summary Report
for Waste Area Group 2 Operable Unit 2-05
Meyer, L.
Green. L.
10/12/94
Document #: 585S
Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit (OU) 2-05 Test Reactor Area
(TR A) TRA-16, TR A-15. TRA-19. and TR A-60.V605
Tank
Author: DOE. EPA. IDHW
Recipient: Not Specified
Date: 01,'19/9 5
B-S
-------
B-6. TRACK 2 INVESTIGATION OF OPERABLE UNIT 2-06
File Number
AR1.7
INITIAL ASSESSMENTS
Document #: 2848
Title: TRA-30, TRA Beta Building Rubble Site
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2847
Title: TRA-31, TRA West Rubble Site
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2253
Title: TRA-35, TRA Rubble Site E. of West Road Neat Beta
Building Rubble Pile
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 01/11/88
AR3.14
TRACK 2 SUMMARY REPORT
Document #: EGG-ER-10806
Title: Preliminary Scoping Track 2 Summary Report for
Operable Unit 2-06
Author: Sherwood. J.A.
Recipient: N/A
Date: 08/01/93
AR3.22
TRACK 2 DECISION STATEMENT
Document #: AM/ERWM-532-93
Title: Transmittal of the Revised Track 2 Summary Reports
for Operable Units 2-03 and 2-06 and the DOE-ID
Track 2 Decision Statements
Author. Lyle. J.L.
Recipient: Pierre, W.; Nygard. D.
Date: 08/13/93
Document*: 5801
Title: IDHW-DHQ Recommendations for Operable Unit 2-
06 Track 2 Summary Report.
B-9
-------
Author:
Recipient:
Date:
Koch. D.
Williams, A.C.
10/13/93
Document #: 5802
Title: EPA Recommendations for the Track 2 Summary
Report for the Test Reactor Area Operable Unit 2-06
Author: Meyer, L.
Recipient: Williams, A.C.
Date: 10/04/93
Document #: 5856
Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit (OU) 2-06 Test Reactor Area
(TRA), TRA-30. TRA-31, and TRA-35
Author: DOE, EPA, IDHW
Recipient: Not Specified
Date: 01/19/95
B-7. TRACK 2 INVESTIGATION OF OPERABLE UNIT 2-07
File Number
ARI.7
INITIAL ASSESSMENTS
Document #: 2254
Title: TRA-36. TRA ETR Cooling Tower Basin (TRA-751
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 01/11/88
Document #: 2239
Title: TRA-38. TRA ATR Cooling Tower (TRA-771)
Author. Alexander. T.G.
Recipient: Clark, C.
Date: OI/12/X8
Document*: ' 2215
Title: TRA-39. TRA MTR Cooling Tower N of TRA-607
Author: Alexander. T.G.
Recipient:. Clark. C.
Date: 01/12/88
B-10
-------
AR3.1 SAMPLING AND ANALYSIS PLAN
Document #: EGG-ER-10652. Rev. 1
Title: Track 2 Sampling and Analysis Plan for the
Characterization of Waste Area Group 2, Operable
Units TRA 2-05 and 2-07
Author: Jessmore, J.J.
Recipient: N/A
Date: 05/01/93
NOTE: This document can be found in Administrative Record Binder
Volume I, OU 2-05
AR3.14 TRACK 2 SUMMARY REPORT
Document #: EGG-ER-11085
Title: Preliminary Scoping Track 2 Summary Report for
Operable Unit 2-07
Author: Jessmore, P.J.
Recipient: N/A
Date: 04/01/94
File Number
AR3.15 HEALTH AND SAFETY PLAN
Document #: EGG-ER-10634, Rev. 2
Title: Health and Safety Plan for Track 2 Characterization of
Operable Units 2-05 and 2-07 at the Test Reactor Area
Author: Rice, R.S.
Recipient: N/A
Date: 06/01/93
NOTE: This document can be found in Administrative Record Binder
Volume II, OU 2-05
AR3.22 TRACK 2 DECISION STATEMENT
Document #: OPE-ER-109-94
Title: Transmittul of the Revised Track 2 Summary Report
for Operable Unit 2-07 at the Test Reactor Area
(TRA) at the INEL
Author: Lyle, J.L.
Recipient: Pierre. W.. Nygard. \V
05/04/94
B-ll
-------
Document #: 5788
Title: IDHW-DEQ Recommendations for OU 2-07 Tra.-k 2
Summary Report
Author: Koch. D.
Recipient: Green, L.
Date: 11/04/94
Document #: 5797
Title: EPA Recommendations for Track 2 Summary Report
("or Waste Area Group 2 Operable Unit 2-05
Author: Meyer. L.
Recipient: Green, L.
Date: 10/11/94
Document #: 5857
Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit (OU) 2-07 Test Reactor Area
(TRA) ETR Cooling Tower. MTR Cooling Tower.
ATR Cooling Tower and TRA-653
Author: DOE; EPA; IDHW
Recipient: Not specified
Date: 01/19/95
B-8. TRACK 2 INVESTIGATION OF OPERABLE UNIT 2-08
File Number
ARI.7
INITIAL ASSESSMENTS
Document #: 2240
Title: TRA-37. TRA MTR Canal in Basement of TRA-603
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 01/12/88
AR.V14
TRACK 2'SUMMARY REPORT
Document #: EGG-ER-11113
Title: Preliminary Scoping Track 2 Summary Report lor the
Test Reactor Area Operable Unit 2-OS
Author: Black more. C.S.
