PB98-964605
EPA 541-R98-061
October 1998
EPA Superfund
Record of Decision:
Idaho National Engineering Lab
(USDOE) (ANL-W) OU 9-04
Idaho Falls, ID
9/29/1998
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W7500-GOO-ES-04
1999
September 25.
I 1ST E.
I
OF HEALTH AND
WELFARE
DIVISION O
ENVIRONME
CL'ALITV
Final Record of Decision
Argonne National Laboratory * West
Operable Unit 9-04
Idaho National Engineering and Environmental Laboratory
Idaho Falls, Idaho
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298-533-7996 EBR (I SHUTDOJM 582 P03 SEP 25 '9? '.3:58
Final Record of Decision
Argonne National Laboratory - West
September 25. 1998
Prepared by:
The Department of Energy
The Idaho Department of Health and Wei fare-Division of Environmental Quality
and
the Environmental Protection Agency-Region 10
Operable Unit 9-04
Idaho National Engineering and Environmental Laboratory
Idaho Falls. Idaho
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11
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DECLARATION OF THE RECORD OF DECISION
Site Name and Location
Argonne National Laboratory - West, Waste Area Group 9
Operable Unit 9-04
Idaho National Engineering and Environmental Laboratory
Idaho Falls, Idaho
Statement of Basis and Purpose
The Argonne National Laboratory - West (ANL-W) Waste Area Group 9 (WAG 9) is o.ne or" the
ten Idaho National Engineering and Environmental Laboratory (INEEL) WAGs identified in the Federal
Facility Agreement and Consent Order (FFA/'CQ). The FFA/CO was signed 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) 9-04 is listed as the "WAG 9 Comprehensive
Remedial Investigation (Ri)/Feasibility Study (PS)", in the FFA'CO. The RI/FS task was to assemble
the investigations previously conducted for WAG 9, 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 identifies eight areas for remedial action and an additional 33 release areas
for "No Action" based on the risk to human health and the environment. The 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 practical 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 information contained in
the Administrative Record for the investigation for the ANL-W facility (WAG 9).
The DOE is the lead agency for this decision. The EPA and IDHW have participated in the
evaluation of the alternatives. The EPA and IDHW both concur with the selected and contingent
remedy for the clean-up of the eight ANL-W areas of concern and with the No Action determinations for
the 33 remaining areas.
Assessment of the Site
Eight areas at ANL-W have actual or threatened releases of hazardous substances, which, if-ct
addressed by implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to human health or the environment. These eight areas include the; Sanitary
Sewage Lagoons (ANL-04), Industrial Waste Pond, Ditches A. Ditch B, (all from ANL-Ol), Mam
Cooling Tower Slowdown Ditch (ANL-Ol A), Interceptor Canal-Canal and-Mound (sub-portions of
ANL-09), and the Industrial Waste Lift Station Discharge Ditch (ANL-35). The response actions
selected in this ROD are designed to reduce the potential threats to human health and the environment to
acceptable levels. The remaining 33 areas were determined to have acceptable risk to human health or
the environment, and therefore require no action.
111
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Description of the Remedial Action Objectives
The Remedial Action Objectives (RAOs) are based on those specified in the National
Contingency Plan. For the ANL-W site, the RAO for human health is to prevent direct exposure to
radionuclide contaminants of concern (COCs) that would result in a total excess cancer risk of greater
than 1 in 10,000 (1E-04) to current and future workers and future residents. The RAOs for the protection
of the environment is to prevent exposure to COCs in soils which may have potential adverse effects to
resident populations of flora and fauna, as determined by a Hazard Quotient (HQ) = 10 times the HQ
calculated from INTEL background soil concentrations.
To meet these RAOs, the risk-based calculation of the concentrations that meet these RAOs
calculated. These concentrations are called the remediation goals (RGs) and establish the quantitative
cleanup levels for the contaminated sites. The RGs for the cesium- 137 for human health was determined
by using a calculation of the concentration needed to produce a risk of 1E-04 for a future resident 100
years from now. As shown in Table A-l, the RG for the cesium- 137 is 23.3 pCi/g for the three sites with
unacceptable human health risks (the Interceptor Canal-Canal, the Interceptor Canal-Mound, and the
Industrial Waste Pond). Likewise, the RGs for the ecological receptors were also risk determined by
back calculating the concentrations which cause a hazard quotient equal to 10 times the hazard quotient
caused by INEEL natural background soil concentrations. The RGs for the six sites that will undergo
remediation for the ecological receptors are shown in Table A- 1 .
Table A-1. Final Remediation Goals for the WAG 9 Sites.
Receptor
Human Health
Human Health
Human Health
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Site
Interceptor Canal-Mound (ANL-09)
Interceptor Canal-Canal (ANL-09)
Industrial Waste Pond (ANL-01)
Industrial Waste Pond (ANL-01)
Industrial Waste Pond (ANL-01)
Industrial Waste Pond (ANL-01)
Industrial Waste Pond (ANL-01)
Ditch A (ANL-01)
Ditch B( ANL-01)
Ditch B (ANL-01)
Main Cooling Tower Slowdown Ditch (ANL-01 A)
Main Cooling Tower Slowdown Ditch (ANL-OIA)
Sewage Lagoons (ANL-04)
Industrial Lift Station Discharge Ditch (ANL-35)
_ . 95VoUCL RG*
Contaminant _ . . _ ,
Concentration1 Concentration
cesium- 137
cssium-137
cesium- 137
chromium (II
mercury
selenium
zinc
mercury
chromium III
line
chromium III
mercury
mercury
silver
30.53 23 3
18 23 3
29.2 2-5 3
1,030 500
2.62 ) -*
8.41 5 1
5,012 2..;o
3.94 )-;
1,306 500
3.020 2.200
709 500
8.33 ?-»
3.2 3 '4
352 112
1 - Concentrations in mg/kg or pCL/g
* - Backward calculated risk-based concentration at the 1E-04 level for humans and ten times
background for ecological receptors.
IV
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Description of the Selected Remedy
The selected remedy for these sites; Industrial Waste Pond and as;ociated Ditches (ANL-01),
Main Cooling Tower Slowdown Ditch (ANL-01 A), Sanitar> Sewage Lagoons (ANL-04), Interceptor
Canal (ANL-09), and the Industrial Waste Lift Station Discharge Ditch i ANL-35) is phytoremediaticn.
Phytoremediation is the generic term for aphytoextraction" an innovative/emerging technology that
utilizes plants to extract the contaminants from the soil. Phytoremediation would be conducted insitu to
remove the metals and the radionuclides from the soils via normal uptake mechanisms of the plants. The
plant vegetation is then harvested, sampled, and shipped to an incinerator on the INEEL for volume
reduction. The resultant ash will then be sampled and sent to a permitted disposal facility.
Phytoremediation would not be initiated on the Sanitary Sewage Lagoons (ANL-04) until approximate!;.
2033 when the ANL-W facility is scheduled for closure. The start of the phytoremediation for the
Industrial Was:: Pond (ANL-01) will not be initiated until che cooling water discharges from the sodium
processing facility are completed. The final sodium cooling water discharges are planned for 2002. This
delay in phytoremediation startup for either site dose not pose any increase in the risks to human health
and or the environment.
The effectiveness and technical implementability of phytoremediation are very site-specific.
DOE estimates that five growing seasons would be required to meet the established Remedial Action
Objectives. This estimate assumes natural decay of the cesium-137 along with five percent uptake by the
plants. Sample results of the ANL-W sites show the contaminants are predominantly bound in the upper
foot of soils. Thus, most of the contaminants are already within the plant root zone and no major
movement of soil is necessary. The plants would require additional irrigation and soil amendments. The
plant stalks along with the wetted soil condition would help control the spread of windblown
contaminants. DOE has conducted a bench-scale testing of soils in 1998 to determine applicability of
this remedial alternative. DOE has tested native and non-native ENEEL plant species for their
applicability for phytoremediation. Where non-native plant species are planted, the plants will be
harvested before they go to seed.
It is anticipated that phytoremediation will remove contaminants to acceptable levels after five
field seasons. These acceptable levels are defined by the Remedial Action Objectives (RAOs) for the
contaminated soils at ANL-W. Phytoremediation will eliminate the need for long-term monitoring and
maintenance activities, surface water diversions, land use and access restrictions after 100 years, and
long term environmental monitoring (air, sediment, and groundwater). The major components of the
selected remedy for ANL-W are:
Completion of phytoremediation workplan for the field-scale testing
Conducting a field-scale phytoremediation test of selected plant species at the sites that pose
unacceptable risks
Determining the effectiveness and implementability of phytoremediation based on results or"
field-scale testing
Collecting soil and plant samples after a two-year field season to be used to determine the
effectiveness of phytoremediation on the ANL-W soils
Harvesting, compacting, incinerating, and disposing of the above- and below-ground plant matter
that will be sent to a permitted landfill
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Continuing the planting/harvesting process for phytoremediation only if completion of the r.vo-
year field-scale testing is successful. This process would continue until RAOs are attained
Installing access restrictions consisting offences, bird r.enina, and posting warning signs
Review of the remedy no less than every five years after the RAOs have been met until the vear
2098
Implementing DOE controls which limit residential land use for at least 100 years from now
(2098).
Description of Contingent Remedy
If it is determined that the selected remedy of phytoremediation does not adequately reduce the
principle risks to human health and the environment after completion of the rwo-year field season, a
contingent alternative of excavation and disposal has been selected. The contingent remedy of
excavation and disposal would be used to remove contaminated soils from the Industrial Waste Pond and
associated Ditches A, B, and C (ANL-01), Main Cooling Tower Slowdown Ditch (ANL-01 A), Sanitary
Sewage Lagoons (ANL-04), Interceptor Canal-Mound (ANL-09), and the Industrial Waste Lift Station
Discharge Ditch (ANL-35). The on-INEEL site disposal location for these contaminated soils could
consist of a yet to be built Soils Repository at the Idaho Chemical Processing Plant or the Radioactive
Waste Management Complex (RWMC). The final on-RvEEL site location would be determined during
the Remedial Design/Remedial Action phase for WAG 9. Excavation and disposal activities would not
be initiated on the Sanitary Sewage Lagoons (ANL-04) until approximately 2033 when the ANL-W
facility is scheduled for closure. The start of the phytoremediation for the Industrial Waste Pond (AXL-
01) will not be initiated until the cooling water discharges from the sodium processing facility are
completed. The final sodium cooling water discharges are planned for 2002. This delay in excavation
and disposal startup for either site dose not pose any increase in the risks to human health and or the
environment. The major components of the contingent remedy for ANL-W are:
Contaminants in the waste areas will be excavated and transported to either the RWMC or the
INEEL Soils Repository for on-INEEL disposal
Verification sampling would be used to validate that the remaining soil concentrations are belo^
the Remedial Action Objectives
Review of the remedy no less than every five vears after the RAOs have been met until the >ear
2098
Implementation of DOE controls which limit residential land use for at least 100 years from no^
(2098).
The no action alternative is reaffirmed and selected as the appropriate alternative for the
remaining 33 areas at the ANL-W facility. These 33 areas have risks that are at acceptable levels based
on the information gathered during the remedial investigation.
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
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operations, maintenance activities, and decontamination and dismantlement activities at AN'L-W. L'oon
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 FF.ACO.
Statutory Determination
The selected remedy and the contingent remedy for the five sites at AN'L-W have 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.
The selected remedy of phytoremediation utilizes permanent solutions and alternative treatment
technology to the maximum extent practicable, and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a principal element.
Because the selected remedy of phytoremediation will result in hazardous substances remaining
on-site above levels for unlimited use, a review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide adequate protection of human health and
the environment. The agencies agree that No Action be taken at 33 additional areas.
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VI11
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Signature Sheet
Signature sheet for the Record of Decision for ±e Waste Area Group 9 Operable Unit 9-04, at
Argonne National Laboratory--West, part 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
Region 10
U.S. Environmental Protection Agency
Date
IX
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Signature Sheet
Signature sheet for the Record of Decision for the Waste Area Group 9 Operable Unit 9-04. at
Argonne National Laboratory-West, part of the Idaho National Engineering and Environmental
Laboratory, between the U.S. Department of Energy and the Environmental Protection Agency. \Mth
concurrence by the Idaho Department of Health and Welfare.
P. Kennedy
Manager, Chicago Operations Office
U.S. Department of Energy
Date
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XI I
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^
(r
Signature Sheet
Signature sheet for the Record of Decision for the Waste Area Group 9 Operable Unit 9-04, at
Argonne National Laboratory-West, part 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.
Aj&febwJr /?^>y 4f
Wallace N. Cory, Administrator Date
division of Environmental Quality
Idaho Department of Health and Welfare
xin
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Table of Contents
DECLARATION OF THE RECORD OF DECISION
ACRONYMS
DECISION SUMMARY . .
1.1 Sice Name
2 SITE HISTORY AND ENTORCEMENT ACTIVITIES
2.1 INEEL Site Description
2.2 ANL-W Site History
2.3 Identification of Release Sites
2.4 enforcement Activities
3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
4 SCOPE OF OPERABLE UNITS AND RESPONSE ACTIONS
5 SUMMARY OF SITE CHARACTERISTICS 5-1
5.1 Physiography 5-1
5.2 Meteorology .;. . 5-1
5.2.1 Air Temperature 5-2
5.2.2 Precipitation 5-1
5.2.3 Evaporation and Infiltration 5-1
5.2.4 Wind 5-1
5.2.5 Special Phenomena '. . 5-3
5.3 Geology 5-3
5.3.1 Surface Geology 5-3
5.3.2 Subsurface Geology 5--*
5.4 Soils y 5-5
5.5 Hydrogeology 5-6
5.5.1 Snake River Plain Aquifer 5-6
5.5.2 Surface Water Hydrology 5-6
5.6 Ecology
5.7 Nature and Extent of Contamination
5.7.1 Nature and Extent of Groundwater Contamination
5.7.2 "Nature and Extent of Soil Contamination
5.7.2.1 Industrial Waste Pond
5.7.2.2 Ditch A
5.7.2.3 Ditch B
5.7.2.4 Ditch C
5.7.2.5 Main Cooling Tower Slowdown Ditch
5.7.2.6 Sewage Lagoons
5.7.2.7 EBR-II Leach Pit
5.7.2.8 Interceptor Canal-Canal
5.7.2.9 Interceptor Canal-Mound
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5.".2.10 fndustrial Waste Discharge Ditch
5.7.2.11 Main Cooling Towef-R+sef-Prts- 5O-
5.8 No Action Sices 5.25
5.8.1 Operable Unit 9-01 Sites 5-2:
5.8.2 Operable Unit 9-02 Site f.;6
5.8.3 Operable Unit 9-03 Sites 5-2"
5.8.4 Operable Unit 9-04 Sites 5-2"
5.8.5 Operable Unit 10-06 Sites 5-28
6 SUMMARY OF SITE RISKS 6-1
6.1 Human Health Risk Evaluation 6-:
6.1.1 Contaminant Identification 6- i
6.1.2 Exposure Assessment ' 6-'.
6.1.2.1 Exposure Scenarios 6-'.
6.1.2.2 Quantification of Exposure 6-2
6.1.3 Toxicity Assessment ' 6-3
6.1.4 Human Health Risk Characterization 6-3
6.1.5 Risk Management 6-4
6.1.6 Human Health Risk Uncertainty 6-4
6.2 Ecological Evaluation 6-14
6.2.1 Species of Concern 6-14
6.2.2 Exposure Assessment 6-15
6.2.3 Ecological Risk Uncertainites 6-16
6.3 Groundwater Risks " - 6-!6
6.4 Basis for Response 6-: 6
7 DESCRIPTION OF ALTERNATIVES '. '-;
7.1 Remedial Action Objectives "-1
7.2 Summary of Alternatives ..."-}
7.2.1 Alternative 1: No Action (With Monitoring) ~-4
7.2.2 Alternative 2: Limited Action ~-4
7.2.3 Alternative 3a and 3b: Containment Alternatives and Institutional Controls
~" _ >
7.2.4 Alternatives 4a and 4b: Excavation and Disposal "-6
7.2.5 Alternative 5: Phytoremediation "-"
7.3 Summary of Comparative Analysis of Alternatives ~-3
7.3.1 Threshold Criteria "-0
7.3.1.1 Overall Protection of Human Health and the Environment ''.->
7.3.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
7.3.2 Balancing Criteria '''
7.3.2.1 Long-term Effectiveness and Permanence
7.3.2.2 Reduction in Toxicity, Mobility, or Volume Through Treatment . .
7.3.2.3 Short-term Effectiveness "-'<"
7.3.2.4 Implementability 7- 1 ~"
7.3.2.5 Cost ~-:S
7.3.3 Modifying Criteria 7-18
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7.3.3.1 State Acceptance ~-;3
7.3.3.2 Community Acceptance ~-!S
8 SELECTED REMEDY 3-!
8.1 Ranking of Alternatives 3-1
8.2 Selected Remedy 3-2
8.3 Selected Contingent Remedy 3-3
3.4 No Action Sites 3-4
8.5 Remediation Goals 3-5
8.6 Estimated Cost Details for the Selected Remedy 3-6
9 STATUTORY DETERMINATIONS 9-1
9.1 Protection of Human Health and the Environment 9-1
9.2 Compliance with ARARs and To Be Considered 9-!
9.2.1 Selected Remedy Compliance with ARARs °-2
9.2.2 Contingent Remedy Compliance with ARARs 9-2
9.3 Cost Effectiveness 9-"
9.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Possible 9-~
9.5 Preference for Treatment as a Principal Element 9-8
10 DOCUMENTATION OF SIGNIFICANT CHANGES 10-1
11 RESPONSIVENESS SUMMARY 11-1
APPENDIX A , A-1
APPENDIX B Administrative Record B-1
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Figures
Figure l-l. Location of the [NEEL and Major Facilities with Respect to the State of Idaho 1-T-
Figure 1-2. Location of the Argonne National Laboratory- West Sites of Concern i-5
Figure 1-3. Ownership of Lands Surrounding the tNEEL ; -~
Figure 2-1. Location of FNEEL with respect to Counties 2-3
Figure 2-2. Shaded Relief Map of WAG 9 and FNEEL 2-5
Figure 2-3. Aerial View of the ANL-W Facility Showing the Main Facilities 2-"
Figure 5-1. Thickness of Surficial Soils at ANL-W .' 5-~
Figure 5-2. Map Showing General Soil Types Near ANL-W 5-3
Figure 5-3. Location of Monitoring Wells Near ANL-W 5-; :
Figure 5-4. Eleven Areas Retained for Evaluation in RI.PS 5-'."
Figure 6-1. Eight Areas at ANL-W with Unacceptable Human Health or Ecological Risks 6- N
Tables
Table 4-1. Summary of data available for WAG 9 and WAG 10 release sites evaluated in the OU 9-04
comprehensive RI/FS -1-2
Table 5-1. Extent of Contamination Soil in WAG 9 Sites Retained for Cleanup 5-15
Table 6-1. Exposure sites with human health risks greater than IE-04 6-5
Table 6-2. Contaminant hazard index greater than 1 for OU 9-04 exposure sites, scenarios, and
pathways ." :..... 6-6
Table 6-3. Exposure sites with risks greater than 1E-06 and less than IE-04 6-"
Table 6-4. Sites retained for evaluation in the feasibility study because of human health risks 6-12
Table 6-5. Uncertainties associated with the human health risk assessment . .' 6- i 3
Table 6-6. Sites that have unacceptable ecological risks, HQ, functional group, and species 6-! 5
Table 6-7. Uncertainties associated with the ecological risk assessment 6- i ~
Table 6-8. Sites with unacceptable human health or ecological risks 6- i S
Table 7-1. Final Remediation Goals for the WAG 9 Sites ~-2
Table 7-2. Volume of Contaminated Soil in the Eight areas Retained for Cleanup ."-3
Table 7-3. Comparative Analysis of Remedial Alternatives Using the Evaluation Criteria "-'10
Table 7-4. Comparative Analysis of Remedial Alternatives " 16
Table 8-1. Detailed Cost Estiamte Summary Sheet for Alternative 3, Containment S-"
Table 8-2. Detailed Cost Estimate Summary Sheet for Alternative 4a, Excavation and Disposal at the
FNEEL Soils Repository $-3
Table 8-3. Detailed Cost Estimate Summary Sheet for Alternative 4a. Excavation and Disposal at
RWMC ' . . *-J
Table 8-4. Detailed Cost Estimate Summary Sheet for Alternative Jb, Excavation with Disposal at
Private Faciltiy 3- ' -1
Table 8-5. Detailed Cost Estimate Summary Sheet for Alternative 5, Phytoremediation S-li
Table 9-1. Evaluation of ARARs and TBC compliance for the Delected remedy- Alternative 5:
phytoremediation 9-3
Table 9-2. Evaluation of ARARs and TBC compliance for the contingent remedy - excavation and On-
FNEEL disposal of contaminated soils 9-5
Table 9-3. Net present value of capital, operating and maintenance (O&M) and total cost for remedial
alternatives at OU 9-04 sites 9-S
xviu
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ACRONYMS
ANL-W Argonne National Laboratory - West
ARARs Applicable or Relevant and Appropriate Requirements
BLS below land surface
CFA Central Facilities Area
COC Contaminant of Concern
COCA Consent Order and Compliance Agreement
COPC Contaminant of Potential Concern
. CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
DOE Department of Energy
DOE-CH Department of Energy-Chicago Operations Office
DOE-ID Department of Energy-Idaho Operations Office
ERA ecological risk assessment
EBR-II Experimental Breeder Reactor II
FS Feasibility Study
FFA/CO ' Federal Facility Agreement and Consent Order
FCF Fuel Cycle Facility
HQs hazard quotients
HFEF/S Hot Fuel Examination Facility South
IDHW Idaho Department of Health and Welfare
INEEL Idaho National Engineering and Environmental Laboratory
LMITCO Lockheed Martin Idaho Technologies Company
MSL mean sea level
NOAA National Oceanic and Atmospheric Administration
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
O&M Operations and Maintenance
OU Operable Unit
PCBs polycholorinated biphenyls
RAOs remedial action objectives
RGs remediation goals
RME reasonable maximum exposure
ROD Record of Decision
RJ Remedial Investigation
RCRA Resource Conservation and Recovery Act
RWMC Radioactive Waste Management Complex
SR? Snake River Plain
SRPA Snake River Plain Aquifer
TBC to-be-considered
TREAT Transient Reactor Test Facility
EPA Environmental Protection Agency - Region 10
UMTRA Uranium Mill Tailings Remedial Action
UCL upper confidence limit
WAG 9 Waste Area Group 9
ZPPR Zero Power Phvsics Reactor
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Waste Area Group 9
Record of Decision
1 DECISION SUMMARY
1.1 Site Name
The Idaho National Engineering and Environmental Laboratory (INTEL) is a government
facility managed by the U.S. Department of Energy (DOE), located 32 miles (51 km) west of Idaho Fails
Idaho, and occupies 890 square miles (2,305 knr) of the northeastern portion of the Eastern Snake R:'. ;r
Plain. The Arsonne National Laboratory-West (AN'L^W) is located in the southeastern portion ^f ;.u.e
INEEL, as shown in Figure I-1. To better manage environmental investigations, the INT-EL was
subdivided into ten Waste Area Groups (WAGs). Identified contaminant releases sites in each WAG
were in rum divided into operable units (OUs) to expedite the investigations and any required remedial
actions. Waste Area Group 9 covers the ANL-W and contains four Ob's that were investigated for
contaminant releases to the environment. Within these four OUs, 37 known or suspected contaminant
release sites have been identified. Two of the identified 37 release sites have been further subdivided
into smaller areas based on their waste discharges and physical modeling parameter variations «, ith:r. j
release site. Thus, the term "site" will herein refer to a named release site in one of the OUs. While
"area" will herein be used to define all or a portion of an identified OU release site. This Record of
Decision (ROD) applies to these 37 sites at WAG 9 and two sites from WAG 10, which, on the basis ot"
the comprehensive remedial investigation (RI)/feasibility study (FS) for WAG 9, were identified as
posing a potential risk to human health and/or the environment. Of these 39 sites, 33 are being
recommended for "No Action." Figure 1-2 shows the locations of the eight areas where remedial ac::cn
is proposed.
The rNEEL lands are within the aboriginal land area of the Shoshone-Bannock Tnbes. The
Tribes have used the land and waters within and surrounding the INEEL for fishing, hunting, plant
gathering, medicinal, religious, ceremonial, and other cultural uses'since time immemorial. These iar.os
and waters provided the Tribes their home and sustained their way of life. The record of the Tribes'
aboriginal presence at the INEEL is considerable, and DOE has documented an excess of 1,500
prehistoric and historic archeological sites at the INEEL.
Facilities at the INEEL are primarily dedicated to nuclear research, development, and v,aste
management. Surrounding areas are managed by the Bureau of Land Management for multipurpose .-.e
The developed area within the INEEL is surrounded by a 500 square mile (1,295 knr) buffer zone used
for cattle and sheep grazing. Communities nearest to ANL-W are Atomic City (southwest). Arco i --*.es:
Butte City (west), Howe (northwest), Mud Lake (northeast), and Terreton (northeast). In the counties
surrounding the FNEEL, approximately 45% is agricultural land. 45% is open land, and 10% is urban
Sheep, cattle, hogs, poultry, and dairy cattle are produced; and potatoes, alfalfa, sugar beets, wheat,
barley, oats, canola, sunflower, 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 FNEEL is strictly controlled by fences and security personnel. State
Highways 22, 28, and 33 cross the northeastern portion of die INEEL approximately 20 miles (32 2 vrni.
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and L'.S. Highways 20 and 26 cross the southern portion approximately 5 miles (8 km) av-a> from
ANL-W. respectively. A total of 90 miles (145 km) of paved highways pass through the FNEEL ar.d _>r-
used by the general public.
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 miles (322 km) long. 20 :o
60 miles (32.2 to 96.5 km) wide, and covers an area of approximately 9,600 square miles (24.853 km: i
The depth to the SRPA varies from approximately 200 feet (61 m) in the northeastern comer of the
INEEL to approximately 900 feet (274 m) in the southeastern comer. This change in groundwater depth
in the northeastern corner to the southeastern corner occurs over a horizontal distance of 42 miles i.6~ 6
km). Depth to groundwater is approximately 640 feet (195 m) below ANL-W and the groundwater How
direction is south-southwest. Drinking water for employees at ANL-W is obtained from r\vo production
wells located in the west-central portion of the ANL-W facility.
Most INEEL facilities are currently operated by one of three Government contractors; Lockheed
Martin Idaho Technologies Company (LMITCO), Westinghouse Electric Corporation, and Argonne
National Laboratory-West. These contractors conduct various programs at the INEEL under the
supervision of three DOE offices: DOE-Idaho (DOE-ID), Department of Defense-Pittsburgh Naval
Reactors Office, and DOE-Chicago (DOE-CH).
ANL-W, a prime operating contractor to DOE-CH, began a redirected nuclear research and
development program in FY 1995. The redirected program involves research to help solve near-term
high priority missions including the treatment of DOE spent nuclear fuel and reactor decontamination
and decommissioning technologies. ANL-W is also currently in the process of conducting shutdown and
termination activities for the Experimental Breeder Reactor II (EBR-II). Within the ANL-W site are a
number of research and support facilities that contribute to the total volume of waste generated at
ANL-W. These facilities currently generate radioactive low-level waste, radioactive transuranic waste,
hazardous waste, mixed waste, sanitary waste, and industrial waste. Approximately 750 people are
employed at the ANL-W facility.
The ANL-W facility does not have any identified wetlands, is not in the 100-year floodplain. and
has been screened as to it's potential for habitat to rare and endangered species. One facility at ANL-W.
the EBR-II reactor may be listed as a historic building eligible for listing on the National Register in the
future. The selected and contingent remedial alternatives would not impact the EBR-II facility.
-------
LEGEND
.S.NL-W -
A*A
AHVFS -
BORAX -
CFA - Ci
EBR-) - E
-------
Industrial
Waste Pond
Sewage Lagoons
Ditch C
Main Cooling Tower
Slowdown Difch
Ditch A
Ditch B
Interceptor Canal
industrial Waste Lift Station
/ Discharge Ditch
Figure 1-.2,
or ±
Afgen:ie National
-------
LEGEND
Kiv to Fjcihues
i ^Kiefui Foicai Land
Pnwc Lind -Noo-Cufljviied
*!' r':.^.71 Pnv« LJ«I-CJuviw
<-,"_"_"' ',^ 5U« 'r"*
^ ' L'nau Gnaflg ?;.-TILU
-- Mounuuu tea SUBU
U S ud Suie A?«U
BORAX 3:cffl '*«
! Ftcury
\
EBR-I
JO FT
:C7»
M^sf MA^d '^utf i^nie f^waar*
NOTF - s>.» 3n>m« 'o. ^ii.>
MV . -l.tjituXfFiut
P9F - ?o»a QifiiFioMv
R'A~MC - IMU^OI^T *'ww *^4D«ftaai :
SPOT - Specw Power Cjafiu* 3 IA=»
TAN - Tui *JU tint
v&f
«WTT
^ '> d:tc.'01
Dale Dnwn: Much 11. '.997
0 2 i 5 * iDNUlei
Figure 1-3. Ownership of Lands Surrounding thi PNEEL
1-7
-------
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 INEEL Site Description
The INTEL site occupies approximately 890 square miles (2,300 km:) of the northwestern
portion of the eastern Snake River Plain (SRP) in southeast Idaho. The INTEL site is nearly 39 miles i63
km) long from north to south and about 36 miles wide (east-west) in its broadest southern portion. Tr.i
INEEL includes portions of five Idaho counties (Bingham, Bonneville, Butte, Clark, and Jefferson) and
lies within Townships 2 to 8 N and Ranges 28 to 34 E, Boise baseline and meridian. Figure 2-1 shows
the location of the INEEL with respect to the counties and State.
The surface of the INEEL is a relatively flat, semiarid, sagebrush desert, with predominant rei.e:'
being manifested either as volcanic buttes jutting up frorrt the desert floor or as unevenly surfaced basalt
flows or flow vents and fissures. Elevations on the INEEL range from 5,200 ft in the northeast to
4,750 ft in the central lowlands, with an average elevation of 4,975 ft. Figure 2-2 shows the shaded relief
map of the WAG 9 and the rest of the INEEL.
2.2 ANL-W Site History
The ANL-W was established in the mid 1950s and is located approximately 30-miles west of
Idaho Falls. ANL-W houses extensive support facilities for three major nuclear reactors: Transient
Reactor Test Facility (TREAT), EBR-II, and the Zero Power Physics Reactor (ZPPR). The location of
the main facilities at ANL-W are shown in Figure 2-3.
The first reactor to operate at the ANL-W site was TREAT, which was built in 1959. As its
name implies, TREAT was designed for overpower transient tests of fuel. Its driver fuel, consisting of
finely divided uranium oxide in a graphite matrix, has a high heat capacity that enables it to withstand
tests in which experimental fuel may be melted. Used extensively at first for safety tests of water-reacrcr
fuels, TREAT is now used mainly for safety tests for various fuel types as well as for non reactor
experiments. It has periodically undergone modifications as part of the TREAT upgrade project.
The EBR-II a 62.5 megawatt thermal reactor went into operation in 1964 capable of producing
19.5-megawatts of electrical power in the liquid metal reactor power plant. It is a pool-type sodium-
cooled reactor, designed to operate with metallic fuel. It was provided with its own Fuel Cycle Facility
(FCF) adjacent to the reactor building for remote pyrometallurgical reprocessing and refabrification or"
reactor fuel. The Fuel Cycle Facility operated from 1964 providing five complete core loadings of
recycled fuel for EBR-IK
Over the years, the mission of the EBR-II has been redirected from that of a power-plant
demonstration with integral fuel cycle to that of an irradiation test facility for mixed uranium-plutomum
fuels for future liquid metal reactors. The pyrometallurgical process used in the Fuel Cycle Facility
not suitable for ceramic fuels so the Fuel Cycle Facility was converted to a Hot Fuel Examination
Facility South (HFEF/S).
2-1
-------
EBR-II continued to be fueled with metallic uranium driver fuel for operating convenience. This
fuel was gradually improved to greatly increase its bumup, thus contributing to a high plant factor for
irradiation tests. Over the years of operation, much valuable operating experience has been gained on
sodium systems, including the removal and maintenance of primary sodium pumps and other
components. In the 1970s, the mission of the EBR-II was again shifted in emphasis, this time to the
Operational Reliability Testing Program. This program was aimed at studying the milder but more
probable types of fuel and reactor malfunctions that could lead to accident sequence. In addition to
preventing accidents, its aim was to better define the operating limits and tolerable faults in reactor
operation, thus leading to both safer and more economical plants. The components of this program in
EBR-II included tests of fuel to and beyond cladding breach, loss-of-coolant flow tests, mild power
transients, and studies of man-machine interfaces.
In the early 1980s, ANL-W reexamined the basic design of liquid-metal-cooled fast reactors.
The results of this study led to the Integral Fast Reactor (IFR) concept. The IFR incorporates four basic
elements: sodium cooling; a pool configuration; a compact, integral fuel cycle facility; and a ternary
metal alloy fuel. Modifications to the EBR-II and the HFEF/S facilities have been made to support the
pyroprocessing and fuel manufacturing for the IFR demonstration project. Since 1994, ANL-W has been
conducting shutdown and termination activities for the EBR-II. These shutdown activities include
defueling and draining the primary and secondary sodium loops and placing the reactor in a
radiologically safe shutdown condition. The Fuel Cycle Facility has been converted to a Fuel
Conditioning Facility. The mission of the Fuel conditioning Facility is to electrochemically treat EBR-II
fuel to create radioactive waste forms which are acceptable for disposal in a national geologic repository.
The ZPPR was put into operation at ANL-W in 1969. The ZPPR is large enough to enable core-
physics studies of full-scale breeder reactors that will produce up to 1,000 megawatts. ZPPR has also
been used for mockups of metallic cores and space-reactor cores. ZPPR was placed in programmatic
standby in fiscal year 1989.
Various chemical and radioactive wastes were generated from these three reactors and the
support facilities at ANL-W. The operation of these facilities and the corresponding waste streams have
been evaluated and documented in the Facility Assessment and Screening document of 1973. This
document, which is based on process knowledge, has been used as an initial starting point for ANL-W
cleanup activities.
2.3 Identification of Release Sites
Potential release sites identified at ANL-W facilities in the Federal Facility Agreement and
Consent Order (FFA/CO) include wastewater structures and leaching ponds, underground storage tanks.
rubble piles, cooling towers, an injection well, french drains, and assorted spills. Possible COPCs at the
various ANL-W sites include primarily petroleum products, acids, bases, PCBs, radionuclides. and heavy
metals. These are the chemical and radioactive wastes generated from the scientific and engineering
research at ANL-W.
2.4 Enforcement Activities
In July 1989, the Environmental Protection Agency proposed listing the INEEL on the National
Priorities List (~NPL) of the National Oil and Hazardous Substances Pollution Contingency Plan fNCP).
-------
110
c
n
i->
o
(J
o
3
O
m
fl
r.
O
r.
-------
Idaho National Engineering and Environmental Laboratory
Beaverhead
Mountains
Ekvaaoo Model Developed
From USDS 1 :4.000 Scate
Digital Line Graphs
COORWNArE SYSTEM Slaqnoa
PROJECTION: Trauvota
DATUM. MAO2'
:o
10
;Q !0 Kjlomeieri
Di'.e Dn»n SiC'.err.Oi: II. I
Figure 2-2. Snaded Relief Map of WAG 9 and INEEL
:-? -c
-------
"igure 2-3. Aerial View of the ANLAV Facilin. Showing the Ma:.
-------
The EPA issued a final ruling that listed the FNEEL as an NPL site in November 1989. The FF.A.CO
was developed to establish the procedural framework and schedule for developing, prioritizing,
implementing, and monitoring response actions at the FN'EEL in accordance with CERCLA, the
Resource Conservation and Recovery Act (RCRA), and the Idaho Hazardous Waste Management Act.
The DOE, EPA and IDHW have determined that hazardous waste release iites at ANL-W 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. The FFA/CO identified 4 OL's
consisting of 19 sites within Waste Area Group 9 that required additional activities under the CERCLA
process. An additional 18 sites were determined to need no further action at the time the FFACO was
signed. Thus, a total of 37 WAG 9 sites were evaluated during the OU 9-04 Comprehensive RITS
process and the results are summarized in this ROD.
One unit in OU 9-04 [Main Cooling Tower BJowdown Ditch (ANL-01A)] was originally
included as a Land Disposal Unit under the RCRA Consent Order and Compliance Agreement ^COC A)
on the basis that corrosive liquid wastes were discharged after 1980. DOE, along with the EPA and
IDHW WAG 9 managers, have determined that the Main Cooling Tower Slowdown Ditch is a RCRA
Land Disposal Unit and will be remediated under the CERCLA process in accordance with the
applicable substantive requirements of RCRA/Hazardous Waste Management Act (HWMA), if an
unacceptable risk to human health or the environment. However, the FFA/CO has only adopted RCRA
corrective action (3004 (u) & (v)), and not RCRA/HWMA closure. Therefore, upon completion of the
remedial action, the DOE must receive approval from the IDHW Department of Environmental Quality
director that the Main Cooling Tower Slowdown Ditch has been closed pursuant to RCRA/HWMA
closure requirements.
The OU 9-04 comprehensive RI/FS conducted ANL-W resulted in the identification of eight
areas with potential risk to human health and/or the environment that would require some type of
remedial action (W7500-000-ES-02, October 1997). The Proposed Plan (January 1998) identified the.
agencies' preferred alternative for the eight areas of concern at ANL-W.
2-9
-------
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 9, ANL-W, was provided to
the public from March 1994 through March 1998. The opportunities to obtain information and provide
input include "kickoff' fact sheets, which briefly discussed the status of the comprehensive investigation.
articles in the f.\EEL Reporter (a publication of the INEEL's Environmental Restoration Program), three
Citizens' Guide supplemental updates, presentations to members of the Citizens Advisory Board, a
proposed plan January 1998, and public meetings. Specific details on how each of the opportunities for
the citizens to obtain additional information on WAG 9 are presented below.
Articles in the March 1994 and November/December 1997 issues of the INEEL Reporter were
distributed to approximately 6,700 members of the INEEL Community Relations Plan mailing list. The
articles contained status reports on activities conducted at WAG 9 in addition to information on how ;0
get additional information in the INEEL Information Repositories.
. Three Citizens' Guide supplemental updates in March/April 1996, April/May 1996, and 1997
annual guide were also mailed to about 6,700 members of the public on the INEEL Community
Relations Plan mailing list. These Citizen's Guide supplemental updates had specific sections on
cleanup activities in WAG 9. Each of the Citizens' Guide supplemental updates also included
information on how to get more information-about WAG 9 via the internet, toll-free phone number,
Administrative Record/Information Repositories, videos, and the INEEL Regional Office in Boise.
The kickoff fact sheet was mailed in September 1996 to members of the public on the INEEL
Community Relations Plan mailing list to encourage participation prior to the initiation of work on the
Comprehensive RI/FS. The information on how to request a briefing, or to get more information on OU
9-04 documents was printed on the back of the kickoff fact sheet.
On January 20, 1998, a brief presentation on the proposed plan was presented to the Citizens
Advisory Board. The advisory board consists of 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. The Citizens Advisory Board meetings are open to the general
public.
Copies of the proposed plan were mailed to approximately 6,700 members of the public on the
INEEL Community Relations Plan mailing list on January 6, 1998, urging citizens to comment of 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 January 12 and 19, and
February 9 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).
In January 1998, DOE issued a news release to more than 100 media contacts informing them of
the beginning of a 30-day public comment period pertaining to the WAG 9 ANL-W proposed plan. Th:s
3-1
-------
comment period began January 12, and ended on March 12, 1998 in response to a request from the
public, for a 30 day extension. Most of the news releases resulted in a short note in community calendar
sections of the newspapers and in public service announcements on radio stations. The fact sheets.
fNEEL Reporter, and the proposed plan all identified that additional documentation on WAG 9 is
available in the Administrative Record section of the fNEEL Information Repositories located in the
FNEEL Technical Library in Idaho Falls, in the FNEEL Boise Office, and in public libraries in Fort Hail.
Pocatello, and Moscow.
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, a informal presentation of the proposed plan was given to Tribal members and their
technical staff on January 7, 1998.
Postage-paid business-reply comment forms were available to those attending the public
meetings. The forms were used to submit written comments either at the meeting or by mail. In
addition, the reverse side of the meeting agenda contained a form for the public to use in evaluating the
effectiveness of the meetings. A court reporter was present at each meeting to keep transcripts of
discussions and public comments. The meeting transcripts were placed in the Administrative Record
section for the WAG 9, OU 9-04 in the 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 and is included as Appendix A to this 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
who made the comment and the page number where the DOE response can be found in the
Responsiveness Summary.
A total of about 75 people not associated with the project attended the public meetings. Overall.
nine citizens or groups provided formal comments. All comments received on the proposed plan were
considered during the development of this ROD. The decision document presents the selected remedial
action for the WAG 9, OU 9-04, chosen in accordance with CERCLA, as amended by Superfund
Amendments and Reauthorization Act and, to the extent practicable, the National Contingency Plan. The
decision for this site is based on the information in the Administrative Record for OU 9-04.
3-:
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4 SCOPE OF OPERABLE UNITS AND RESPONSE ACTIONS
Under the FFA/CO, the INEEL is divided into 10 WAGs. of which ANL-W is included as \V'AG
9. WAG 9 is further subdivided into four OUs that included a total of 37 release sites. The four OL's are
classified as: Remedial Investigation Sites, Track 2 Sites, Track 1 Sites, -rNo Action" Sites. In addition
to the WAG 9 sites, two sites from WAG 10 are included in the evaluation of WAG 9. The inclusion of
these two WAG 10 sites into the WAG 9 ROD was based on the close physical location of these sites to
other WAG 9 facilities. These WAG 10 sites did not have individual risks but may add to the cumulative
risks of WAG 9. Table 4->l shows the 39 sites that were evaluated as part of the OU 9-04 Comprehensi'. e
RI/FS, 37 sites from WAG 9, and two sites from WAG 10.
The task of the "comprehensive" RI/FS is to evaluate contamination of environmental media
(soil, air, and groundwater) and the potential risks to human health and the environment from exposure
via those pathways. Each of the retained sites has undergone a "comprehensive"evaluation because risks
from all known and potential release sites within WAG 9 and the two sites from WAG 10 have been
evaluated. In addition, it is also "cumulative" because the receptor may be exposed to contamination
from multiple release pathways (e.g., air and groundwater exposure pathways), from multiple release
sites. Analyzing the air and groundwater pathways in a cumulative manner is necessary because
contamination 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.
From the evaluation of the 39 sites that were evaluated as part of this ROD, eight areas at ANL-
W 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 eight areas are subunits of five CERCLA sites (ANL-
01, ANL-01A, ANL-04, ANL-09, and ANL-35) identified in the FFA/CO. This includes one area with
only unacceptable risks to human health, five areas with only unacceptable risks to the ecological
receptors, and two sites with unacceptable risks to both human health and the ecological receptors. The
screening, development, and detailed analysis of the remedial alternatives resulted in the selected
alternative for each of the retained 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 ar.d
appropriate requirements (ARARs).
In addition to the eight areas that require some type of remedial action, this comprehensive ROD
also addresses 33 WAG 9 areas that do not pose an unacceptable risk to human health or the
environment, based on the evidence compiled during the OU 9-04 Comprehensive RI/FS. These 33
areas are being recommended for No Action and, with approval of this ROD, the No Action decision is
formalized.
4-1
-------
Table 4-1. Summary of data available for WAG 9 and WAG iO release sites evaluated in the OL" 9-0-i
comprehensive RI/TS.
OL'
Site
Sice description
COCs
Data available
Source ofinfortrution
None
None
None
None
ANL-IO Dry Well between T-1
and ZPPR Mound
ANL-11 Waste Retention Tank
783
ANL-12 Suspect Waste Retention
Tank bv 793
ANL-14 Septic Tank and Drain
Fields (2) by 753
None
ANL-15 Dry Wei I by 768
None ANL-16 Dry Well by 759 (2)
None ANL-17 Dry Well by 720
None ANL-18 Septic Tank and Drain
Field by 789
None ANL-20 Septic Tank and Drain
Field by 793
None Interviews with t'acihey personnel
indicate that :he dry well was
hooked up :o a septic tank which
was removed :n !966. Therefore,
no source ixists.
None Interviews ot" former facility
operators indicate that no
hazardous constituents were ever
disposed at the :ank; Therefore, no
source exists.
None Interviews of former facility
operators indicate that the tank was
removed in 1979 and that no
source exists.
None Process knowledge and interviews
with plant services personnel
indicate that the only materials
' disposed were trace quantities of
cleaning supplies. The tank was
removed in 1979 and no source
exists.
None Process knowledge and interviews
with facility personnel indicate that
the only hazardous constituent
disposed was hydrazine.
None. Process knowledge and interviews
with facility personnel indicate that
the only hazardous constituent
disposed was hydrazine.
None Process knowledge and interviews
with facility personnel, no
hazardous constituents were ever
disposed and therefore no source
exists.
None the septic tank and drain field
were removed in 1979. Process
knowledge and interviews with
facility personnel indicate that no
hazardous constituents were
disposed at the site.
None Engineering drawings, and
interviews with employees indicate
no hazardous constituents were
disposed and therefore no source
exists.
Initial Assessment R;cor. :>r
ANL-Wi|986)
Initial Assessment Repor for
ANL-W (1986). SuT.mar.
.Assessment Rzpor : I9^0ai
Initial Assessment Rip.;.- :'-
ANL-W (1986). Sdrr.rr.ar>
Assessment Report < 1 990ai
Initial .Assessment R;pcr.for
ANL-W (1986), Summary
Assessment Report < I990ai
Initial Assessment Report for
ANL-W (1986), Summary
Assessment Report i 19^0a.
Initial Assessment Report for
ANL-W (1986), Summary
Assessment Report 11990ai
Initial Assessment Report for
ANL-W (1986). Summary
Assessment Repor. 11990ai
Initial Assessment Riper f :r
ANL-W (1986).
Initial Assessment Repor :r
ANL-W (1986). Summary
Assessment Reoort i! 990a»
4-2
-------
Table 4-1. (continued).
OL
Site
Site description
COCs
Data available
Source of information
A.NL-21
A.M-22
A.NL-23
None ANL-24
None ANL-25
None ANL-26
None
ANL-27
^'cne
None
AM-32
ANL-33
TR£AT Suspect Waste
Tank and Leaching Field
("Non-radioactive)
TREAT Septic Tank and
the current Leaching
Field
T°£AT Seepage Pit and
Septic Tank West of "20
Lab and Office Acid
Neutralization Tank
Interior Building Coffin
Neutralization Tank
Critical Systems
Maintenance Decreasing
Unit
Plant Services
Decreasing Unit
TREAT Control
Building 721 Septic
Tank and Leach Field
(Present)
TREAT Control
Building 721 Septic
Tank and Seepage Pit
None Process knowledge and interviews
with plan! services persorjiei
indicate :hat '.he only rr.aier.als
disposed were trice quar.t::ics of
c.caning supplies, therefor:, no
source exists
None Process knowledge and interviews
with facility personnel indicate that
no hazardous constituents were
disposed it the site, therefore, no
source exists
None .Process knowledge and interviews
with facility personnel indicate that
. no hazardous constituents were
disposed at the site. The tank was
filled wiih sand m 1980; therefore,
no source exists.
None Process knowledge and interviews
with facility personnel indicate that
no hazardous constituents were
disposed at the site. Therefore, no
source exists.
None .After neutralization with sodium
hydroxide, the liquid was
transferred to the retention tank:
Thus, no source exists.
None The degreasing unit is
self-contained and is inside another
building. No evidence exists (from
spill records and interviews) of any
hazardous constituents being
spilled. All wastes are collected
by a commercial vendor, therefore
no source exists.
None The degreasmg unit is
self-contained and is inside another
building. No evidence exists (from
spill records and interviews) of any
hazardous constituents being
spilled. All wastes are collected by
a commercial vendor, therefore no
source exists.
None Process knowledge and interviews
with facility personnel indicate that
no hazardous constituents were
disposed u Uie site; iricrefore. no
source exists.
None Process knowledge and interviews
with facility personnel indicate that
no hazardous constituents were
disposed at the site. The lank was
removed in 1978 ind no source
exists.
Initial Assessme.-.t Report :>r
AM.-W (1986). Summary
Assessment Report !9<;'.'3
Initial Assessment Rcpor
ANL-W <
Initial Assessment Rcpcr.
ANL-W (1986)
Initial Assessment Riper. :or
ANL-W (1986)
Initial Assessment Report :'cr
ANL-W (1986). Summary
Assessment Report (1990ai
Initial Assessment Report for
ANL-W (1986). Summary
Assessment Report 1.1990ai
Initial Assessment Repor. :'cr
ANL-W (1986), Summar.
Assessment Report i! 990a:
Initial Assessment R:por :
ANL-W (1986). Sum.T.ar-
Assessment Report i 1990a i
Initial Assessment Ripor :'or
ANL-W (1986). Summary
Assessment Report < 1990a
4-]
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Table 4-1, (continued).
OL
9-01
Site
ANL-04
Site description
AN'L Sewage Lagoons
COCs
Metals and
radionuclides
Data available
Sludge samples were collected in
1994 md analyzed for metals and
radionuclides.
Source of information
Track 1 Decision Documentation
Package (ANL-W I995a}
identified further ivaluation .'f '.
9-01
ANL-19 Sludge Pit West of T-7
(ImhotTTank)
9-01
9-01
9-01
9-01
9-01
9-01
9-01
9-01
9-01
ANL-28
EBR-M Sump
ANL-29 Industrial Waste Lift
Station
ANL-30 Sanitary Waste Lift
Station
ANL-36 TREAT Photo
Processing Discharge
Ditch
ANL-60 FCnawa Bune Debris Pile
ANL-61-t- EBR-II Transformer
Yard
ANL-61A+ PCB-contarainated soil
adjacent to ANL-61
ANL-62 Sodium Boiler Building
(766) Hotwell
AN'L-63 Septic Tank 789-A
None Engineenng drawings indicate that
industrial wastes and laboratory
process wastes were discharged to '
a separate waste piping system.
The tank was filled with dirt in
1978. Therefore no source exists.
Sulfuric acid Based on water chemistry results.
and hexavaJent the hexavalent chromium was
chromium reduced to trivalent chromium and
the pH of the liquid discharged
typicaJly ranged between 4-11.
Silver Sludge samples were collected in
1986. 1990. and 1995 and analyzed
for silver.
Silver Process knowledge, review of
historical records, and drawings
indicate there was a release of
silver to the site.
Silver Soil samples were collected in
1987 and analyzed for silver.
None Process knowledge of where the
soil and debris was moved from
indicate there is no source at the
site.
PCBs Analytical results from the soil at
this site during removal of the
transformers.
PCBs Analytical results from the soil at
this site dunng removal of the
transformers.
None Process knowledge and interviews
with facility personnel indicate that
the only hazardous constituents
disposed were hydrazme and
tritium.
None Process knowledge and interviews
with facility personnel indicate that
no hazardous constituents were
disposed at the sue. Therefore no
source exists.
million gallon-.vater loss. V'.-.:i
was evaluated :n '.he OL' 9-04
RLT-S Work Plan. The Jata ii i.io
summarized m Section j. I I I of
this OL! 9-04 RJ.-TS report.
Track 1 Decision Documentation
Package I RUST Geotech
Track I Decision Documentation
Package (RUST Geotech
Track I Decision Documentation
Package (ANL-W 1995b).
Track 1 Decision Documentation
Package (ANL-W I994a).
Track I Decision Documentation
Package (RUST Geotech 19^4C i
Track I Decision Documentation
Package (ANL-W I9940).
Track 1 Decision Documentation
Package (RUST Geotech 1994d i.
Track 1 Decision Documentation
Package for ANT-61 (RUST
Geotech 1994d).
Track I Decision Documer.:at:on
Package (ANL-W ! 914^1
Track I Decision Documenu^ur.
Package (RUST Geotech
4-4
-------
Table 4-1. (continued).
OL
"-. :
3~":
S-tj
9-03
9-04
9-04
9-04
9-04
9-04
10-06*
10-06*
Site Site description
ANL-08 EbR-II Leach Pit
(Radioactive)
ANL-05 ANL Open Bum Piis * 1 .
»;. and »3
ANL-31 I.idusirial/Sanitary
Waste Lift Station
(Industrial Side Not
Used)
AN'L-34 Fuel Oil Spill by
Building 7JJ
AM. -01 Industrial Waste Pond
and Cooling Tower
Slowdown Ditches A, B.
andC)
ANL-OIA Main Cooling Tower
Slowdown Ditch
ANL -09 ANL Interceptor Canal
-Canal, and -Mound
portions
ANL-35 Industrial Waste Lift
Station Discharge Ditch
ANL-53 Cooling Tower Riser
Pits
ANL-W Windblown
Soil
ANL-W Stockpile
COCs
Radionuchces.
metais.
dioxms. and
semivolatile
organic
compounds
Metals.
radionuclides.
VOCs, PAHs.
and
dioxiris, furans
Metals and
radionuclides
Fuel Oil
(benzene/
naphthalene)
Metals.
radionuclides.
VOCs, and
herbicides
Metals.
radionuclides.
and
semivolatile
organic
compounds
Metals and
radionuclides
Metals.
radionuclides.
VOCs. and
dioxirvfurans
Metals
Radionuclides
Radionuclides
Data available
Anaivticai results rrom sludge soil
ind rasalt ar.d groundwater
samples collected .n 1991 and
1993
Site inspections, historical records.
and analytical results Lrom soil
samples collected in 19S8 and
1994
Historical operational knowledge
and analytical results of the
sampling conducted in 1995.
Modeling results based on the
estimated volume of the fuel oil
spill.
Analytical results from soil, sludge.
and water samples at the I'.VP
collected in 1986. 1987, 1988 and
1994 and analytical results from
soil samples collected at the ditches
in 1988 and 1994.
Analytical results from soil
samples collected in 1987. 1988
and 1994.
Analytical results from soil
samples collected m 1994.
.Analytical results from soil
samples were collected in 1988 and
1994 and analytical results from
water samples collected in 1988.
Analytical results from soil
samples collected m 1989.
Analytical results from RESL 1993
48 Soil Samples in 1994
Source of information
9-02 Track 2 Summary Riper
(RL'ST Geotech I994b.
Revised 9-03 Trick : Surr.mir.
Report lANT-W I99:o.
Revised 9-03 Track 2 Summary
Report (A.VL-U. I995c;
Revised 9-03 Track : Summary
Report (ANT-W I995O
Revised Preliminary Scoping
Package (ANT-W I995d
Revised Preliminary Scoping
Package (ANL-W H95e)
Revised Preliminary Scoping
Package (ANL-W 1995 fl
Revised Preliminary Scoping
Package (.ANL-W 1995g)
Preliminary Scoping Package
(ANL-W 1993).
Rl/FS for 10-06 (LMIT i995',
Rl/FS for 10-06 (LMIT !*>5>
- ANL-61 and ANL-o'l A is counted as one sue that has undergone r*o phases of cleanup.
These OU 10-06 sites have been added
for inclusion in the
9-04 RiFS
4-5
-------
This page intentionally left blank.
4-6
-------
5 SUMMARY OF SITE CHARACTERISTICS
The characteristics such as physiography, meteorology, hydrology, soils, and ecology specific to
the ANL-W site are summarized in Sections 5.1 through 5.6. These characteristics are included to help
the reader understand the specific details needed to assess the alternatives in the ROD. A complete
discussion of each of these can be found in chapter 2 of the 9-04 Comprehensive RJ/FS. Sections 5.7.3
through 5.7.13 identify the nature and extent of contamination at each of the eight areas that are retained
for cleanup.
5.1 Physiography
The SRP, is the largest continuous physiographic feature in southern Idaho. This large
topographic depression extends from the Oregon border across Idaho to Yellowstone National Park and
northwestern Wyoming. Figure 2-1 shows the location of the Snake River Plain Aquifer with respect to
the INEEL and the State of Idaho. The portion of the SRP occupied by the INEEL may be divided into
three minor physical provinces: a central trough that extends to the northeast through the INEEL and
two flanking slopes that descend to the trough, one from the mountains to the northwest and the other
from a broad ridge on the plain to the southeast.
The ANL-W facility is found in the southeastern portion of the INEEL and is responsible for a
roughly rectangular-shaped administrative area encompassing approximately 890 acres. A double
security fence with largest east-west and north-south dimensions of 580 m and 765 m (1,902 ft and 2,512
ft), respectively, surrounds the major portion of ANL-W. Located inside the fenced area are more than
60 buildings and 13 temporary trailers. Located outside the security fence are six buildings/facilities that
support the ANL-W facility. One building that support the Transient Reactor Test Facility, the three
sanitary Sewage Lagoons, the Radioactive Scrap and Waste Facility, the security forces firing range, the
parking lot, and the helicopter landing pad. Outside the perimeter of ANL-W are uhpaved roads,
groundwater monitoring wells, the interceptor canal, industrial waste pond, three old construction rubble
burn areas, and borrow excavation pits used for construction at ANL-W facilities. All ANL-W facilities
are within a local topographically closed basin. The surface of the facility slopes gradually from south to
north, at approximately 30 ft per mile. Maximum topographic relief within the ANL-W administrative
boundary is about 50 ft, ranging from 5,110 ft above mean sea level on the north boundary to 5,160 ft on
a basalt ridge to the southeast.
The Twin Buttes are the most prominent topographic features within the [NEEL and are found to
the southwest of ANL-W. East and Middle Twin Buttes rise 1,100 and 800 ft, respectively, above the
plain. Big Southern Butte, a composite acidic volcanic dome several miles south of the INEEL, is the
most prominent single feature on the entire plain, rising approximately 2,500 ft above the level of the
plain.
5.2 Meteorology
The U.S. Weather Bureau established a monitoring station at the Central Facilities Area (CFA) in
1949. A 250-ft tower is also located just outside the east security fence of the ANL-W area; however,
this tower has not been in continuous operation for as long as the CFA station. The longest and most
complete record of INEEL meteorological observations exists for the CFA weather statipn. Although
5-1
-------
meteorological conditions between the ANL-W and CFA facility are similar, the ANL-W site specific
conditions were used.
5.2.1 Air Temperature
Data have been collected from both the two- and ten-meter above the ground surface at ANL-W.
The two-meter data set is limited in time from August 1993 to the present. The record presented is
considered typical of temperature conditions in the vicinity of the ANL-W facility. Although there is a
much longer record available from the CFA station, the distance of .ANL-W from that station precludes
its use. Therefore, these data are presented here because they more accurately portray surface conditions
at ANL-W. The maximum average monthly temperature during the time of record was 84.8°F for July
and the minimum average monthly temperature of 7.9°F was recorded in December.
5.2.2 Precipitation
Precipitation is not measured at the ANL-W tower. However, the National Oceanic and
Atmospheric Administration (NOAA) conducted an evaluation and the use of CFA data for these
parameters is reasonable. Precipitation was measured as rainfall and snowfall for the period January
1950 to December 1988. During this period, most of the precipitation was received in May and June and
averaged 1.2 inches, while the annual total average was 8.71 inches. As could be expected, most
snowfall occurred during December and January. The monthly average snowfall event for December
and January was 6.4 and 6.1 inches, respectively. Wet bulb temperature humidity measurements from
CFA run from 1956 to 1961. The highest average occurred in the winter at 55%; a low average of 18%
was recorded in the summer.
5.2.3 Evaporation and Infiltration
Although NOAA does not measure pan evaporation at the INEEL, adjusted Class A values have
been made through regression analysis of other southeast Idaho sites. Data from 1950-51, 1958-59,
1963-64, and 1969-70 yielded an adjusted range of 40 to 46 inches per year. Other estimates for the
INEEL have values of 36 inches per year from saturated ground, 32 to 36 inches per year from shallow
lakes, and 6 to 9 inches per year from native vegetation. Evaporation rates calculated from the drop in
level of the ANL-W Industrial Waste Pond (IWP) yield values between 0.85 and 0.14 inches per day for
summer and winter, respectively. Infiltration as calculated by using the hydrologic equation (Equation
5.1 of Water Supply and Pollution Control, Fourth Edition) and solving for the infiltration term. This
yields values for the IWP of between 0.48 to 0.004 inches per day for summer and winter, respectiveK
5.2.4 Wind
Wind measurements at ANL-W are made at rwo and ten meters and the top of the tower (250 rt
above the ground surface). From these data, ANL-W is clearly subject to the same southwest and
northeast winds as the rest of the INEEL. Winds tend to be diurnal with up-slope winds (those out of the
southwest) occurring during the day and down-slope winds (those out of the northeast) occurring at
night. During the 5-year time of record at ANL-W from 1990 to 1994, winds blew from the southwest
14% of the lime, from the south-southwest 11% of the time, and from the northeast 10% of the time.
Winds were calm during only 2.49% of the time on record.
5-2
-------
5.2.5 Special Phenomena
A thunderstorm is defined by the National Weather Service as a day on which thunder is heard at
a given station. According to the definition, lightning, rain and/or hail are not required during this time.
Following this strict definition, the ANL-W may experience two to three thunderstorm days from June to
August. Thunderstorms have been observed during each month of the year, but only rarely from
November to February. Thunderstorms on the FNEEL tend to be less severe than in the surrounding
mountains because of the high cloud base. In many instances, precipitation from a storm will evaporate
before reaching the ground. Individual storms may, however, occasionally exceed long-term average
rain amounts for a storm.
Local thunderstorms may also be accompanied by micro bursts. These micro bursts can produce
dust storms and occasional wind damage. Thunderstorms may also be accompanied by both
cloud-to-ground and cloud-to-cloud lightning.
Major range fires in the summer of 1995 and 1996 have burned most of the natural vegetation
around the ANL-W facility. Reseeding efforts were conducted in the summer of 1996 to establish new
growth in the areas upwind of the access road to ANL-W. It is not known at this time what long-range
impacts these range fires have had with the flora and fauna around the ANL-W facility. Early
indications have shown that the wet summer of 1997 has produced abundant small grasses that may
decrease the heavy demand for food at other non-burned areas around ANL-W.
5.3 Geology
Much of the INEEL's surface is covered by Pleistocene and Holocene basalt flows. The second
most prominent geologic feature is the flood plain of the Big Lost River. Alluvial sediments of
Quaternary age occur in a band that extends across the IKEEL from the southwest to the northeast. The
alluvial deposits 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.
5.3.1 Surface Geology
Surficial materials at ANL-W facilities are found within a topographically closed basin. Low
ridges of basalt found east of the area rise as high as 100 feet above the level of the plain. Surficial
sediments cover most of the underlying basalt, except where pressure ridges form basalt outcrops.
Thickness of these Surficial sediments ranges from zero to 20 feet (Northern Engineering and Testing,
Inc. 1988).
Test borings at ANL-W have revealed two distinct layers in die surface sediments. The
uppermost layer, from zero to several feet below land surface (BLS), consists of a light brown silty loam.
The upper I to 2 feet, of this silty loam layer contains plant roots. This silty loam layer may also contain
basalt fragments in areas where it directly overlies basalt.
The lower layer is a sandy-silt (loess) that extends to the underlying basalt. The loess of this
layer was probably transported by wind from other parts of the plain. The windblown loess is calcareous
5-3
-------
and light buff to brown in color. Small discrete lenses of well-sorted sands that occur within the ioess
are probably the result of reworking by surface runoff into local depressions. The lower portion of this
loess layer often contains basalt fragments of gravel to boulder size. The surface of the underlyina
basalt, whether it is in contact with the upper or lower layer, is highly irregular, weathered, and often
very fractured.
5.3.2 Subsurface Geology
The subsurface lithology presented in this section is based on information gathered from past and
recent borings around the ANL-W facility. Information gathered from recent borings (i.e., those drilled
after 1992) have lead to a better understanding of the subsurface geology around ANL-W. The deep
geology around ANL-W is dominated by basaltic lava flows. Minor discontinuous sedimentary
interbeds occur at various depths, overlying the tops of basalt flows.
The subsurface geology at ANL-W is similar to that on the rest of the INEEL. The most striking
difference is the lack of continuous sedimentary interbeds beneath the facility. Those sedimentary
interbeds intercepted during drilling appear to be discontinuous stringers, deposited in low areas on
basalt surfaces. These interbeds are generally composed of calcareous silt, sand, or cinders. Rubble
layers between individual basalt flows are composed of sand and gravel to boulder sized material. The
interbeds range in thickness from less than 1 inch to 15 feet. In 1988, drilling near the IW? an interbed
was encountered between 40 to 50 feet BLS. This interbed is not continuous across the ANL-W area and
does not appear west of the IWP. More aerially extensive interbeds have been identified above the
regional water table, at approximately 400, 550, and 600 feet. BLS (Northern Engineering and Testing,
Inc. 1988). The depth to the SRPA below the ANL-W facility is approximately 640 feet. BLS. The
nature of these sedimentary interbeds and rubble zones does not appear to cause perching, but may retard
the downward movement of water and produce preferred flow paths.
The thickness and texture of individual basalt lava flows are quite variable. Individual basalt
flows range in thickness from 10 to 100 feet The upper surfaces of the basalt flows are often irregular
and contain many fractures and joints that may be filled with sediment. The existence of rubble zones at
variable depths and extents are shown from caliper logs of hole diameter that reveal zones of blocky or
loose basalt. Exposed fractures commonly have silt and clay infilling material. The outer portions of a
flow (both top and bottom) tend to be highly vesicular. The middle portions of the flow typically have
few vesicles and are dominated by vertical fractures formed during cooling.
The variability of basalt thickness and fracturing also plays an important role in well response to
changes in the SRPA. This effect is most notable in well responses to barometric pressure changes.
These responses to the barometric pressure changes result in groundwater elevation data that has to be
corrected for barometric-pressures in order to plot the contour of the water surface. Most of the wells at
ANL-W act as water table wells with a rapid response to barometric fluctuations. However, wells
ANL-MON-A-11 and the new well ANL-MON-A-14 are very slow to respond to barometric changes.
often taking many hours to re-equilibrate to barometric shifts. Review of the driller's log for these wells
shows that a thick, apparently massive basalt, rests just above the water table. This thick flow acts as a
confining layer and restricts free air exchange near the well bore. Discussions with the INEEL field
office of USGS suggest this is common on the INEEL and that the local area of such effects tends to be
on the order of hundreds of feet. Neither the USGS nor ANL-W believes that this effect influences the
wells' ability to intercept upgradient contaminants from the Leach Pit (ANL-08) and the Main Cooling
5-4
-------
Tower Slowdown Ditch (ANL-01A). Furthermore, placement of the well away from the immediate
downgradient edge of the source area allows for any lateral spreading of contaminants that may occur
above this dense basalt before entry into the aquifer.
The sequence of interbedded basalt and sediments, discussed above, continues to well below the
regional water table. The regional water table is typically encountered at an elevation of about 4,483 feet
above mean sea level (MSL) near the ANL-W facility. A deep corehole was drilled in 1994 in an
attempt to locate the effective base of the aquifer. This base is a layer below which the hydraulic
conductivities drop by orders of magnitude. A large sedimentary interbed (up to 100 feet thick) and a
marked change in the alteration of the basalts characterize the contact of the effective base. This contact
was encountered at a depth of 1,795 feet below land surface (BLS) in the deep corehole at ANL-W. The
sedimentary layer was approximately 15 feet thick.
5.4 Soils
The ANL-W site is located on a small meadow within a local drainage. The thickness of the
surficial sediment in the vicinity of the ANL-W site is shown in Figure 5-1. These depths range from
outcroppings at the surface to depths of 14 feet. In general, the depths of the surface soils above the
basalt tend to increase from approximately 2 feet on the east side of the facility to a depth of 14 feet near
the west side of the security fence.
The general soil types for the ANL/-W facility are shown in Figure 5-2. The two types of soils
shown in the figure for ANL-W are 425-Bondfarm-Rock outcrop-Grassy Butte complex and
432-Malm-Bondfarm-Matheson complex. As shown in the figure, the soil type 425-Bondfarm-Rock
outcrop-Grassy Butte complex is found over all the sites in OU 9-04. This soil consists of 40%
Bondfarm loamy sand, 30% rock outcrop, and 20% Grassy Butte loamy sand. The Bondfarm soil is
found on the concave and convex side slopes and is surrounded by hummocky areas of the Grassy Burte
soils. Rock outcrop is in the areas of slightly higher than areas of Bondfarm soils. Also included in this
complex are about 10% Matheson loamy sand, a soil that is similar to the Grassy butte soils but that is
less than 40 inches deep to bedrock, and Terreton loamy sand. The Bondfarm soil is shallow and well
drained. It formed from eolian material. Typically, the surface layer is light brownish gray loamy sand
about 4 inches thick. The subsoil and substratum are very pale brown sandy loam 14 inches thick.
Basalt is at a depth of 18 inches. The soil is calcareous throughout and may have a layer of lime
accumulation at depth. The permeability of the soil is moderately rapid. Effective rooting depth is 10 to
20 inches. Available water capacity is low. Surface runoff is slow or medium, and the hazard of erosion
is slight or moderate. The hazard of vegetated soil blowing is very slight.
Rock outcrop consists of exposed basalt rock. Crevices in the rock contain some soil material
that supports a sparse stand of grasses, forbs, and shrubs. While, the Grassy Butte soil is very deep and
somewhat excessively drained. It formed in sandy eolian material. The underlying material to the depth
of 60 inches or more is grayish brown and gray loamy sand. The soil is calcareous throughout and has a
layer of lime accumulation at a depth of 19 inches. The permeability of die soil is rapid. Effective
rooting depth is 60 inches or more, and the available water capacity is low or moderate. Surface runoff is
very slow or slow. The hazard of vegetated soil blowing is very high.
-------
5.5 Hydrogeology
Recharge to the SRPA in the vicinity of ANL-W occurs as snowrnelt or rain. During rapid
snowmelt in the spring, moderate recharge to the aquifer can occur. However, high evaporranspiration
rates during the summer and early fall prevents significant infiltration from rainfall during this period.
Because of the distance from the surrounding mountains and permanent surface water features (i.e.. the
Big Lost River), the SRPA beneath ANL-W is unaffected by underflow or recharge from these sources.
No permanent, natural surface water features exist near the ANL-W site. The existing surface
water features (e.g., drainage ditches and discharge ponds) were constructed for ANL-W operations for
the collection of intermittent surface runoff. A natural drainage channel has been altered to discharge to
the Industrial Waste Pond via the Interceptor Canal. Under the unusual conditions when the air
temperature has been warm enough to cause snow-melt, but the ground has rer- lined frozen, precluding
infiltration, surface runoff along this channel has discharged to the Industrial Waste Pond. This
condition most recently occurred during the spring of 1995. During this time, flow was visible from the
surrounding basin into the Industrial Waste Pond for approximately 4 days. However, at no time did any
water discharge from the pond to the downstream channel. Before 1995, the most recent occurrence of
this situation was in 1976.
Perched water is defined as a discontinuous saturated lens with unsaturated conditions existing
both above and below the lens. Classical conceptualization of a perched water body implies a large,
continuous zone of saturation capable of producing some amount of water. These perched zones can
occur over dense basalts that exhibit low hydraulic conductivity in addition to sediment interbeds that
have low permeability. It is unknown which conceptual model is more prevalent at the INEEL.
However, in the subsurface basalts at ANL-W, the "perched water" appears as small, localized zones of
saturated conditions above some interbeds and within basalt fractures, which are incapable of producing
any significant amount of water.
5.5.1 Snake River Plain Aquifer
Estimates show that nearly 2*10' acre-feet of water exist in the SRPA with water usage within
the boundaries of the INEEL being approximately 5.6 * 10' acre-feet per year. From 1979 to 1994, the
ANL-W withdrew an average of 138 million gallons of water per year from the SRPA. Principal uses of
the water are for plant cooling water operations, boiler water, and potable water. On average, 85% of the
water is discharged to either the sanitary Sewage Lagoons (ANL-04) or Industrial Waste Pond (AM.-
01), 13% is discharged to the air via cooling towers, and 2% is discharged to subsurface septic systems.
Regional flow in the SRPA is from northeast to southwest. Depth to the SRPA near the ANL- A
facility is approximately 640 feet BLS, based on 1995 water level measurements. Transmissivities or" the
SRPA range from 29,000 to 556,000 feet squared per day, based on aquifer test data from rwo production
wells at the ANL-W. Figure 5-3 shows the location of monitoring wells near the ANL-W facility,
hydraulic gradient, and the groundwater flow direction.
5.5.2 Surface Water Hydrology
Most of the [NEEL is located in a topographically closed drainage basin, commonly referred to
as the Pioneer Basin, into which the Big Lost River, Little Lost River, and Birch Creek may drain. As
5-6
-------
.'; SEWAGE //
./ DISPOSAL/// ,
///
-=^^<^,^9-A <
-'5*^£^ '^ i'~i 'T^ai
OIK Onwn: ScpicraMr 19.
i :
-------
National Laboratory-West (ANL-W) Area Soils
! Miles
Figure 5-2 Map Showing General Soil Types Ne.ir
ANL-VV
-------
LEGEND
Date Drawn: September 23. 199"
500 icoo
Figure 5-3. Location of Monitoring Wells Near ANL-W
-------
shown in Figure 2-1, these streams drain mountain watersheds to the north and west of the fNEEL.
including the Pioneer, Lost River, Lemhi, and Centennial mountain ranges. Land surface elevations rise
from 4,774 feet in the basin to 12,656 feet on Borah Peak in the Lost River Range (Bennett 1990).
Rainfall and snowmelt within the upper basin contribute to surface water, mainly during spring.
Most of the water in these streams is diverted upstream of the FNEEL for irrigation or is lost to
the subsurface due to high infiltration rates in the channel bed. During periods of high flow, some
surface water may reach the INEEL. This water is approximately 15 miles west of the ANL-W facility.
Because there are no permanent, natural surface water features near ANL-W, flooding is not a major
concern. During rapid snowmelt events at ANL-W the Interceptor Canal and the Industrial Waste Pond
receive surface water runoff. There is a diversion dam constructed south of the facility to handle these
events. This dam has a headgate that, when closed, diverts water into the adjacent drainage ditch and
eventually tu :he Interceptor Canal (ANL-09), and from there directly into the Industrial Waste Pone
(ANL-01). No surface outflow leaves the INEEL, except for minor local slope runoff.
5.6 Ecology
The [NEEL is located in a cool desert ecosystem characterized by shrub-steppe vegetation
communities typical of the northern Great Basin and Columbia Plateau Region. The surface of the
INEEL is relatively flat, with several prominent volcanic buttes and numerous basalt flows that provide
important habitat for small and large mammals, reptiles, and some raptors. Juniper woodlands occur
near the buttes and in the northwest portion of the INEEL; these woodlands provide important habitat for
raptors and large mammals. Limited riparian communities exist along intermittently flowing waters of
the Big Lost River and Birch Creek drainages.
Wildlife species present in and around ANL-W include birds, mammals, and reptiles that are
associated with facilities, sagebrush-steppe, rock outcroppings, deciduous trees and shrubs, grasslands,
and water (e.g., Industrial Waste Pond, Sewage Lagoons, and drainage ditches). Both terrestrial and
aquatic species are potentially present. Sagebrush communities surrounding ANL-W typically support a
number of species including sage grouse (Centrocerciu urophasianta), sage sparrow (Amphispiza belli},
and pronghom (Antilocapra americana). Rock outcroppings associated with these communities also
provide habitat for species such as bats, woodrats (Neotoma cinerea), and sensitive species such as the
pygmy rabbit (Brachylagus idahoensis). Nearby grasslands serve as habitat for species including the
western meadowlark (Sturnella neglecta) and mule deer (Odocoileus hemionus). ANL-W facility
structures also provide important wildlife habitat. Buildings, lawns, ornamental vegetation, and ponds
are utilized by a number of species such as waterfowl, raptors, rabbits, and bats. Lawns can be an
important resource to species at WAG 9 (the source of the water for these lawns is from the ANL-W
deep wells). No surface-hydrology has existed to support fish. Current and future aquatic invertebrates
are, however, supported by habitat provided by the Sewage Lagoons and the Industrial Waste Pond while
they are receiving wastewaters from the facility.
The WAG 9 screening-level ecological risk assessment (SLERA) has also been conducted. The
plant oxytheca (Oxytheca dendroidea) typically supports a number of species including sage grouse
which was listed as a sensitive species with the U.S. Bureau of Land Management and the Idaho Native
Plant Society/Idaho Fish and Game Conservation Data Center. Recently, the Environmental Science and
Research Foundation conducted and published a biological assessment for WAG 9, which was organized
by species groups and published.