Recipient: N/A
Date: O.VOl/94
B-1.2
-------
AR3.22
DECISION STATEMENT
Document #: OPE-ER-72-94
Title: Decision Statement for the Track 2 Summary Report
for Operable Unit 2-08
Author: Lyle, J.L.
Recipient: Nygard, W.; Pierre W.
Date: 04/04/94
Document #: 5787
Title: IDHW-DEQ Recommendations for OU 2-08 Track 2
Summary Report
Author: Koch, D.
Recipient: Green. L.
Date: 11/04/94
Document #: 5798
Title: EPA Recommendations for Track 2 Summary Report
For Waste Area Group 2. Operable Unit 2-08
Author: Meyer. L.
Recipient: Green, L.
Date: 10/11/94
Document #: 5854
. Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit (OU) 2-08 Test Reactor Area
{TRA) Materials Test Reactor (MTR) Canal
Author: DOE, EPA. IDHW
Recipient: Not Specified
Date: 01/19/95
B-9. TRACK 2 INVESTIGATION OF OPERABLE UNIT 2-09
File Number
AR1.7
INITIAL ASSESSMENTS
Document #: 2864
Title. TRA-07, TRA Sewage Treatment Plant (TRA-624 &
Sludge Pit (TRA-732)
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 10/03/86
B-13
-------
Document #: 2865
Title: TRA-08. TRA Cold Waste Disposal Pond (TRA-702)
Author: Alexander. T.G.
Recipient: Clark. C.
Date: 09/12/86
Document #: 2870
Title: TRA-13. TRA Final Sewage Leach Ponds (2) by
TRA-732
Author: Alexander. T.G.
Recipient: Clark, C.
Date: 10/03/86
AR3.14
TRACK 2 SUMMARY REPORT
Document #: EGG-ER-10595
Title: Preliminary Scoping Track 2 Summary Report for
Operable Unit 2-09 TRA Sewage Treatment Area and
Cold Waste Pond
Author: Salomon. H.
Recipient: N/A
Date: 07/01/93
AR3.22
DECISION STATEMENT
Document #: AM/ERWM-RPO-518-93
Title: Decision Statement for the Track 2 Summary Report
for Operable Unit 2-09
Author: Lyle. J.L.
Recipient: Nygard. W.; Pierre. W.
Date: 08/10/93
Document #: 7673
Title: IDHW-DHQ Recommendations for OU 2-09 Track 2
Summary Report
Author: Koch, D.
Recipient: Green. L.
Date: 05/17/94
Document #: 5X12
Title: EPA Recommendations for Track 2 Summar\ Report
For The Test Reactor Area Operable Unit 2-09
Author: Meyer. L.
Recipient: Williams. A.C.
Date: 10/04/93
IM4
-------
Document #: 5860
Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit
-------
AR3.7 INTERIM ACTIONS
Document #: EGG-WM-9622
Title: Interim-Action Risk Assessment for the TRA Warm
Waste Leach Pond
Author: Figueroa. I., McClellan, Y., and King, J.J.
Recipient: N/A
Date: 06/01/91
AR3.IO SCOPE OF WORK
Document #: 2916
Title: Scope of Work for An Interim Action of the TRA
Warm Waste Pond
Author: Baumer, A.R.
Recipient: N/A
Date: 03/01/91
AR42 FEASIBILITY STUDY REPORTS
Document*: EGG-WM-K)O(K)
Title: Test Reactor Area Warm Waste Pond at the Idaho
National Engineering Laboratory Sediment
Treatability Study Phase I Report
Author: Beller, J.M.
Recipient: N/A
Date: 11/01/91
AR4.3 PROPOSED PLAN
Document #: 3558
Title: Proposed Plan for a Cleanup of the Warm Waste Pond
Sediments at the TRA at the INHL
Author: Baumer. A.R.
Recipient: N/A
Date: 07/01/91
AR5.1 RECORD OF DECISION
Document #: 3320
Title: Declaration for the Warm Waste Pond at the TRA at
(he INEL - Declaration of the Record of Decision
(ROD)
Author. Baumer. A.R.
Recipient: N7.-\
Date: 12/05/91
-------
AR5.3
EXPLANATION OF SIGNIFICANT DIFFERENCE
Document #: 5253
Title: Explanation of Significant Difference for the Warm
Waste Pond Sediments Record of Decision at the Test
Reactor Area, at the INEL
Author: Jensen, N.R.
Recipient: N/A
Date: 03/15/93
Document #: 5241
Title: Technical review Comments for the Draft Treatability
Study Report of the Warm Waste Pond Operable Unit
2-10
Author: Hoveland, R.D.
Recipient: Jensen, N.R.
Date: 03/08/93
Document #: 5243
Title: Results of the Pilot Scale Treatability Study for the
TRA Warm Waste Pond Vol. I and II
Author: Meyer, L.
Recipient: Green, L.A.
Date: 03/08/93
Document*: 5244
Title: Presentation Slide Copies on the TRA Warm Waste
Pond
Author: Montgomery, R.A.
Recipient: N/A
Date: 03/08/93
Administrative Record Binder II
Document #: EGG-ERD-10435
Title: Test Reactor Area Warm Waste Pond at the Idaho
National Engineering Laboratory Pilot-Scale
Treatability Study Work Plan
Author: Montgomery, R.A.