5-13
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5.7 Nature and Extent of Contamination
The following sections describe the nature and extent of contamination for the WAG 9 sites that
were retained for evaluation in the OU 9-04 Comprehensive RIPS after completion of the Track 1 or
Track 2 evaluation, and screening against the FNEEL 95% upper confidence level (95% L'CL) of
background soil concentrations. The complete evaluation of the groundwater and the soils investigation
is found in the OL' 9-04 Comprehensive RJ/FS. Only a brief summary of each is included in this ROD.
5.7.1 Nature and Extent of Groundwater Contamination
The GWSCREEN model (Rood 1994) was selected to perform the groundwater fate and
transport calculations for contaminants at ANL-W. The model was designed to perform groundwater
pathway screening calculations for the Track I and Track 2 process. It was also an appropriate model to
use when site characterization data are lacking and little would be gained by the use of a more complex
model.
A receptor grid was overlain on the source areas such that contributions to contaminant
concentrations from all retained sites could be calculated at each receptor node. Each source area was
modeled either as surface, buried sources, or pond as described in the GWSCREEN user's manual.
Prior to modeling the groundwater exposure pathway, soil contamination data for each site was screened
to eliminate low-risk contaminants and minimize the modeling input. Two inorganics, arsenic and
chromium were retained as contaminants of potential concern. The groundwater concentrations for each
of the retained sites were determined along with the cumulative effects of the overlapping plumes for
similar contaminants from more than one release site. These groundwater concentrations for arsenic and
chromium were then used to determine the associated human health risks of using the groundwater. Of
all the potential contaminants of concern at the ANL-W facility, all of the contaminants including the
arsenic and chromium were screened as contaminants of potential concern during the risk assessment.
Thus, there is no nature and extent of groundwater contamination at ANL-W since no detrimental effects
to the groundwater have occurred or are modeled to occur at the ANL-W facility from the contaminants
identified during the evaluation of the CERCLA sites.
5.7.2 Nature and Extent of Soil Contamination
All of the 37 FFA/CO sites at WAG 9 were evaluated as part of the OU 9-04 Comprehensive
RI/FS. The site screening was conducted using a four step process. The first .step was to review all the
information on a particular site to make sure no contaminant was overlooked. The second step was to
identify any new sites or unevaluated sites. The third step was to eliminate sites that were found to be
No Action based on the results of either the Track I or Track 2 assessment. The fourth step was to
eliminate sites that had no source (i.e., no contaminants above 95% UCL of INEEL background). The
result of the screening process resulted in thirty sites being screened from the detailed risk assessment
process. The seven sites that were retained are: the Sanitary Sewage Lagoons (ANL-04), the EfiR-lI
Leach Pit (ANL-08), the Industrial Waste Pond and Ditches A, B. and C (ANL-Ol), the Main Cooling
Tower Slowdown Ditch (ANL-Ol A), the Interceptor Canal (ANL-09), the Industrial Waste Discharge
Ditch (ANL-35), and the Main Cooling Tower Riser Pits (ANL-53).
Two of these seven WAG 9 sites were subdivided into smaller areas to facilitate a more accurate
risk assessment based on actual physical characteristics, and water discharge rates. These two sites are
5-14
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the Interceptor Canal and the Industrial Waste Pond and Ditches A, B, and C. The Interceptor Canal was
divided into two areas, the Interceptor Canal-Canal and -Mound areas. While the Industrial Waste Pond
and associated Ditches A, B, and C has been subdivided into four areas the Industrial Waste Pond, Ditch
A, Ditch B, and Ditch C. Thus, eleven areas were evaluated in the OU 9-04 Comprehensive RI/FS. The
nature and extent of contamination in these eleven areas is described in sections 5.7.2.1 through 5.7.2.11
These eleven sites that were retained for evaluation in the OU 9-04 Comrehensive RI/FS are shown in
Figure 5-4.
Appendix A of the Operable Unit 9-04 Comprehensive RI/FS contains all of the sampling
information on these sites including: sample location maps, color concentration profiles, contaminant of
concern statistics including sample size, mean, maximum, and 95% upper confidence limit (L'CL)
concentrations. Table 5-1. shows a summary of the FFA/CO site, the subarea, extent of contamination,
contaminant of potential concern (COPC), and 95% UCL for the COPC for the eleven sites that were
retained for evaluation in the OU 9-04 Comprehensive RI/FS.
Table 5-1. Extent of Contamination Soil in WAG 9 Sites Retained for Cleanup.
FFA/CO
Site Area Name
ANL-Ol Industrial Waste Pond
Width
(ft)
200
Length
(ft)
250
Depth
(ft)
0.5
COPC
Cs-137
Cr+3
Hg
Se
Zn
Cone.
(rag/kg or
pci/g)
292
10,260
; 2.62
8.41
5012
ANL-Ol Ditch A 5 400 0.5
ANL-Ol Ditch B 5 1,400 1.3
ANL-Ol Ditch C 5 500 2.5
ANL-OIA Main Cooling Tower Slowdown Ditch 6 700 2
ANL-04 Sewage Lagoons 300 700 1
ANL-08 EBR-U Leach Pit
ANL-09 Interceptor Canal-Canal 30 1,425 6
ANL-09 Interceptor Canal-Mound 20 500 4
ANL-35 Industrial Waste Lift Station Discharge Ditch 4 500 I
ANL-53 Main Cooling Tower Riser Pits 6 10 1.5
Hg
Cr+3
Zn
Hg
Cr~3
Hg
Hg
Cs-137
Cs-137
Ag
As
Cr-3
Pb
Hg
3.94
1.170
3.020
0.29
"09
3 S3
IS
305!
-6
5-15
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5.7.2.1 Industrial Waste Pond
The Industrial Waste Pond (ANL-Ol) is an unlined, approximately 1.2-ha (3-acre) evaporative
seepage pond fed by the Interceptor Canal and site drainage ditches. The pond was excavated in 1959,
obtained a maximum water depth of about 4 m (13 ft) in 1988, and is still in use today. During this time.
the Cooling Tower Slowdown ditches have been rerouted several times. ANL-W auxiliary cooling
tower blowdown ditches convey industrial wastewater from the EBR-II Power Plant and the Fire Station
(Bldgs. 768 and 759) to the Industrial Waste Pond. The Industrial Waste Pond was originally included
with the Main Cooling Tower Slowdown Ditch (ANL-Ol A) as a Land Disposal Unit under the RCRA
Consent Order and Compliance Agreement on the basis of potentially corrosive liquid wastes discharged
with the cooling tower effluent. However, ANL-W conducted a field demonstration with the EPA and
State of Idaho representatives in attendance in July 1988 that showed that any potentially corrosive
wastes discharged to the Industrial Waste Pond were naturally neutralized in the Main Cooling To\ver
Slowdown Ditch before reaching the Industrial Waste Pond. On that basis, EPA removed the Industrial
Waste Pond as a Land Disposal Unit and re-designated it as a Solid Waste Management Unit. Therefore.
this site is still under the regulatory authority of RCRA in addition to being on the FFAVCO and under the
regulatory authority of CERCLA.
DOE anticipates that the Industrial Waste Pond will continue to be used for storm water disposal
as well as future releases of liquid cooling water discharges from the Sodium Process Facility. The
Sodium Process Facility cooling water discharges will average 100 gallons per minute and are
anticipated to last for three years starting in the spring of 1998 and lasting until summer of 2002. These
cooling water releases will be discharged to the surface drainage ditch on the North side of ANL-W and
drain approximately 250 ft. west to the Industrial Waste Pond. The Sodium Process Facility is a
permitted HWMA/RCRA facility and is scheduled for clean closure under RCRA. .
Appendix A of the OU 9-04 Comprehensive Rl/FS shows the sampling location plan map and
the statistics for contaminant of concern (COC) by pathway for all samples collected from the Industrial
Waste Pond. Soil and sediment samples were collected from the Industrial Waste Pond as part of four
different investigations occurring from 1986 to 1994. Cesium-137 was retained as a COPC for humans
while, four inorganic contaminants were retained as COPCs for the ecological receptors.
The cesium-137 and the four inorganics (trivalent chromium, mercury, selenium, and zinc) were
present in the southern and eastern part of the Industrial Waste Pond with concentrations typically
greatest for surface samples near the inlet pipe in the southern part of the Industrial Waste Pond .
Samples were screened against the 95% UCL concentrations for grab samples at the INEEL and will be
referred to as 95% UCL background. The highest number of metals above the 95% UCL background
concentration were collected from location #101 with 11 metals exceeding background, then location 3
97 with ten metals exceeding the 95% UCL background concentration. The maximum cesium-137
concentration was 57.91 pCi/g, while the 95% UCL concentration was 29.2 pCi/g. For the trivalent
chromium, mercury, selenium, and zinc the maximum concentrations were 11,400, 6.8, 37.9, and 5,850
5-16
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SEWAGE
LAGOONS
(ANL-04)
INDUSTRIAL
WASTE POND
(ANL-01)
MAIN COOLING TOWER
SLOWDOWN DITCH (ANL-01 A)
DITCH A
(ANL-01)
= INDUSTRIAL WASTE LIFT STATION
DISCHARGE DITCH (ANL-351
COOLING TOWER
RISER PITS
(ANL-53)
INTERCEPTOR
CANAL-MOUND
(ANL-09)
DITCH C
(ANL-01)
INTERCEPTOR
CANAL-CANAL
(ANL-09)
DITCH "B
(ANL-01)
EBR
LEACH PIT
(ANL-08)
Figure 5-4. Eleven Areas Retained for Evaluation in Rl IS
S-iQ-»8
5-17
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mg/kg and the UCL values were 1,30, 2.62, 8.41, and 8.41 mg/kg, respectively. Therefore, the horizontal
extent of contamination is the dimensions of both the southern and eastern part of the Industrial Waste
Pond 200 feet wide and 250 feet long. While, the vertical extent of contamination is in the upper 0.5 feet
of sediments in the Industrial Waste Pond.
5.7.2.2 Ditch A
Ditch A conveyed industrial wastewater from the EBR-II Power Plant auxiliary cooling tower to
the Industrial Waste Pond. Ditch A is still being used today to transport storm water runoff as well as
intermittent auxiliary cooling tower waters. Discharges to Ditch A flow into the Main Cooling Tower
Slowdown Ditch and ultimately into the Industrial Waste Pond.
Soil samples were collected from Ditch A as part of two different investigations. These studies
are the Chen Northern in 1988 and the 1994 ANL-W study. Appendix A of the OU 9-04 Comprehensive
RI/FS shows the sampling location plan map, color intensity profile maps, and statistics for COC by
pathway. In the 1988 Chen Northern study, eight soil samples were collected from three locations in the
western part of the ditch. In the 1994 ANL-W study, 30 soil samples were collected from 11 locations
throughout the entire length of the ditch.
Mercury was retained as a COPC for ecological receptors and was detected in 74% (27/38) of the
samples analyzed. All of the mercury detections exceeded the upper limit of the 95% UCL background
concentration (0.074 mg/kg). The source of the mercury is most likely from mercuric chloride used as a
wood preservative in the cooling tower or from a neutron absorber in the power plant which is being
decommissioned. The maximum detected concentration of 4.1 mg/kg was detected at location #IOW in
the surface sample (0 to 6 inches). While, the UCL concentration for mercury in Ditch A was 3.94
mg/kg. In all but one instance, the surface samples at each location contained the highest concentrations
of mercury with the exception of #26E. The mercury contamination in Ditch A is spread through the
entire length with the highest concentrations near the intersection of the Main Cooling Tower Slowdown
Ditch and Ditch A. The mercury concentrations also decrease with increasing depth with the highest
concentrations in the surface 0 to 6 inch samples. Therefore, the extent of contamination is the
dimensions of both the eastern and western part of Ditch A 5 feet wide and 400 feet long and the vertical
extent contained to the surface soils 0 to 6 inches.
5.7.2.3 Ditch B
Ditch B was also used to transport storm water runoff as well as wastewater from the EBR-U
Power Plant and the Fire Station (Bldgs. 768 and 759) to the Industrial Waste Pond. Only a small 125
feet portion of Ditch B is still being used today since the majority 1,275 feet of Ditch B was backfilled
with clean soil to grade approximately 5-feet during the installation of a secondary security fence.
Soil samples were collected from Ditch B as part of three different investigations. Six soil
samples were collected from the 1988 DOE study, 15 samples collected from the 1988 Chen-Northern
study, and 10 samples in the 1994 ANL-W study. Appendix A of the OU 9-04 Comprehensive RJ/FS
shows the sampling location plan map, color intensity profile maps, and statistics for COC by pathway
for the 1994 samples collected from Ditch B. The contaminant screening resulted in COPCs for humans
and only two inorganics being retained as COPCs for the ecological receptors. These two inorganics are
trivalent chromium and zinc. The extent of the inorganic contaminants are discussed belo*.
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The contaminants in the covered portion of Ditch B have been screened from the risk assessment
since the pathway was eliminated when the area was backfilled with clean soils. The open portion of
Ditch B has chromium and zinc at concentrations that could pose unacceptable human and ecological
risks. The maximum concentration of trivalent chromium and zinc are 4,530 and 3,020 mg/kg and the
UCL concentrations are 1,306 and 1,460 me/kg, respectively. The extent of the inorganic contaminants
span the entire length of the open portion of Ditch B is 5 feet wide and 125 feet long. No stratification of
inorganics was determined from the results in that portion of Ditch B and thus the total depth of the
alluvium to the basalt of 0 to 1.3 feet is used to define the extent of contamination.
5.7.2.4 Ditch C
The Ditch C portion of the Industrial Waste Pond and associated ditches (ANL-01) \vas created
in 1978 when a portion of Ditch B was backfilled. The water in Ditch C is the same as that in Ditch B
mentioned in previous section. The discharge water going to Ditch B is rerouted via culvert under the
security fence to Ditch C which drains to the Main Cooling Tower Slowdown Ditch and ultimately the
Industrial Waste Pond. Ditch C is dimensions are approximately 5 x 500 x 2.5 feet deep. The
contaminant screening resulted in mercury being retained as a COPC for the ecological receptors. The
maximum mercury concentration was 0.83 mg/kg and the 95% UCL concentration was determined to be
0.29 mg/kg. The extent of the contamination was spread throughout the entire length of the ditch (5 x
500 feet) and the vertical extent of contamination was 2.5 feet deep.
5.7.2.5 Main Cooling Tower Slowdown Ditch
The Main Cooling Tower Slowdown Ditch (ANL-01 A) runs north on the westside of the Main
Cooling Tower and then north between the security fences to the Industrial Waste Pond. It is an unlined
channel approximately 700 feet in length and 3 to 15 feet wide. From 1962 to 1996, the ditch had been
utilized to convey industrial wastewater from the Cooling Tower to the Industrial Waste Pond. The main
source of impurities to the Industrial Waste Pond were water treatment chemicals used for the
regeneration of backwash waters from the ion exchange resin beds and remove minerals from cooling
tower water used in the EBR-II steam system. From 1962 to July 1980, a chromate-based corrosion
inhibitor was added to the Cooling Tower water and the blowdown contained significant quantities of
hexavalent chromium. Ion exchange column regeneration discharges have occurred from 1962 to March
1986. Regeneration of these column is accomplished with sulfuric acid for cation columns and sodium
hydroxide for anion columns.
In January 1986, a pH measurement of 1.86 was measured in the effluent discharged to the Main
Cooling Tower Blowdown Ditch. This classified the liquid wastes as corrosive according to 40 CFR
261.22. The site was then classified as a Land Disposal Unit under RCRA. A temporary neutralization
system was installed in March, and a permanent neutralization tank was installed in October 1986. A
few discharges of regeneration water occurred, but they were in small batches and were'monitored before
discharge. Since October 1986, after the neutralization tank was installed, reagents are being neutralized
in a tank prior to discharge to the ditch. DOE, along with EPA and IDHW WAG 9 managers, have
determined that the Main Cooling Tower Blowdown Ditch is a RCRA Land Disposal Unit and will be
remediated under the CERCLA process in accordance with the applicable substantive requirements of
RCRA/Hazardous Waste Management Act (HWMA), if an unacceptable risk to human health or the
environment. However, the FFA/CO has only adopted RCRA corrective action (3004 (u) & (v)), and not
RCRA/HWMA closure. Therefor, upon completion of the remedial action, the DOE must receive
5-:o
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approval from the IDHW Department of Environmental Quality director that the Main Cooling Tower
Slowdown Ditch has been closed pursuant to RCRA/HWMA closure requirements.
Appendix A of the OU 9-04 Comprehensive RJ/7S shows the sampling location plan map, color
intensity profile maps, and statistics for COC by pathway for samples collected from the Main Cooling
Tower Slowdown Ditch. Soil samples were collected from the Main Cooling Tower Slowdown Ditch as
pan of four different investigations occurring from 1987 to 1994. In 1987, one soil sample (EST-SED)
was collected from the northern part of the ditch where a storm water discharge ditch flows into it. In
1988, four soil samples were collected from the different parts of the ditch. Three soil samples were
collected from the west part of the ditch (C103B-S, C100B-S.D, and C73A-S), one sample was collected
in the eastern portion of the ditch at the discharge point (B6B-S.D). In 1989, two soil samples (M-8 and
M-10) were collected in the 145-foot interbed along the western portion of the ditch. Finally, in 1994, 35
samples were collected along the entire length of the ditch. The contaminant screening resulted in r.vo
inorganics; trivalent chromium and mercury at levels high enough be retained as a COPC for the
ecological receptors.
Chromium concentrations were the highest in the outfall from the Cooling Tower. But, the
entire length of the Main Cooling Tower Slowdown Ditch has concentrations of chromium above the
95% UCL background concentration levels for the INEEL surface soils. The analysis performed on the
chromium was for the total chromium analysis. The chromium was release was almost exclusively in the
trivalent form rather than the more toxic hexavalent form. But, to be conservative, DOE assumed that
ten percent of the total chromium would be in the more toxic hexavalent form. The chromium
concentrations almost exclusively decreased with increasing depth, and also decreased with increasing
distance downstream of the cooling tower outfall. The maximum chromium concentration was 2,200
mg/kg and the UCL concentration was 1,306 mg/kg for the Main Cooling Tower Slowdown Ditch.
Forty-eight percent (22746) of the mercury concentrations exceeded the upper limit of the 95%
UCL background concentration (0.074 mg/kg) ranging from 0.08-13.4 mg/kg. The highest detected
concentration was from the surface sample at location 9E. Mercury concentrations were highest in the
eastern part of the ditch and typically decreased to less than one mg/kg in the subsurface samples except
for one location. At location 1 IE, mercury concentrations were 2.8 mg/kg in the surface and 2.3 mg/kg
in the subsurface sample. The maximum mercury concentration was 13.4 mg/kg and the UCL
concentration was 8.83 mg/kg for the surface soils in the Main Cooling Tower Slowdown Ditch.
The extent of the contamination is mainly concentrated in the southern portion of the ditch near
the cooling tower outfall. However, there are some concentrations greater than the upper limit of the
95% UCL background concentration for some metals in the northwestern part of the ditch. Therefore,
the horizontal extent of contamination is the dimensions of both the eastern and western part of the Main
Cooling Tower Slowdown Ditch 3 to 15 feet wide and 700 feet long. Because the width of the ditch
varies from 3 to 15 feet, an average width of 6 feet will be used. The majority of the inorganic
contaminants were concentrated in the top 6 inches of soils. However, some detections greater than the
upper limit of the 95% UCL background concentration were made in some subsurface samples.
Therefore, the vertical extent of contamination is assumed to be one-half the average depth to basalt 2
feet.
5-21
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5.7.2.6 Sewage Lagoons
The sanitary Sewage Lagoons (ANL-04) are located at the Sanitary Sewage Treatment Facility.
north of the ANL-W facility. Two lagoons were constructed in 1965, with a third built later in 1974.
According to engineering drawings, the three sanitary sewage lagoons cover approximately two acres.
Appendix B shows a figure of the three lagoons with dimensions of; (1) 150 * 150 * 7 feet, (2) 50 * !00
* 1 feet, and (3) 125 * 400 * 7 feet. The lagoons receive all sanitary waste waters originating at
ANL-W, with the exception of the Transient Reactor Test Facility, Sodium Process Facility, and the
Sodium Components Maintenance Shop. Sanitary waste discharged is from rest rooms, change facilities.
drinking fountains, and the Cafeteria. The three lagoon bottoms are sealed with a 0.125 to 0.25-inch
layer of bentonite and are situated approximately 640 feet above the groundwater. The Sewage Lagoons
are still in use and will continue to be used for disposal of sanitary wastes for the next 35 years.
Between 1975 and 1981, photo processing solutions were discharged trom the Fuel Assembly
and Storage Building to the Sanitary Waste Lift Station, which discharges to the Sewage Lagoons. There
has been no known radioactive or hazardous substances released into the Sewage Lagoons. Periodic
sampling of the Sewage Lagoon and the radionuclide detector placed in the lift station (Sanitary Waste
Lift Station-788) supplying the Sewage Lagoons document that no radioactive substances have been
released.
The results of the contaminant screening indicated that one contaminant, mercury, should be
retained as a COPC for the ecological receptors. The mercury concentrations were detected throughout
all of the sludge 0 to 6 inch samples in the Sanitary Lagoons. The maximum mercury concentration in
the Sewage Lagoons was 3.2 mg/kg and this value was used in place of the UCL concentration because
of the small data set (eight samples).
5.7.2.7 EBR-II Leach Pit
The EBR-II Leach Pit is located between the inner and outer security fences in the southwest
comer of the ANL-W facility. The Leach Pit was an irregularly shaped, unlined underground basin that
was excavated with explosives into basalt bedrock in 1959. The Leach Pit was used to dispose of
ANL-W liquid industrial waste including cooling tower blowdown, sanitary effluent, cooling
condensates, and radioactive effluent, until 1973. The average annual discharge to the Leach Pit was
approximately 9 * 104 gallons from 1960 to October 1973 containing a total of 10.4 curies of
radioactivity. The majority of the sludge was removed during an interim action in December 1993, after
which the bottom of the Leach Pit was lined with 5 to 7 cm (2 to 3 in.) of bentonite clay and backfilled to
grade. The contaminant screening resulted in various radionuclides being retained for evaluation of the
groundwater pathways for the human health risk assessment and no COPCs being retained for the
ecological receptors.
The extent of the radionuclide contamination was the physical dimensions of the EBR-II Leach
Pit since it was blasted into the basalt. The extent of the EBR-II Leach Pit is 18 x 40 x O.I feet since the
sludge was removed in 1993 and no horizontal or vertical migration has been detected in coring and
drilling activities around and through the Leach Pit. The predominant radionuclides retained are cesium-
137, strontium-90, cobalt-60, and uranium-238.
5-22
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5.7.2.8 Interceptor Canal-Canal
The canal portion was utilized to transport industrial waste to the Industrial Waste Pond and to
divert spring runoff and other natural waters around the AN'L-W facility for flood control. Berween 1962
and 1975, two 4-in. pipes transported liquid industrial wastes and cooling tower effluent, to the
Interceptor Canal. One line transported cooling tower blow-down water and regeneration effluent while
the other line originated at the Industrial Waste Lift Station (Bldg. 760) and transported industrial wastes.
Liquid radioactive wastes were discharged through the same line as the industrial wastes, but they were
diverted to the EBR-II Leach Pit. Discharge of industrial wastes was discontinued in 1973, and
discharge of cooling tower blowdown water was discontinued in 1975.
During clean out operations at the Interceptor Canal in October 1969, abnormal background
radioactivity was detected. Additional radiation surveys in 1969, 1973. and 1975 indicated that the entire
length of the Interceptor Canal was contaminated. Approximately 4,540 yd3 of contaminated soil was
identified and only 1,240 ydj was targeted for removal. Of this soil that was removed, approximate^
182 ydj was disposed at the RWMC from 1975 to 1976, and remaining 1,058 yd1 of contaminated soil
was removed and stockpiled on site (this stockpiled soil was evaluated as part of the OU 10-06). The
remaining soil, 3,300 yd3 was left in the ANL-09-Mound and was investigated as part of the RJ/FS
process. Another survey conducted in 1993 indicated that two small areas had elevated readings above
background.
The contaminant screening resulted in only cesium-137 being retained as a COPC for humans
and no COPCs for the ecological receptors. The 95% UCL concentration for cesium-137 is 18 pCi/g and
is fairly uniform throughout the entire length of the ditch. Thus, the extent of contamination is 30 x
1,425x6 feet.
5.7.2.9 Interceptor Canal-Mound
This section summarizes the analytical results for soil samples collected at the Interceptor Canal-
Mound (ANL-09) area. The Interceptor Canal-Mound was formed when 1,384 m1 (1,810 yd1) of dredged
material was placed on the bank of the Interceptor Canal. Soil samples from the Interceptor Canal
Mound were only analyzed for radionuclides. Inorganic releases to the Interceptor Canal-Canal occurred
after the canal was dredged and therefore would not be in the dredged piles. Surface soil samples 0 to 6
inches and a subsurface soil sample approximately 3 to 4 feet were collected at the ANL-09-Mound area.
In addition, another subsurface soil sample was collected from approximately 5 to 6 feet at three sample
locations (#356, #368, and #378). Subsurface soil samples were collected at a depth that corresponds to
the bottom of the mound. The deeper subsurface samples were collected to determine if migration of
contaminants has occurred. The contaminant screening resulted in only one radionuclide (cesium-13")
being retained as a COPC for humans and no COPCs for ecological receptors.
The cesium-137 was detected at every sample location throughout the mound, with the highest
detected concentration (52 pCi/g) at location Ml9. While the t'CL concentration for the cesium-137 was
30.53 pCi/g. Therefore, the horizontal extent of the cesium-137 is defined as the entire length of the
mound 500 * 20 feet. For the vertical extent of the cesium-137 contamination, there is a significant
decrease in concentrations (approximately one order of magnitude) between the surface and subsurface
samples. The maximum detected C-137 concentration in the subsurface sample was only 5.9 pCi/g.
5-23
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Nevertheless, as this concentration is above the established background, the vertical extent of
contamination will be 4 feet.
5.7.2.10 Industrial Waste Discharge Ditch
The Industrial Waste Lift Station Discharge Ditch (ANL-35), also known as the North Ditch, is
located inside the ANL-W security fences. The ditch is approximately 500 feet in length with a bottom
width of 3 to 4 feet. At any one time, there is approximately 2 to 3 inches of water in the ditch. The
ditch receives industrial waste water, primarily cooling water and photo processing wastes (e.g., photo
developers, fixers, and stabilizers, and acids), but also including several retention tank overflows that
may contain ethanol, sodium hydroxide, and some radionuclides, from a variety of facilities at ANL-VV.
The ongoing and future discharges of these processing wastes are regulated under other EPA laws such as
RCRA. The cleanup action specified in this ROD address only those past releases of these processing
wastes.
Soil samples were collected from this site on three separate occasions. Three soil samples were
collected during the 1989, DOE Survey, 17 soil samples were collected during the 1988 Chen Norther
sampling, and an additional 19 soil samples were collected in 1994 by ANL-W. Soil samples from all
three sampling efforts were collected and analyzed for organics, inorganics, radionuclides, and
dioxin/furans. Appendix A of the OU 9-04 Comprehensive Ri/FS shows the sampling location plan
map, color intensity profile maps, and statistics for COC by pathway for all samples collected in 1994
from the Industrial Waste Lift Station Discharge Ditch. Sample collection depths for the 1994 study
were 0 to 6 inches and 1.5 to 2 feet.
The results of the contaminant screening resulted in no COPCs for human and only one
inorganic, silver being retained as a COPC for the ecological receptors. Silver was analyzed for in all
three studies and was detected at 87% (33 of 39) of the sample locations with the highest detection (352
mg/kg) at #41. This sample location is located in the middle of the ditch. The maximum concentration
was used in risk assessment as the UCL value because of the small data set and large standard deviation
in the data. However, high concentrations were also detected at other locations grid 18, ND03, 15, 18,
and 19. Therefore, the horizontal extent of contamination is defined as the entire length of the ditch. No
trends on the vertical extent of contamination were detected for silver. Thus, the average soil depth on
top of the basalt 1.0 foot was used to define the vertical extent of contamination. Thus, the extent of
contamination at the Industrial Waste Lift Station Discharge Ditch is defined as 15 * 500 * 1 foot.
5.7.2.11 Main Cooling Tower Riser Pits
The Cooling Tower Riser Pits consist of four pits located approximately 10 feet east of the Mam
Cooling Tower. Each of the four pits is approximately 12 feet deep with 9 to 15 inches of soil covering
the rock bottom. During winter shutdown periods of the \fain Cooling Tower, the riser pipes were
drained to prevent damage caused by freezing and the riser pits are used to collect this discharge. The
contaminant screening indicated that four inorganics be retained as COPCs for human health risk
assessment. The four inorganics are arsenic, divalent chromium, lead, and mercury. The maximum
concentrations of each of these inorganics are 76, 1,717, 4,725, and 0.78 mg/kg, respectively. The extent
of contamination is the entire inside dimension of each of the riser pits and the total depth of soil above
the basalt (i.e., 6 x 10 x 1.5 feet).
5-24
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5.8 No Action Sites
Based on the process used to conduct the OU 9-04 Comprehensive RI/FS, these sites uere
screened from the risk assessment. The screening process included review of the previous information.
review of the risks presented in either a Track I or Track 2 type document, and evaluation of the
contaminant source, and pathway to a receptor. These sites are considered to be no action sites even
under an unrestricted land use scenario and hence will not require 5 year reviews. These sites are
described in short detail below, additional details on these sites can be found in the OU 9-04
Comprehensive RI/FS.
5.8.1 Operable Unit 9-01 Sites
This OU consists often sites (ANL-04, -019, -28, -29, -30, -36, -60, -61", -62, and -63) that <.vere
identified in the FFA/CO. These ten sites consisted predominantly of low hazard miscellaneous sites
with small discharges or construction wastes. Of the ten OU 9-01 sites, only two sites (ANL-04 and -61 i
were retained for further evaluation in the OU 9-04 Comprehensive RI/FS. The OU 9-04 Comprehensis e
RI/FS indicates that only ANL-04, the ANL-W sewage lagoons, pose unacceptable risks to the
environment as discussed earlier in this ROD. A brief history of the other nine OU 9-01 sites that do not
pose unacceptable risk follows:
Sludge Pit West of T-7 (Imhoff Tank) (ANL-19)The Imhoff Tank and sludge pit collected
sanitary waste from the power plant (Bldg. 768), the Fuel Conditioning Facility (Bldg. 765), the
Laboratory and Office building (Bldg. 752), and the Fire House (Bldg. 759). The Imhoff Tank was used
to settle out the sanitary wastes from 1963 to 1966. No potential source -of hazardous materials is known
to be associated with this site.
EBR-II Sump (ANL-28)The EBR-II Sump is a 660-gallons underground coated carbon steel tank,
5 feet in diameter by 4.5 feet in depth located off the southwest comer of the Power Plant (Bldg. 768)
The Sump is believed to have been installed in the early 1970s and is currently in use. The tarik is a
centralized collection facility for auxiliary cooling tower blowdown, ion exchange regeneration effluent.
and small quantities of laboratory chemicals from the water chemistry laboratory in the Power Plant
before discharging via a pipe to the Main Cooling Tower Slowdown Ditch. Currently, the Power Plant :s
not operating, but minor volumes of water chemistry water are still being discharged to the Main Cooling
Tower Blowdown Ditch. No potential source of hazardous materials is known to be associated with this
site.
Industrial Waste Lift Station (ANL-29)The Industrial Waste Lift Station receives wastes from
three major facilities; the Lab and Office (Bldg. 752), the Zero Power Physics Reactor (Bldg. 774), and
the Fuel Manufacturing Facility (Bldg. 704). The only contaminant of potential concern identified from
process knowledge of water released to the Industrial Waste Lift Station is silver. A Track 1
investigation was originally performed for this site and. based on the above information, it was
determined that the potential health risks are less than the lower limit of the NCP target risk range.
Sanitary Waste Lift Station (ANL-30)The Sanitary Waste Lift Station (Bldg. 778) was built in
1965. It receives all sanitary waste originating at ANL-W, with the exception of the Transient Reactor
Test F?-Ji**^s (Bldgs. 720, 721, 722, 724, and T-15), the Sodium Process Facility operations trailer, and
the Sodium Components Maintenance Shop (Bldg. 793). The only waste discharged to the lift station
5-25
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was silver from photographic film development. The maximum detected silver concentration of 63
mg/kg was less than the cleanup goal across all exposure pathways of 1,350 nig/kg.
TREAT Photo Processing Discharge Ditch (ANL-36)The Transient Reactor Test Photo
Processing Discharge Ditch is located approximately 20 feet northeast of and parallel to the Photo Lab
(Bldg. 724) and the TREAT Office Building (Bldg. 721). Approximately 400 gallons of photo
processing solutions are estimated to have been discharged to the ditch over the 2-year period from 1977
to 1979. The maximum detected silver concentration of 17 mg/kg was less than the cleanup goal across
all exposure pathways.
Knawa Butte (ANL-60)The Knawa Butte is located due north of the Hot Fuel Examination Facility
(Bldg. 785) near the security fence. The butte was used as a construction refuse pile until September
1972 when a service request was made to renovate the existing pile and convert it to a doughnut-shaped
mound. The butte consists primarily of clean soil and rock excavated from ANL-W facility basement
construction. No potential source of hazardous constituents is known to be associated with this site.
EBR-II Transformer Yard (ANL-61)The EBR-II Transformer Yard located south of the EBR-II
Power Plant (Bldg. 768) is the site of PCB and diesel fuel contamination. The PCB contamination is due
to historic (i.e., prior to 1978) leakage from four transformers. All four transformers were replaced and
the majority of the contaminated soil was removed during a cleanup action from 1988 through 1992. An
additional area of PCB contaminated soil adjacent to an underground diesel storage tank was identified
for removal. The PCB contaminated soil and underground diesel storage tank were removed in the
summer of 1997. Verification samples were collected after removal and show that the remaining PCB
contamination was remediated to the cleanup goal levels
Sodium Boiler Building Hotwell (ANL-62)The Sodium Boiler Building (Bldg. 766) condensate
hotwell, was built in 1962, and is located north of the EBR-II Power Plant (Bldg. 768). This hotwell,
which is identical to the EBR-II Power Plant condensate hotwell, receives water from the steam trap and
condensate drains. Neither hazardous constituents (hydrazine and tritium) believed to have been present
at the site were detected.
Septic Tank 789-A (ANL-63)This septic tank is located approximately 60 feet northeast of the
Equipment Building (Bldg. 789-A) and was believed to have been installed in the (ate 1950s. No
potential source of hazardous materials is known to be associated with this site.
5.8.2 Operable Unit 9-02 Site
OU 9-02 consists of one site (ANL-08, EBR-II Leach Pit) identified in the FFA/CO. The EBR-II
Leach Pit is located between the inner and outer security fences in the southwest corner of the ANL-W
facility. The Leach Pit was an irregularly shaped, unlined underground basin that was excavated with
explosives into basalt bedrock in 1959. The Leach Pit was used to dispose of ANL-W liquid industrial
waste including cooling tower blowdown, sanitary effluent, cooling condensates, and radioactive
effluent, until 1973. The average annual discharge to the Leach Pit was approximately 9*10* gallons
from 1960 to October 1973 containing a total of 10.4 curies of radioactivity. The majority of the sludge
was removed during an interim action in December 1993. after which the bottom of the Leach Pit was
lined with 2 to 3 inches of bentonite clay and backfilled to grade. A risk assessment performed on the
concentration of the contaminants in the basalt and in the remaining sludge indicates that the total
5-26
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potential risk is 6E-06 from ingestion of groundwater contaminated with beryllium and neprunium-23 ".
which is at the lower limit of the NCP target risk range (i.e., IE-06). A Track 2 Summary Report was
completed and signed by the RPMs that recommended additional evaluation of the vadose zone below
the Leach Pit in the OU 9-04 Comprehensive RI/FS.
5.8.3 Operable Unit 9-03 Sites
OU 9-03 consists of three sites (ANL-05, -31, and -34) that were identified in the FFA-CO.
These three sites had all received potentially hazardous chemicals that required additional sampling in
order to determine the risks to human health and the environment. Of the three OU 9-03 sites, all three
are recommended for No Action based on results in the Track 2 Summary Report.
ANL Open Burn Pits 1, 2, and 3 (ANL-05)Three abandoned open bum pits are located at
ANL-W. The pits were initially used to burn construction wastes, such as paper and wood in the early
I960's. In addition, approximately 150 gallons of organic wastes from analytical chemistry operations
were disposed in the burn pits from 1965 to 1970. The organic wastes consisted primarily of toluene,
xylene, hexane, isopropyl alcohol, butyl cellosolve, tributylphosphate, and mineral oil. A risk
assessment was performed on the results of sampling and indicates that the potential risk from exposure
to all contaminants detected is less than the lower limit of the NCP target risk range.
Industrial/Sanitary Waste Lift Station (ANL-31)The Industrial/Sanitary Waste Lift Station
(Bldg. 760) consists of an industrial and a sanitary lift station separated by a similar sump wall. The
sanitary side is still used to pump sanitary wastes to the Sanitary Lagoons while the industrial side is
inactive and has been backfilled with clean sand. Based on samples collected in the industrial side in
1995, the risk assessment indicated that several radionuclides pose a potential risk at the lower limit of
the NCP target risk range for the current occupational scenario. Therefore in 1995, under a best
management practice, ANL-W backfilled the industrial waste side with clean sand to remove the
exposure route and removed the piping and contaminated soil from the Lift Station to the Meter House.
Also under a best management practice the remaining 90 feet of the piping and soil from the Meter
House to the EBR-II Leach Pit was removed in the summer of 1996. After the removals the verification
samples collected showed that the remaining contaminants were below the cleanup goal concentrations.
Fuel OU Spill by Building 755 (ANL-34)ANL-34 is the site of a 50-gal spill of #5 fuel oil from an
above ground storage tank. The spilled fuel oil occupied an area approximately 5 x 20 feet and was
confined within the bermed area. A risk assessment was performed on the most mobile
(i.e., naphthalene) and the most hazardous (i.e., benzene) constituents of the fuel oil. The risk
assessment indicates that the risk would be below die lower limit of the NCP target risk range.
5.8.4 Operable Unit 9-04 Sites
OU 9-04 consists of five sites (ANL-Ol, -01 A. -09. -35. and -53) that were identified in the
FFA/CO. All five sites had received potentially hazardous chemicals that required additional sampling
in order to determine the risks to human health and the environment. All of these sites were retained for
detailed evaluation in die OU 9-04 Comprehensive RI/TS because they contained contaminants above the
screening levels for either humans or the ecological receptors.
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5.8.5 Operable Unit 10-06 Sites
Two WAG 10 sites at or near ANL-W that contain radionuclide-contaminated soils have been
investigated in the OU 10-06 RJ/FS. The rwo sites are the ANL-WWindblown area and
ANL-WStockpile site. These two sites are located within a mile of WAG 9 and are now included in
the OU 9-04 Comprehensive RLTS because the wastes had originated at .ANL-W. Additional
information on these two sites can be found in the 10-06 administrative record under rN~EL-9J-003~ and
[NEL-95/0259. These two OU 10-06 sites are being incorporated into the OU 9-04 record of decision.
The following two sections describe a short summary of the radionuclides detected and the associated
risks.
ANL-W Windblown Area. This area actually consists of two areas, the windblown area around the
remotely located TREAT reactor and the windblown area around the ANL-W facility. Soil samples v.ere
collected at both these facilities in 1993, and analytical results from soil samples collected by the
Radiological and Environmental Sciences Laboratory (RESL, which is now called the Environmental
Science & Research Foundation, Inc.) were used to evaluate risks from exposure to contaminants at the
site. Risks for the current occupational exposure scenario and the future residential exposure scenario
were within the NCP target risk range (i.e., 1E-04 to 1E-06). [n addition to human health, risks to
ecological receptors were also evaluated. This evaluation showed no unacceptable risks to populations
of exposed ecological receptors.
ANL-WStockpile site. The ANL-W Stockpile is an abandoned borrow pit that was excavated as
part of road building activities near ANL-W in the 1950s. The borrow pit is located on the west side of
the ANL-W entrance road and is approximately 300 ft long and 200 ft wjde. In 1975, ANL-W personnel
used the borrow pit to dispose of approximately 1,058 cubic yards of low-level radionuclide
contaminated soil from the ANL-W Interceptor Canal. The Operable Unit 10-06 Phase II field
investigation was conducted at the ANL-W Stockpile to determine the nature and extent of radionuclide -
and metal- contaminated soils within the stockpile. Radioactive hot spots were identified in the stockpile
soil using field radiation survey instruments. Data were collected from three of the hot spots. The mam
radionuclide contaminant that contributed most of the risk was cesium-137, with concentrations up to
26,700 pCi/g. The human health risk assessment that was performed indicated that for the 100-year
residential exposure the total risk is 5E-03, which is attributed to the external exposure (4E-03) and food
crop ingestion (9E-04) from Cesium-137. In 1996, a non-time critical removal action was performed on
the radionuclide contaminated stockpile site. The contaminated soils were removed using large
excavation equipment and the soil was transported to the Warm Waste Pond at the Test Reactor .Area.
The preliminary remediation goal (PRO) for the Cesium-137 contaminated soil was 16.7 pCi/g and
remaining soils were below this level. The remaining risks associated with this site is 1E-05 which is
within the NCP target risk range.
5-28
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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 toxiciry assessment, and a
risk characterization discussion. The OU 9-04 Comprehensive Baseline Risk Assessment includes an
evaluation of human health risks associated with exposure to contaminants through soil ineestion,
fugitive dust inhalation, volatile inhalation, external radiation exposure, groundwater ingestion, ingestion
of homegrown produce, dermal adsorption 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 9 sites. The list of contaminants was screened based on comparison with background
concentrations determined for the INEEL, a 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. The complete contaminant of concern list for each of the sites retained for evaluation
are shown in Tables 3-3 through 3-18 of the OU 9-04 Comprehensive Rl/FS. Because "substances that
are essential nutrients can be toxic at high concentrations, this final screening step was applied only
when the essential nutrient concentrations were less than 10 times the background concentrations.
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 ANL-W were identified by considering
both the current and future land use scenarios.
The residential scenarios model a person living on the site 350 days a year for 30 years,
beginning in 2097 (100 years from 1997). The 100-year residential scenario was selected for analysis
because the DOE control of the INEEL lands is currently expected to last for at least 100 years. For
purposes of the baseline risk assessment the assumption was made that future residents will construct 10-
foot basements beneath their homes, and so the residents could be exposed to contaminants down to that
depth.
Two occupational scenarios were evaluated as part of the baseline risk assessment for ANL-W.
The assumptions used in the baseline risk assessment include noninrrusive daily industrial use without
restrictions for 25Q days per year for 25 years. Two time periods that were evaluated are'starting now
6-1
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(1997) and lasting 25 years. The second occupational scenario that was evaluated starts in 30 years
(2027) and lasts for 25 years.
6.1.2.2 Quantification of Exposure
The following exposure pathways were considered applicable to the evaluation of human
exposure to contaminants at the ANL-W sites: ingestion of soil, inhalation of fugitive dust, inhalation of
volatiles, external radiation exposure, groundwater ingestion (residential scenario only), ingestion of
homegrown produce (residential use only), and inhalation from indoor use of groundwater (residential
scenario only).
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 actual
cancer risk highly unlikely. The exposure parameters used in the risk assessment were:
All Pathways
-Exposure frequency, residential 350days/vr
Exposure frequency, occupational 250 days/yr
-Exposure duration, occupational 25 yr
-Exposure duration, residential 30 yr
External exposure path way
-Exposure tjme, residential 24 hr/day
-Exposure time, occupational 8 hr/day
Soil ingestion pathway
-Soil ingestion rate, residential-adult 100 mg/day
-Soil ingestion rate, residential-child 200 rag/day
-Soil ingestion rate, occupational 50 mg/day
-Exposure duration, residentjal-adult 24 hr
-Exposure duration, residential-child 6 hr
Dust inhalation path way
-Inhalation rate _. 20 m3 of air/day
Gro undwater ingestion path way
-Groundwater ingestion rate, residential 2 L/day
The contaminant exposure point concentrations evaluated in the baseline risk assessment were
developed from site-specific sampling information. The ninety-five percent upper confidence level (95%
UCL) of the mean concentration for the data set were calculated and depending on the size of the data
set, either the 95% UCL or the maximum detected concentration was used as the concentration in the risk
6-2
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assessment calculations. This follows EPA guidance to determine the reasonable maximum exposure
concentrations for contaminants at WAG 9.
6.1.3 Toxicity Assessment
A toxicity assessment was conducted to identify potential adverse effects to humans from
contaminants at ANL-W. 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 Summary Tables: Annual FY-95, 903-R-94-020, November 1995.
For the eleven sites that were retained for detailed analysis of human health risks, only one
contaminant has been identified as a COPC in the Nature and Extent of Soil Contamination (Section
5.7.2 of this ROD). This contaminant is cesium-137 which is rapidly absorbed into the bloodstream of
humans and is distributed thoughout the active fissures of the body. Metabolically, cesium-137 behaves
as an analog of potassium. Its distribution throughout the body and the energetic beta and gamma
radiation from its decay daughter, barium-137 metastable result in essentially whole-body irradiation.
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 (1x10'4) or exponential notation (1E-06). An excess lifetime cancer risk of 1E-
06 indicates that, an individual has an additional 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. If an individual has a typical United States average cancer risk of 1 in 4, or 25 percent, then
exposure to a carcinogen at the risk threshold concentration would raise his cancer risk to 0.250001 from
0.25. Excess cancer risks estimated below 1E-06 typically indicate that no ftuther investigation or
remediation is needed. Risks estimated between IE-04 to 1E-06 indicate that further investigation or
remediation may be needed. Risks estimated above the IE-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 IE-04 in making risk management decisions. A specific risk estimate above IE-04 may
be considered acceptable if justified based on site-specific conditions.
The calculation of the noncarcinogenic hazard quotients were also calculated for the
contaminants at WAG 9. The hazard quotients are ratios of a single substance exposure level to a
reference dose for the same time duration. The tolerance ability for humans varies and the reference
dose is based on the most susceptible individuals and then multiplied by the uncertainty factors (up to
10,000). This produces a very conservative value for non-cancer causing COC's . The hazard quotients
are added together by exposure pathway to determine the hazard index.
For the sites that were retained for detailed analysis of the risks in the OU 9-04 Comprehensive
RI/FS, ANL-W has prepared summary tables of the routes and calculated risks. These tables have been
separated out by the contaminants contributing to each of the risk ranges (i.e., risks > IE-04, risks
between IE-04 and 1E-06, and sites with HI greater than 1). The complete list of calculated carcinogenic
and non-carcinogenic risk values is found in Appendix B of the OU 9-04 Comprehensive RI/FS. Each of
these tables shows the release site, exposure scenario, exposure pathway, COC contributing to the risk,
6-3
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calculated risk or hazard quotient, and total exposure pathway excess cancer risk or hazard index. Table
6-1 shows only those sites with contaminants that have exposure pathway cancer risks greater than IE-
04. For contaminants that have not been identified as being a'carcinogen the contaminant may still pose
health risk to humans. The sites and contaminants with exposure pathway hazard index greater than 1
are shown in Table 6-2. Table 6-3 shows the sites and contaminants that have calculated exposure
pathways cancer risks between 1E-04 and 1E-06. For the sites, contaminants, and exposure pathways
with cancer risks less than IE-06 have been screened from inclusion in this ROD.
6.1.5 Risk Management
The risk management process is used to formally document decisions that have been made by
ANL-W, the EPA, and IDHW project managers to determine validity of the risk assessment to the actual
site conditions. The baseline risk assessment results tend to be very conservative and are based on the
EPA's default exposure parameters. These default exposure parameters tend to overestimate the
exposure fora small site on the INEEL. The risk management section (5.11) of the OU 9-04
Comprehensive Rl/FS described the 5 screening steps used by WAG 9 to determine which sites really
pose unacceptable risks to human health or the environment. The five steps are: (1) elimination of sites
with carcinogenic risk less than IE-06; (2) elimination of sites with carcinogenic risks between 1E-04
and IE-06, a risk management decision; (3) elimination of sites that the COC or exposure pathway has
been eliminated; (4) elimination of contaminants at or below ANL-W specific background
concentrations; and finally (5) elimination of sites with hazard quotients less than 1. Based on the risk
management evaluation process, the human health evaluation resulted in three areas with unacceptable
risks to human health. These three areas are the Industrial Waste Pond (ANL-01), the Interceptor Canal-
Canal (ANL-09) and the Interceptor Canal-Mound (ANL-09). The contaminants, pathway, and risks for
these three areas are shown in Table 6-4.
6.1.6 Human Health Risk Uncertainty
Many of the parameters used to calculate risks in the WAG 9 Baseline Risk Assessment and
Ecological Risk Assessment (ERA) have various uncertainties associated with them. For example,
limitations in site sampling produce some uncertainty associated with the extent of contamination at
most of the WAG 9 sites. Limitations in the characterization of the WAG 9 physical environment
produce some uncertainty associated with fate and transport properties of WAG 9 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, yet reasonable, estimate of WAG 9
risks.
Table 6-5 shows risk assessment parameter, the uncertainties associated with it, and the effect on
the risk. Uncertainties In analytical data include collection and evaluation are produced by variability in
observed concentrations due to sampling design and implementation, laboratory analysis methods,
seasonality, contaminant level variation, and natural concentration variation. Toxicity assumption
uncertainties are inherent due to the nature of collecting toxilogical information from animal studies and
relating those to humans. Other toxilogical uncertainties are encountered when uncertainty factors and
modifying factors are used in derivation of the slope factors and reference doses. The exposure
assessment uncertainties are produced by characterizing transport, dispersion, establishment of exposure
settings, and derivation of chronic intakes. Contaminant modeling uncertainties are encountered when
6-4
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Table 6-1. Exposure siles with human health risks greater than 1E-04.
ANI.-W Release
Site
ANL-OI-IWP
ANI.-09-Canal
A Nl. -09- Mound
ANI.-6IA
All WAG 0 silcs
(Cum Pathway)
Exposure
Scenario
0-25-year Occupational
30-55-year Occupational
100-year Residential
0-25-year Occupational
30-55-year Occupational
0-25-year Occupational
30-55-year Occupational
100-year Residential
lOU-year KcsKlcnli.il
I.UUO-yeui Residential
100-year Koideniul
1 ,000-year Residential
100- and 1,000- year
Residential
100- and 1.000-year
Residential
Exposure Pathway
External Radiation Exposure
External Radiation Exposure
External Radiation Exposure
External Radiation Exposure
External Radiation Exposure
External Radiation Exposure
External Radiation Exposure
External Radiation Exposure
digestion of Soil
digestion ol Soil
digestion of 1 lomegrown
Produce
digestion of Homegrown
Produce
Ingestion of Groundwater
Inhalation of vapors from
indoor water use
Contributing
COC
Cs-137
Cs-137
Cs-137
Cs-137
Cs-137
Cs-137
Cs-137
Cs-137
PCUs
PCBs
PCBs
PCDs
Arsenic
Arsenic
Calculated
Cancer Kisk
8E-04
4E-04
112-04
5E-04
2E-04
8E-04
4E-04
IE-04
6E-04
6li-04
2L-04
211-04
3E-04
IR-03 "
Exposure
Pathway
Cancer Kisk
9E-04
5E-04
411-04
5E-04
2E-04
8E-04
4L-04
IE-04
61--04 .
6I--04
2I--0-4
2I:-04
3L-04
li:-03
Justification for
Screening
(Step H)
NA
NA
NA
3
3
NA
NA
NA
1
3
i
3
4
4
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Table 6-2. Contaminant hazard index greater than I for OU 9-04 exposure sites, scenarios, and pathways.
ANL-VV Release
Silt;
ANI.-OI-IWP
ANI.-OI-Dilcli A
ANL-OI-DitchB
All WAG 9 sites
(Cumulative
Pathway)
Exposure Scenario
100- and 1,000 year
Residential '
100- and 1,000 year
Residential
100- and 1,000 year
Residential
100- and 1.000 year
Residential
Exposure Pathway
Ingestion of Soil
Ingestion of Homegrown
Produce
Ingestion of Homegrown
Produce
Ingestion of Homegrown
Produce
Ingest ion of Groundwater
Contributing COC
Arsenic
Chromium (VI)
Zinc
Mercury
Zinc
Mercury
Zinc
Mercury
OCDD
2,4,5-TP (silvex)
Antimony
Arsenic
Cadmium
Fluoride
Selenium
Zinc
Calculated
Excess Hazard
Quotient
0.3
0.8
0.4
0.5
O.I
0.9
0.8
0.5
3E-OI
2E-OI
2E-OI
ItiOO
61- -01
IHiOO
2E-OI
2E-OI
Exposure
Pathway Hazard
Index
1
1
1
1
5
Justification
for
Screening
(SlepW)
4
5
5
5
l& 5
-------
Table 6-3. Exposure sites with risks greater than 1E-06 and less than 1E-04.
ANL-VV Release
Site
Main Cooling
Tower
Blowdown
Ditch (ANL-
OIA)
Industrial
Waste Pond
(ANI.-OI)
Ditch A (ANL-
01)
Exposure Scenario
0-25- and 30-55-
year Occupational
1
0-25- and 30-55-
year Occupational
100-year Residential
100-year Residential
100 Residential
0-25- and 30-55-
year Occupational
0-25- Occupational
100-year Residential
100-year Residential
0-25- and 30-55-
year Occupational
0-25- and 30-55-
year Occupational
Exposure Pathway
Ingest ion of Soil
External Radiation Exposure
Ingestion of Soil
External Radiation Exposure
Ingestion of 1 lomegrown Produce
Ingeslion of Soil
External Radiation Exposure
Ingestion of Soil
Ingestion of Homegrown Produce
Ingeslion of Soil
External Radiation Exposure
Contributing
COC
Arsenic
U-238
Arsenic
U-238
Arsenic
Arsenic
Co-60
Arsenic
Arsenic
Arsenic
U-238
Calculated
Cancer Risk
IE-05
2E-06
5E-05
4E-06
5E-06
5E-06
6E-06
7E-05
8E-06
4E-06
5E-06
Exposure
Pathway
Cancer Risk
IE-05
2E-06
5E-05
4E-06
5E-06
5E-06
9E-04
7E-05
8E-06
41- -06
5li -06
Justification for
Screening
(StepM)
2
2
2
2
0
2
2
2
2
2
2
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Figure 6-3. Continued.
ANL-W Release
Site
Ditch H(ANL-
01)
Ditch C (ANL-
01)
Exposure Scenario
100- year Residential
100-year Residential
100-year Residential
0-25- and 30-55-
year Occupational
100-year Residential
100-year Residential
0-25- and 30-55-
year Occupational
0-25- Occupational
30-55-year
Occupational
100-year Residential
100-year Residential
100-year Residential
Exposure Pathway
Ingestion of Soil
External Radiation Exposure
Ingestion of Homegrown Produce
Ingestion of Soil
Ingestion of Soil
digestion of Homegrown Produce
Ingestion of Soil
External Radiation Exposure
External Radiation Exposure
Ingestion of Soil
External Radiation Exposure
Ingestion of Homegrown Produce
Contributing
COC
Arsenic
U-238
Arsenic
Arsenic
Arsenic
Arsenic
Arsenic
Co-60
U-238
U-238
Arsenic
U-238
U-238
Arsenic
Calculated
Cancer Risk
3E-05
9E-06 .
4E-06
2E-06
2E-05
3E-06
2E-06
1 E-06
2E-05
2E-05
2E-05
2E-06
3E-05
3 E-06
Exposure
Pathway
Cancer Risk
3E-05
9E-06
4E-06
2I--06
2E-05
3 E-06
2E-06
2 1- -05
2E-05
2E-05
3E-05
31:- 06
Justification Tor
Screening
(Step ft)
2
2
2
2
T
2
2
T
2
1
2
2
2
2
6-8
-------
Figure 6-3. Continued.
ANL-W Release
Site
Interceptor
Canal- Canal
(ANL-09)
Interceptor
Canal- Mound
(AMI. 09)
Industrial
Waste
Uftstalion
Discharge
Ditch (ANL-
35)
Exposure Scenario
0-25- and 30-55-
year Occupational
1
0-25-year
Occupational
100- year Residential
100-year Residential
100-year Residential
0-25-year
Occupational
30-55-year
Occupational
100-year Residential
0-25-year
Occupational
Exposure Pathway
Ingestionof Soil
External Radiation
Ingestion of Soil
External Radiation
Exposure
Exposure
Ingestion of Homegrown Produce
External Radiation
External Radiation
External Radiation
External Radiation
Exposure
Exposure
Exposure
Exposure
Contributing
coc
Arsenic
Co-60
Arsenic
Cs-137
Arsenic
Co-60
U-238
U-238
U-238
Co-60
Cs-137
U-238
Calculated
Cancer Risk
3E-06
2E-06
3E-05
8E-05
3E-06
IE-05
2E-06
2E-06
3E-06
2E-06
5E-05
2E-06
Exposure
Pathway
Cancer Risk
3E-06
-
5E-04
3E-05
8E-05
3E-06
8E-04
4E-04
1 I--04
6E-05
Justification for
Screening
(Step tt)
2
1
2
2
2
2
2
2
2
2
1
2
-------
Figure 6-3. Continued.
ANL-W Release
Site
Cooling lower
Riser Pits-
Soulh(ANL-
53)
I-UK II
Transformer
Yanl(ANI.-
6IA)
All WAG 9
sites
(Cumulative
Pathway)
Exposure Scenario
30-55-year
Occupational
100-year Residential
0-25- and 30-55-
year Occupational
100-year Residential
100-year Residential
0-25- and JO 55-
year Occupational
100- year
Residential
100- year
Residential
Exposure Pathway
External Radiation Exposure
External Radiation Exposure
Ingestion of Soil
digestion of Soil
digestion of 1 lomegrown Produce
Ingestion of Soil
digestion of Ground water
Inhalation of water vapors from
Indoor Water Use
Contributing
COC
Cs-137
U-238
U-238
Cs-137
Arsenic
Arsenic
Arsenic
PCIJ's
I3is(2-
Ethylhexyl)
Phthalate
Methylene
Chloride .
Methylene
Chloride
Calculated
Cancer Risk
3E-05
2E-06
3E-06
9E-06
2E-06
2E-05
3E-06
7H-05
4E-06
7E-06
1 f:-06
Exposure
Pathway
Cancer Risk
3H-05
1 1--05
2E-06
2f--05
3E-06
7l-:-05
1 E-06
1 L-06
Justification for
Screening
(Step ft)
2
2
2
2
2
2
o
T
2
2
2
-------
Figure 6-3. Continued.
ANL-W Release
Site
TREAT
Windblown
Area (10-06)
Stockpile Soil
(10-06)
All WAG 9
sites
(Cumulative
Pathway)
Exposure Scenario
30- year Residential
1
100-year Residential
100- year
Residential
100- year
Residential
c
Exposure Pathway
Ingestion ofllomegrown Produce
External exposure
Ingestion of Ground water
Inhalation of water vapors from
Indoor Water Use
Contributing
COC
Sr-90
Cs-137
Bis(2-
Elhylhexyl)
Phthalate
Methylene
Chloride
Methylene
Chloride
Calculated
Cancer Risk
2E-06
IE-OS
4E-06
7E-06
1 E-06
Exposure
Pathway
Cancer Risk
2 E-06
1 E-05
IE-06
1 1- -06
Justification for
Screening
(Step «)
2
2
2
2
2
6-1
-------
Table 6-4. Sites retained fur evaluation in the feasibility study because of human health risks.
AMI. W Release
Site
Eiposure
Scenario
Eiposure Pathway
Contributing
COC
Calculated
Cancer Risk
Eiposure
Pathway
Cancer Risk
Justification for
Screening
(Step 0)
ANL-01-IWP
0-25-year Occupational
30-55-year Occupational
100-year Residential
External Radiation Exposure Cs-137
External Radiation Exposure Cs-137
External Radiation Exposure Cs-137
8E-04
4 E-04
IE-04
9H-04
5H-04
4 E-04
NA
NA
NA
ANI.-09-Mound
0-25-year Occupational
30-55-year Occupational
100-year Residential
External Radiation Exposure Cs-137
External Radiation Exposure . Cs-137
External Radiation Exposure Cs-137
8E-04
4 E-04
1E-04
8E-04
4E-04
I E-04
NA
NA
NA
6-12
-------
default values are used-instead of actual site conditions and model outputs cannot be verified with actual
data.
Table 6-5. Uncertainties associated with the human health risk assessment.
Area
Uncertainties
Effect oa Risk
Sampling and
Analysis
Concentration
Terms
A representative concentration may not have been obtained where limited sampling was
performed.
95% UCL values were used in Risk Assessment.
ANL-W used one-half the detection limit when the constituent is not detected.
Overestimate or
Underestimate
Overestimate
Overestimate
Fate and Use of conservative generic modeling parametersTnay not be truly representative of
Transport ANL-W site conditions.
Distribution coefficient values have wide ranges for various soil types.
GWSCREEN GWSCREEN input parameters (i.e., contaminant solubility limit, distribution coefficient
Modeling GO, and infiltration rate are considered conservative, but contain some uncertainty.
Maximum source term concentrations are assumed for the entire volume modeled for
each site.
Exposure Assumes residence could be established in area that are uninhabitable due to physical or
Assessment administrative limitations.
Default exposure values assume maximum possible exposure times, particularly for the.
occupational scenario where exposure times were 8 hours per day rather than more
realistic time of a maximum of a few hours a week.
Overestimate
Overestimate
Underestimate
or Overestimate
Overestimate
Overestimate
Overest-jnate
Toxicity
Assessment
Risk
Characterization
The dermal absorption pathway was not included in the risk assessment calculations.
Use of parent nuclide slope factor plus daughter (~D) rather than adding slopes for each
radionuclide.
Extrapolation of values from nonhuman studies to humans, from high doses to low doses.
Chromium was assumed to be 10% hexavalent and 90% crivalent form based on worst
case studies at ANL-W.
Route-to-route extrapolations are used.
Risks are added across constituents and pathways, although they may not affect the same
target organ or mechanisms of damage.
Assumption that constituents are evenly distributed at 'Jie 95% UCL concentration.
Toxicity values for some constituents such as ciiromium and silver are based on industrial
conditions.
Underestimate
Underestimate
Overestimate or
Underestimate
Overestimate
Overestimate ,r
Underestimate
Underestimate
or Overestimate
Overestimate
Overestimate
6-13
-------
6.2 Ecological Evaluation
The ecological assessment for ANL-W is a quantitative 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 RJ/FS scheduled for 1999.
The assessment endpoints developed around the protection of biota represented by functional groups and
individual threatened and endangered and Category 2 species known to exist at ANL-W. Assessment
endpoints were defined for ANL-W were in the INEEL ERA Guidance Manual (VanHorn et al., 1995)
'and incorporate the suggested criteria for developing assessment endpoints. including ecological
relevance and policy goals (EPA 1992).
The selection of measurement endpoints for the ANL-W flora and fauna were not surveyed
directly. Rather, published references were used as the primary sources of ecological and to.xicological
data from measurement endpoints were derived. Values extracted from these references were used to
calculate the ecological based screening levels for all ecological receptors and to develop the toxicity
reference values for the contaminants.
The measurement endpoints are the modeled dose as compared to the toxicity reference values
(TRVs) for each contaminant for each receptor or functional group. The dose was divided by the TRV to
produce a hazard quotient (HQ) for each contaminant and receptor of concern. The HQ is ultimately
used to measure whether the assessment endpoint has been attained, that is, no indication of possible
effects is determined (i.e., HQs are less than target value for all receptors for each contaminant). This
target value for the ecological HQs was established to be 10 times the HQ of the 95% UCL for the :
INEEL background.
This INEEL-wide ecological assessment provided an indication of the affect of INEEL releases
in the ecology at a population level. In the area near ANL-W, there are no critical or sensitive habitats.
Based on the present COCs and ecological information the quantitative eco-evaluation performed for this
ROD. Six areas pose potentially unacceptable risks to the ecological receptors for up to five inorganics;
chromium, mercury, selenium, silver, and zinc. Of these six areas, one also shows unacceptable human
health risks. Table 6-6 lists the six areas, contaminants of concern, and corresponding mltiplication of
the HQ above the INEEL background HQ for those sites that were retained for the ecological receptors.
6.2.1 Species of Concern
The only federally listed endangered species known to frequent the INEEL is the peregrine
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 hawk, 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 milkvetch,
wing-seed evening primrose, nipple cactus, and oxytheca. Table 6-6 shows the sites of concern along
with the functional group identification number and a species common in the functional group.
6-14
-------
Table 6-6. Sites that have unacceptable ecological risks, HQ, functional group, and species.
Multiple of
FF.VCO Area Name /size (ft) rnr, ENEEL natural P
Site COC background Functional
??Q- Group
ANL-01 Industrial Waste Pond/ 200x250x0. 5 Cr-3
Hg
Se
Zn
200
50
20
20
Plants
(M222)
(M222)
(AV232)
Common
Species
Nurr.erOLis
Merriams ihre-.v
Merriams shre1-*.
Red-wj-.sed
biackbiri
ANL-01
Ditch A / 5x400x0.5
Hg
50
(AVI32)
Sara
ANL-01
ANL-0 1 A
Ditch 8/5x1,400x1.3
Cr+3
Zn
Main Cooling Tower Slowdown Ditch / Cr+3
6x700x2
20
15
15
120
Plants
(AV232)
Plants
(M222)
Numerous
Numerous
Merriarr.s shre
ANL-04 Sewage Lagoons / 300x700x 1
Hg
40
(M222) Memams shr:
ANL-35 Industrial Waste Lift Station Discharge Ag 30 Plants Numerous
Ditch/4x500x1
The agencies agreed that action would be taken on WAG 9 sites where the hazard quotient caused by a COC exceeded
hazard quotient cased by natural background concentrations by a factor of 10 or more.
6.2.2 Exposure Assessment
The WAG 9 ecological risk assessment (ERA) evaluated all the FFA/CO sites and determined
that five sites have a potential source of contamination and/or a pathway to ecological receptors. These
sites were evaluated using the general approach as discussed m VanHom et al. (1995) and following
guidelines proposed by EPA (EPA 1992). The results of the ERA evaluation of the remaining sites ire
presented as a range of hazard quotients (HQs) calculated for functional groups. Due to the uncemmrs
in the ERA methods, HQs are used only as an indicator of risk and should not be interpreted as a final
indication of actual adverse effects to ecological receptors. In addition, DOE used the INEEL 95% L'CL
background concentrations for the inorganics which resulted in HQs greater than 1. Based on the
conservative nature of the HQ calculations, DOE will only remediate those WAG 9 sites that have HQs
that are at least 10 times the HQ calculated using the INEEL or ANL-W specific 95% UCL background
concentration. Six areas; ANL-01, Ditch A, Ditch B, ANL-01 A, ANL-04, and, ANL-35-were retained
because of ecological risks.
6-15
-------
6.2.3 Ecological Risk Uncertainties
Uncertainty is inherent in the risk assessment 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. variations in
background inorganic concentrations, 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 to some extent. Table 6-7 shows
risk assessment parameter, the uncertainties associated with the identified parameter, and the effect on
the risk.
The uncertainties for the ecological risk assessment conducted for WAG 9 include the use of HQ
as an indicator of risk. The HQ is a ratio of the calculated dose for a receptor from a COC to the toxic IP.
reference value. These ratios provide a quantitative index of risk to define functional groups or
individual receptors under assumed exposure conditions. A HQ less than the target value (i.e., typically
1) implies "low likelihood" of adverse effects from that contaminant. However, in many cases, FNEEL
background concentrations of inorganics produced HQ greater than I. Thus, for WAG 9 the approach of
using the ten times the background HQ was adopted in establishing the action levels.
6.3 Groundwater Risks
The GWSCREEN model was selected to perform the groundwater contaminant fate and transport
calculations. The source areas were modeled individually instead of modeling a single composited site.
Each source area was located according to its physical geographic location within the ANL-W facility and
the contaminant specific plumes were added together to determine the maximum contaminant
concentration. The maximum contaminant concentration for the groundwater was then used in the risk
assessment calculations. The results of the cumulative evaluation of the groundwater indicate that arsenic
and chromium are the only contaminants that pose a potentially unacceptable groundwater contaminant
levels. The maximum arsenic and chromium concentrations for the future residents 100-years in the future
were calculated. The chromium risk were less than 1E+06 and the arsenic resulted in a risk of 3E-04 for
the ingestion of groundwater and 1E-03, for the inhalation of vapors from indoor water use. Both risk
values for arsenic exceeded the upper limit of the National Contingency Plan level of 1E-04. The arsenic
was determined to be from natural sources at the INEEL and screened as a contaminant of concern during
the risk management process for these CERCLA sites at ANL-W. Additional information on the
groundwater modeling and screening of arsenic as a contaminant of concern at ANL-W can be found :n :he
OU 9-04 Comprehensive RI/FS Sections 5.4, 5.5, 5.6, 5.7, 58, and 5.11.2.4.
6.4 Basis for Response
The ANL-W OU 9-04 Comprehensive RI/FS evaluated the risks associated with the 37 sites
from WAG 9 along with two sites from WAG 10. Together these 39 sites were evaluated to determine
the risks to the current and future receptor scenarios. The following two paragraphs explain which sites
pose unacceptable risks for the human health and ecological receptors.
6-16
-------
Table 6-7. Uncertainties associated with the ecological risk assessment.
Area
Uncertainties
Effect on Risk
Sampling and
Analysis
Concentration
Terms
A representative concentration may not have been obtained -vvhere limited sampling was Overestimate :r
performed. Underestimate
95% UCL values were used in Risk Assessment. Overestimate
ANL-W used one-half the detection limit when the constituent is not detected.
Overestimate
Fate and
Transport
Use of conservative generic modeling parameters may not be truly representative of
ANL-W site conditions.
Overestimate
Distribution coefficient values have wide ranges for various soil types.
Overestimate
Functional The functional groups were designed to assess a hypothetical species using input values Overestima;
Groups that represent the greatest exposure of the combined functional group members.
Estimation of
Ingestion Rates
Estimation of
Plant Uptake
Factors
Estimation of
Toxicity
Reference
Values
Only a few of the intakes for the terrestrial receptors were based on ingestion rates found Overestimate _
-------
(ANL-35). These eight areas with unacceptable human health or ecological risks are shown in Figure 6-
1. A summary of the sites with actual or threatened releases of hazardous substances to humans or
ecological receptors is shown in Table 6-8. These sites with unacceptable risks to humans and/or the
ecological receptors are described in the following two paragraphs, respectfully.
The Baseline Risk Assessment (BRA) indicated that for the current and future occupational
scenario, only one contaminant cesium-137, would produce an unacceptable risk to human health. The
cesium-137 posed an unacceptable risk to both current and future occupational receptors and future
residential receptors at two sites, the Industrial Waste Pond (ANL-01) and the Interceptor Canal-Mound
(ANL-09). While the cesium-137 at the Interceptor Canal-Canal (ANL-09) site only poses an
unacceptable risks for the current and future occupational receptors. The Interceptor Canal-Canal (ANL-
09) risks will be mitigated for the current and future occupational receptors by implementation of the
land use restrictions during the 100-year DOE control as defined in the in the land use assumptions.
Thus, the Interceptor Canal-Canal (ANL-09) portion'will only undergo implementation of standard
operating procedures to reduce the risks to the occupational receptors to acceptable levels.
The results of the WAG 9 ERA indicate that of the 37 WAG 9 release sites and the 2 WAG 10
sites, only six areas produce potentially unacceptable risks for ecological receptors due to the presence of
various inorganic contaminants. These six areas are; the Industrial Waste Pond, Ditch A, Ditch B (all
from ANL-01), the Main Cooling Tower Slowdown Ditch (ANL-OIA), the Sewage Lagoons (ANL-04),
and the Industrial Waste Lift Station Discharge Ditch (ANL-35). The remaining sites that were
evaluated as part of the OU 9-04 Comprehensive RI/FS had risks that were within the acceptable range
of the National Contingency Plan. These sites are being mentioned here to formally document in this
ROD that they require No Action.
None of the contaminants exceeded the hazard index of 1 for either the current or future
occupational exposure route. The response actions selected in this ROD are designed to reduce the
potential threats to human health and the environment to acceptable levels.
Table 6-8. Sites with unacceptable human health or ecological risks.
ANL-W Area /Site Code
Industrial Waste Pond / (ANL-01)
Ditch A /(ANL-01)
Ditch B / (ANL-0)
Main Cooling Tower Slowdown Ditch / (ANL-OIA)
Sewage Lagoons / (ANL-04)
Interceptor Canal-Canal / (ANL-09)
Interceptor Canal-Mound / (ANL-09)
Industrial Waste Lift Station Discharge Ditch / (ANL-35)
Human Health Risk?
Yes-
No
No
No
No
Yes
Yes
No
Ecological Risk?
Yes-
Yes
Yes
Yes
Yes
No
No
Yes
* This is the only site with both human health and ecological risks.
6-18
-------
SEWAGE
LAGOONS
(ANL-04)
INDUSTRIAL
WASTE POND
(ANL-01)
MAIN COOLING TOWER
SLOWDOWN DITCH^ (ANL-01A)
INDUSTRIAL WASTE LIFT STATION
DISCHARGE DITCH (ANL-35)
j
DITCH
(ANL
INTERCEPTOR
CANAL-MOUND
(ANL-09)
INTERCEPTOR
CANAL-CANAL
(ANL-09)
Figure 6-1. Eight Areas at ANL-W with Unacceptable Human Healih or Ecological Risks
6-19
-------
7 DESCRIPTION OF ALTERNATIVES
r
7.1 Remedial Action Objectives
Remedial action objectives (RAOs) for OU 9-04 sites with unacceptable risks were developed in
accordance with the N'CP and CERCLA Ri/FS guidance. The RAOs were defined through discussions
among the three agencies (IDHW, EPA, and DOE). The RAOs are based on the results of the human
health and ecological risk assessment and are specific to the COCs and exposure pathways developed for
OU 9-04. They are as follows:
For protection of human health:
<
Prevent direct exposure to radionuclide contaminants of concern (COCs) that would
result in a total excess cancer risk of greater than 1 in 10,000 to 1 in 1,000,000 (1E-04 to
1E-06) to current and future workers and future residents.
For protection of the environment:
Prevent exposure to COCs in soils which may have potential adverse effects to resident
populations of flora and fauna, as determined by a KQ = 10 times the HQ calculated
from INEEL background soil concentrations.
To meet these objectives, remediation goals (RGs) were established. These goals are
quantitative cleanup levels based primarily on AJRARs and risk-based doses. The RGs are used in
remedial action planning and the assessment of effectiveness of remedial alternatives. Final RGs are
based on the results of the baseline risk assessment and evaluation of expected exposures and risks for
selected alternatives.
The 1 chance in 10,000 risk (1E-04) for human health and a hazard quotient of 10 times the
FNEEL background for ecological receptors were used to determine the RGs for the OU 9-04 sites of
concern. For human health the basis for using the upper end of the NCP risk range of 1E-04 to 1E-06
was based on the remoteness of the INEEL site, conservativeness of the risk assessment, the absence of
current residents, results based on the 100-year DOE control of INEEL lands, and current and future
occupational workers are and will continue to be protected by standard operating procedures that are
inplace and will continue to be updated while the ANL-W is operating. The RGs for the remediation of
the cesium-137 for humans was determined by using a backward calculation of the concentration needed
to produce a risk of 1E-04. Likewise, the RGs for the ecological receptors were also risk based and were
determined by back calculating the concentrations equal to 10 times the HQ resulting from INEEL
background soils. Table 7-1 shows the final RGs that have been established for the eight areas of
concern at ANL-W.
Remedial actions will ensure that risk is mitigated to the point that exposure would not exceed
these levels. On the basis of these RGs, areas and volumes of contaminated media that would require
some form of remedial action were identified. These estimated areas, depths, and volumes for the eight
areas to be remediated are presented in Table 7-2.
7-1
-------
Table 7-1. Final Remediation Goals for the WAG 9 Sites.