Recipient: N/A
Date: 09/01/92
B-17
-------
Document #: EGG-ER-I06I6, Vol. I
Title: Results of the Pilot-Scale Treatability Study for the
Test Reactor Area Warm Waste Pond
Author: Montgomery, R.A.
Recipient: N/A
Date: 04/01/93
Document #: EGG-ER-10616, Vol. 2
Title: Results of the Pilot-Scale Treatability Study for the
Test Reactor Area Warm Waste Pond
Author: Montgomery, R.A.
Recipient: N/A
Date: 04/01/93
Administrative Record Binder III
File Number
AR5.3
EXPLANATION OF SIGNIFICANT DIFFERENCE (continued)
Document*: 9I052I-N/C
Title: Warm Waste Pond Bench-Scale Treatability Study
Author: Nuclear Remediation Technologies Corporation
Recipient: ASI
Date: 09/01/92
AR7.2
ENDANGERMENT ASSESSMENTS
Document*: 2915
Title: Rare. Threatened and Endangered Plants and Animals
of Idaho
Author: Moseley, R.
Recipient: N/A
Date: 03/01/90
ARK) 3
PUBLIC NOTICES
Document #: 5255
Title: Informal Meeting - Explanation of Significant
Difference for the Test Reactor Area Warm Waste
Pond
Author: INEL Community Relations
Recipient: N/A
Date: 03/21/93
B-IS
-------
ARI0.4
PUBLIC MEETING TRANSCRIPTS
Document #: 3540
Title: Public Meeting Transcripts - Public Comment
Meetings Concerning Proposed Cleanup Projects at
the Test Reactor Area at the Idaho National
Engineering Laboratory
Author: N/A
Recipient: N/A
Date: 07/07/91
B-11. TRACK 2 INVESTIGATION OF OPERABLE UNIT 2-11
File Number
ARl.7
INITIAL ASSESSMENTS
Document #: 2860
Title: TRA-03A, TRA Warm Waste Leach Pond (TRA-758)
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 09/12/86
Document #: 2861
Title: TRA-04, TRA Warm Waste Retention Basin (TRA-
712)
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 09/11/86
Document*. 2862
Title: TRA-05, TRA Waste Disposal Well, Sampling Pit
(764) and Sump (703)
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 09/11/86
AR3.14
TRACK 2 SUMMARY REPORT
Document #: AM/ERWM-RPO-358-93
Title: Transmittal of Revised Track 2 Summary Report for
Operable Unit 2-1 1 at the Test Reactor Area (TRA) at
the IN'EL (DOE-ID Decision Statement incorporated
in Truck 2 Summary Report)
'' - Lxle.J.L.
Recipient: N\i:ard. \\'.: Pierre. W.
Date: 03/11/93
B-19
-------
Document #: EGG-ERD-10518
Title: Scoping Track 2 Summary Report for Operable Unit
2-11 at the Test Reactor Area
Author: Golder Associates
Recipient: N/A
Date: 03/01/93
AR3.22
DECISION STATEMENT
Document #: 7051
Title. IDHW-DEQ Recommendations lor OU 2-1 1 Track 2
Summary Report
Author: Koch, D.
Recipient: Green. L.
Date: 08/02/93
Document #: 581)
Title: EPA Recommendations lor Track 2 Summary Report
For The Test Reactor Area Operable Unit 2-1 I
Author: Meyer. L.
Recipient: Williams, A.C.
Date: 10/04/93
Document #: 5859
Title: Decision Statement for the Track 2 Summary Report
for the Operable Unit (OU) 2-1 1 Test Reactor Area
(TRA) TRA-03, TRA-04. and TRA-05
Author: DOE. EPA. IDHW
Recipient: Not Specified
Date: 01/19/95
B-12. PERCHED WATER SYSTEM RI/FS OPERABLE UNIT 2-12
Administrative Record Volume I
Kile Number
ARl I
BACKGROUND
Document #: HGG-HRD-1031 3
Title. Selection Ot Grounduaier l-'km And Coniaminant-
TraiiNport Models
Author: Dames and Moore
Recipient: N/A
Date: (KVOl/92
B-20
-------
Administrative Record Volume IV
AR4.3
PROPOSED PLAN
Document #: 5130
Title: Dear Citizen Pamphlet on the Proposed Plan for the
Perched Water System
Author: INEL Community Relations
Recipient: N/A
Date: 06/26/92
AR5.I
RECORD OF DECISION
Document #: 5230
Title: Record of Decision for the TRA Perched Water
System
Author: INEL Community Relations
Recipient: N/A
Date: 12/01/92
ARK). 3
PUBLIC NOTICES
Document #: 5136
Title: Attention: Agencies Seek Public Comment on Three
Proposed Plans
Author: INEL Community Relations
Recipient: N/A
Date: 07/01/92
AR10.4
PUBLIC MEETING TRANSCRIPTS
Document #: 5164-TRA
Title: Public Meeting Transcripts on the Proposed Plan for
the TRA Perched Water System
Author: N/A
Recipient: N/A
Date: 07/20/92
B-22
-------
AR3.10 SCOPE OF WORK
Document #: 2377
Title: Scope ot" Work Perched Water System RI/FS
Author: Vemon. O.K.
Recipient: N/A
Date: 05/23/91
Document #: ERD-343-91
Title: Transmittal, Working Schedule tor the TRA Perched
Water RI/FS
Author: DOE, Lyle, J.