Receptor
Human Health
Human Health
Human Health
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Ecological
Site
Interceptor Canal-Mound (ANL-09)
Interceptor Canal-Canal (ANL-09)
Industrial Waste Pond (ANL-Ol)
Industrial Waste Pond (ANL-Ol)
Industrial Waste Pond (ANL-Ol)
Industrial Waste Pond (ANL-Ol)
Industrial Waste Pond (ANL-Ol)
Ditch A (ANL-Ol)
Ditch B (ANL-Ol)
Ditch B (ANL-Ol)
Main Cooling Tower Slowdown
Ditch (ANL-Ol A)
Main Cooling Tower Slowdown
Ditch (ANL-Ol A)
Sewage Lagoons (ANL-04)
Industrial Lift Station Discharge
Ditch (ANL-35)
95% UCL RG*
Contaminant Concentration' Concentration'
cesium- 1 37
cesium-137
cesium-137
chromium III
mercury
selenium
zinc
mercury
chromium III
zinc
chromium III
mercury
mercury
silver
3-0.53
18
29.2
1,030
2.62
8.41
5,012
3.94
1,306
3,020
709
8.83
3.2
352
25.3
23.3
23.3
500
0."4
3.4
2,200
O.M
500
2,200
500
0.74
0.74
112
' - Concentrations in mg/kg or pCi/g
* - Backward calculated risk-based concentration at the IE*04 level.
7-2
-------
Table 7-2. Volume of Contaminated Soil in the Eight areas Retained for Cleanup.
OU 9-04
Release site
ANL-01
ANL-01
ANL-01
.ANL-01 A
ANL-04
ANL-09
ANL-35
Site name
Industrial Waste Pond
Ditch A
Ditch B
Main Cooling Tower Slowdown Ditch
Sewage Lagoons
Interceptor Canal-Mound
Industrial Waste Lift Station Discharge Ditch
Width
(ft)
200
5
5
6
300
20
4
Length
(ft)
250
400
1,400
700
700
500
500
Depth
(ft)
0.5
0.5
1.3
2
1
4
1
Volume
(ydj)
926
3
3 '. '.
7,7~S
MS;
"4
7.2 Summary of Alternatives
In accordance with Section 121 of CERCLA, the FS identified alternatives that (a.) achieve the
stated RAOs, (b.) 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 the OU 9-04 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 9-04 sites:
1. No Action (with monitoring)
2. Limited Action
3. Containment with Institutional Controls
4. Excavation and Disposal
5. Phytoremediation
Estimated present work costs for the remedial alternatives for all sites are shown in Table 9-3 in
Section 9. Post-closure costs were estimated for 100-years of monitoring for Alternative 3, where the
contaminants were left at WAG 9. For Alternatives 4 and 5, where contaminants are removed or treated
to meet the RAOs, the monitoring period extended to the end of the removal or until the RAOs are met
through treatment. DOE controls will be implemented for Alternatives 4 and 5, after the RAOs are met.
7-3
-------
7.2.1 Alternative 1: No Action (With Monitoring)
Formulation of a No Action alternative is required by the NCP [40 CFR 300.430 (e)(6)] and
guidance for conducting feasibility studies under CERCLA. The No Action alternative serves as the
baseline for evaluating other remedial action alternatives. This alternative can include environmental
monitoring, but does not include actions to reduce potential exposure pathways, such as fencing or deed
restrictions. Therefore, the No Action alternative developed for OU 9-04 sites involves only
environmental monitoring (groundwater, air, and sediment) in accordance with DOE Orders and the
ANL-W Environmental Monitoring Plan for at least 100 years after site closure. The monitoring would
be necessary to validate that none of the contaminants were shown to migrate off-site or into the
groundwater through modeling used in the OU 9-04 Comprehensive RJ/FS.
While the No Action alternative does not involve any construction or operational activities that
would result in disturbances to the surfaces of the OU 9-04 sites, IDAPA 16.01.01.650 (Rules for
fugitive dust) could nonetheless apply to any sites that were a source of fugitive dust and is, therefore
considered an ARAR that would not be met. Inorganics present in fugitive dust would not meet IDAPA
16.01.01.585-586 (Rules for the Control of Air Pollution in Idaho). IDAPA 16.01.11.200 (Rules for
groundwater quality) would be met by ongoing groundwater monitoring. The No Action alternative
would not meet DOE Orders because health risks to current workers and the 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.
7.2.2 Alternative 2: Limited Action
The limited action alternative involves only institutional controls to remain in effect for the next
100 years. This alternative essentially continues management practices currently in place at OU 9-04
and will continue for the next 100 years of DOE control. Actions under this alternative focus on routine
maintenance and upkeep of the drainage ditches and Industrial Waste Pond, restricting access (posting
warning signs and deed restrictions), and environmental monitoring including radiation surveys!
Current management practices and institutional controls are in place as a result of DOE
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 (ALAJLA), and requires that DOE activities be conducted in compliance with a
documented radiation protection program approved by DOE. At the INEEL, the requirements of 10
CFR 835 are primarily implemented through DOE Order 5400.5. Regulations for 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.
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 anticipated duration of
such controls will be placed in the "INEEL Comprehensive Facility and Land Use Plan" maintained by
the DOE-ID Office of Program Execution. DOE shall also provide the Bureau of Land Management the
7-4
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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.
Monitoring and radiation survey programs would b-. established to ensure that the contaminants
remain within the boundaries of the OU 9-04 sites, and would provide early detection of potential
contaminant migration. These programs would be implemented annually for the first 5 years following
site closure. The need for further environmental monitoring would be evaluated and determined by the
Agencies during subsequent 5-year reviews.
Short-term effectiveness of this alternative is considered high, as this alternative is already
implemented at the most of 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 has already occurred. The estimated costs for this alternative are shown in
Table 9-3 of;:-.isROD.
7.2.3 Alternative 3a and 3b: Containment Alternatives and Institutional Controls
The two centralized containment alternatives consist of the consolidation and isolation of
contaminated soil from potential receptors for the period of time that unacceptable cumulative exposure
risks will be present. This consolidation would place the contaminated soils from the OU 9-04 sites into
an engineered landfill at WAG 9. The landfill would have a. thick soil and/or rock cover placed over it.
The containment alternatives would include: long-term environmental monitoring, 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 two centralized containment alternatives were
considered for all eight areas at ANL-W.
Alternative 3a consists of consolidation of contaminated soils and capping with engineered cover
originally developed by the Uranium Mill Tailings Remedial Action (UMTRA) program for stabilization
of abandoned uranium mill tailings. This design, based on the recent bio intrusion research studies at the
INEEL, was recently constructed at the INEEL Stationary Low-Power Reactor-I burial ground site.
Advantages of this engineered cover are:
Requires minimal maintenance
Inhibits inadvertent human intrusion
Minimizes plant and animal intrusion
Inhibits contaminant migration
The cover design consists of four layers of natural geological materials including native soil,
gravel, basalt cobbles, and rip-rap. Implementing Alternative 13 a), for sites at ANL-W would-entail
consolidation of soils from both the radiological and ecological sites into one centralized location at
WAG 9 prior to capping. The volume of soils in most of the ANL-W sites is relatively small and the
costs associated with building multiple engineered covers at each release site is not justifiable. The most
logical centralized location for the engineered cover would be near the Interceptor Canal and the
Industrial Waste Pond which have the largest volume of contaminated soil. The engineered cover (3 a)
would prevent both human and ecological receptors from contacting the soils. Additionally the
engineered cover (3a) would be sloped accordingly to prevent ponding of surface waters which should
7-5
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have the potential to migrate through the soils and ''leach out" the radiological and inorganic
contaminants. Site-specific considerations (such as annual precipitation, frost depth, and anticipated soil
erosion rates) would be used to design the optimum configuration for this alternative during the remedial
design phase.
Alternative 3b consists of consolidation of contaminated soils in an engineered landfill with a
native soil cover. The native soil cover would consist of 10 ft of clean FNEEL soil, with a surtace
covering of vegetation, rock armor or other material. Implementing this alternative at OL- 9-04 would
require a centralized location near the release sites in which to build the containment, moving the
contaminated soil to the centralized location, and then adding clean soil layers above grade to bring the
total thickness to 10 ft. The native soil cover is applicable to both the radiologically and inorganically
contaminated sites. The long-term effectiveness of this type of cap to prevent exposure of inorganics
past the 100-year institutional control period is not known. The native soils cap would be effective for
the radiological contamination since the cesium-137 risk would be at the upper limit of the NCP risk
range within 130 years.
Each capping technology is designed to prevent direct radiation exposures to resist erosion due
to wind and surface water runoff, and to resist biointrusion that may penetrate into the contamination
zone, or facilitate erosion. The primary differences between the two capping technologies are the length
of time these functions can be maintained and the effectiveness of the biointrusion and erosion control
components of the designs. The design life of the capping technologies specified for the containment
alternatives will depend on the construction materials specified, number and thickness of layers required,
and sequence of those layers. The long-term effectiveness and permanence required by the Interceptor
Canal-Mound (ANL-09) and the Industrial Waste Pond (ANL-01) is driven by the radioactive decay of
the cesium-137 contaminant in their soils and sediments. The cesium-137 contaminant will decay to
acceptable risk levels in 130 years. The multilayered engineered barrier design (alternative 3a) is likely
to provide a higher level of protection against biointrusion. A 10-foot thick soil cover would eliminate
intrusion into contaminated soil by most of the burrowing INEEL species, but not all plants and
invertebrates. Root intrusion into contaminated soils could result in mobilization of radionuclides
through the plant exposing environmental receptors. Costs associated with the cover alternatives at each
site are detailed in Sections 8 and 9 of this ROD.
7.2.4 Alternatives 4a and 4b: Excavation and Disposal
These alternatives involve complete removal of contaminated materials that pose an
unacceptable risk to human health and/or ecological receptors. Two alternatives were evaluated during
the WAG 9 RI/FS. Alternative 4a consists of excavation and disposal at two on-INEEL location whereas
in Alternative 4b the soils would be disposed at an off-INEEL private facility. Both Alternatives -la and
4b would include collection of verification samples after removal to ensure that the final remediation
goals were met.
Implementation of Alternative 4a would require excavating all soils and debris from the
radiological and inorganic contaminated sites that are above the RGs, and transporting the soil to either
the proposed [NEEL Soil Repository, or the Radioactive Waste Management Complex (RWMC). An
INEEL Soils Repository, is included as part of the WAG 3 Proposed Plan that will be presented for
public comment in the fall of 1998. The other option for on-INEEL disposal is to use the currently
operating RWMC facility. Each of these on-INEEL facilities are expected to have or will have specific
acceptance criteria that the WAG 9 soils currently meet. The final selection between the on-INEEL
7-6
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disposal areas would be completed during the WAG 9 RD/RA workplan development that is scheduled
to start in the summer of 1998. The excavation and transport of the radiologically contaminated soils
would require additional monitoring to verify that workers do not receive excessive radiation exposure.
Verification sampling would be used to ensure that all contamination exceeding RGs was removed.
Implementation of Alternative 4b would require excavation of all soils and debris from the
radiological and inorganically contaminated soil sites that are above the RGs, and transporting the 501! to
a rail transfer station at the 1NEEL Central Facilities Area (CFA) for shipment to a private off-fNTEEL
disposal facility. The operating permit for the private off-fNEEL disposal facility will specify the
radionuclide activity levels that can be accepted. The WAG 9 soils have concentrations that are
currently acceptable by most off-INEEL facilities that are permitted to accept radiologically
contaminated material. The excavation and transport of the radiologically contaminated soils would
require additional monitoring to ensure that no excess exposures are encountered. Verification samplir.
-------
results, ANL-W will conduct a full-scale two-year demonstration field test in 1999 and 2000 on fhe
ANL-W sites of concern. Engineering controls would be utilized to control possible spread of
contamination. Propagation of nonnative plants will be controlled by harvesting prior to the plants aoina
to seed. The plant matter will be dried, baled, and stored in a controlled area prior to shipment to an
incinerator for volume reduction in accordance with off-site requirements. Air pollution controls used
to control air emissions would be required and the resulting ash would be properly disposed of in an
approved disposal facility. Depending on the plants that are selected, two or more "crops" are possible
each field season. After completion of the two-year demonstration field test (1999 and 2000), ANL-W
will collect data to determine if the process is working as predicted in the actual field situation. This data
will be used to determine the remaining number of field seasons that would be required to meet the RGs
as well as provide a means of projecting future costs. This field data would be required to determine the
feasibility of the technology for the treatment of the radiological and inorganic contaminants at WAG 9
In the fall of 2000, after analysis of the soil samples, the agencies will review the data and make the
determination on continued use of phytoremediation at WAG 9. If phytoremediation is working and the
process is continued, verification sampling would be used after the final field season to ensure that the
RGs have been met.
This alternative provides long-term effectiveness and permanence because the soils would actually
be treated insitu to remove the contaminant. Long-term monitoring would no longer be required, assuming
removal of contaminated soils achieve acceptable levels. DOE will continue with short-term soil, air,
vegetation, and groundwater sampling for 20 years in accordance with DOE orders and the ANL-W
Environmental Monitoring Plan until the year 2018. These samples will be collected only to ensure
continued compliance of current discharges and/or migration from past releases. CERCLA five-year
reviews would be required for the next 100 years to ensure that the RGs would meet the established RAOs.
DOE anticipates that the five-year reviews will consist of a memorandum summarizing a checklist-driven
inspection of the signs, fences, and other physical features that assure DOE controls are still in place.
Costs of insitu phytoremediation are shown in Sections 8 and 9, and are relatively low as compared to
other alternatives that do not treat the contaminated soils.
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. These criteria are:
I. Overall protection of human health and the environment- 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.
2. Compliance with ARARs- addresses whether a remedy will meet all of the ARARs under
federal and state environmental laws and/or justifies a waiver.
3. Long-term effectiveness and permanence- refers 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 of toxicity, mobility, or volume through treatment- addresses 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
7-8
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by the site.
5. Short-term effectiveness- addresses any adverse impacts on human health and the
environment that may be posed during the construction and implementation period, and
the period of time needed to achieve cleanup goals.
6. Implementability- addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.
7. Cost- includes estimated capital and operation costs, expressed as net present-worth
costs.
8. State acceptance- 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 acceptance- summarizes the public's general response to the alternatives
described in the Proposed Plari and in the RI/FS. The evaluation of this criterion is 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 ARAJRs; (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. Alternatives 2 and 3b, limited action and
containment with native soil cover, respectively, do not meet the threshold criteria for protection of the
environment due to the potential for plant root intrusion and were screened from further evaluation in the
FS.
7-9
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Table 7-3. Comparative Analysis of Remedial Alternatives Using the Evaluation Criteria.
Criteria
Alternative I
No action
Alternative 3a
Engineered cover
Alternative 4a:
Conventional excavation and
off-site disposal at INEEL
Soil Repository or RWMC
Alternative 4b:
Conventional excavation and
off-sile disposal at private
facility
Alternative 5:
PliyloicmeUialion
()vccall nrdlcciion of human health and the environment
Human health
pioicclion
No reduction in
risk.
Environmental
protection
Allows possible
migration of
contaminated
surface soil by wind
and surface water
erosion.
f.inipliance v»ilh ARARi
/Uiiun-ipccific
Idaho Fugitive Dust
Lmissiuns-IDAPA
1601 01.650 etseq.
Idaho Hazardous
Waste Management
Aci-IDAPA
1601 OSOOSclseq.
Idalio Hazardous
Waste Management
Aot-IDAPA
16 01.05.006 el seq.
Would not meet
ARAK because no
contiols would be
implemented
NA
NA
Engineered cap would prevent
direct exposure to
contaminated soil and debris
for over 130 years. Minimal
exposure risks during cap
construction.
Provides effective protection
for over 130 years. Minimal
environmental impacts during
construction.
Will meet AKAK by
eliminating potential fur
windblown soil contamination
NA
NA
Eliminates potential
exposure from contaminated
soil at site. Proteciiveness is
based on completely
removing contamination
from site. Short-term risk is
moderate due to direct
exposure during excavation.
Eliminates contamination
from site.
Will meet ARAR by
eliminating potential for
windblown soil
contamination
Soil simples would be
collected and analyzed so
wastes can be regulated as
necessary
NA
Eliminates potential
exposure from contaminated
soil at site. Profeclivcncss is
based on completely
removing contamination
from site. Short-term risk is
moderate due to direct
exposure during excavation.
Eliminates contamination
from site.
Will meet AKAK by
eliminating potential for
windblown soil
contamination
Soil samples would be
collected and analyzed so -
wastes can be regulated as
necessary
NA
Treatment reduces the
potential exposure from
contaminated soil al silc to
acceptable levels j.ongicrm
protcclivcncss is based on
reduction ot the
concentrations. Shurt-icrm
risk is low.
The treatment reduces the
contaminant concentrations
below the RGs.
Will meet AKAK by
eliminating potential for
windblown suit couiajiiinalion
both during and alter
treatment.
Plant samples would be
collected and analyzed so
wastes can be regulated as
necessary
Plain samples will be tested
by using approved methods (u
delenninc if the plant mailer
is hazardous waste
7-10
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Table 7-3. (continued).
Alternative 1 Alternative 3a
(f iieria N» action Engineered cover
General Requirements NA NA
for shippers 49 CFR
173
Alternative 4a:
Conventional excavation and
off-site disposal at INI-I2L
Soil Repository or RWMC
Placards would be applied to
the trucks during transport
on-INEEL facility
Alternative 4b:
Conventional excavation and
off-site disposal at private
facility
Placards would be applied to
the trucks and rail cars
during transit to the off-
INEE1. facility.
Alternative 5:
Phytoicnicdialion
Trucks used to lianspoit (lie
plant nullerial will have the
have the appropriate placuids.
Natiuncal Contingency
I'lan -Procedures for
planning and
implementing off-site
response actions
(40CFR 300.440)
NA
NA
NA
NA
If determined lobe a
hazardous waste, the ash Iron)
incinerated plant matter will
be shipped off-site to a KCRA
Subtitle C landfill which is
operated in compliance wild
RCRA
Chemical-specific
NESIIAPS-40CFR
61 92
Kules for the Control
of Air Pollution in
luaho-IUAPA
16.01.01.585 and .586
Location-specific
National Historic
Preservation Act-16
UbC 470
NA
Would not meet
ARAK it toxic
metals or organics
were present in
fugitive dust,
because no controls
would be
implemented.
NA
Would meet ARAR by
controlling the source term for
all cxpoiuie pathways
Would meet ARAR through
use of engineering comiols
These sites are in areas that are
SO years old in previously
disturbed areas Ifcultual
artifacts are encountered. DOE
will stop work and conduct a
detailed survey of the area.
Would meet ARAR by
eliminating the source term
for all exposure pathways
Would meet ARAR by
removing contamination
from site.
These sites are in areas that
are 50 years old in
previously disturbed a/eas.
Ifcullual artifacts are
encountered, DOI: will slop
work and conduct a detailed
survey of the area.
Would meet ARAR by
eliminating the source term
for all exposure pathways
Would meet ARAR by
removing contamination
from sile.
These sites are in areas that
are 50 years old in
previously disturbed areas
If cullual artifacts are
encountered, DOE will slop
work and conduct a detailed
survey of the area.
Would meet ARAR by
treating the soils so the
contaminants are below the
RGs for all exposure
pathways
Would meet ARAR by
treatment to reduce the
contamination to levels below
the Kdi
These sites are in areas that
are 50 years old in previously
disturbed aicas Ifcullual
artifacts arc encountered,
IM)i: will slop woik and
conduct a detailed survey of
the uica
7-11
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Table 7-3. (continued).
10
Alternative 1
Criteria No action
To Be Considered
Alternative 3a
Engineered cover
Alternative 4a:
Conventional excavation and
off-site disposal at INEEL
Soil Repository or RWMC
Alternative 4b:
Conventional excavation and
off-site disposal al private
facility
Alternative 5:
I'hyioicmedialion
Environmental Would not meet
Protection, Safety, and TBC because np
Health Protection controls would be
Standards-UOE Order implemented
4401
Radioactive Waste
Management-Dot'
Order 5820.2A and
new order 435.1 in FY
2000
Would not meet
TBC because no
controls would be
implemented.
Radiation Protection of Would not meet
the Public and TBC because no
Environnienl-DOE control* would be
Older 231 I implemented.
I iiim-'iciiii effectiveness and pcniMiiciKt
Magnitude of residual Nuiliangc IIOIM
lisk existing risk
Adequacy and No conl/ol and,
reliability of controls therefore, no
reliability
Would meet TBC through use
of engineering and instilu|ional
controls and best management
practices.
Would meet TBC through use
of engineering and institutional
controls and best management
practices.
Would meet TBC through use
of engineering and institutional
controls and best management
practices.
Souice-io-reccptor pathways
eliminated while cap remains
in place. Inherent hazards of
inorganics would remain. Cs-
137 within IE-04 acceptable
range alter 130 years
Limited access to contaminated
soil and environmental
monitoring effective only
during institutional period of
control (al least 100 years).
Barrier cont/ol over
contaminated soil for al least
130 years
Would meet TBC through
use of engineering controls
and best management
practices..
Would meet TBC through
use of engineering controls
and best management
practices.
Would meet TBC through
use of engineering controls
and best management
practices.
No reduction in contaminant
concentrations. All
contaminated soils would be
removed from site and
transported for disposal at
another facility.
Disposal facility is assumed
to provide adequate and
reliable control over
disposed soil and debris.
Would meet TBC through
use of engineering controls
and best management
practices..
Would meet TBC through
use of engineering controls
and best management
practices.
Would meet TBC through
use of engineering controls
and best management
practices
Nn reduction in contaminant
concentrations All
contaminated soils would be
removed from site and
transported for disposal al
another facility.
Disposal facility is assumed
to provide adequate and
reliable control over
disposed soil and debris.
Would meet TBC through use
of engineering controls and
best management practices.
Would meet TIK' through use
of engineering controls and
best management practices.
Final disposal ol plant mailer
after incineration.
Would meet TBC through use
of engineering controls and
best management practices
Final incineration of biomass
would be conducted in an
appioycd facility.
Ill-mill licjlincm ol Ilie soil*
would result in auiljjiiinjjii
levels that are below the K(is
Phyloremcdiation treatment
has been successfully used in
mining applications
Contingency alternative could
be selected if
phyioremcdiation is not
working al AN1.-W
7-12
-------
Table 7-3. (continued).
Criteria
|
-------
Table 7-3. (continued).
Alternative 1
Criteria No action
Worker pioicciion No increase or
decrease in
potential risks lo lf»e
worker.
Environmental impacts No change from
existing conditions.
Alternative 3a
Engineered cover
Worker risk during barrier
installation is minor due to
shielding afforded by existing
clean soil and engineering
controls
Limited lo disturbances from
vehicle and material transport
Alternative 4a:
Conventional excavation and
off-site disposal at INtLl.
Soil Repository or RWMC
Worker risk is minimal after
the soil is removed and
meets the established RAOs.
Limited to disturbances
from vehicle and material
Alternative 4b:
Conventional excavation and
off-site disposal at private
facility
Worker risk is minimal after
the soil is removed and
meets the established KAOs
Limited to disturbances
from vehicle and material
Alternative 5:
I'liytorcmcdiation
Worker risk from exposure lo
contaminated soil during
farming activities will require
'administrative and
engineering controls.
Limited increase in animal
usage of the sites outside the
activities associated with
bonier construction. Limited
potential for airborne
contamination in (he form of
fugitive dust, due to use of
engineering controls.
transport activities
associated with excavation.
Limited potential for
airborne contamination in
the form of fugitive dust,
due lo use of engineering
controls.
transport activities
associated with excavation.
Limited potential for
airborne contamination in
the form of fugitive dust,
due lo use of engineering
controls.
ANL-W facility during the
phylorcmediation. Very small
potential for airborne
contamination in the form of
fugitive dust, due to use of
engineering controls and
irrigation.
'I line until action is
complete
NA
Approximately 12 to
15 months.
Approximately 18 to
24 months
Approximately 18 to
24 months.
lislimaled lo be 5 years based
on the use of multiple
plantings per field season
IninlcmcniiibililY
Ability lo construct
and operate
No construction or
operation.
Involves available construction
technology.
Somewhat difficult, due to
redundant and/or conflicting
safety requirements for
ANL-W and LMITCO.
Somewhat difficult, due lo
redundant and/or conflicting
safely requirements rom
both ANL-W and LMITCO
Potential scheduling
problems because of rail
shipment to off-site private
facility.
Small farming equipment is
readily available. Sue
application lo select plant
species, soil amenities,
irrigation schedules, and
disposal of biomass will be
determined per field season.
7-14
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Table 7-3. (continued).
Criteria
liasc of implementing '
additional action if
necessary
Ability to monitor
effectiveness
Ability to obtain
approvals and
Alternative 1
No action
May require repeal
of feasibility study/
record of decision
process.
,
Monitoring of
conditions is readily
implemented.
No approvals
required.
Alternative 3a
Engineered cover
Additional remedial actions
would be difficult, as the
barrier is intended to prevent
access lo contamination.
Barrier would require removal.
Barrier performance can be
monitored through radiation
surveys, and can be visually
assessed on the basis of
physical integrity.
No difficulties identified
Alternative 4a:
Conventional excavation and
off-Site disposal at INEEL
Soil Repository or RWMC
Shipment of the soil to an
on-siic disposal facility
would require interaction
between ANL-W and
LMITCO that could cause
delays in the schedule.
The effectiveness in
removing all contaminated
materials associated with
site is easily monitored.
Potentially difficult, due lo
additional requirements for
Alternative 4b:
Conventional excavation and
off-site disposal at pi i vale
facility
In addition lo co-ordinai ion
between ANI.-W and
LMITCo. the off-site
disposal facility would also
have lo be involved in the
discussions and scheduling.
The effectiveness in
removing all contaminated
materials associated with
site is easily monitored.
Potentially difficult, due 10
additional requirements for
. Alternative 5:
I'liylorcmcdiation
Use of this treatment
technology would nut inhibit
the use of a different
alternative later.
The effectiveness in removing
contaminants to levels below
the R(Js can be determined
through sampling Ontcllie
soil is treated future
monitoring would not be
required.
No difficulties identified.
coordinate with
regulatory agencies
Availability of services None required
and capacity
Darner design and services
reside within the DOE and are
consideied readily available lo
Ihe INLLL
environmental assessments,
safety analyses, and AKAKs
compliance.
Services available either
onsite or offsilc through
subcontractor.
environmental assessments,
safely analyses, and AKAKs
compliance.
Services available either
oniilc or olTsite through
subcontractor.
Services available cither
onsile or olhilc through
subcontractor
Availability of None required
equipment, specialists,
and mulciials
Availability of None required
technology
Cost (present worth!
See Table 9-2
NA - Not Applicable
Equipment and materials are
readily available at the INEEL
or within surrounding
communities
Readily available at Ihe INEEL.
See Table 9-2
Equipment and materials are
either available onsite,
through subcontractors or
will be purchased. Trained
specialists are available
within the communities
surrounding Ihe INEEL.
Readily available at Ihe
INEEL.
See Table 9-2
Equipment and materials are
cither available onsile,
through subcontractors or
will be purchased. Trained
specialists are available
within the communities
surrounding the INEEL.
Readily available at the
INEEL
See Table 9-2
Cquipmcnl and malciiuls arc
cither available onsile or
through subcontractors.
Readily available at ANI.-East
wiih experienced personnel.
See Table 9-2
7-15
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Table 7-4. Comparative Analysis of Remedial Alternatives.
Alternative
Evaluation Criteria 3a 4ai 4a: 4b 5
Overall Protection of Human Health and the Environment M«u M"u M«u M«" M«U
Compliance with Applicable and Relevant and Appropriate I I I I
Requirements
Long-term Effectiveness and Permanence O I I I
Short Term Effectiveness O I * > I
Reduction of Toxicity, Mobility, or Volume Through O O O O
Treatment
Implementability I
Cost (in millions) 7.6 5.9 5.9 13.1 2.8
= Best I = Good O = Worst
'- Using RWMC.
2 - Using the Proposed INEEL Soils Repository at WAG 3.
7.3.1.1 Overall Protection of Human Health and the Environment
The primary measure of this criterion is the ability of an alternative to achieve RAOs for the
sites. Since this is a threshold criterion, each alternative must be able to meet the RAOs in order for the
alternative to be retained. Alternatives 4a, 4b, and 5 meets the criteria and would provide the best
long-term protection of human health and the environment because the soils would be removed from
WAG 9 (Alternatives 4a and 4b) or the concentrations would be reduced to acceptable levels (Alternative
5). Alternatives 4a and 4b (conventional excavation and landfill disposal) would accomplish this by
removing the contaminated soil from the ANL-W site. Alternative 3a (engineered landfill at WAG 9)
meets the criteria because it would not prevent unacceptable exposure to cesium-137 after the 100-year
DOE control period. Alternative 1 (no action) would not prevent exposures resulting in risks greater than
1E-04, and is therefore eliminated from further consideration.
7.3.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
Compliance with ARARs is also a threshold criterion. Each alternative must be able comply
with all ARARs in order for the alternative to be retained. For this criterion Alternative 5 is ranked the
highest because the planting, harvesting and irrigating of the contaminated soils would result in no
emissions of fugitive dust. Alternatives 3a, 4a, and 4b are ranked equally, since all are considered
equally capable of achieving compliance through use of engineering controls to meet the State of Idaho
regulations for controlling emissions of fugitive dust and toxic substances. Alternatives 3a, 4a, and 4b
are also ranked equally in compliance with other ARARs.
7-16
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are also ranked equally in compliance with other ARARs.
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) implementabiliry; and (5) cost.
7.3.2.1 Long-term Effectiveness and Permanence
Alternative 5 would provide the highest degree of long-term effectiveness and permanence,
because the contamination would have been reduced to acceptable levels for this criterion. Alternative
4a and 4b provide the next highest degree of long-term effectiveness and permanence, because
contaminated soil exceeding cleanup goals would no longer exist at the sites. Alternative 3a would be
effective as long as the cap prevents human and biotic intrusion and controls erosion and leaching of
contaminants.
7.3.2.2 Reduction in Toxicity, Mobility, or Volume Through Treatment
Alternative 5 is the only treatment alternative that provides reduction in toxicity mobility or
volume through treatment. In addition to removing the contaminants from the soil, Alternative 5 also
reduces the volume of contaminants to be disposed. For phytoremediation, a large reduction in volume
is anticipated by incineration of the plant matter, incineration, and solidification of the ash as compared
to excavation and disposal of the contaminated soil. The other alternatives were ranked the lowest since
they do not reduce the toxicity, mobility, or volume of the contaminated soils through treatment.
However, Alternative 3a, 4a, and 4b do reduce the toxicity and mobility of the contaminants through
containment.
7.3.2.3 Short-term Effectiveness
These WAG 9 sites are not located near inhabited areas and no public roads are in the vicinity
Thus, no significant impacts to surrounding communities would be anticipated from exposure to
contaminants during remediation in the WAG-9 sites. However, there is a potential short-term impact to
workers who will be conducting the remedial action. Alternatives 4a, 4b, and 5 are equally ranked and
are higher than Alternative 3a, because the wastes would remain on site or would only have to be moved
once. Alternative 3a is ranked the lowest because the soils would have to b« handled twice, once for the
removal from the ditches and once when the soils are consolidated into the cap.
7.3.2.4 Implementability
Each of the alternatives retained for detailed analysis is technically implementable. The relative
ranking of the alternatives with respect to implementabiliry is shown in Table 7-4. Alternatives 3a, 4a.
7-17
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and 4b are equally ranked because they will require the procurement of a contractor to perform the
excavation, construction, transport of equipment, permits, and coordination with other on-site and
off-site contractors. These permits would consist of safe work permits, digging permits, radiation safe
work permits, and transportation placards. Alternative 5 is ranked the lowest because of the unknowns
associated with it meeting the RAOs within a cost effective time frame. The potential success of
Alternative 5 will be determined through bench-scale and field testing. If Alternative 5 is utilized,
ANL-W personnel can plant and harvest the phytoremediation plants and farming equipment is available
locally.
7.3.2.5 Cost
Separate line item costs are developed for the primary components of each remedial action
alternative, such as monitoring; capping; excavation; disposal; and reporting requirements such as
remedial design/remedial action scope of work, remedial design/remedial action work plans, safety
documentation, and'progress reports. The estimated present worth cost of each alternative is shown in
Table 9-3 and the relative ranking for this criterion is shown in Table 7-4.
7.3.3 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
have strong opposition.
7.3.3.1 State Acceptance
The IDHW has been involved in the development and review of the RI/FS report, the Proposed
Plan, and this ROD. All 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 alternative of phytoremediation for the eight areas
that have been identified for remedial action, as well as the 33 No Action sites in this ROD. The IDHW
is signatory to the ROD with DOE and EPA.
7.3.3.2 Community Acceptance
Community participation in the remedy selection process includes participation in the public
meetings held in January 1998 and review of the Proposed Plan during the public comment period of
January 12 through March 12, 1998. Community acceptance is summarized 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.
As shown in the Responsiveness Summary, most of the public agreed with the selection of
Alternative 5, phytoremediation to clean up the eight areas at ANL-W. The commentors also expressed
concern over the possible selection of non-native plants, possible increased exposure to ecological
receptors that may browse on the plants, and incineration and ash disposal issues. The agencies have
7-18
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addressed these comments and, where applicable, have incorporated these comments into this ROD
Other comments w,|| be addressed during .mp.ementation and interpretation oTh
7-19
-------
Tliis p;i--i.- intentionally left blank
7-20
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8 SELECTED REMEDY
The results of investigations and risk assessments at WAG 9, OL" 9-04, at FNEEL indicate that
eight areas pose unacceptable risks to human health and/or the enviornment. Two areas have human
heath carcinogenic risks greater than 1 in 10,000 (1E-04), five areas have unacceptable HQs greater than
10 times the HQ for INEEL background, and one area has both human and ecological risks. The
investigation also showed that 33 FFA/CO sites do not exceed a 1E-04 carcinogenic risk or have HQ less
than the 10 times the HQ for [NEEL background, and therefore require no action. It is important to note
that there are no unacceptable cumulative effects from the WAG 9 sites, and the remedial actions being
recommended address individual risks as well as prevent cumulative risks to a future residential receptor
at WAG 9. Based on consideration of the requirements of CERCLA, the detailed analysis of
alternatives, and public comments, DOE, EPA, and IDHW have a selected and a contingent alternative
for remediation of the sites contained in this ROD. The justification for the selection of the remedial
alternatives is discussed in the following sections.
8.1 Ranking of Alternatives
Table 7-4 provides a summary of how the alternatives rank 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.
Although the contaminated soil types (radiologically- and inorganically-contaminated soil) were
evaluated separately against the evaluation criteria, both soil types produced similar rankings of the
remedial alternatives. The overall ranking order of the alternatives is 5, 4a, 3a, and 4b. Thus, the
information presented in the following paragraph presents the results of the ranking of soil types along
with the justification for the selected alternative.
Each of the retained alternatives with the exception of the no action alternative (Alternative I),
would meet the remedial action objectives associated with the protection of human health and the
environment. Alternative 1, No Action, does not meet the threshold criteria of overall protection of
human health and the environment, but it serves as a baseline to determine the benefits of the other
alternatives. Alternative 2, Limited Action and Alternative 3b, Native Soil Cap were screened prior to
the detailed analysis of the alternatives because they do not meet the threshold criteria of overall
protection of human health and die environment. However, certain limited action items such as access
restrictions, land use restrictions, and monitoring are employed in Alternatives 3a, 4a, and 5.
Alternatives 3a, 4a, and 4b meet all the remedial action objectives and provide overall protection of
human health and the environment. But, these alternatives do not use treatment to reduce die toxic icy,
mobility, or volume of the contaminants. They do however eliminate the potential exposure of human
and ecological receptors to the contaminants. Although Alternatives 3a, 4a, and 4b use similar
containment technology to reduce the exposure of the contaminants to humans and the environment,
Alternative 4a was ranked higher than Alternatives 3a and 4b because of the lower present value costs.
Alternative 5 is the only alternative that reduces the toxicity, mobility, and volume of the contaminated
media through treatment. In addition, it is anticipated that the costs of using phytoremediation are less
than the costs of Alternatives 3 a, 4a, and 4b. Alternative 5 can be used for both radiologically and
inorganically contaminated soils and provides a barrier against windblown contamination. Alternative 5
best meet the first seven evaluation criteria and is therefore the preferred alternative. Alternative 5,
8-1
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reduces the mass of contaminated material that must be disposed of to less then one percent of the mass
of the contaminated soil. After the anticipated five field seasons for phytoremediation, the
concentrations of contaminants in the soils should meet the established RAOs and the soils will remain
under land use and access restrictions until they can be released for unlimited used. DOE anticipates that
this wil be in approximately 100 years from now (2098).
8.2 Selected Remedy
The selected remedial remedy for the eight WAG 9 areas with unacceptable risks to human
health and/or the environment is Alternative 5, phytoremediation. This alternative is the only alternative
that offered a permanent solution for reduction of the toxicity, mobility, or volume of the contaminated
material through treatment. This alternative is protective of human health and the environment, was
ranked the best for three of the Five modifying criteria including; long-term permanence, reduction of
toxicity, mobility, or volume, and cost, and received generally favorable comments from the IDHW and
public during the public involvement process. Monitoring of the soil, groundwater, and vegetation will
continue for 20 years (2018) approximately 15 years after the RGs are met for each site in accordance
with DOE Orders and the ANL-W Environmental Monitoring Plan, (ANL-W, 1998). The soil,
groundwater, and vegetation monitoring results collected semi-annually will determine trends of low
level radionulcide and inorganic contaminant levels around the ANL-W facility. After the RGs are met,
CERCLA 5 year reviews would be required to ensure that the assumption of DOE control of the INEEL
lands is still applicable. DOE anticipates that these five-year reviews will consist of a memorandum
summarizing a checklist-driven inspection of the signs, fences, and other physical features that assure
that DOE administrative controls are still in place. Phytoremediation would not be initiated on the
Sanitary Sewage Lagoons because they will remain in service until approximately the year 2033 when
the facility is scheduled for closure. Likewise, the Industrial Waste Pond phytoremediation will not be
initiated until the cooling water discharges from the Sodium Processing Facility are completed. The.
final sodium cooling water discharges are currently planned for 2002. This delay in phytoremediation
startup does not pose any unacceptable risks to human health and or the environment since these sites
would be in a wetted condition. The major components of the selected remedy for ANL-W are:
Completion of the phytoremediation workplan for the bench-scale testing
Conducting a bench-scale phytoremediation test of selected plant species at the sites that pose
unacceptable risks
Determine effectiveness and implementabiliry of phytoremediation based on results of bench-
scale testing
Collecting and analyzing of soil and plant samples from the two-year field season to determine
the effectiveness of phytoremediation on the ANL-W soils insitu
Harvesting, compacting, incinerating, and disposing of the above and below ground plant matter
in a permitted landfill
8-2
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Continue planting/harvesting process until RAOs are attained if the two-year field-scale testing
is successful
Installing access restrictions consisting offences, bird netting, and posting warning signs
Review of the selected remedy no less than every five years until the RAOs have been met
Implementation of DOE controls which limit residential land use for at least 100 years from now
(2098).
Implementation of this alternative will increase the short-term human and ecological exposure to
the contaminants. These short-term increases in exposure are estimated to last for five years and will
ultimately reduce the long-term exposure of the contaminants to humans or the ecological receptors.
Engineering controls will be used to reduce the short-term exposures to the human workers, while
fencing, covering, and harvesting methods will be optimized to reduce the short-term exposure to the
ecological receptors. These engineering controls will be further detailed and described in the RD Work
Plan for WAG 9.
In summary, phytoremediation has been selected as the remedial alternative for cleanup of the
eight areas at WAG 9 that pose unacceptable risks. Phytoremediation is an innovative treatment
technology that appears to be the most appropriate remedy for WAG 9. However, bench-scale
greenhouse testing and insitu field testing is needed to verify the technology's applicability for use on
WAG 9 soils. The bench-scale greenhouse tests are currently being conducted and the results will
indicate if the uptake rates are too low, or if it would take too long to meet the RGs. The results of the
bench-scale greenhouse testing will determine if the selected remedial remedy will be replaced with the
more conventional contingent alternative.
8.3 Selected Contingent Remedy
Alternative 4a, excavation and disp9$al at an on-lNEEL facility has been selected as the
contingent remedial remedy for the eight areas that pose unacceptable risks to human health and the
environment. This contingent remedial alternative has been selected because it offers'a proven
technology to meet the RGs. This contingent remedy would be implemented if the selected remedial
remedy (phytoremediation) does not prove adequate for use on the WAG 9 soils. Alternative 4a involves
the physical removal of the contaminated soil at the eight areas at WAG 9. The soils will be transported
to either the proposed FNEEL Soils Repository or the RWMC facility. The final determination of which
of these two facilities would be used will be determined during the remedial design phase after die ROD
has been signed. The excavation with on-INEEL disposal alternative offers the highest degree of
implementability and the second lowest costs of the retained alternatives. It is estimated that the
excavation and disposal will take two years to complete after being initiated. DOE will continue soil, air,
and groundwater monitoring for 20 years from now (to 2018) for the ANL-W site in accordance with
DOE Orders and the ANL-W Environmental Monitoring Plan. (ANL-W, 1998). The soil, groundwater.
8-3
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and vegetation monitoring results collected semi-annually will determine trends of low level
radionulcide and inorganic contaminant levels around the ANL-W facility. After the remediation goals
are met, CERCLA 5 year reviews would be required to ensure that the assumption of DOE control of the
FNEEL lands is still applicable. DOE anticipates that these five-year reviews will consist of a
memorandum summarizing a checklist-driven inspection of the signs, fences, and other physical features
that assure that DOE administrative controls are still in place. The major components of the contingent
remedy for ANL-W are:
Contaminants in the waste areas will be excavated and transported to either the R \V~MC or the
INEEL Soils Repository for on-TNEEL disposal
Verification sampling would be used to validate that the remaining soil concentrations are below
the RAOs
Review of the remedy no less than every five years until the RAOs have been met
Implementation of DOE controls which limit residential land use for at least 100 years from now
(2098).
The No action alternative is reaffirmed and selected as the appropriate alternative for the
remaining 33 areas at the ANL-W facility. These 33 areas have risks that are at acceptable levels based
on the information gathered during the remedial investigation.
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 ANL-W. Upon
discovery of a new contaminant source by DOE, FDHW, or EPA, that contaminant source will be
evaluated and appropriate response action taken in accordance with the FFA/CO.
8.4 No Action Sites
The No Action alternative was reaffirmed as the appropriate alternative for 35 areas, 33 areas
from WAG 9 and two sites from WAG 10. This alternative was chosen because there are no known or
suspected contaminant releases, contaminants exceeding acceptable levels, or previous cleanups resulted
in acceptable 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 these 36 No Action sites do not pose a
cumulative risk. These 35 areas are listed below.
Operable Unit-None
ANL-10 Dry Well between T-l and ZPPR Mound
ANL-11 "Waste Retention Tank 783 (never used)
ANL-12 Suspect Waste Retention Tank by 793 (removed 1979)
ANL-14 Septic Tank and Drain Fields (2) by 753 (tank removed 1979)
ANL-15 Dry Well by 768
ANL-16 ' Dry Well by 759 (2)
ANL-17 Dry Well by 720
ANL-18 Septic Tank and Drain Field by 789 (removed 1979)
ANL-20 Septic Tank and Leach Field by 793
ANL-21 TREAT Suspect Waste tank and Leaching Field (non-radioactive)
ANL-22 TREAT Septic Tank and Leaching Field
ANL-23 TREAT Seepage Pit and Septic Tank W of 720 (filled 1980)
ANL-24 Lab and office Acid Neutralization Tank
8-4
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ANX-25
ANL-26
ANL-32
ANL-33
ANL-27
Interior Building Coffin Neutralization Tank
Critical Systems maintenance Degreasing Unit
TREAT Control Building 72! Septic Tank and Leach Field (present)
TREAT Control Building 72 i Septic Tank and Seepage Pit (removed 1978)
Plant Services Degreasing Unit
Operable Unit-9-Ol
ANL-19
ANL-28
ANL-29
ANL-30
ANL-36
ANL-60 '
ANL-61
ANL-62
ANL-63
Sludge Pit W of T-7 (Imhoff Tank) (filled in 1979)
EBR-II Sump (regeneration)
Industrial Waste Lift Station
Sanitary Waste Lift Station
TREAT Photo Processing Discharge Ditch
Knawa Butte Debris Pile
E B R-11 Iran 5 form er Yard
Sodium Boiler Building (766) Hotwell
Septic Tank 789-A
Operable Unit-9-02
ANL-08 EBR-II Leach Pit (radioactive)
Operable Unit-9-03
ANL-05
ANL-31
. ANL-34
ANL Open Burn Pits # 1 #2 and #3
Industrial/Sanitary Waste Lift Station (industrial side not used)
Fuel Oil Spill by building 755
Operable Unit-9-04
ANL-01
ANL-53
Operable Unit-10-06
Only the Ditch C portion of ANL-01
Cooling Tower Riser Pits
ANL-W Stockpile site
ANL-W Windblown Area
8.5 Remediation Goals
The purpose of selecting a remedial response action in this ROD is to formally document the
remedial alternative and contingent alternative that will be implemented at WAG 9. The successful
completion of the remediation technology will reduce the contaminant risks to acceptable levels for the
human and environmental receptors. For the eight areas that require an action, phytoremediation is the
selected treatment technology. Excavation and disposal has been selected as the contingent remedial
alternative. The RGs are die same for either remedial alternative selected. These RGs are shown in
Table 7-1 for each of the eight areas at ANL-W. Confirmation soil samples will be collected after the
phytoremediation field seasons, or after excavation and disposal in order to ensure that the cleanup meets
or exceeds the RGs.
8-5
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8.6 Estimated Cost Details for the Selected Remedy
^
for protection of human health and the environment. a'temat'VeS ** mrt the
8-6
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Table 8-1. Detailed Cost Estiamte Summary- Sheet for Alternative 3, Containment.
Cost Elements
WAG 9 Management Costs
CERCLA RD/RA Oversight
Documentation Package
Site surveying
Final Design Bid Package
Safety Analysis Report
Verification Sampling Plan
Verification Sampling Costs
Safe Work Permit
Radiation Work Permit
Excavation Permit
RCRA Subtitle D Landfill Application
Construction Costs
Mobilization and Demobilization
Construction of Base
Density Testing of Base
Soil Removal
Backfill Site to Grade
Re-vegetation
Cap Construction
WAG 9 Construction Oversight
Fencing
Surface Water Diversion
Operations and Maintenance Costs
Post-closure Management
Monitoring -
WAG 9, Five-year Reviews
Total in 1998 dollars
Total in Net Present Value dollars*
Estimated Costs (S)
Subtotal
S
S
S
s
S
s
$
s
$
Subtotal
$
$
$
$
$
S
$
$
$
$
Subtotal
$
S
$
Subtotal
S
S
51,526,974
47,250
7,000
8, '50
7,000
10,500
3,500
3,500
3,500
35,000
5126,000
70,000
1,161,944
7,000
1,161,944
1,619,444
192,350
958,000
70,000
150,600
30,120
54,963,913
812,500
1,196,000
338,000
52,346,500
8,963,387
7,580,000
* Net present value costs are determined by taking the cost estimates for performing the work in 1998 and assumes
a constant 5% inflation rate to determine the projected future costs between 1999 and 2098. The total of these
future costs are then totaled and a 5% discount rate is applied to determine the act present value.
8-7
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Table 8-2. Detailed Cost Estimate Summary Sheet for Alternative 4a, Excavation and Disposal at the
[NEEL Soils Repository.
Cost Elements
W.\G 9 Management Costs
CERCLA RD/RA Oversight
Documentation Package
Site surveying
Final Design Bid Package
Safety Analysis Report
Verification Sampling Plan
Verification Sampling Costs
Safe Work Permit
Radiation Work Permit
Excavation Permit
Waste Acceptance Report to LMITCO
Construction Costs
Mobilization and Demobilization
Soil Removal
Soil Transport to INEEL Repository
Tipping Fee/cy
Backfill Site to Grade
Re-vegetation
Operations and Maintenance Costa
Post-closure Management
Monitoring
WAG 9, Five-year Reviews
Total in 1998 dollar* .
Totai in Net Present Value dollars*
Estimated Costs ($)
Subtotal
S
$
$
$
$
$
$
$
$
Subtotal
$ .
S
S
$
$
$
Subtotal
S
S
S
Subtotal
S
S
SU32.496
31,500
7.000
8,750
7,000
10,500
3,500
3,500
3,500
52,500
5127,750
70,000
. 1,161,944
1,161,944
232,388
1,619,444
192,350
$4,438,070
203,125
239,200
338,000
$780,325
6,578,641
5,876,000
* Net present value costs are determined by taking the cost estimates for performing the work in 1998 and assumes
a constant 5% inflation rate to determine the projected future costs between 1999 and 2098. The total of these
future costs are then totaled and a 5% discount rate is applied to determine the net present value.
8-8
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Table 8-3. Detailed Cost Estimate Summary Sheet for Alternative 4a, Excavation and Disposal at
RWMC.
Cost Elements
WAG 9 Management Costs
CERCLA RD/RA Oversight
Documentation Package
Site surveying
Final Design Bid Package
Safety Analysis Report
Verification Sampling Plan
Verification Sampling Costs
Safe Work Permit
Radiation Work Permit
Excavation Permit
Waste Acceptance Report to LMITCO
Construction Costs
Mobilization and Demobilization
Soil Removal
Soil Transport to RWMC
Tipping Fee/cy
Backfill Site to Grade
Re-vegetation
Operations and Maintenance Costs
Post-closure Management
Monitoring
WAG 9, Five-year Reviews
Total in 1998 dollars
Total in Net Present Value dollars*
Estimated Costs (S)
Subtotal
$
$
$
S
S
S
S
$
S
Subtotal
$
$
$
S
$
$
Subtotal
$
S
S
Subtotal
S
S
SU32,496
31,500
7,000
8,750
7,000
10,500
3,500
3,500
3,500
52,500
$127,750
70,000
1,161,944
1,549,259
0
1,619,444
192,350
$4,592,997
203,125
239,200
338,000
$780^25
6,733,568
6,110,000
* Net present value costs are determined by taking the cost estimates for performing the work in 1998 and assumes
a constant 5% inflation rate to determine the projected future costs between 1999 and 2098. The total of these
future costs are then totaled and a 5% discount rate is applied to determine the net present value.
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Table 8-4. Detailed Cost Estimate Summary Sheet for Alternative 4b, Excavation with Disposal at
Private Faciltiy.
Cost Elements
WAG 9 Management Costs
CERCLA RD/RA Oversight
Documentation Package
Site surveying
Final Design Bid Package
Safety Analysis Report
Verification Sampling Plan
Verification Sampling Costs
Safe Work Permit
Radiation Work Permit
Excavation Permit
Waste Acceptance Report .to LMITCO and
Private Faciltiy
Construction Costs
Mobilization and Demobilization
Soil Removal
Soil Transport to Railyard
Tipping Fee/cy
Backfill Site to Grade
Re-vegetation
Operations and Maintenance Costs
Post-closure Management
Monitoring
WAG 9, Five-year Reviews
Total in 1998 dollars
Total in Net Present Value dollars*
Estimated Costs (S)
Subtotal
S
S
s
S
$
S
S
$
$
Subtotal
$
S
$
$
S
$
Subtotal
S
$
$
Subtotal
S
S
52,905,696
31,500
7,000
8,750
7,000
10,500
3,500
3,500
3,500
5:,500
S127,750
70,000
1,161,944
1,161,944
5,422,407
1,619,444
192,350
59,628,089
203,125
239,200
338,000
5780,325
13,441,860
13,126,000
Net present value costs are determined by taking the cost estimates for performing the work in 1998 and assumes
a constant 5% inflation rate to determine the projected future costs between 1999 and 2098. The total of these
future costs are then totaled and a 5% discount rate is applied to determine the net present value.
8-10
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Table 8-5. Detailed Cost Estimate Summary Sheet for Alternative 5, Phytoremediation.
Cost Elements
WAG 9 Management Costs
CERCLA RD/RA Oversight
Documentation Package
Site surveying
Final Design Bid Package
Safety Analysis Report
Verification Sampling Plan
Verification Sampling Costs
Safe Work Permit
Radiation Work Permit
Excavation Permit
Waste Acceptance Report to LMITCO
Construction Costs
Specialized Equipment Cost
Prepare Soil for Planting
Planting/growing season
Irrigating/growing season
Fertilizing/growing season
Harvesting/growing season
Bailing/growing season
Rad Surveys/growing season
Transport to FNEEL WERF Incinerator/season
Additional Four Year Phyto Costs
Fencing
Surface Water Diversion
Operations and Maintenance Costs
Post-closure Management
Monitoring
WAG 9, Five-year Reviews
Total in 1998 dollars
Total in Net Present Value dollars*
Subtotal
Estimated Costs (S)
5528,259
S 8,400
$
$
S
$
S
$
S
S
Subtotal
$
$
$
S
S
$
S
$
S
S
$
S
Subtotal
$
$
S
Subtotal
S
S
7,000
8,750
7,000
21,000
3.500
3,500
3,500
35,000
597,650
300,000
28,852
28,852
57,705
' 14,426
28,852
28,852
12,022
28,852
913,662
150,600
30,120
Sl,622,795
203,125
239,200
338,000
5780,325
3,029,029
2,824,000
Net present value costs are determined by taking the cost estimates tor performing the work in 1998 and assumes
a constant 5% inflation rate to determine the projected future costs between 1999 and 2098. The total of these
future costs are then totaled and a 5% discount rate is applied to determine the net present value.
8-11
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8-12
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STATUTORY DETERMINATIONS
The selected and contingent remedy for remediation of the eight WAG 9 areas meets the
statutory requirements for CERCLA § 121, the regulations contained in the NCP, and the requirements
of the FFA/CO for the INEEL. Both 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
practical, and that the implemented action be cost effective. Finally, the statute includes a preference for
remedies that employ treatment to permanently and significantly reduce the toxicity, mobility, or volume
through treatment.
Phytoremediation works well for sites that have relatively shallow contamination over a large
area at concentrations slightly above the cleanup levels. This is the case for the eight areas at WAG 9.
Two of these areas that have low levels of radionuclide contamination, five areas have slightly elevated
levels of inorganics, and one area has both low levels of radionuclides and inorganics. It is anticipated
after the remedial action, none of the 39 total sites at WAG 9 will have contaminated soils and sediments
left in place at levels associated with a risk greater than 1E-04 or a hazard quotient greater that 10 times
the background hazard quotient. However, after the remediation goals are met, CERCLA 5 year reviews
would be required to ensure that the assumption of DOE control of the INEEL lands is still applicable.
9.1 Protection of Human Health and the Environment
As previously described in Section 8, both the selected phytoremediation and the contingent
excavation and disposal remedies can meet the RGs described in Table 7-1 that ensure protection of
human health and the environment. The phytoremediation alternative will utilize treatment to remove
contaminants from soils to levels at or below the RGs. While the contingent alternative excavation with
on-INEEL disposal, will ensure protection of human health and the environment by physically removing
the contaminated soil to levels below the RGs.
9.2 Compliance with ARARs and To Be Considered
Applicable requirements are those cleanup standards, standards of control, and other substantive
environmental protection requirements, criteria, or limitations promulgated under federal or state law
which specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or
other circumstance at a CERCLA site. Relevant and appropriate requirements are those same standards
mentioned for applicable requirements, except while not applicable at the CERCLA site, address
problems or situations sufficiently similar to those encountered at the site such that their use is well
suited to the particular site.
Three types of ARARs exist: location-specific, action-specific, and chemical-specific. In
general, location-specific ARARs place restrictions on the concentration of hazardous substances or the
conduct of activities solely because they occur in special locations. Action-specific ARARs are usually
9-1
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technology or activity based requirements or limitations on actions or conditions involving specific
substances. Chemical-specific ARARs are health or risk-based numerical values or methodologies that
result in the establishment of numerical values. The values establish the acceptable concentrations of
chemicals or substances that may be found in or discharged to the environment.
Documents that are not legally binding are identified as To-Be-Considered (TBC) guidance or
procedures documents. Both the selected phytoremediation and the contingent excavation and on-
fKEEL disposal facility meet the TBC procedures or guidance documents that were identified by the
agencies. The following two sections identify the specific ARARs and TBCs that were considered for
the selected and contingent alternatives to be remediated at WAG 9.
9.2.1 Selected Remedy Compliance with ARARs
Implementation of phytoremediation remedy will be designed to comply with all chemical-,
action-, and location-specific Federal and State ARARs, and TBCs as shown in Table 9-1. Table 9-1
lists each the ARAR statutes, specific citation reference, reason why the ARAR is retained, relevancy,
and how DOE will attain compliance with the ARAR. In addition to including the ARARs in Table 9-1,
the TBCs are also included. For the ANL-W facility, the TBCs consist of DOE Orders which act as
guidance documents for work practices at DOE facilities. These DOE Orders are TBCs and are used in
the absence of applicable state or federal regulations. As shown in Table 9-1, all of the ARARs and
TBCs for the selected phytoremediation remedy can be met.
Other Federal and State laws are not included as ARARs for WAG 9 but may be invoked during
future phases of the phytoremediation remedy. The future phases involve the disposal of ash at the
Waste Experimental Reduction Facility (WERF) from the incineration of the contaminanted plant matter
generated during phytoremediation. The resultant ash will be tested and depending on the results, either
be disposed of at an approved Hazardous waste Treatment, Storage, and Disposal facility or a subtitle D
landfill. The sampling and disposal of the incinerated ash will be conducted under the standard operating
procedures outlined in the latest revision of the Reusable Property, Recyclable Materials, and Waste
Acceptance Criteria (RRWAC) document. The two action-specific laws, IDAPA 16.01.05.008 (40 CFR
264) -"Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal
facilities" and IDAPA 16.01.05.011 (40 CFR 268)-"Land Disposal Restrictions" have not been included
as ARARs but may become applicable to the disposal facility if the incinerated ash is found to be a land
disposal restricted hazardous waste. Another action specific law, IDAPA 16.01.05.006 (40 CFR 262.34)
"Accumulation of Waste" may become applicable if plant matter is determined to be a hazardous waste.
and if a large quantity of plant matter must be accumulated at ANL-W prior to shipping. One chemical-
specific law, IDAPA 16.01.11.200-Idano Groundwater Quality Rule" has not been included as an ARAR
but may become applicable if future groundwater concentrations exceed those levels that were predicted
in the OU 9-04 Comprehensive RI/FS. Currently DOE does not exceed any of these regulated
groundwater concentrations at WAG 9 and does not expect to exceed them in the future. However, DOE
will continue with groundwater monitoring in accordance with the ANL-W Environmental Monitoring
Program.
9.2.2 Contingent Remedy Compliance with ARARs
Implementation of the contingent remedy of excavation with on-INEEL disposal will comply
with all chemical-, action-, and location-specific Federal and State ARARs, and TBCs as shown in Table
9-2
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Table 9-1. Evaluation of ARARs and TBC compliance for the selected remedy- Alternative 5. phytoremediation.
ARAR Statute
Citation
Reason
Uelevancy
Attained by
Action
Idaho Fugiiive Dust Emissions IDAPA 16.01.01.650 To control dust during excavation/farming
operations.
Idaho I lazardous Waste
Management Act
Idaho Hazardous Waste
Management Act
General Requirement for
Shippcis
National Contingency Plan -
Procedures for planning and
implementing off-site response
actions
IDAPA 16.01.05.005
(40 CFR
261 >"Identification
and Listing of
Hazardous Waste"
IDAPA 16.01.05.006
(40 CFR
262.11)"Hazardous
Waste Determination"
49CKR 173
40 Cl R 300.440
All plant materials will need to be sampled
for hazardous materials prior to shipment to
an incinerator.
All waste that could potentially contain
hazardous constituents must be sampled
using approved methods.
DOE will have to comply with the
requirements fur packaging and transporting
ol radioactive and hazardous material to an
incinerator.
The statute will apply if incinerated ash is a
RCRA regulated hazardous waste and is
shipped off-site for disposal.
Applicable Application of water and/or chemical dust
suppressants to land disturbed by excavation and/or
farming operations.
Applicable Plant material samples will be collected and
analyzed to determine if the plant matter is
regulated hazardous waste.
Applicable Plant material samples will be tested using approved
EPA methods to determine if the plant mutter is
regulated as a hazardous waste.
Applicable These packaging and transportation regulations will
be met by placing the waste in appropriate shipping
container and applying the appropriate placards.
Applicable If determined to be a ha/^irdous waste, the ash will
be shipped off-site to a RCRA Sublitle C landfill
which is operated in compliance with RCRA.
Chemical
NESHAPS-Radionuclides other 40 CFR 61.92
than Radon-222 and Radon-220
at DOE facilities-Emission
Standard
Limits the exposure of radioactive
contaminant release to 10 mrem/year for the
off-site receptors.
Applicable Monitors for airborne radionuclides are currently
installed around the ANL-W facility and can be
supplemented with additional portable monitors if
necessary. Dust control measures will also help
limit the release of radioactive contaminants.
9-3
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Table 9-1. (Continued).
AKAK Statute
Citation
Reason
Relevancy
Attained by
Rules for the Control of Air
Pollution in Idaho
Location
Archeological and Historic
Preservation Act
IDAPA 16.01.01.585
and 586
16 USC 470
Idaho rules governing the release and
verification of carcinogenic and
noncarcinogenic contaminants into the air.
Applicable The phytoremediaiton will add live vegetation as a
soil cover material that will prevent the release of
dust/air pollution due to wind erosion. Air
monitoring will be used lo verify that the limits
specified in 585 and 586 are not exceeded.
This will be applicable if unexpected cultural Relevant and The areas at WAG 9 that will be remediated are less
artifacts are uncovered during
excavation/farming operations.
Appropriate than 50 year old man made ditches and ponds and
have not been identified as having cultural
significance. If cultural artifacts are encountered.
DOE will slop work and conduct a detailed survey
of the area.
To Be Considered
Environmental Protection, DOE Order 440.1
Safety, and Health Protection
Standards
DOE Orders for protecting workers.
Radioactive Waste Management DOE Order 5820.2A DOE Orders provide guidance on disposal of
and 435.1 in FY 2000 low-level radioactive waste.
Radiation Protection of the
Public and Environment
DOE Order 231.1
DOE Orders that provide guidance on
radiological environmental protection and
guidelines on cleanup of residual radioactive
material prior to release of the property.
To Be Worker compliance with Standard Operating
Considered Procedures specified in the DOH Order-based
Environmental Safety and Health manual ensures
safe remediation activities.
To Be Worker compliance with Standard Operating
Considered Procedures specified in the DOE Order-based
Environmental Safety and Health manual and the
Waste Handling manual ensures safe packaging and
disposal of low-level radioactive waste.
To Be Worker compliance with Standard Operating
Considered Procedures specified in the DOE Order-based
Environmental Safely and Health manual ensures
protection of the public and enviomment from
radiological hazards.
-------
Table 9-2. ({valuation of ARAKs and TBC compliance for the contingent remedy - excavation and On-INKI-l. disposal of contaminated soils.
ARAK Statute
Citation
Reason
Relevancy
Action
Idaho Fugitive Dusi Emissions IDAPA 16.01.01.650 To control dust during excavation operations. Applicable
General Requirements for
Shippers
49 CFR 173 DOE will have to comply with the requirements
for packaging and transporting of radioactive
and hazardous material to on-INEEL disposal
site.
Applicable
Attained by
Application of water and/or chemical dust
suppressants to land disturbed by
excavation/trucking operations.
These packaging and transportation regulations will
be met by placing the waste in appropriate shipping
containers and applying the appropriate placards.
Chemical
NESMAPS-Radionuclidesother 40 CFR 61.92
than Kadon-222 and Radon-220
at DOE facilities-Emission
Standard
Limits the exposure of radioactive contaminant
release to 10 mrem/year for (he off-site
receptors.
Rules for the Control of Air
Pollution in Idaho
IDAPA 16.01.01.585 Idaho rules governing the release and
and 586 verification of carcinogenic and
noncarcinogenic contaminants into the air.
Applicable Monitors for airborne radionuclides are currently
installed around the ANL-VV facility and can be
supplemented with additional monitors if necessary.
Dust control measures will limit the release of
radioactive contaminants.
Applicable The excavation and truction operations will use
water and chemical suppressants to limit (he release
of dust. Revegetation of the disturbed areas will he
completed after the excavations. Air monitoring
will be used to verify that the limits specified in
sections 585 and 586 are not exceeded.
9-5
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Table 9-2 (Continued).
ARAR Statute
Citation
Reason
Relevancy
Attained by
Location
Archeological and Historic 16 USC 470
Preservation Act
This will be applicable if unexpected cultural
artifacts are uncovered during excavation
operations.
Relevant and The areas at WAG 9 that will be remediated are less
Appropriate than 50 years old man made ditches and ponds and
have not been identified as having cultural
significance. If cultural artifacts are encountered,
DOE will slop work and conduct a detailed survey
of the area.
To Be Considered
Environmental Protection,
Safely, and Health Protection
Standards
DOE Order 440.1 DOE Orders for protecting workers.
Radioactive Waste Management DOE Order 5820.2A DOE Orders provide guidance on disposal of
and 435.1 in FY 2000 low-level radioactive waste.
Radiation Protection of the
Public and Environment
DOE Order 231.1
DOE Orders that provide guidance on
radiological environmental protection and
guidelines on cleanup of residual radioactive
material prior to release of the property.
To Be Worker compliance with Standard Operating
Considered Procedures specified in the DOK Order-based
Environmental Safety and Health manual ensures
safe remediation activities
To Be Worker compliance wiih Standard Operating
Considered Procedures specified in the DOE Order-based
Environmental Safety and Health manual and the
Waste Handling manual ensures safe packaging and
disposal of low-level radioactive waste.
To Be Worker compliance with Standard Operaling
Considered Procedures specified in the DOE Order-based
Environmental Safety and Health manual ensures
protection of the public and enviomment from
radiological hazards.
9-6
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9-2. Table 9-2 lists each the ARAR statutes, specific citation reference, reason why the ARAR is
retained, relevancy, and how DOE will attain compliance with the ARAR. In addition to including the
ARARs in Table 9-2, the TBCs are also included. For the ANL-W facility, the TBCs consist of DOE
Orders which prescribe minimum standards for work practices at DOE facilities. These DOE Orders are
TBCs and are used in the absence of applicable state or federal regulations. As shown in Table 9-2, all
of the ARARs and TBCs for the contingent remedy of excavation and On-INEEL disposal can be met.
Other Federal and State laws are not included as ARARs for WAG 9 but may be invoked for the
on-FNEEL disposal site operator. The operator of the disposal site will have to comply with these action-
specific laws: IDAPA 16.01.05.008 (40 CFR 264) -"Standards for Owners and Operators of Hazardous
Waste Treatment, Storage and Disposal facilities" and IDAPA 16.01.05.011 (40 CFR 268)-"Land
Disposal Restrictions". One chemical-specific law, IDAPA 1601.11.200-Idaho Groundwater Quality
Rule" has not been included as an ARAR but may become applicable to the contingent remedy if future
groundwater concentrations exceed those levels that were predicted by the OU 9-04 Comprehensive
RJ/FS. Currently ANL-W does not exceed any of these regulated groundwater concentrations and does
not expect to exceed them based on modeling results. However, DOE will continue with groundwater
monitoring in accordance with the ANL-W Environmental Monitoring Program.
9.3 Cost Effectiveness
The selected remedial action of phytoremediation for the ANL-W sites of concern is cost
effective because it is anticipated that its costs will be the lowest of those alternatives that met the RAOs.
The costs for phytoremediation will depend on the actual uptake percentages for the radionuclide and
inorganic contaminants that are being determined during the bench-scale testing. The contingent remedy
of excavation .with on-INEEL disposal offers the second lowest costs for meeting the RAOs. The costs
for the excavation with on-INEEL disposal costs are well defined since the packaging and transportation
of hazardous and low level radioactive wastes are routine operations.
Table 9-3 summarizes the estimated costs in net present value for all of the alternatives that were
retained for detailed analysis. These costs were estimated assuming an annual inflation rate of 5%. The
selected remedy of phytoremediation is the most cost effective remedial alternative for all eight areas
with the exception of the Industrial Waste Pond. The contingent remedy of excavation and on-INEEL
disposal is the next lowest cost alternative. The variations in costs between the phytoremediation and the
excavation and on-INEEL disposal depended on the depth of contamination and surface area of the
remedial sites. Compared to excavation and disposal, the costs of phytoremediation are lower for sites
that have relatively large surface areas and which have contamination at relatively shallow depths (i.e.,
0.5 to 4 feet). Due to cost savings which can be realized on overhead and equipment costs when one
cleanup technique is applied to all WAG 9 sites, phytoremediation was selected for all WAG 9 sites.
Costs for the bench-scale-greenhouse testing have not been included into the phytoremediation
alternatives for each site. These bench-scale greenhouse costs are relatively small (less than $200,000)
and are being incurred prior to the signing of the ROD and as such are considered pre-ROD costs.
9.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Possible
The selected remedy will result in the permanent removal of contaminants from the soil and will
concentrate the wastes, minimizing the volume of waste to be disposed. The phytoremediation is
9-7
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designed to work on sites that contain radionuclide and/or inorganically contaminated wastes. Tests on
the effectiveness of phytoremediation to extract the radionuclides and/or inorganics from the ANL-W
soils are currently being performed. The outcome of these tests will determine the implementability of
phytoremediation prior to the start of the 1999 growing season. The contingent remedy of excavation
and on-INEEL disposal offers a permanent solution to the removal of the radionuclide and/or inorganic
wastes from ANL-W in a non-concentrated form. Both the selected and the contingent remedies offer
permanent solutions since both alternatives will remove the contaminants from the ANL-W site.
Table 9-3. Net present value of capital, operating and maintenance (O&M) and total cost for remedial
alternatives at OU 9-04 sites.
Alternative
Alternative 3a
Technology
Engineered Cover with
Capital Costs
S6.625.000.00
Operations and
Maintenance Costa
$954,000.00
Total Cost
$7,580,000 00
Alternative 4a
Alternative 4a
Alternative 4b
Alternative 5
Institutional Controls
Excavation and Disposal
at the On-INEEL
Proposed INEEL Soils
Repository
Excavation and Disposal
at the On-FNEEL
RWMC Facility
Excavation and Disposal
at a Private Off-INEEL
Facility
Phytoremediation with
Off-FNEEL Disposal of
Plant Matter/Ash
55,340,00000
$5.575,000.00
$12.591.000.00
$2,289,000.00
$535,000.00
$535,000.00
$535,000.00
$535,000.00
$5,876,000.00
$6,110,00000
$13,126,000.00
$2,824,000.00
9.5 Preference for Treatment as a Principal Element
The selected remedial remedy of phytoremediation, satisfies the criterion for treatment of the
contaminated media. The phytoremediation is an innovative treatment technology that appears to be the
most appropriate remedy for cleanup of both radionuclide- and inorganically-contaminated soils at
WAG 9. CERCLA grants preferential treatment to technologies that treat soils to reduce principal
wastes. Field tests will be conducted to verify the perfomance of phytoremediation on the ANL-W soils
The contingent remedy, excavation with on-INEEL disposal, does not include treatment, but does
provide a proven conventional technology to meet the established RGs for each of the eight areas at
WAG 9.
9-8
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10 DOCUMENTATION OF SIGNIFICANT CHANGES
CERCLA Section i I7(b) requires that an explanation of any significant changes from the
preferred alternative originally presented in the Proposed Plan be provided in the ROD.
Cost estimates for Alternatives 4a excavation and disposal at the RWMC have since been
prepared. These costs are similar in magnitude to those of the Alternative 4a for the proposed FNEEL
Soils Repository. Costs are slightly higher because of the increase in travel costs associated with the
longer transportation distance. The overall project costs for Alternative 4a using the proposed INEEL
Soils Repository or the RWMC facility are considered to be essentially the same. Thus, if the selected
alternative does not \\ork.'and the contingent alternative is implemented, the final selection of which
disposal option in Alternative 4a will be made during the remedial design phase.
One area, the Ditch C portion of ANL-01 was identified as having inorganic contaminants that
posed unacceptable risks to the ecological receptors in the Proposed Plan. This area has now been
eliminated as an area requiring remediation. In preparation of the Screening Level Ecological Risk
Assessment (SLERA) the maximum contaminant concentrations were used to calculate the HQ for the
ecological receptors. These HQs were determined by using the maximum contaminant concentration at
these two sites. New HQs have been calculated for all WAG 9 sites using the 95% UCL concentrations
reported in Appendix A of the OU 9-04 Comprehensive RI/FS. Under CERCLA the calculation of the
contaminant concentration is based on a reasonable maximum exposure (RME). The 95% UCL
concentration is more reasonable than using the maximum concentration when the number of samples in
the data set is greater than 10. The result of using the 95% UCL concentration verses the maximum
concentration reduced the ecological receptors HQs at these two sites to acceptable levels. Thus, the
Ditch C portion of ANL-01 will no longer require remedial action because the 95% UCL inorganic
concentrations are below the remediation goal concentrations. The remaining six areas identified in the
Proposed Plan as having inorganics that posed unacceptable risks to the ecological receptors, have had
similar refinements in the calculation of the HQs using 95% UCL values verses the maximum
concentrations. These remaining six areas are; Industrial Waste Pond (ANL-01), Ditch A (ANL-01),
Ditch B (ANL-01), Main Cooling Tower Slowdown Ditch (ANL-01 A), Sewage Lagoons (ANL-04), and
the Industrial Waste Liftstation Discharge Ditch (ANL-35). All of these six areas still have at least one
inorganic contaminant at concentrations above the RGs and are still retained for remedial action.
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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 OU
9-04 and a summary of comments received and corresponding agency responses.
ll-l
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Appendix A
Responsiveness Summary
-------
Appendix A
Responsiveness Summary
Table of Contents
A-l. OVERVIEW V!
A-2. BACKGROUND ON COMMUNITY INVOLVEMENT A-:
A-3. LISTING OF COMMENTERS, COMMENT NUMBERS, AND PAGE NUMBERS A-2
A-4. SUMMARY OF COMMENTS WITH RESPONSES A-5
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APPENDIX A
RESPONSIVENESS SUMMARY
A Summary of Comments Received
During the Public Comment Period
A-1. OVERVIEW
Operable Unit (OU) 9-04 is within Waste Area Group (WAG) 9 at the Argonne National
Laboratory - West (ANL-W) at the Idaho National Engineering and Environmental Laboratory (FNEELj.
WAG 9 contains 37 identified release sites contained within four operable units. DOE added 2 sites
from WAG 10 to the 37 release sites evaluated in the OU 9-04 Comprehensive RI/FS. Eight subareas
from five of these 39 sites were determined to have contamination that posed a potential risk to human
health and the environment. For those sites that will require remedial action to reduce or eliminate those
risks, the remedial action alternatives were evaluated and a preferred alternative was selected. In
addition to the eight areas of concern at OU 9-04, there were 33 areas that were determined to pose no
unacceptable risk to human health or the environment and were identified by the agencies as requiring
No Action. A Proposed Plan that summarized the results of the RI/FS and presented the preferred
remedial alternative and the contingent alternative was released by the agencies for public review on
January 8, 1998. Public comment on this document started on January 12, 1998, and was extended until
March 12, 1998 due to a request from the public. Public meetings were held in Boise, Moscow, and
Idaho Falls, Idaho, on January 20, 21, and 22, 1998, respectively.
This Responsiveness Summary responds to both written and verbal comments, received during
the public comment period and meetings. Generally, support for the preferred alternative was favorable
with some commentors expressing concern over mobility of contaminants and the introduction of non-
native plant species to remove the contaminants from soils.
A-2. BACKGROUND ON COMMUNITY INVOLVEMENT
In accordance with Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) Sections 1 l3(kX2)(BXI-v) and 117, a series of opportunities were made available for public
information and participation in the remedial investigation and decision process for OU 9-04, WAG 9 of
the ANL-W from 1991 to the present Public outreach activities included distribution of fact sheets that
briefly discussed the status of investigations to date, INEEL Reporter articles and updates, a Proposed
Plan, and focus group interactions, including tele-conference calls, briefings, presentations, and public
meetings.