Recipient: EPA. Pierre, W. and IDHW, Nygard. D.
Date: 09/12/91
Document #: 3515
Title: Working Schedule for the TRA Perched Water RI/FS
Author: DOE. Lyle, J.
Recipient: EPA, Pierre, W. and IDHW, Nygard. D.
Date: 09/12/91
AR3.4 RI REPORTS
Document #: EGG-WM-10002
Title: Rl Report for the TRA Perched Water System OU 2-
12
Author: Lewis, S.M.
Recipient: N/A
Date: 06/01/92
Administrative Record Volume II
File Number
AR.V4 Rl REPORTS (oominued)
Document #: EGG-WM-10002 (continued)
Appendices A through E
Administrative Record Volume III
Document #: EGG-WM-10002 (continued)
Appendices h through I
11-21
-------
B-13. PERCHED WATER SYSTEM RI/FS OPERABLE UNIT 2-13
Administrative Record Volume I
File Number
ARl.l
BACKGROUND
Document*: 10269
Title: Decision Documentation Package for Chemical Waste
Pond (TRA-06)
Author: Not specified
Recipient: Not specified
Date: 01/23/92
Document #: EGG-WM-9193
Title: Closure Plan for the Test Reactor Area Chemical
Waste Pond (COCA Unit TRA-06)
Author: Bums. S.M.; Stanisich, S.N.; Spry, M.J.; Shoop. D.S.
Recipient: Not specified
Date: 10/01/90
Document #: EG&G-85-17
Title: Unusual Occurrence Report - Facility Number ATR-
85-3
Author: Sheldon, D.E.; Boyer, R.D.; Alletzhauser, G.J.;
Mousseau, D.R.; Amidei, W.; Hong, J.A.
Recipient: Not specified
Date: lt/U/85- - *.-
Document #: EG&G-85-41
Title: Unusual Occurrence Report - Facility Number ATR-
85-8
Author: Sheldon, D.E.; Boyer, R.D.; Alletzhauser. G.J.:
Mousseau. D.R.. Amidei, W.; Hong, J.A.
Recipient: Not specified
Date: 11/13/85
Document #: EGG-ER-10547, Rev. 1
Title: Post Record of Decision Monitoring Plan for the Test
Reactor Area Perched Water System Operable Unit 2-
12
Author: Not specified
Recipient: Not specified
Date: 09/01/93
B-23
-------
AR1.7
INITIAL ASSESSMENTS
Document #: 2863
Title: TRA-06. WAG 2 Comprehensive RI/FS Including
TRA Chemical Waste Pond (TRA-701)
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 10/15/86
Administrative Record Volume II
AR3.3
WORK PLAN
Document #: INEL-94/0026, Revision 0
Title: Work Plan for Waste Area Group 2 Operable Unit 2-
12 Comprehensive Remedial Investigation/Feasibility
Study
Author: Lientz. A.R.; Green, T.S.; Burns, D.E.; Burton, B.N.
Recipient: N/A
Date: 04/01/95
Administrative Record Volume III
Document #: OPE-ER-076-95
Title: Transmittal of Final Remedial Investigation/Feasibility
Study Work Plan for the Waste Area Group (WAG) 2
Comprehensive Remedial Investigation/Feasibility
Study (Rl/FS), Operable Unit (OU) 2-13 at the Idaho
National Engineering Laboratory (INEL)
Author: Jensen. N.R.
Recipient: Pierre, W.; Nygard. D.
Date: 04/26/95
AR3.4
RI REPORTS
Document #:
Title:
Author:
Recipient:
Dale:
OPE-ER-90-96
Transmittal of Draft Remedial Investigation Report tor
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study I RI/FS).
Operable Unit (OU) 2-1 3 at the Idaho National
Engineering Laboratory tlNF.L)
Jensen. N.R.
Pierre. W.. Nygard. D.
05/24/96
H-24
-------
File Number
AR3.7
AR3.K)
AR3.12
INTERIM ACTIONS
Document #: 02.010.2.1.209.01
Title: Draft Remedial Action Report Test Reactor Area
Warm Waste Pond Interim Action Operable Unit (OU)
2-10
Author: N/A
Recipient: Green, L.A.
Date: 06/15/94
SCOPE OF WORK
Document*: INEL-94/0013
Title: Scope of Work for Operable Unit 2-13 WAG 2
Comprehensive Remedial Investigation Feasibility
Study
Author: Lientz, A.
Recipient: N/A
Date: 11/01/94
RI/FS REPORTS
Document #: OPE-ER-129-96
Title: Transmittal of Draft Remedial Investigation/Feasibility
Study (RI/FS) Report for the Waste Area Group
(WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study. Operable Unit (OU) 2-
13, at the Idaho National Engineering Laboratory
(INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 08/22/96
Document #: OPE-ER-191 -96
Title: Transmittal of Draft Final Remedial
Investigation/Feasibility Study (RI/FS) Report for the
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study, Operable
Unit (OU) 2-13, at the Idaho National Engineering
Laboratory (INEL)
Author: Jensen. N.R.
Recipient: Pierre. W.; Nygard, D.
Date: 12/16/96
B-25
-------
Document #: OPE-ER-IO-97
Title: Transmittal of Final Remedial Investigation/Feasibility
Study (RI/FS) Report for the Waste Area Group
(WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study. Operable Unit (OU) 2-
13, at the Idaho National Engineering Laboratory
(INEL)
Author: Jensen, N.R.