On January 8, 1998, the U.S. Department of Energy, (DOE) issued a news release to more than
100 media contacts concerning the beginning of a 30-day public comment period pertaining to the WAG
9 ANL-W Proposed Plan, which began January 12, 1998, and was extended to March 12, 1998. In
addition, an INEEL Reporter article was sent to approximately 6,700 people on the INEEL Community
Relations Plan mailing list and mentioned the public meeting schedule. Both the news release and
INEEL Reporter gave notice to the public that WAG 9 ANL-W 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
A-1
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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 Boise, Moscow, and Idaho Falls, Idaho, on January
20, 21, and 22, 1998, 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 75 people not associated with the project attended the public meetings. Overall, 9 citizens
provided formal comments: of these, 1 citizen provided verbal comments and eight provided written
comments. Comments were also received from the FNEEL Citizens Advisory Board and are included in
this responsiveness summary.
This Responsiveness Summary has been prepared as a 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. Table A-1 is provided as a reference and lists the
commentors in alphabetical order, identifies the comment and response number, and identifies the paae
the comment and response can be found. The ROD presents the selected alternative and contingent
alternative for the eight areas in OU 9-04 that are of concern and recommends No Action for the
remaining 33 areas. The selected alternative was chosen 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). In addition, the
selected alternative fully complies with CERCLA §121 statutory preference for treatment of
contaminants for as a permanent solution. The decisions presented in the ROD are based on information
contained in the Administrative Record.
A-3. LISTING OF COMMENTERS, COMMENT NUMBERS, AND PAGE NUMBERS
All of the formal comments submitted by the public in either written or verbal form were
tabulated and assigned a comment number. Where applicable the commentors are listed alphabetically
in the first column, the comment number appears in the second column, and the page the comment and
response can be found on is shown in the third column.
NAME
CAB
CAB
CAB
CAB
CAB
CAB
Beatrice Brailsford
Beatrice Brailsford
AFFILIATION
Citizen Advisory Board
Citizen Advisory Board
"Citizen Advisory Board
Citizen Advisory Board
Citizen Advisory Board
Citizen Advisory Board
Snake River Alliance
Snake River Alliance
COMMENT #
40
41
42
43
44
45
57
58
APPENDIX A
PAGE #
17
17
|
IS !
18
is ;
I
22 !
22 1
A-2
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NAME
Beatrice Brailsford
Beatrice Brailsford
Beatrice Brailsford
Beatrice Brailsford
Beatrice Brailsford
Beatrice Brailsford
Beatrice Brailsford
Beatrice Brailsford
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Chuck Broscious
Dennis Donnelly
Dennis Donnelly
Dennis Donnelly
Dennis Donnelly
AFFILIATION
Snake River Alliance
Snake River Alliance
Snake River Alliance
Snake River Alliance
Snake River Alliance
Snake River Alliance
Snake River Alliance
Snake River Alliance
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Environmental Defense Institute
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
COMMENT #
59
60
61
62
63
64
65
66
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
47
19
20
21
->2
APPENDIX A
22 !
23 !
23 ,:
23
23 !
24
24
24 '
6
7
7
8
8
10 ;
10
10 '
10 i
10 !
11
11
11
12
12 ;
5 ;
12 ;
12
12
13
A-3
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NAME
Dennis Donnelly
Dennis Donnelly
Dennis Donnelly
.Walt Hampson
Walt Hampson
Walt Hampson
Walt Hampson
Walt Hampson
Martin Huebner
Martin Huebner
Martin Huebner
Darwin Jeppesen
Darwin Jeppesen
Darwin Jeppesen
KayLin Loveland
{Cay Lin Loveland
KayLin Loveland
KayLin Loveland
KayLin Loveland
KayLin Loveland
KayLin Loveland
KayLin Loveland
KayLin Loveland
Swen Magnuson #1
Swen Magnuson tt \
Swen Magnuson #1
Swen Magnuson #2
Unknown 4 1
AFFILIATION
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
Coalition 21
Coalition 21
Coalition 21
Concerned Citizen
Concerned Citizen
Concerned Citizen
Envirocare of Utah lac.
Envirocare of Utah Inc.
Envirocare of Utah Inc.
Envirocare of Utah Inc.
Envirocare of Utah Inc.
Envirocare of Utah Inc.
Envirocare of Utah Inc.
Envirocare of Utah Inc.
"Envirocare of Utah Inc.
Concerned Citizen
Concerned Citizen
Concerned Citizen
Concerned Citizen
Unknown
COMMENT *
23
24
25
27
28
29
30
31
34
35
36
37
38
39
48
49
50
51
52
53
54
55
56
1
2
3
26
32
APPENDIX A
PAGE # '
13
13
14
14 !
14
14
15
15
16
16
16
16
16
17
19
20
20
21
21
21
21
->-i
11 '
5
6
6
14
'5 ;
A-4
-------
NAME
Unknown -1
Unknown *2
AFFILIATION
Unknown
Unknown
COMMENT #
-» -^
jj
46
APPENDIX A
PAGE*
15 :
19
A-4. SUMMARY OF COMMENTS WITH RESPONSES
Comments and questions raised during the public comment period on the Proposed Plan for the
WAG 9, OU 9-04 Comprehensive Rl/FS for ANL-W are summarized below. The public meetings '.vere
divided into a brief presentation, 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 \vas
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 summarize 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, verbally during the public meetings, or by recording a message using INEEL's toll-free number.
Comment 1 I am concerned that DOE-ID appears to be using the engineered barrier or rock cover
that was emplaced at the SL1 burial grounds and at the BORAX facility as the prototype
barrier for any subsequent proposed disposal facilities on the INEEL. This SLI-style
rock cover or "barrier" is part of the containment alternative presented in the proposed
plans for both WAG 8 and WAG 9. It is well documented that the effect of this rock
cover would be to increase infiltration and minimize evaporation thereby increasing the
amount of water available to leach contaminants from the disposed soil the cover is
supposed to protect. I have read the proposed plan for WAG 8 and pertinent portions of
the WAG 8 Comprehensive RI/FS and see no acknowledgment that this rock cover will
increase infiltration. The fact that this rock cover will increase infiltration and leaching
should be plainly stated in the proposed plan for the information of members of the
public. If anything, the wrong impression is given in the Overall Protection of Human
Health And the Environment section of the proposed plan for WAG 8 (page 16) u»here it
is stated that Alternative 3 will "minimize infiltration". This last statement is miserably
incorrect and needs to be changed.
Response If the "engineered cover" had been selected as the remedial alternative, it would have
been designed to limit the infiltration of water over the containment area with the use of
multiple layers of different materials. The "engineered cover" depicted in the WAG 9
Proposed Plan was only a sketch giving an idea of the relationship between the
contaminated soil and a generic multi layer rock cover. The "engineered cover" is not
the selected alternative nor is it the contingent alternative for WAG 9 because other
alternatives offered greater benefit at reduced cost. Because of the nature and location of
A-5
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the radiologically contaminated soils at the Naval Reactors Facility (WAG 8), the
engineered cover has been selected as the preferred alternative for WAG 8. WAG S
engineers are currently evaluating the use and effectiveness of various media that could
be potentially used in their multilayered engineered cover.
Comment 2 While the groundwater pathway may not have been a risk in the baseline risk assessment
for either WAGs 8 or 9, even with infiltration rates as high as 1 m/yr, it still seems
wrong from an environmental stewardship viewpoint to needlessly install a rock cover
that will undoubtedly increase leaching from the contaminated soil and increase
concentrations of leached contaminants in the Snake River Plain aquifer. I feel this
statement is true even if the increased infiltration caused by the rock cover only
incrementally increases contaminant concentration in the aquifer I,cause there are better
cover alternatives. True engineered barriers that provide the necessary shielding and
biotic protection have been designed and are being tested on the [NEEL. These barriers
are resistant to erosion and minimize infiltration. These barrier designs should be given
a thorough comparative evaluation to an SLl-style barrier for use in the selected
alternative. This comparison should include analysis of even incremental risk increases
in the groundwater pathway from increased infiltration due to the rock cover. Hopefully,
this comparison will occur since there are words in the Comprehensive RI/FS for WAG
8 that the proposed rock cover in Alternative 3b is a "conceptual design" and that the
final design will be developed during the remedial design process.
Response The "engineered cover" as depicted on page 15 of the WAG 9 proposed plan is only a
conceptual figure. If an engineered barrier were selected as the remedy, it would be
disgned to reduce infiltration, resist erosion, and prevent biotic intrusion. Decisions as
to the use of an impermeable layer will be made during the remedial design phase of this
CERCLA process.
Comment 3 The WAG 8 Comprehensive RI/FS cites Reith and Caldwell (1990) as stating the
proposed barrier is appropriate for containment in an arid area. I have read the article by
Reith and Caldwell, and, although the article admits that several of these rock covers
have been built at UMTRA sites, the main point presented in the article is that since
vegetated soil covers are more effective for reducing infiltration and subsequent leaching
from contaminated soils rather than simple rock covers. This gives the appearance that
the Reith and Caldwell article is incorrectly cited out of context for purposes of
justifying the choice of engineered barriers.
Response Vegetated soil covers were not selected because some plants indigenous to the fNEEL
have very deep tap roots that could penetrate the soil cover. This could lead to
inadvertent uptake by these plants and possible exposure to other ecological receptors.
The "native soil cover" is not the preferred alternative nor is it the contingent alternate e
for WAG 9 because other alternatives offered benefit gains at reduced costs.
Comment 4 This must not be called a "comprehensive" plan because it does not include ANL-W$
underground high-level waste site (Radioactive Scrap and Waste Facility) which as of
A-6
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1981 has 81 cubic meters of waste containing 9,823,000 curies of radioactive materials
including 40.73 grams of plutonium [ID-100.54-81-@ 19] DOE must not continue to
postpone treatment and disposition of this waste.
Response The Olf 9-04 comprehensive RI/FS included an evaluation of all active, operating
facilities which are co-located near the 37 WAG 9 inactive waste sites that are beins
investigated under CERCLA. Any release sites discovered in the future will be
evaluated as new sites for remediation under the provisions of the FFA, CO. The
Radioactive Scrap and Waste Facility (RSWF), is one such facility. The RSW7 is a dry-
type spent nuclear fuel and radioactive waste storage facility. The spent fuel and waste
is stored in double lined steel containers that are inserted into cathodically protected steel
cylinders which are set vertically into the ground. All RSWF spent fuel and waste is
retrievable and DOE plans to treat these materials prior to disposal in an appropriate off-
site disposal facility. The RSWF is currently operating under a Resource Conservation
and Recovery Act (RCRA) storage permit for hazardous and radioactive mixed wastes.
Closure of the RSWF will be governed by RCRA closure requirements.
Comment 5 ANL-W intends to continue to use the contaminated Industrial Waste Pond (ANL-01)
and the sewage Lagoons (ANL-04) and the State and EPA regulators are silent.
Continued waste water discharge perpetuates the leaching of contaminates into the soil
column and eventually to the aquifer below.
Response The fate of all contaminants at WAG 9 inactive waste sites have been modeled using a
very conservative modeling program (GWSCREEN). This program takes into account
the soil types, depth to the aquifer (630 ft), and continued water discharges to these sites.
The results of this conservative modeling show that continued use of the Industrial
Waste Pond and Sewage Lagoons does not pose an unacceptable risk to human health or
the environment. Core samples collected in drainage ditches as well as the Industrial
Waste Pond verify that the contaminants have not migrated greater than 3.5 feet below
the surface after 37 years of operation. The planned continued use of these facilities for
approximately the next 5 and 35 years, respectively, is also not likely to drive these
contaminants down to the aquifer at levels that pose unacceptable risk to human health
and the environment. The contaminants will be remediated down to the cleanup goals
after the useful life of the Industrial Waste Pond and Sewage Lagoons, approximately 5
and 35 years, respectively.
Comment 6 The Plan-acknowledges that: "Human health risks from cesium-137 will be at acceptable
levels within 130 years due to radiological decay." [Plan@14J Yet in the next paragraph.
the plan states: "Institutional controls are assumed to remain in effect for at least 100
years." What about the next 30 years. Once the CERCLA process is wound up in a tew
years, there are uncertainties that DOE or any other federal agency is going to fulfill its
questionably enforceable commitment to provide monitoring and institutional control to
ensure no people gain access to the waste sites. Again, a trust fund is warranted and a
requirement under the NRC 10 CRF ss 61.63 "Financial Assurances for Institutional
Controls."
A-7
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Response It is true that the cesium-137 contamination would radioactively decay to acceptab.'e
levels in 130 years if no action were taken at the WAG 9 site. The !00 years of
institutional controls proposed in Alternative 3, is based on the most likely future use of
the INEEL which is the continued control the land by DOE. . Alternative 3, includes an
engineered cover that is designed to last longer than the 130 years necessary to limit the
direct radiation exposure pathway to future residents.
Comment 7 ANL-W's Plan, like the NRF deficient Plan, is to consolidate all the contaminated soil
into the Industrial Waste Pit, and again, it does not meet Applicable or Relevant and
Appropriate Requirements (ARAR's). This lack of full disclosure by the polluter and
the regulators is unacceptable. The drawing offered in the Plan [p!an@15] of the
Industrial Pit does not vaguely resemble the 20 foot deep Iocc!ized depression :hat the p;t
is in. The Plan drawing shows a flat terrain with the leach pit being the only depression.
This is a major discrepancy. Continued pooling of surrounding precipitation over the pit
(covered or not) will provide water to leach contaminates towards the aquifer.
Moreover, the cap does not include an impermeable seal to keep precipitation out. The
Waste Pit currently receives drainage from a considerable area to the southeast in
addition to storm water from the ANL-W site. A major flaw in the Plan is not providing
drainage diversion away from the pit regardless of the alternative chosen. The fact that
chromium, mercury, selenium, and zinc are in the pit sediments compels DOE to do
Toxicity Characteristic Leaching Procedure (TCLP) to determine if it qualifies the waste
as a mixed hazardous/radioactive waste and it must be then disposed pursuant to RCRA
land disposal restrictions (40 CFR-148). DOE's preferred remedial alternative simply is
not supported by essential information.
Response None of the alternatives evaluated for WAG 9 include consolidating contaminated soils
in an Industrial Waste Pit. The containment alternative (Alternative 3) would
consolidate the WAG 9 contaminated soils in an engineered landfill located at a well-
drained location near ANL-W. If the contingent Alternative 4a (use of an INEEL Soils
Repository, or RWMC) is selected, the soils would be consolidated several miles away
from WAG 9 under an engineered cover that would prohibit the pooling of surface water
or precipitation. The "engineered cover" as depicted on page 15 of the WAG 9 proposed
plan is only a conceptual figure. Decisions as to the use of an impermeable layer will be
made during the remedial design phase of this CERCLA process. Contaminant
modeling has shown that continued use of the ANL-W Industrial Waste Pond as a
drainage collection area does not pose an unacceptable risk to humans or the
environment.
Samples have been collected and analyzed for total and TCLP analysis in the waste sites
with the highest concentrations of arsenic, chromium, mercury and lead. All of these
samples had concentrations less than the TCLP limits and therefore, do not have the
potential to leach to groundwater at concentrations high enough to pose a risk. None or
the WAG 9 soils have the potential to fail the TCLP test for selenium.
Comment 8 The plan states at page 8 that: "contaminantes to the groundwater show only arsenic and
chromium exceeded the cleanup goal screening levels." The ANL-W RJ/FS well (M-13)
A-8
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1993 sample data shows strontium-90 at 1,330 pCi/L [RJ./FS, Vol III App.H pg.3J. EPA
maximum concentration level for strontium-90 in drinking water is 8 pCi/L. Sampling
in 1994-95 shows well M-12 contains organic chemicals hundreds of times over the
MCL [Rl/FS, Vol v]. The Plan does not acknowledge this strontium migration or
propose remedies that will correct the problem. This contaminate migration exemplifies
the disastrous impact of leach pits and why the AM.-W' Industrial Pond must be
immediately closed and appropriately cleaned up.
Response The Proposed Plan actually states that "the modeling of contaminants to the groundwater
shows that only arsenic and chromium exceeded the cleanup goal screening levels.
Therefore, the maximum concentrations of the arsenic and chromium at 100 years in the
future were used to determine the risks to human health." The cleanup goal screening
levels provided a tool to screen contaminants from inclusion into the risk assessment
because of the contaminants low concentrations and or mass.
The organic contaminant detected at well M-12 is bis(2-Ethylhexyl)phthalate and was
detected numerous times in the sampling of the upgradient as well as the downgradient
wells at WAG 9. This is a common laboratory contaminant and as such the EPA
recognizes that samples can be qualified as un-detectable if the concentration is less then
10 times the concentration in the blank sample. The bis(2-Ethylhexy!)phthalate was
screened as a contaminant of concern for the following reasons; (1) because the highest
concentration of bis(2-Ethylhexyl)phthalate was detected in the upgradient well (M-12),
(2) no data trends exist of increasing concentrations, and (3) EPA recognizes it is a
common laboratory contaminant.
It is correct that strontium-90 had an estimated detection of 1,330 pCi/L from the ANL-
W downgradient.monitoring well M-13 for the sample collected October 25, 1995.
However, the sample collected the same day for the upgradient monitoring well M- r2
also had an estimated detection of strontium-90 of 1,320 pCi/L. The data from this
October 25, 1995 sampling has been qualified as estimated (J) by the data validator
because the laboratory control samples (LCS) were outside control limits. Because the
data was flagged by the data validator, at thousands of times above the detection levels,
DOE believes that laboratory error was the cause of these erroneously high values.
Also, data results collected on July 31, 1995 showed 0.7 and 0.1 pCi/L from M-12 and
M-13, respectively. These well are located 4,928.83 feet apart with M-13 almost
directly downgradient of M-12. The groundwater in the Snake River Plain Aquifer flows
at most 10 feet per day and thus it would take 492 days for the water under M-12 to
reach M-13. If this were the case the strontium-90 would have to have been detected in
the upgradient M-12 well for over a year and this is not the case since the July 31, 1995
data shows both the M-12 and M-13 stronti-jm-90 results at 0.7 and 0.1 pCi/L. In an
effort to substantiate the strontium-90 detections in the M-12 and M-13 wells, two
groundwater samples from each well were collected on December 14, 1995. The
upgradient M-12 samples were both non-detects at 0.4 and 0.0 pCi/L, while the
downgradient M-13 well had one non-detect at 0.5 and one detection at 1.6 pCi/L. Also,
results of drinking water wells EBR-II * \ and 2 have been analyzed semi-annually for
gross beta with the results being lower than the MCL level of 8 pCi/L.
A-9
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Comment 9 Alternative 5 (phytoremediation) that would use plants, over five growing seasons, to
absorb the contaminants in the leach pit, is so ludicrous in an arid environment that it
does not deserve rebuttal.
Response Phytoremediation is a technology that has proven successful at other DOE radiolooicaliy
contaminated waste sites and has been selected as the preferred alternative to remediate
soils in feight areas at ANL-W. Because WAG 9 is located in a semi-arid environment.
the contaminant extracting plants would be irrigated as required to enhance plant arowth.
The EBR-II Leach Pit was remediated in 1993 and is not part of this proposed action.
Comment 10 There are issues of plant density to prevent wind erosion (contaminate dispersion).
Response Four of the eight areas where the Agencies propose using phytoremediation are ditch
bottoms and ponds. Based on the physical nature of these depressed sites, they tend to
accumulate windblown sediments. The otte site (ANL-09-Mound) is on the banks of a
large storm water Interceptor Canal and currently has only sparse vegetation growing.
Any additional vegetation that is growing during the dry season will only help prevent
against windblown contamination. The contaminant extracting plants would be densely
planted to ensure effective root penetration into contaminated soils.
Comment 11 What is ANL going to do after annual harvest and between growing seasons to prevent
wind erosion?
Response After each of the growing seasons are completed, DOE may continue to keep the area
wetted until the ground freezes. This would prevent any windblown contamination
problems. Other erosion control options may include use of a biodegradable soil
tackifler that would be sprayed on after each harvest.
Comment 12 Bench scale tests in ANL's greenhouse will only reflect efficiencies in an artificial
climate controlled environment, not the real desert thing.
Response Every effort is being taken during the greenhouse studies to simulate actual conditions at
the INEEL. These include temperature control, humidity control, and sunlight duration.
Comment 13 The Sanitary Waste Lift Station (ANL-31) is listed as a no action site presumably
because-ANL wants to continue to use the pumps. The Plan offers no data to
substantiate this no action decision.
Response As stated in the Operable Unit9-04 Comprehensive RI/FS, the ANL-31 building consists
of two lift stations in the same building. The South side contains a sanitary sewage
waste lift station and will remain in service. The North side of ANL-31 contained the
industrial lift station that was used to pump wastes to the EBR-II Leach Pit. This side of
ANL-31 was remediated in 1995 when ANL-W collected samples, removed the sludge.
collected verification samples and backfilled this half of the building with clean sand.
Also, all of the associated piping and contaminated soil below the piping from the
A-10
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industrial lift station to the EBR-II Leach Pit was removed and disposed of at RWMC in
1995 and 1996. In their current conditions, neither of the two lift stations in the AXL-J i
site poses an unacceptable risk to human health or the environment.
Comment 14 The Track 2 Investigation shows maximum concentrations of sludge collected from the
Lift Station as follows: cesium-137 at 9,380 pCi/g, strontium-90 at 2,470 pCi/g, uraniurr
at 4.8 pCi/g, neptunium-237at 13 pCi/g, and cobalt-60 at 16.3 pCi/g. [Vol. Ill track 2
App. -H pg4] This contamination suggests that this Lift Station was inappropriately
excluded from the cleanup. May 1995 Track 2 reflect continued high gross alpha and
gross beta in the pump water and sludge. [Vol. Ill Appendix - E]
Response The Track 1 investigation resulted in the removal action that is described in the response
to comment 13. The lift station no longer poses an unacceptable risk to human health jr
the environment.
Comment 15 The EBR-II Leach Pit (ANL-08) underwent an interim "cleanup" action in 1993 when
only "the majority of the sludge was removed" and the pit was backfilled. The Plan fails
to acknowledge that the remaining sludge had the following pCi/g concentrations:
cesium-I37at29,110, iodine-129 at 124, neprunium-237 at 329, strontium-90 at 2,24",
yttrium-90 at 2,247. [Rl/FS Vol. II pg. 59-60] Inadequate interim actions end up being
permanent because of the additional volume of contaminated soil used as backfill is now
part of the problem.
Response Every effort was taken during the 1993 removal action to remove as much of the sludge
as possible. These actions included pressure washing of the irregular basalt floor and
collection of the material that was removed during the washing. The residual sludge
remaining was estimated to be at most one-eighth of and inch thick, a worst case
estimate of the sludge volume (using a one-eighth-inch thickness) was used in modeling
the transport of contaminants to the aquifer. These values were used in the OU 9-04
Comprehensive RI/FS along with the modeling of contaminants that may have leached
from the sludge in the years prior to the 1993 removal action. The modeling of past and
future contaminant behavior shows that the EBR-II Leach Pit no longer poses an
unacceptable risk to human health or the environment.
Comment 16 The public has demanded for many years that DOE treat its radioactive waste into a
stable vitrified form so that it can be stored onsite until a safe permanent repository can
be established.
Response Vitrification was evaluated as a potential alternative in Chapter 7 of the OU 9-04
Comprehensive Rl/FS and screened out because of it is typically used for long lived
radionuclide wastes. Contaminants at WAG 9 are short lived radionuclides and do not
require isolation for 10,000 years. In addition the high cost of vitrification is not
justifiable for use on the short lived radionuclide wastes and offer very little gained
benefits over the selected and contingent remedies.
A-11
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Comment 17 At the very legal minimum, all contaminated soil should be shipped off the fXEEL site
to a licensed and permitted RCRA hazardous/radioactive disposal site.
Response None of the wastes at the WAG 9 sites have failed the TCLP test for RCRA wastes. The
off-INEEL disposal (Alternative 4b) was not selected because of the cost effectiveness.
The preferred and contingent alternatives at ANL-W are protective of human health and
the environment, and comply with Applicable and Relevant and Appropriate
Requirements, including the requirements of the Resource Conservation and Recovery
Act.
Comment 18 a compromise would be if there is an area on the FNEEL site that is not over the Snake
River Plain Aquifer, use it to build a licensed and permitted RCRA
hazardous/radioactive disposal site for INEEL low-level wastes only.
Response None of the wastes at the WAG 9 sites have failed the TCLP test for RCRA wastes. The
Agencies have proposed Alternative 5, phytoremediation as the preferred alternative.
This alternative would treat the soils to remove the contaminants. The contaminants
would then be recovered, stabilized, and disposed of in accordance with the Waste
Acceptance Criteria of a licensed off-site disposal facility.
Comment 19 I fee! the goal of your contamination cleanup should be the unrestricted future use of the
land and water resources at the site.
Response The Agencies agree that the goal of the cleanup at WAG 9 should be the unrestricted
future use of the land and water resources at ANL-W. By selecting Alternative 5,
phytoremediation, as the preferred alternative to remediate the eight areas of WAG 9 that
pose unacceptable risks to human health and the environment, the Agencies will be able
to release the lands without any restriction after the remediation goals are met.
Comment 20 To attain unrestricted future use of the land and water resources at the site, 1 feel the plan
should address the removal of spent fuel from all die reactors.
Response OU 9-04 Comprehensive RI/FS investigated the 37 inactive waste sites at ANL-W, and
two inactive waste sites from WAG 10 near ANL-W that have had past releases to the
environment, and active ANL-W facilities were reviewed for future releases. The active
facilities are currently operating under stringent operating procedures and permits.
When the operating facilities are shut-down they will be defueled and decontaminated
and left in a radiologically and industrially safe condition. Four of five reactors at ANL-
W have been shutdown and have been derueled. The remaining small neutron
radiography reactor is still operating and will be defueled when DOE terminates its
operation.
Comment 21 What about the sodium from the Experimental Breeder Reactor II, all of it what will
be its fate? The plan should remove of all the sodium coolant and materials
contaminated with radioactive sodium. I feel the sodium is especially important due to
A-12
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the environmental mobility of sodium and the location of this site over the aquifer that
supplies most of the water for this region.
Response As part of the DOE's shutdown plan for the Experimental Breeder Reactor-II, the
primary and secondary sodium coolant will be drained and chemically convened to ncn
hazardous sodium carbonate. DOE has constructed a facility at ANL-VV to convert al!
EBR-II sodium and sodium potassium alloy to sodium carbonate powder, a non-
hazardous compound that has very low levels of radioactivity.
Comment 22 When I visited the Argonne-West site over fifteen years ago, I remember seeing, on the
northeast side of the complex, a series of waste-holes that appeared to be vertical pipes
with concrete lids that were said to contain intermediate-level radioactive wastes which
were contaminated with sodium. I see no mention of these structures in your description
of the site Have they been removed?
Response The Radioactive Scrap and Waste Facility (RSWF), is a dry-type spent nuclear fuel and
radioactive waste storage facility. The spent fuel and waste is stored in double lined
steel containers that are inserted into cathodically protected steel cylinders which are set
vertically into the ground. All RSWF spent fuel and waste is retrievable and DOE plans
to treat these materials prior to disposal in an appropriate off-site disposal facility. The
RSWF is currently operating under a Resource Conservation and Recovery Act (RCRA")
storage permit for hazardous and radioactive mixed wastes. Closure of the RSWF will
be governed by RCRA closure requirements.
Comment 23 I also remember the Hot Fuel Examination Facility, and how really hot the cells were
inside. Your contamination cleanup should address this contamination, as well as all
other fission or activation products onsite.
Response OU 9-04 Comprehensive RI/FS investigated the 37 inactive waste sites at ANL-W, two
inactive waste sites from WAG 10 near ANL-W, and active ANL-W facilities The
active facilities, such as the Hot Fuel Examination Facility, are currently operating under
stringent operating procedures and permits. When the operating facilities are eventually
shut-down they will be derueled and decontaminated and left in a radiologically and
industrially safe condition. At that time residual risks to human health and/or the
environment will b« evaluated under the CERCLA process with appropriate remedies
undertaken as necessary.
Comment 24 This plan's general approach of covering existing waste with a couple feet of dirt and
rock and leaving it there is unacceptable.
Response If an engineered cover were implemented it would be designed to prevent the infiltration
of water and exposure to humans and ecological receptors. However, the preferred
alternative for remediation of the eight areas that pose unacceptable risks to human
health and the environment is phytoremediation. The applicability of phytoremediation
to remove the contaminants from the soil is currently being evaluated using bench-scale
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greenhouse tests. If phytoremediation does not work satisfactorily, a contingent
alternative of off-site containment and disposal in a soils repository has been selected.
Comment 25 I feel your program should address and plan to truly cleanup the big problems at the site,
as well as the little ones. My fear is that if you do not, no one ever will.
Response The goal of the CERCLA activities at WAG 9 is to eliminate unacceptable risks to
human health and the environment. OU 9-04 Comprehensive RJ/FS investigated the 37
inactive waste sites at ANL-W, two inactive waste sites from WAG 10 near ANL-W,
and also addressed active ANL-W facilities. The active facilities are currently operating
under stringent operating procedures and permits. When the operating facilities are shut-
down they will be defueled and decontaminated and left in a radiologically and
industrially safe condition.
Comment 26 I commend the agencies for selecting an innovative and relatively inexpensive approach
to remediate a facility that is environmentally clean compared to other facilities in the
INEEL and especially compared to other facilities in the DOE-complex.
Response The agencies acknowledge the commentor's statement that the preferred Alternative 5,
phytoremediation is the best and most cost effective alternative option.
Comment 27 Analyses seem conservative and thorough. I favor Alternative 3, considering cost and
expeditious improvement over the present state.
Response Although Alternative 3, capping in-place would offer expeditious implementation, it's
costs are considerably higher than other alternatives that treat the soils. Thus, the
preferred Alternative is 5 and the contingent Alternative is 4a.
Comment 28 Phytoremediation may be scientifically interesting with some long range potential. So
pursue that on the parallel path - a small scale development and proof-tests.
Response ANL-W has started bench-scale greenhouse tests to determine the applicability on ANL-
W soils. If the bench-scale greenhouse test results are a success a two-year field season
will be implemented with verification samples collected to determine how well it is
working in the field. If phytoremediation is unsuccessful at either the bench-scale tests
or two-year field season, the contingent Alternative 4a would be implemented. The costs
associated with parallel implementation of phytoremediation with other alternatives
would be prohibitive.
Comment 29 Let's not delay progress on known methods of improvement for years permitting proof
of new ideas.
Response The extra costs of using the excavation and disposal over the phytoremediation
alternative is not warranted by the benefits gained. Institutional controls practices that
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are currently in-place are preventing exposures to current occupational workers at
ANL-W. Phytoremediation has proven successful at other DOE contaminated sites for
remediating radipnuclide and metal contaminated soils. However, ANL-W, with it's
specific set of contaminants and location in a semi-arid climate; coupled with the
agencies desire to use native plants as much as possible, mandates that the evaluation
process be conducted for however long it takes to grow, harvest, and analyze the plants
to determine contaminant uptake factors, both in the greenhouse study and at AN"L-\V
The results of the sampling show that after nearly 40 years of operation, the
contaminants are relatively shallow (0-2 feet) and the continued facility continued
operation will not leach the contaminants to deeper depths. Thus, there appears to be no
determent in allowing phytoremediation to be implemented over the expected time
frame.
Comment 30 To say that phytoremediation is "site specific" is probably an understatement qualifying
its practicality for general use?
Response Phytoremediation is very contaminant and site specific. That is why the Agencies have
selected a contingent alternative if phytoremediation does not work satisfactorily during
the bench-scale tests and the two-year field season.
Comment 31 I would hasten to add "more power to new/better ideas - innovation etc"; let's just prove
them out before large scale application where sure results are needed.
Response ANL-W has started bench-scale greenhouse tests to determine the applicability on ANL-
W soils. If the bench-scale greenhouse test results are a success a two-year field season
will be implemented with verification samples collected to determine how well it is
working in the field. If phytoremediation is unsuccessful at either the bench-scale tests
or two-year field season the contingent Alternative 4a (consolidation at a soils
repository) will be selected.
Comment 32 I feel the damage is done! We keep moving this contaminated material around.
Response The OU 9-04 Comprehensive RI/FS determined that only eight areas pose unacceptable
risks to human health and the environment. Phytoremediation has been selected by the
Agencies as the preferred alternative to remediate these areas. Phytoremediation
extracts the contaminants from the soil, thus eliminating the need to move the
contaminated soil around. The plants used in phytoremediation will be incinerated
(volume reduction) and the ash solidified prior to shipment to an approved landfill.
Comment 33 We just keep piling the contaminated soil on the rN'EEL so it can filtrate through the
soils to the groundwater or be released to the atmosphere.
Response The preferred Alternative 5, phytoremediation, will use plants to uptake contaminants
into the plant tissues. This will eliminate the chance that they can filtrate in the soil or
be spread to the atmosphere.
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Comment 34 The Coalition 21 wishes to commend the DOE and the ANL for considering the
phytoremediation technology. The Coalition concurs, contingent on the success of on-
going and future studies of this technology, that this should be the preferred method.
Response The Agencies acknowledge the commentor's statement that the preferred Alternative 5.
phytoremediation, is the best and most cost effective alternative option.
Comment 35 Care should be taken that if non-native plants are used in the proposed phvtorerr.ed:a:
that such exotic species be absolutely prevented from escaping into the Idaho
environment.
Response If non-native plants to the INEEL are selected for phytoremediauon, DOE will take
every precaution to prevent their propagation. These precautions will, at a minimum
include harvesting the plants prior to flowering, and may also include spraying a
herbicide to form a sterile zone around the sites to be remediated, and harvesting the
whole plant (above and below ground).
Comment 36 Also, the methods for disposing of the ash residues that contains the materials removed
from the ANL-West site per this Waste Plan should be specified and evaluated to ensure
that the methods meet all applicable criteria.
Response The ash residue after incineration will meet the acceptance criteria of an appropriate
radioactive waste disposal facility, or a RCRA permitted hazardous waste disposal
facility. The actual method for preparation of the ash for disposal will depend on the
standard operating procedures for the operation of the incinerator used.
Comment 37 My comment is that I noticed that there was no mention of a soil type or senes in > our
report.
Response That is correct, the Proposed Plan did not mention the soil type or series. The Proposed
Plan is only a short 28 page summary of the 2,600 page OU 9-04 Comprehensive RIF5
Section 2.5 of the OU 9-04 Comprehensive RI/FS discusses the soils type and senes.
Comment 38 Being a BLM Soil Scientist, I maybe able to assist you in identifying the national icii
series located adjacent to your Argon clean up site. If your soil is what I think ma> 're
there. The Natural Resource Conservation Service and I have a complete
characterization lab analysis of this soil on the FNEEL.
Response The Agencies would appreciate any help in confirming the specific soil series ot :he i/.ii
where phytoremediation would be implemented. Figure 2-4 of the OU 9-04
Comprehensive RI/FS shows the general soils types near ANL-W. This figure shows
that WAG 9 is located in a transition zone between two soil types (432-Malm-Bonafanr!-
Matheson complex, and 425-BondfamvRock outcrop-Grassy Butte complex).
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Comment 39 Gale Olson, Randy Lee with Lockheed and I have published soil information on the site
in: "The Status of Soil Mapping for the Idaho National Engineering Laboratory," Jan.
1995 through the Lockheed Company. (IKEL-95.0051) Soil series at Argonne'are
believed to be different than those found in the Bonneville and Jefferson County L'SDA
soils survey reports.
Response DOE used the Gale Olson, Randy Lee document to complete Section 2.5 Soils t>pe for
the O(J 9-04 Comprehensive RI/FS. Figure 2-4 was taken from this report.
Comment 40 The INEEL CAB recommends selection of Alternative 5, phytoremediation. as the
preferred alternative for achieving remedial objectives at ANL-W. As described in the
Proposed Plan, Phytoremediation is an innovative technology that utilizes plants to
uptake toxic metals and radionuclides through roots in sifu. Plants that have been used
successfully in the past include grasses, shrubs, and/or trees. Following uptake the plant
vegetation would be harvested, sampled, and incinerated for volume reduction. The
resultant ash would be sampled and sent to a permitted disposal facility. Alternative 5
was ranked best in 6 out of the 7 evaluation criteria, and the cost is significantly lower
than the other alternatives. We will be pleased if the technology'proves successful. We
will support continued endeavors to pursue innovative technologies that could enhance
INEEL's role as an environmental laboratory and that could be marketed for use at other
contaminated sites
Response The agencies acknowledge the INEEL Citizens Advisory Board's support for Alternative
5, phytoremediation, as the best and most cost effective alternative option for WAG 9
contaminated sites.
Comment 41 We are concerned about the potential for spread of any non-native INEEL species that
may be used in the remediation. We recommend that the Record of Decision (ROD)
provide more detailed explanations of the species to be used and how DOE proposes to
control their potential spread.
Response If non-native plants to the INEEL are selected for phytoremediation, DOE will take
every precaution to prevent their propagation. These precautions will, at a minimum
include harvesting the plants before flowering, and may also include spraying a
herbicide to form a sterile zone around the sites to be remediated, and harvesting the
whole plant (above and below ground). The ROD includes selection of the alternatives
The actual selection of the plants would follow successful completion of the bench-scale
greenhouse testing. This documentation of the selected plant species as well as planting
and harvesting practices will be documented in the Remedial Design Work Plan.
Comment 42 In addition, we are concerned that contaminants taken up into vegetation could be
consumed by animals using the remediation area for habitat and feeding. We
recommend the ROD address this concern and provide an explanation of steps that will
be taken to limit ecological risks to wildlife populations.
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Response Some of the plants being investigated in the bench-scale greenhouse test are weedy
plants that animals and insects do not eat. The actual selection of the plants would
follow successful completion of the bench-scale greenhouse testing. A thorough
description of the selected plant species, as well as planting, harvesting, and animal
fencing practices will be documented in the Remedial Design Work Plan.
Comment 43 We are finally concerned about dioxins resulting from incineration. We recommend that
the combustion of secondary wastes should be addressed in the ROD.
Response Recently, more information has become available on the production of dioxins through
incomplete burning of wet and damp vegetation and wood in the presence of high
chloride/chlorine concentrations. The plants that DOE is proposing to use have low
levels of chloride/chlorine and they will also be completely dried prior to bailing and
submittal to the incinerator. Standard Operating Procedures used at the incinerator will
prevent incomplete oxidation during the incineration of the plant matter. The off-site
rule requires the use of a RCRA subtitle C incinerator or testing of the off-gas.
Secondary waste from the burning of dried phytoremediation plant matter would not be
of concern since plant matter will have to meet the operating incinerator acceptance
criteria. Meeting the incinerator's acceptance criteria will ensure that emissions remain
under limits described in the incinerator's air quality permit.