Recipient: Pierre. W.: Nygard. D.
Date: 02/03/97
Document #: OPE-ER-1 1 -97
Title: Transmittal of Copies of Final Remedial
Investigation/Feasibility Study (Rl/FS) Report for the
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study. Operable
Unit (OU) 2-13. at the Idaho National Engineering
Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 02/07/97
Administrative Record Volume IV
Document #: DOE/ID-10531, Rev. 0
Title: Comprehensive Remedial Investigation/Feasibility
Study for the Test Reactor Area Operable Unit 2-13, at
the Idaho National Engineering and Environmental
Laboratory
Author: Burns, D.E.; Davis. K.M.; Flynn. S.C.; Keck. J.F :
Hampton, N.L.; Owen, A.H.: VanHorn. R.L.
Recipient: Not specified
Date: 02/01/97
Administrative Record Volume V
AR3.I5
HEALTH AND SAFETY PLAN
Document *: INEL-94/0002. Rex. 0
Title: Health and Safety Plan for Test Reactor Area ()l' 2-13
Comprehensive Remedial ln\estimation/Feasibility
Study at the Idaho National Engineering Laboratory
Author: Sherwood. J.A.
Recipient: N/A
Dale: 04/01/95
H-20
-------
AR4.3
PROPOSED PLAN
Document #: 10408
Tide: Proposed Plan for Waste Area Group 2 - Test Reactor
Area Idaho National Engineering and Environmental
Laboratory
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/01/97
ARI0.3
PUBLIC NOTICES
Document #: 10407
Title: Notice of Availability - Agencies Propose to
Remediate Eight Sites at the Test Reactor Area
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/09/97
Document #: 10406
Title: Comment Period Extended March 10 to May 9, 1997 -
Agencies Propose to Remediate Eight Sites at the Test
Reactor Area
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/23/97
Document #: 10405
Title: Comment Period Extended - Agencies Propose to
Remediate Eight Sites at the Test Reactor Area
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/24/97
AR11.6
TECHNICAL MEMORANDUM
Document #: 10148
Title: Post-Record of Decision Monitoring for the Test
Reactor Area Perched Water System Operable Unit 2-
12. Second Annual Technical Memorandum
Author: Meyer. L.
Recipient: Green, L.A.
Date: 09/22/95
B-27
-------
Document^ 10149
Title: Post-Record of Decision Monitoring for the Te
-------
Document*: I(K)05
Title: The Draft Work Plan for Waste Area Group 2
Operable Unit 2-13 Comprehensive Remedial
Investigation/Feasibility Study
Author: Blood, H.R.
Recipient: Green, L.A.
Date: 02/10/95
ARI2.1
EPA COMMENTS
Document #: 10288
Title: Comments On Draft Remedial Investigation Report
for the Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study (RI/FS).
Operable Unit (OU) 2-13 at the Idaho National
Engineering Laboratory (INEL)
Author: Poeton, R.W.
Recipient: Green, L.A.
Date: 07/10/96
Document #: 10300
Title: Comments On Draft Remedial
Investigation/Feasibility Study (RI/FS) Report for the
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study (RI/FS)
Operable Unit (OU) 2-13 at the Idaho National
Engineering Laboratory (INEL)
Author: Poeton, R.W.
Recipient: Jensen, N.R.
Date: 10/09/96
Document*: 10314
Title: Comments On Draft Proposed Plan for the Waste Area
Group (WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study (RI/FS), Operable Unit
(OU) 2-13, at the Idaho National Engineering
Laboratory (INEL)
Author: Poeton. R.W.
Recipient: Jensen. N.R.
Date: 01/24/97
B-29
-------
Document*: 10397
Title: Comments on: March. 1997 Draft Proposed Plan for
the Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study, Operable
Unit (OU) 2-13. at the Idaho National Engineering and
Environmental Laboratory (INEEL)
Author: Poeton. R.W.
Recipient: Jensen. N.R.
Date: 02/14/97
ARI2.2
IDHW COMMENTS
Documents: 10006
Title: Review Comments on WAG 2 Draft RI/FS Work Plan
Author: Underwood, E.J.
Recipient: Green, L.A.
Date: 02/13/95
Documents: 10289
Title: Review Comments on WAG 2 Draft Comprehensive
RI/BRA Report
Author: Underwood, E.J.
Recipient: Green, L.A.
Date: 07/12/96
Documents: 10301
Title: Review Comments on WAG 2 Draft Comprehensive
Rl/FS Report
Author: Underwood, E.J.
Recipient: Jensen. N.R.
Date: .10/10/96
Documents. 10310
Title: Review Comments on WAG 2 Draft Final
Comprehensive Rl/FS Report
Author: Underwood. E.J.
Recipient: Jensen. N.R.
Date: 01/02/97
Documents: 10313
Title: Review Comments on WAG 2 Draft Proposed Plan
Author: Underwood. F.J.
Recipient: Jensen. N.R.
Date: 01/27/97
B-30
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AR12.3
DOE RESPONSE TO COMMENTS
Document #: OPE-ER-20-97
Title: DOE Transmittal of Responses to Comments on the
Draft Proposed Plan for the Waste Area Group
(WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study, Operable Unit (OU) 2-
13, at the Idaho National Engineering Laboratory
(INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 02/26/97
ARI2.4
EXTENSIONS AND APPROVALS
Document #: OPE-ER-169-96
Title: Twenty Day Extension Notification for Submittal of
the Waste Area Group (WAG) 2 Draft Final
Comprehensive Remedial Investigation/Feasibility
Study (RI/FS), Operable Unit (OU) 2-13 at the Idaho
National Engineering Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 11/12/96
Document #: OPE-ER-01 -97
Title: Fifteen-day Extension for Finalization of the Waste
Area Group (WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study (RI/FS) Report,
Operable Unit (OU) 2-13. at the Idaho National
Engineering Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre. W.; Nygard. D.
Date: 01/15/97
ARI2.5
PROJECT MANAGEMENT MEETING MINUTES
Document #: 5865
Title: WAG 2 Comprehensive Scoping Meeting Minutes
Author: IDHW, EPA. DOE. GEOTECH. EG&G Idaho, Inc.
Recipient: N/A
Date: 08/18/94
B-31
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Administrative Record Volume I
File Number
ARI.l
BACKGROUND
Document*: 10269
Title: Decision Documentation Package for Chemical Waste
Pond (TRA-06)
Author: Not specified
Recipient: Not specified
Date: 01/23/92
Document*: EGG-WM-9193
Title: Closure Plan for the Test Reactor Area Chemical
Waste Pond (COCA Unit TRA-06)
Author: Bums, S.M.; Stanisich. S.N.; Spry, M.J.: Snoop, D.S.
Recipient: Not specified
Date: 10/01/90
Document #: EG&G-85-17
Title: Unusual Occurrence Report - Facility Number ATR-
85-3
Author: Sheldon, D.E.; Boyer, R.D.; Alletzhauser. G.J.;
Mousseau, D.R.; Amidei, W.; Hong, J.A.
Recipient: Not specified
Date: 11/13/85
Document*: EG&G-85-4I
Title: Unusual Occurrence Report - Facility Number ATR-
85-8
Author: Sheldon. D.H.; Boyer. R.D.: Alletzhauser. G.J.;
Mousseau, D.R.: Amidei. W.; Hong. J.A.
Recipient: Not specified
Dale: 11/13/85
Document #: F.GG-ER-10547. Rev. 1
Title. Post Record of Decision Monitoring Plan for the Test
Reactor Area Perched Water Svslem Operable Unit 2-
12
Author: Not specified
Recipient: Not specified
Date: 09/01/93
B-32
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AR1.7
INITIAL ASSESSMENTS
Document #: 2863
Title: TRA-06, WAG 2 Comprehensive RI/FS Including
TRA Chemical Waste Pond (TRA-701)
Author. Alexander, T.G.
Recipient: Clark, C.
Date: 10/15/86
Administrative Record Volume II
AR3.3
WORK PLAN
Document #: INEL-94/0026, Revision 0
Title: Work Plan for Waste Area Group 2 Operable Unit 2-
12 Comprehensive Remedial Investigation/Feasibility
Study
Author: Lientz, A.R.; Green, T.S.; Burns, D.E.; Burton, B.N.
Recipient: N/A
Date: 04/01/95
Administrative Record Volume III
Document #: OPE-ER-076-95
Title: Transmittal of Final Remedial Investigation/Feasibility
Study Work Plan for the Waste Area Group (WAG) 2
Comprehensive Remedial Investigation/Feasibility
Study (RI/FS), Operable Unit (OU) 2-13 at the Idaho
National Engineering Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre. W.; Nygard, D.
Date: 04/26/95
AR3.4
RI REPORTS
Document #: OPE-ER-90-96
Title: Transmittal of Draft Remedial Investigation Report for
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study (RI/FS).
Operable Unit (OU) 2-13 at the Idaho National
Engineering Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 05/24/96
B-33
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AR3.7
INTERIM ACTIONS
Document*: 02.010.2.1.209.01
Title: Draft Remedial Action Report Test Reactor Area
Warm Waste Pond Interim Action Operable Unit (OU)
2-10
Author: N/A
Recipient: Green, L.A.
Date: 06/15/94
AR3.IO
SCOPE OF WORK
AR3.12
Document #: INEL-94/0013
Title: Scope of Work for Operable Unit 2-13 WAG 2
Comprehensive Remedial Investigation Feasibility
Study
Author: Lientz, A.
Recipient: N/A
Date: 11/01/94
RI/FS REPORTS
Document #: OPE-ER-129-96
Title: Transmittal of Draft Remedial Investigation/Feasibility
Study (RI/FS) Report for the Waste Area Group
(WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study, Operable Unit (OU) 2-
13, at the Idaho National Engineering Laboratory
(1NEL)
Author: Jensen, N.R.
Recipient: Pierre. W.; Nygard, D.
Date: 08/22/96
Document #: OPE-ER-191 -96
Title: Transmittal of Draft Final Remedial
Investigation/Feasibility Study (RI/FS) Report lor the
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study, Operable
Unit (OU) 2-13. at the Idaho National F.ngineering
Laboratory iINHL)
Author: Jensen. N.R.
Recipient: Pierre. W.; Nygard. D.
Date: 12/16/96
B-34
-------
Document #: OPE-ER-10-97
Title: Transmittal of Final Remedial Investigation/Feasibility
Study (RI/FS) Report for the Waste Area Group
(WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study, Operable Unit (OU) 2-
13, at the Idaho National Engineering Laboratory
(INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 02/03/97
Document #: OPE-ER-11 -97
Title: Transmittal of Copies of Final Remedial
Investigation/Feasibility Study (RI/FS) Report lor the
Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study, Operable
Unit (OU) 2-13, at the Idaho National Engineering
Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 02/07/97
Administrative Record Volume IV
Document #: DOE/ID-10531, Rev. 0
Title: Comprehensive Remedial Investigation/Feasibility
Study for the Test Reactor Area Operable Unit 2-13, at
the Idaho National Engineering and Environmental
Laboratory
Author: Burns, D.E.; Davis. K.M.; Flynn. S.C.. Keck. J.F.;
Hampton, N.L.; Owen. A.H.; VanHorn. R.L.
Recipient: Not specified
Date: 02/01/97
Administrative Record Volume V
AR3.15 HEALTH AND SAFETY PLAN
Document #: INEL-94/0002. Rev. 0
Title: Health and Safety Plan for Test Reactor Area OU 2-13
Comprehensive Remedial Investigation/Feasibility
Study at the Idaho National Engineering Laboratory
Author: Sherwood. J.A.
Recipient: N/A
'" ' 04/01.'95
B-35
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AR4.3
ARI0.3
PROPOSED PLAN
Document #: 10408
Title: Proposed Plan for Waste Area Group 2 - Test Reactor
Area Idaho National Engineering and Environmental
Laboratory
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/01/97
PUBLIC NOTICES
Document #: 10407
Title: Notice of Availability - Agencies Propose to
Remediate Eight Sites at the Test Reactor Area
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/09/97
Document #: 10406
Title: Comment Period Extended March 10 to May 9. 1997 -
Agencies Propose to Remediate Eight Sites at the Test
Reactor Area
Author: INEEL Community Relations
Recipient: Not specified
Date: 03/23/97
Document #: 10405
Title: Comment Period Extended - Agencies Propose to
Remediate Eight Sites at the Test Reactor Area
Author. INEEL Community Relations
Recipient: Not specified
Date: 03/24/97
ARM.6
TECHNICAL MEMORANDUM
Document #: 10148
Title: Post-Record of Decision Monitoring for the Test
Reactor Area Perched Water System Operable Unit 2-
12. Second Annual Technical Memorandum
Author: Meyer. L.
Recipient: Green. L.A.
Date: 09/22/95
-------
Document #: 10149
Title: Post-Record of Decision Monitoring for the Test
Reactor Area Perched Water System Operable Unit 2-
12, Second Annual Technical Memorandum
Author: Underwood. E.J.
Recipient: Green, L.A.
Date: 10/05/95
Document #: 10304
Title: Post-Record of Decision Monitoring for the Test
Reactor Area Perched Water System Operable Unit 2-
12, Third Annual Technical Memorandum
Author: Poeton, R.W.
Recipient: Jensen, N.R.
Date: 10/08/96
Document #: 7782
Title: Technical Memorandum Post Record of Decision
Monitoring for the Test Reactor Area Perched Water
System Operable Unit 2-12
Author: Jessmore, P.J.
Recipient: Not specified
Date: 06/01/94
Document #: INEL-95/0408
Title: Post Record of Decision Monitoring for the Test
Reactor Area Perched Water System Operable Unit 2-
12 Second Annual Technical Memorandum
Author: Arnett, R.C.; Meachum, T.R.; Jessmore. P.J.
Recipient: Not specified
Date: 08/01/95
Document #: INEL-96/0305
Title: Post Record of Decision Monitoring for the Test
Reactor Area Perched Water System Operable Unit 2-
I 2 Third Annual Technical Memorandum
Author: Arnett, R.C.; Meachum. T.R.; Jessmore, P.J.
Recipient: Not specified
Date: 09/01/1996
Document #: 10308
Title: OU 2-1 2 Third Annual Technical Memorandum and
Three-Year Review-
Author: Underwood. E.J.
Recipient: Jensen. N.R.
Date. Ot/Oo/1997
B-37
-------
Document #: 10005
Title: The Draft Work Plan for Waste Area Group 2
Operable Unit 2-13 Comprehensive Remedial
Investigation/Feasibility Study
Author: Blood. H.R.
Recipient: Green, L.A.
Date: 02/10/95
AR12.I
EPA COMMENTS
Document #: 10288
Title: Comments On Draft Remedial Investigation Report
for the Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study (RI/FS).
Operable Unit
-------
ARI2.2
Document #: 10397
Title: Comments on: March, 1997 Draft Proposed Plan for
the Waste Area Group (WAG) 2 Comprehensive
Remedial Investigation/Feasibility Study. Operable
Unit (OU) 2-13, at the Idaho National Engineering and
Environmental Laboratory (INEEL)
Author: Poeton, R.W.
Recipient: Jensen, N.R.
Date: 02/14/97
IDHW COMMENTS
Document*: 10006
Title: Review Comments on WAG 2 Draft RI/FS Work Plan
Author: Underwood, EJ.
Recipient: Green, L.A.
Date: 02/13/95
Document #: 10289
Title: Review Comments on WAG 2 Draft Comprehensive
RI/BRA Report
Author: Underwood, E.J.
Recipient: Green, L.A.
Date: 07/12/96
Document*: 10301
Title: Review Comments on WAG 2 Draft Comprehensive
RI/FS Report
Author: Underwood, E.J.
Recipient: Jensen, N.R.
Date. 10/10/96
Document*: 10310
Title: Review Comments on WAG 2 Draft Final
Comprehensive RI/FS Report
Author: Underwood, E.J.
Recipient: Jensen, N.R.
Date: 01/02/97
Document*: 10313
Title: Review Comments on WAG 2 Draft Proposed Plan
Author: Underwood. E.J.
Recipient: Jensen. N.R.
Date: 01/27/97
B-39
-------
ARI2.3
DOE RESPONSE TO COMMENTS
Document #: OPE-ER-20-97
Title: DOE Transmittal of Responses to Comments on the
Draft Proposed Plan for the Waste Area Group
(WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study, Operable Unit (OU) 2-
13, at the Idaho National Engineering Laboratory
(INEL)
Author: Jensen. N.R.
Recipient: Pierre, W.; Nygard, D.
Date: 02/26/97
ARI2.4
EXTENSIONS AND APPROVALS
Document #: OPE-ER-169-96
Title: Twenty Day Extension Notification for Submittal of
the Waste Area Group (WAG) 2 Draft Final
Comprehensive Remedial Investigation/Feasibility
Study (RI/FS), Operable Unit (OU) 2-13 at the Idaho
National Engineering Laboratory (INEL)
Author: Jensen, N.R.
Recipient: Pierre, W., Nygard, D.
Date: 11/12/96
Document #: OPE-ER-01 -97
Title: Fifteen-day Extension for Finalization of the Waste
Area Group (WAG) 2 Comprehensive Remedial
Investigation/Feasibility Study (RI/FS) Report,
Operable Unit (OU) 2-13. at the Idaho National
Engineering Laboratory (INEL)
Author. Jensen. N.R.
Recipient: Pierre, W.; Nygard. D.
Date: 01/15/97
AR12.5
PROJECT MANAGEMENT MEETING MINUTES
Document #: 5865
Title: WAG 2 Comprehensive Scoping Meeting Minutes
Author: IDHW. EPA. DOE. GEOTECH. EG&G Idaho. Inc.
Recipient: N/A
Date: 08/18/94
B-40
-------
B-14. NO-ACTION SITES FOR THE TEST REACTOR AREA
Administrative Record Binder I
File Number
ARl.6
NO-ACTION SITES
Document #: 3608
Title: TRA-IO MTR Construction Excavation Pile
Author: N/A
Recipient: N/A
Date: 09713/91
Document #. 3609
Title: TRA-23 ETR Excavation Site Rubble Pile
Author: N/A
Recipient: N/A
Date: 09/I3/9I
Document #: 3502
Title: TRA-24 TRA Guardhouse Construction Rubble Pile
Author: N/A
Recipient: N/A
Date: 09/13/91
Document #: 3503
Title: TRA-25 TRA Sewer Plant Settling Pond Rubble Pile
Author: N/A
Recipient: N/A
Date: 09/13/91
Document #: 3504
Title: TRA-26 TRA Rubble Site by USGS Observation Well
Author: N/A
Recipient: N/A
Date: 09/13/9I
Document #: 3505
Title: TRA-27 TRA North Storage Area Rubble Pile
Author: N/A
Recipient: N/A
Date: 09/13/91
B-41
-------
Document #: 3506
Title: TRA-28 TRA North (Landfill) Rubble Site
Author: N/A
Recipient: N/A
Date: 09/13/91
Document #: 3507
Title: TRA-29 ATR Construction Rubble Pile
Author. N/A
Recipient: N/A
Date: 09/13/91
Document #: 3508
Title: TRA-32 TRA West Road Rubble Pile
Author: N/A
Recipient. N/A
Date: 09/13/91
Document #: 3163
Title: TRA-33 TRA West Staging Area/Drainage Ditch
Rubble Pile
Author: N/A
Recipient: N/A
Date: 09/13/91
Administrative Record Binder II
ARI.-
INITIAL ASSESSMENTS
Document #: 2867
Title: TRA-10. MTR Construction Excavation Pile
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 10/03/86
Document #: 2855
Title: TRA-23. ETR Excavation Site Rubble Pile
Author: Alexander. T.G.
Recipient: Clark. C.
Date: 10/03/86
Document #: 2854
Title: TRA-24. TRA Guardhouse Construction Rubble Pile
Author: Alexander. T.G
Recipient: Clark. C
Date: 10/O.VSh
B-42
-------
Document #: 2853
Title: TRA-25. TRA Sewer Plant Settling Pond Rubble Pile
Author: N/A
Recipient: N/A
Date: 10/03/86
Document #: 2852
Title: TRA-26. TRA Rubble Site by USGS Observation
Well
Author: N/A
Recipient: N/A
Date: 10/03/86
Document #: 2851
Title: TRA-27, TRA North Storage Area Rubble Pile
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2850
Title: TRA-28, TRA North Landfill Rubble Site
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2849
Title: TRA-29, TRA ATR Construction Rubble
Author: Alexander, T.G.
Recipient: Clark, C.
Date: 10/03/86
Document #: 2846
Title: TRA-32. TRA West Road Rubble Pile
Author: Alexander, T.G.
Recipient: Clark. C.
Date: 10/03/86
Document #: . 2845
Title: TRA-33, TRA West Staging Area/Drainage Ditch
Rubble Site
Author: Alexander. T.G.
Recipient. Clark. C.
Date: 10/03/86
B-43
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