Comment 44 With regard to the contingency identified in the preferred alternative (i.e. Alternative 4A,
which would include excavation and disposal on-site at the Soils Repository proposed
for Waste Area Group 3 - Idaho Chemical Processing Plant), we have some concern
regarding the identification of a facility that may or may not be constructed. We
understand that the Radioactive Waste Management Complex (RWMC) may be licensed
at some time to receive wastes generated through implementation of cleanup activities in
compliance with the Comprehensive Environmental Response, Compensation, and
Liability Act. If so, the ROD should explicitly name the RWMC as a back-up to
Alternative 4 and document that it would perform similarly to the Soils Repository
according to the evaluation criteria.
We understand that the costs associated with the use of RWMC would be comparable to
the Soils Repository. The ROD should provide more complete disclosure of the costs
associated with the contingency and its backup to support comparisons between them.
Response The language in the Proposed Plan was intended to describe the use of either the
Proposed INEEL Soils Repository or the RWMC as a contingent remedial alternative
These two possible locations are identified as Alternative 4a (excavation and disposal on
the INEEL) in the OU 9-04 Comprehensive RI/FS. The final selection would be
completed in the Remedial Design phase of the CERCLA process, because of the
unknowns associated with the proposed INEEL Soils Repository. Costs for both the
RWMC and proposed INEEL Soils Repository will be included in the ROD.
.VI8
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Comment 45 Finally, we urge the rapid determination of the feasibility of phytoremediation so that it
or the contingency plan can be implemented expeditiously. We request that DOE report
the results of the bench scale tests to the INEEL CAB once available.
Response DOE will release the results of the phytoremediation bench-scale tests in
August/September 1998, to the CAB as well as other INEEL WAG managers as soon as
thev are available.
Comment 46 Agree that alternative 5 is best/cost effective option.
Response The Agencies acknowledge the commentor's statement that the preferred alternative is
the best and most cost effective alternative option.
Comment 47 DOE's continued use of Envirocare in Utah is unacceptable because it is not a permitted
and licenced RCRA/NRC Subtitle C hazardous/radioactive dump. Envirocare is
currently being sued by the Natural Resources Defense Council for RCRA non-
compliance.
Response The use of Alternative 4b, excavation and disposal off-INEEL was not retained as the
preferred or the contingent alternative for the WAG 9 soils that require remediation.
Therefore, no WAG 9 CERCLA wastes would be sent to the Envirocare facility for
disposal.
Comment 48 The remediation time is lengthy. At least five growing seasons will be required for the
remediation to be implemented. This obviously prolongs the risk to human health and
the environment for at least four years longer than Alternative 4, Excavation and
Disposal, which is the next preferred option and could easily be accomplished
commercially in one construction season.
Response Although Alternative 4, would offer expeditious implementation, it's costs are
considerably higher than Alternative 5 and no benefits would be gained because current
institutional controls at ANL-W limit the occupational worker exposures to acceptable
levels. The only risk to humans is from the exposure of cesium-137. These sites are
outside the work area of ANL-W that is enclosed with a security fence. Well over 95°'>
of the workers at ANL-W work exclusively within the security fenced area. If work is
ever performed in these areas, institutional controls will be implemented to reduce the
worker exposure to the levels that pose acceptable risks.
In addition, under CERCLA, permanent solutions and alternative treatment technologies
or resource recovery technologies, to the maximum extent practicable, are given
preference. Alternative 5 offers cost effective treatment while Alternative 4 does not.
Thus, Alternative 5 has been selected for use at WAG 9.
Comment 49 If phytoremediation does not work after the five growing seasons, an alternative remedy
will have to be implemented, costing additional time and money and extending the safety
A-19
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and health risks. Additionally, Alternate 4b could be implemented for the same
approximate cost and completed in a much shorter time .
Response Phytoremediation will undergo two series of tests with stringent go, no-go, criteria prior
to full utilization at WAG 9. The first is a bench-scale greenhouse test conducted on
ANL-W soils and based on these results the second full scale two-year field test will be
implemented or the contingent alternative will be selected. At the end of the two-year
field test, samples will be collected of the soil and the plants to determine if Alternative
5 is still practicable for use or if the contingent alternative should be implemented. The
long-term benefits gained by being able to remove the contaminants from the soils
justify the costs of conducting the bench-scale greenhouse test and the two-year field
season. Institutional controls are in-place to reduce the occupational worker exposure:
to acceptable levels during the implementation of the phytoremediation tests.
Comment 50 Phytoremediation is a complicated, multi-step process including five separate planting
and harvesting campaigns, incineration of each harvest and consequent disposal of all
ash generated from plant bums. In comparison, excavation and disposal is a quick and
proven technology that will insure that all remediation goals are met.
Response The long-term benefits gained by being able to remove the contaminants from the soils
justify the costs of conducting the bench-scale greenhouse test and the two-year field
season. These sites are outside the work area of ANL-W that is enclosed with a security
fence. Well over 95% of the workers at ANL-W work exclusively within the security
fenced area. Thus, institutional controls are in-place to reduce the occupational worker
exposures to acceptable levels during the implementation of the phytoremediation tests.
Comment 51 Although fugitive dust and toxic substances may be reduced while plant life is growing
in the contaminated area, five harvesting cycles create five invasive situations where
dust will present contamination problems and expose workers, rather than a one time
remediation.
Response The risk driver to humans is through the direct exposure pathway of the radionuclides
Engineering controls such as the use of Personnel Protection Equipment, dust
suppression, fencing, and commercially available farm equipment with climate
controlled cabs can be utilized to reduce the workers exposure.
Comment 52 The government must continue to pay surveillance costs for at least five years until the
contaminated area remediation is complete, thus the operations and maintenance costs
should be significantly higher than Alternative 4, Excavation and Disposal.
Response DOE is proposing that Alternatives 4 and 5 would each have continued operations and
maintenance (O&M) costs that would include continued groundwater, soil and air
monitoring in accordance with DOE Orders for the next 20 years. The continued O&M
will allow DOE to validate the contaminant modeling results in the RI/FS. Thus, no
savings would be realized in O&M costs between Alternatives 4 and 5.
A-20
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Comment 53 It is important to calculate increases in cost over time since this remediation is spread
out over five years and Alternative 4 can be completed in one construction season. The
cost of this alternative increases over time, and a realistic comparison must account for
this.
Response DOE performed the present value costs for all the retained alternatives for WAG 9. The
present value cost for Alternataive 5 was estimated to be less than the present value cost
for Alternative 4. The present value costs take into account the inflation costs of work
performed in the future as well as the time value of money interest rates. To account for
these unknowns, seven years worth of growing seasons were used in preparation of the
estimate, evan though it is estimated to take only five years.
Comment 54 The reasoning and facts used to discount Alternative 4b were flawed in some areas. Th=
cost analysis exaggerated commercial excavation and disposal by approximately 240°'->
over disposal costs that are currently available to the DOE and INEEL through existing
contracts.
Response DOE used a tipping fee of S350 per cubic yard for disposal of low level radioactive
contaminated soil at private facility. The tipping fee was based on costs presented by
Envirocare during a soil remediation seminar in Idaho Falls in the fall of 1996. These
tipping fee costs along with the $10 per cubic yard rail transport costs make this
alternative much more expensive for large sites than either Alternative 4a or 5.
Comment 55 The reasoning and facts used to discount Alternative 4b were flawed in' some areas
Operations and maintenance costs are listed at S535,000. Why is there a cost for this
since remediation could be completed in one construction season?
Response See response to comment 52.
Comment 56 The fervor with which the preferred alternative was presented at the Idaho Falls public
meeting seemed to transcend the enthusiasm for environmental remediation customar:!>
displayed by the Department of Energy and the State of Idaho.
Response DOE, EPA, and the State support phytoremediation for use at WAG 9 because this
remedy is the least invasive to the existing ecosystem, has a high probability of success.
and is the least costly. In addition, this alternative meets the CERCLA preference for
treatment of contaminated soils.
Comment 57 Phytoremediation is being pursued under a Cooperative Research and Development
Agreement between Argonne and Applied Natural Sciences. How much federal money
has and will be invested in this CRADA? What other federal resources is Applied
Natural Sciences using for this project? How will any eventual profits from
Treemediation be distributed?
A-21
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Response This information that you are referring to came from literature of past studies of
phytoremediation. DOE is pursuing phytoremediation through it's ANL-W contractor
who is working with the ANL-E phytoremediation experts. All costs of the project are
going to pay for labor and operations for ANL employees. ANL is a non-profit
organization and is only interested in improving the technology and helping others
implement it at other facilities.
Comment 58 Is research on phytoremediation going forward in the private sector unaided by the
federal government? Is Argonne making use of that research?
Response Private sector use of phytoremediation is growing rapidly with major cleanup activities
at non-government facilities. The private research information is being shared between
companies on the applicability and success of phytoremediation. however, each of the
private companies have patent pending processes and specialized plants that they are
using that they will not share with others outside the company.
Comment 59 It is unclear how often harvest will occur. Will the plants be dug up only once (at the
end of five growing seasons), after every growing season, after the 1999 field season (to
obtain sample results)?
Response The answer to this question will be determined after the bench-scale greenhouse testing
is complete, [fa small annual grass plant is selected the plants would be harvested after
each growing season. Likewise if a perennial plant is selected, the harvesting will occur
after two year growing season.
Comment 60 Are the tests planned for the end of the 1999 field season of the contaminated soil or of
the plants?
Response Successful bench-scale greenhouse tests have to be completed prior to the two-year long
field season. If the bench-scale greenhouse testing is successful, both plant and soil
samples will be collected after the two-year long field season and used to validate the
applicability of the phytoremediation process at WAG 9. The contaminant analysis of
the plants will determine percent uptake of the contaminats on a dry weight basis. These
uptake rates will be used along with the density of the plants and the mass of the plant
matter to determine the length of time needed to achieve the RAOs. If phytoremediaticn
is unsuccessful at either the bench-scale greenhouse test or the two-year field season, the
contingent alternative will be selected.
Comment 61 Phytoremediation seems to necessitate handling the same contaminant several times:
during harvest, during sampling, during incineration, during further sampling, entrained
on filters, in transport to disposal, during disposal. Are the public and worker health,
environmental, and economic costs of each' of those steps included in the analysis under
review?
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Response One of the CERCLA criteria used to evaluate the alternatives is short-term effectiveness
Short-term effectiveness addresses any adverse impacts on human health and the
environment that may be posed during the implementation period and period of time
needed to achieve the cleanup goals. Institutional controls will be used to reduce worker
exposure during activities associated with phytoremediation including; planting,
harvesting, shipping, sampling, incineration, characterization, and disposal.
Comment 62 Has Argonne undertaken a mass balance analysis yet0 Even an attempt at a theoretical
mass balance analysis (curies in soil vs curies disposed) would be useful.
Response DOE has performed a rough mass balance of total curies of cesium-137 in the soil and
the total curies of cesium-137 that would have to be removed to meet the remediation
goals for WAG 9. A total of 0.295 curies of cesium-137 is in the sites that pose
unacceptable human health risks and DOE would have to remove 0.06 curies to meet the
established 23,3 pCi/g cleanup goal. This is approximately 20 percent removal of the
cesium-137.
Comment 63 When the plants are dug up, airborne releases of contaminants might occur. When asked
about that possibility at the Boise public meeting, presenters seemed to indicate that the
workers doing the digging would be protected by radiation suits. In Idaho Falls,
however, there was reference instead to holding down the dust with a garden hose. The
contrast between those two responses seems to indicate a lack of planning and, perhaps,
a lack of respect for public concerns.
Response DOE apologizes for the inconsistencies between the meetings. The risk driver to
humans is through the direct exposure pathway of the radionuclides. Engineering
controls such as the use of Personnel Protection Equipment, dust suppression, fencing,
and commercially available farm equipment with climate controlled cabs can be utilized
to reduce the workers exposure. Final design of the correct engineering controls will be
defined in the Remedial Design phase after completion of the ROD.
Comment 64 The low grade, ongoing problems at Envirocare, a commercial nuclear dump in Utah.
emphasize that shipping contamination from here to there may not effect any particular
environmental benefit.
Response DOE agrees that no benefit is gained by hauling the soil from WAG 9 and placing it
under a cap at an off-INEEL landfill. Ultimately the soil contamination still exists and
potential harm to the existing ecosystem from excavation could be significant.
Comment 65 Has INEEL investigated all possible offsite disposal options and their relative risks and
benefits? Is that analysis available to the public?
Response DOE has evaluated two off-site disposal options as part of the 24 possible remedial
process options evaluated in the WAG 9 RI/T-S. These process options were screened
using effectiveness, cost, and implementabiliry and used to develop the WAG 9 remedial
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alternatives. The five WAG 9 remedial alternatives were then evaluated using the nine
CERCLA evaluation criterion. The possible offsite disposal option that was retained for
WAG 9 is Alternative 4b. In this alternative DOE used the Envirocare facility in Utah to
develop the cost estimates. The final selection of an offsite facility would take place in
the Remedial Design phase. However, Alternative 4b is not the preferred or the
contingent alternative for WAG 9.
A complete review of this process can be found in Chapters 7, 8. 9, and 10 of the WAG 9
Comprehensive RJ/FS.
Comment 66 When was the management and operating contract for Argonne National Laboratory last
put out for competitive bid?
Response To date, the management and operating contract for Argonne National Laboratory has
never been put out on a competitive'bid.
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Appendix B
Administrative Record
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Appendix B
Administrative Record
Table of Contents
Category Listing B-l
Index File for No Action Sites B-6
Index File for Track 1 Inestigations for OU 9-01 Sites 8-'. 2
Index File forTrack 2 Investigations for OU 9-02 Sites B- 6
Index File for Track 2 Investigation for OU 9-03 Site B-21
Index File for Remedial Investigation/Feasibility Study Sites B-23
Index File Initial Assessments for WAG 9 Sites B-26
B-!
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ENVIRONMENTAL RESTORATION & WASTE MANAGEMENT
ADMINISTRATIVE RECORD DOCUMENT CATEGORY LISTING
January 20, 1998
AR1.0 SITE IDENTIFICATION
ARM Background
AR1.2 Notification/Site Inspection Reports
AR1.3 Preliminary Assessment (PA) Report
AR1.4 Site Investigation (SI) Report
AR1.5 Previous Operable Unit Information
AR1.6 No Action Sites
AR1.7 Initial Assessments
AR2.0 REMOVAL RESPONSE
AR2.1 Sampling and Analysis Plans (SAP)
AR2.2 Sampling and Analysis Data/Chain of Custody Forms (COC)
AR2.3 EE/CA Approval Memorandum
AR2.4 EE/CA
AR2.5 Action Memorandum
AR2.6 Amendments to Action Memorandum
AR2.7 Health and Safety Plan
AR2.8 Workplan
AR2.9 Quality Assurance Project Plan
AR2.10 Hazard Classification
AR3.0 REMEDIAL INVESTIGATION (RI)
AR3.1 Sampling and Analysis Plans (SAP)
AR3.2 Sampling and Analysis Data/Chain of Custody Forms (COC)
AR3.3 Work Plan
AR3.4 RI Reports
AR3.S - Track I Investigations
AR3.6 Track n Investigations
AR3.7 Interim Actions
AR3.8 Risk Assessment
AR3.9 Quality Assurance Project Plan
AR3.10 Scope of Work
AR3.11 Field Sampling
AR3.12 RI/FS Reports
AR3.13 Cost Analysis
AR3.14 Track 2 Summary Report
AR3.15 Health & Safety Plan
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DOCUMENT CATEGORY LISTING
January 20,199$
Page 2
AR3.0 REMEDIAL INVESTIGATION (RI) (continued)
AR3.16 Contingency Plan
AR3.17 Remedial Investigation and Baseline Risk Assessment Report
AR3.18 Environmental Assessment (EA)
AR3.19 Finding of No Significant Impact (FONSI)
AR3.20 Treatability Study
AR3.21 Schedule
AR3.22 Track 2 Decision Statement
AR3.23 Track 2 Preliminary Scoping Package
AR4.0 FEASIBILITY STUDY (FS)
AR4.1 ARAR Determinations
AR4.2 FS Reports
AR4.3 Proposed Plan
AR4.4 Supplements and Revision to the Proposed Plan
AR4.5 Feasibility Study Questionnaire
AR5.0 RECORD OF DECISION (ROD)
AR5.1 ROD
AR5.2 Amendments to ROD
AR5.3 Explanation of Significant Differences
AR5.4 Record of Decision Review Comments
AR5.5 ESDROD
AR6.0 STATE COORDINATION
AR6.1 Cooperative Agreements/SMO As
AR6.2 State Certificate of ARARs ,,
AR7.0 ENFORCEMENT
AR7.1 Enforcement History
AR7.2 Endangerment Assessments
AR7.3 Administrative Orders
AR7.4 Consent Decrees
AR7.5 Affidavits
AR7.6 Technical Discussions with PRPs on Response Actions
B-3
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DOCUMENT CATEGORY LISTING
January 20,1998
Page 3
AR7.0 ENFORCEMENT (continued)
AR7.9 Secretarial Policy
AR7.7 Notice Letters and Responses
AR7.8 Offsite Shipments
AR8.0 HEALTH ASSESSMENTS
AR8.1 ATSDR Health Assessments
AR8.2 Toxicological Profiles
AR8.3 Hazard Classification
AR9.0 NATURAL RESOURCE TRUSTEES
AR9.1 Notices Issued
AR9.2 Findings of Fact
AR9.3 Reports
AR10.0 PUBLIC PARTICIPATION
AR10.1 Comments and Responses
AR10.2 Community Relations Plan
AR10.3 Public Notices) (Availability of the Administrative Record File,
Availability of the Proposed Plan, Public Meetings)
AR10.4 Public Meeting Transcripts
AR10.S Documentation of Other Public Meetings
AR10.6 Fact Sheets and Press Releases
AR10.7 Responsiveness Summary
AR10.8 Late Comments
AR11.0 TECHNICAL SOURCES AND GUIDANCE DOCUMENTS
AR11.1 EPA Headquarters Guidance
AR11.2 EPA Regional Guidance
AR11.3 State Guidance
AR11.4 Technical Sources
AR11.5 Evaluation of Guidance Documents
AR11.6 Technical Memorandum
AR11.7 Technical Evaluation
AR11.8 Land Use Documents
B-4
-------
DOCUMENT CATEGORY LISTING
January 20,1998
Page 4
AR12.0 EPA AND IDH\V REVIEWS
AR12.1 EPA Comments
AR12.2 BDHW Comments
AR12.3 DOE Response To Comments
AR12.4 Extension Requests and Approvals
AR12.5 ' Project Management Meeting Minutes
B-3
-------
IDAHO NATIONAL ENGINEERING LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR NO ACTION SITES
FOR THE ARGONNE NATIONAL LABORATORY - WEST WAG 9
11/04/94
ADMINISTRATIVE RECORD VOLLfMf /
FILE NUMBER
AR1.6
NO ACTION SITES
Document t:
Title:
Author:
Recipient:
Date:
Document f:
Title:
Author:
Recipient:
Date:
Document f:
Title:
Author:
Recipient:
Date:
Document f:
Title:
Author:
Recipient:
Date:
Document f:
Title:
Author:
Recipient:
Date:
Document f:
Title:
Author:
Recipient:
Date:
5170
ANL-10 Dry Well between T-1 and Zppr Mound
Stewart. N. A.
Sekot, M.
09/21/92
5173
ANL-1 1 Waste Retention Tank 783 (never used)
Stewart, N. A.
Sekot, M.
09/21/92
5174
ANL-1 2 Suspect Waste Retention Tank by 793 (removed 1979)
Stewart, N. A.
Sekot, M.
09/21/92
5175
ANL-1 4 Septic Tank and Drain Reids (2) by 753 (removed 1979)
Stewart, N. A.
Sekot. M.
09/21/92
5176
ANL-1 5 Dry Well by 768
Stewart, N. A.
Sekot, M.
09/21/92
5177
ANL-1 6 Dry Well by 759 (2)
Stewart. N. A.
Sekot, M.
09/21/92
B-o
-------
NO ACTION SITES WAG 9 11/04/94
ADMINISTHA T7VF RECORD VOLUME U
FILE NUMBER
AR1.6 NO ACTION SITES (continued)
* Document f: 5178
Title: ANL-17 Dry Well by 720
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document i: 5179
Title: ANL-18 Septic Tank and Drain Field by 789 (removed 1979)
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document f: 5180
Title: ANL-20 Septic Tank and Leach Field by 703
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document f: 5181
Title: ANL-21 TREAT Suspect Waste Tank and Leaching Reid (non-radioactive)
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document *: 5182
Title: ANL-22 TREAT Septic Tank and Leaching Field
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document f: 5183
Title: ANL-23 TREAT Seepage Pit and Septic Tank W of 720 (filled 1980)
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
B-T
-------
NO ACTION SITES WAG 9 11/04/94
FILE NUMBER
AR1.6 NO ACTION SITES (continued)
» Document *: 5184
Title: ANL-24 Lab and Office Acid Neutralization Tank
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document f: 5185
Title: ANL-25 Interior Building Coffin Neutralization Tank
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
ADMINISTRA TTVf PECORD VOLUME III
* Document f: 5186
Title: ANL-26 Critical Systems Maintenance Degreasing Unit
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document f: 5187
Title: ANL-27 Rant Services Degreasing Unit
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
* Document 9: 5188
Title: ANL-32 TREAT Control Building 721 Septic Tank and Leach Field
(present)
Author: Stewart, N. A.
Recipient: Sekot. M.
Date: 09/21/92
* Document f: 5189
Title: ANL-33 TREAT Control Building 721 Septic Tank and Leach Field
(removed 1978)
Author: Stewart, N. A.
Recipient: Sekot, M.
Date: 09/21/92
B-S
-------
NO ACTION SITES WAG 9 11/04/94
ADMINISTRATIVE RECORD VOLUME IV
FILE NUMBER
AR1.7 INITIAL ASSESSMENTS
* Document *: 5475
Title: ANL-10, Dry Wells Between T-1 and ZPPR Mound
Author: N/A
Recipient: N/A
Date: 10/08/86
* Document I: 5476
Title: ANL-11, Waste Retention Tank 783 (Never Used)
Author: N/A
Recipient: N/A
Date: 09/09/86
* Document *: 5477
Title: ANL-12, Suspect Waste Retention Tank 783 (Removed 1979)
Author: N/A
Recipient: N/A
Date: 10/14/86
* Document *: 5478
Title: ANL-14, Suspect Tank and Drain Reids (2) by 753 (Tank Removed 1979)
Author: N/A
Recipient: N/A
Date: 10/05/86
* Document f: 5479
Title: ANL-15. Dry Well By 768
Author: N/A
Recipient: N/A
Date: 09/15/86
* Document *: 5480 .
Title: ANL-16, Dry Well By 759(2)
Author: N/A
Recipient: N/A
Date: 09/30/86
B-9
-------
NO ACTION SITES WAG 9 11104194
FILE NUMBER
AR1.7 INITIAL ASSESSMENTS (continued)
» Document t: 5481
Title: ANL-17, Dry Well By 720
Author: N/A
Recipient: N/A
Date: 10/06/86
» Document i: -5482
Title: ANL-18, Septic Tank and Drain Field by 789 (Removed 1979}
Author: N/A
Recipient: N/A
Date: 09/30/86
* Document i: 5484
Title: ANL-20. Septic Tank and Leach Field by 793
Author: N/A
Recipient: N/A
Date: 10/05/86
* Document f: 5485
Title: ANL-21, TREAT Suspect Waste Tank and Leaching Field (Non-
Radioactive)
Author: N/A
Recipient: N/A
Date: 10/02/86
* Document t: 5486
Title: ANL-22, TREAT Septic Tank and Leaching Reid
Author: N/A
Recipient: N/A
Date: 10/03/86
* Document f: 5487
Title: 'ANL-23, TREAT Seepage Pit and Septic Tank W of 720 (Filled 1980)
Author: N/A
Recipient: N/A
Date: 10/05/86
» Document f: 5488
Title: ANL-24, Lab and Office Acid Neutralization Tank
Author: N/A
Recipient: N/A
Date: 09/30/86
B-IO
-------
NO ACTION SITES WAG 9 11/04/94
PU F NUMBER
AR1.7 INITIAL ASSESSMENTS (continued)
* Document f: 5489
Title: ANL-25, Interior Building Coffin Neutralization Tank
Author: N/A
Recipient: N/A
Date: 09/30/86
* Document t: 5490
Title: ANL-26, Critical Systems Maintenance Degreasing U~.:t
Author: N/A
Recipient: N/A
Date: 10/05/86
* Document f: 5491
Title: ANL-27, Plant Services Degreasing Unit
Author: N/A
Recipient: N/A
Date: 09/30/86
» Document f: 5496
Title: ANL-32, TREAT Control Building 721 Septic Tank and Leach Field
(Present)
Author: N/A
Recipient: N/A
Date: 09/30/86
* Document f: 5497
Title: ANL-33, TREAT Control Building 721 Septic Tank and Seepage Pit
(Removed 1978)
Author: N/A
Recipient: N/A
Date: 10/03/86
B-U
-------
IDAHO NATIONAL ENGINEERING LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR THE TRACK 1 INVESTIGATION OF
OPERABLE UNIT WJ1 ANL-W
11/18/96
ADMINISTRATIVE RECORD VOLUME I
FILE NUMBER
AR1.7
INITIAL ASSESSMENTS
Document i: 5471
Tide: ANL-04, ANL Sewage Lagoons, OU 9-01
Author: N/A
Recipient: N/A
Date: 10/15/86
Document *: 5483
Tide: ANL-19, Sludge Pit W of T-7 (Imhoff Tank) (Filled in 1979), OU 9-01
Author: N/A
Recipient: N/A
Date: 10/21/86
Document t: 5492
Tide: ANL-28, EBR-O Sump (Regeneration), OU 9-01
Author: N/A
Recipient: N/A
Date: 09/30/86
Document i: 5493
Tide: ANL-29, Industrial Waste Lift Station, OU 9-01
Author: N/A
Recipient: N/A
Date: 10/23/86
Document f: 5494
Tide: ANL-30, Sanitary Waste Lift Sation, OU 9-01
Audwr: N/A
Recipient: N/A
Date: 10/08/86
Document #: 5500
Tide: ANL-36, TREAT Photo Processing Discharge Ditch, OU 9-01
Author: N/A
Recipient: N/A
Date: 07/21/87
B-I2
-------
TRACK 1 INVESTIGATION OF OPERABLE UNIT 9-01 11/18/96
FILE NUMBER
AR3.1 SAMPLING AND ANALYSIS PLAN'
Document!: W7500-4234-NP-01, Rev. I
Title: Sampling and Analysis Plan for Operable Units 9-01, 9-03, and 9-04 at the Idaho
National Engineering Laboratory: Track 1 .Sampling Track 2 Samplingt and RI/FS
Screening Sample Collection
Author: Lee, S.D.
Recipient: Not specified
Date: 11/11/94
This document can be found in OU 9-03, Volume n
AR3.5 TRACK I INVESTIGATION
4 Document f: 5704
Title: Track 1 Investigation of WAG 9, Site Code: ANL-19, Imhoff Tank and Sludge Pit
Author: ANL-W
Recipient N/A
Date: 04/12/94
* Document t: 5743
Title: Track 1 Investigation of WAG 9, Site Code: ANL-28 EBR-EI Sump
Author: ANL-W
Recipient . N/A
Date:
07/25/94
Document I: 5744
Title: Track 1 Investigation of WAG 9, Site Code: ANL-30 Sanitary Waste Lift Station
Author: ANL-W
Recipient N/A
Date: 07/27/94
Document f: .5745
Tide: Track 1 Investigation of WAG 9, Site Code: ANL-60 Knawa Butte Debris Pile
Author: ANL-W
Recipient N/A
Date: 07/25/94
B-13
-------
TRACK 1 INVESTIGATION OF OPERABLE UNIT 9-01 11/18/96
ADMINISTRATIVE RECOUP VOLUME II
ETTK NTTMRFR
AR3.5
TRACK I INVESTIGATION (continued)
Document t: 5758
Tide: Track 1 Investigation of WAG 9, Site Code: ANL-04 ANL Sewage Lagoons -
Proceed to Track 2 or RI/FS
Author: ANL-W
Recipient: N/A
Date: 07/25/94
Document i: 5759
Title: Track 1 Investigation of WAG 9, Site Code: ANL-62 Sodium Boiler Building (766)
Hotwell No Further Action
Author: ANL-W
Recipient: N/A
Date: 07/28/94
Document f: 5760
Title: Track 1 Investigation of WAG 9, Site Code: ANL-63 Septic Tank 789-A - No
Further Action
Author: ANL-W
Recipient: N/A
Date: 07/27/94
Document f: 10293
Title: Addendum to the Previously Signed WAG 9 Track 1 ANL-W Sewage Lagoons, Site
Code: ANL-04
Author: Not specified
Recipient: N/A
Date: 05/23/96
Document t: 10294
Title: Addendum to the Previously Signed WAG 9 Track 1 ANL-W Industrial Lift Station,
Site Code: ANL-29
Author: Not specified
Recipient: N/A
Date: 05/23/96
B-14
-------
TRACK 1 INVESTIGATION OF OPERABLE UNIT 9-01 11/18/96
FILE NUMBER
AR3.5
TRACK I INVESTIGATION (continued)
Document 1: 10295
Title: Track 1 Investigation of WAG 9, Site Code: ANL-29 Industrial Waste Lift Station
(778-A) - No Further Action
Author: ANL-W
Recipient: N/A
Date: 07/25/94
Document #: 10302
Title: Track 1 Investigation of WAG 9, Site Code: ANL-36 TREAT Photo Processing
Discharge Ditch - No Further Action
Author: DOE, EPA, IDHW
Recipient: N/A
Date: 07/25/94
Document *: 10303
Title: Track 1 Investigation of WAG 9, Site Code: ANL-61 EBR-H Transformer Yard -
No Further Action
Author: DOE, EPA, IDHW
Recipient: N/A
Date: 07/27/94
B-15
-------
IDAHO NATIONAL ENGINEERING LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR THE TRACK 2 INVESTIGATION OF
OPERABLE UNIT 9-02 ANL-W
12/03/97
ADMINISTRATIVE RECORD VOLUME I
FTT.R NTTMBFR
AR1.7 INITIAL ASSESSMENTS
» Document f: 5473
Title: ANL-08, EBR-II Leach Pit (Radioactive), OU 9-02
Author: N/A
Recipient: N/A
Date: 10/24/86
AR2.1 SAMPUNQ AND ANALYSIS PLANS
Document *: W7630-OOO4-ES-00
Title: Sampling and Analysis Plan - Sludge Removal and Waste Solidification -
EBR-II Leach Pit
Author: Jannotta, D.
Recipient: ANL-W
Date: 09/06/93
AR2.2 SAMPLING AND ANALYSIS DATA/CHAIN OF CUSTODY FORMS (COO
* Document f: 5277
Title: Report For The EBR-II Leach Pit Sampling and Analysis Program and
Monitoring Well Installation
Author: Colder Associates
Recipient: Sekot, M.
Date: 05/18/93
ADMINISTRATIVE RECORD VOLUME II
AR2.4 EE/CA
» Document f: 5291
Title: Engineering Evaluation/Cost Analysis Report for EBR-II Leach Pit Removal
for Inclusion into the Administrative Record File
Author: Marshall. G.C.
Recipient: Hughes, E.J.
Date: 06/15/93
B-16
-------
TRACK 2 INVESTIGATION OF OPERABLE UNIT 9-02 12/03/97
FILE NUMBER
AR3.3 WORK PLAN
Document *: W7630-0002-ES-00
Title: .Technical Work Plan Sludge Removal and Waste Solidification -
- EBR-II Leach Pit
Author: Jannotta, D.
Recipient: ANL-W
Date: 08/23/93
AR3.7 INTERIM ACTIONS
Document *: W7630-0007-ES-00
Title: Spill Prevention. Control and Countermeasures Plan Sludge Removal and
Waste Solidification - EBR-II Leach Pit
Author: Jannotta. 0.
Recipient: ANL-W
Date: 08/24/93
AR3.8 RISK ASSESSMENT
Document f: W7630-0006-ES-OO
Title: Hazards Assessment for the EBR-II Leach Pit Sludge Removal Project at
Argonne National Laboratory - West
Author: Jenkins. S.L.
Recipient: N/A
Date: 08/24/93
AR3.9 QUALITY ASSURANCE PROJECT PLAN
4 Document f: W7630-0005-ES-00
Title: Quality Assurance Project Plan - Sludge Removal and Waste Solidification
- EBR-II Leach Pit
Author: Jannotta, D.
Recipient: ANL-W
Date: 09/06/93
B-17
-------
TRACK 2 INVESTIGATION OF OPERABLE UNIT 9-02 12/03/97
FILE NUMBER
AR3.14 TRACK 2 SUMMARY REPORT
4 Document * DOE/ID-12584-162
Title: Preliminary Scoping Track 2 Summary Report for Operable Unit 9-O2:
EBR-II Leach Pit, Volumes I and II
Author: Not specified
Recipient: Not specified
Date: 04/11/94 (signed by Agencies on 05/23/96)
AR3.15 HEALTH AND SAFETY PLAN
4 Document *: W7630-0003-ES-00
Title: Health and Safety Plan - Sludge Removal and Waste Solidification
- EBR-II Leach Pit
Author: Jannotta, D.
Recipient: ANL-W
Date: 08/16/93
AR3.16 CONTINGENCY PLAN
* Document *: W7630-0008-ES-00
Title: Contingency Plan for the EBR-II Leach Pit Sludge Removal Project at
Argonne National-Laboratory - West
Author: Jenkins, S.L.
Recipient: N/A
Date: 08/25/93
AR10.3 PUBLIC NOTICE
* Document f: 5336
Title: Citizens Asked to Comment on Removal Action at Argonne National
Laboratory - West (ANL-W)
Author: INEL Community Relations
Recipient: N/A
Date: 07/09/93
B-IS
-------
TRACK 2 INVESTIGATION OF OPERABLE UNIT 9-02
12/03/97
FILE NUMBER
AR12.1
EPA COMMENTS
Document f : 9597
Title:
Author:
Recipient:
Date:
Review Comments
Summary Report
Jones, E.
Green, L.
01/28/94
- EBR-II Leach Pit, Operable Unit 9-02 Track 2
Document * : 5742
Title: Review Comments - Argonne EBR-II Leach Pit, Operable Unit 9-02
Track 2 Summary Report
Author: Jones. E.
Recipient: Green, L.
Date: 07/14/94
AR12.2
IDHW COMMENTS
Document *: 10018
Title: Review Comments - EBR-II Leach Pit, Operable Unit 9-02
Track 2 Summary Report
Author: Rosenberger, S.
Recipient: Green, L.
Date: 05/05/95
AR12.4
REQUEST FOR EXTENSION
Document f : AM/ERWM-RPO-279-92
Title: Request to Extend the Track 2 Investigation Summary Report Submittal
Date for the Experimental Breeder Reactor (EBR)-II Leach Pit, OU 9-O2 at
the INEL
Author: Lyle, J.L,
Recipient: Pierre, W.; Nygard, D.
Date: 12/15/92
Document f: 7551
Title: Request to Extend Track 2 Summary Report Date for the Experimental
Breeder Reactor (EBR)-II Leach Pit, OU 9-02 at the INEL
Author: Pierre, W.
Recipient: Lyle, J.L.
Date: 12/31/92
B-19
-------
TRACK 2 INVESTIGATION OF OPERABLE UNIT 9-02 12/03/97
PILE NUMBER
AR12.4
REQUEST FOR EXTENSION (continued)
Document *: 6092
Title: Approval to Extend the Track 2 Investigation Summary Report Submittal
Date for the Experimental Breeder Reactor (EBR)-II Leach Pit. OU 9-02
Author: Nygard, D.
Recipient: Lyle, J.L.
Date: 01/11/93
Document t AM/ERWM-RPO-536-93
Title: Request For Further Extension of OU 9-02 Summary Report Target Date
Author: Lyle, J.L.
Recipient: Pierre, W.; Nygard, D.
Date: 08/19/93
B-20
-------
IDAHO NATIONAL ENGINEERING LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR THE TRACK 2 INVESTIGATION OF
OPERABLE UNIT 9-43 ANL-W
09/29/97
ADMINISTRATIVE RECORD VCHllMF I
FTT.E NTTMBER
AR1.7 INITIAL ASSESSMENTS
* Document #: 5472
Title: ANL-05, ANL Open Burn Pits *l, fl, and #3, OU 9-03
Author: N/A
Recipient; N/A
Date: 10/15/86
* Document*: 5495
Title: ANL-31, Industrial/Sanitary Waste Lift Station (Industrial Side Not Used), OU 9-03
Author: N/A
Recipient: N/A
Date: 10/22/86 .
4 Document i: 5498
Title: ANL-34, Fuel Oil Spill by Building 755, OU 9-01
Author: N/A
Recipient: N/A
Date: 10/14/86
ADM1NKTKATJVF. RECORD VOLUME II
AR3.1 SAMPLING AND ANALYSIS PLAN
Document*: W7500-4234-NP-01, Rev. 1
Title: Sampling and Analysis Plan for Operable Units 9-01, 9-03, and 9-04 at the Idaho
National Engineering Laboratory: Track 1 Sampling, Track 2 Sampling, and Rl/FS
Screening Sample Collection
Author: Lee, S.D.
Recipient: " Not specified
Date: 11/11/94
B-21
-------
TRACK 2 INVESTIGATION OF OPERABLE UNIT 9-03 ANL-W 09/29/97
RECOUP VOLUME 111
FILE NUMBER
AR3.14 TRACK 2 SUMMARY REPORT
Document* W7500-4244-NP-01, Vol. 1
Tide: Revised Track 2 Summary Report for Operable Unit 9-03: Open Burn Pits (1, 2,
and 3) Industrial/Sanitary Waste Lift Station, and the Fuel Oil Spill by Building 755 ,
Volume I
Author: Not specified
Recipient: Not specified
Date: 05/23/96
ADMINISTRATIVE RECORD VOLUME IV
Document i: W750O4244-NP -01, Appendix B, Section Q
Title: Revised Track 2 Summary Report for Operable Unit 9-03: Open Bum Pits (1, 2, and
3), Industrial/Sanitary Waste Lift Station, and the Fuel Oil Spill by Building 755, *
Volume n
Author: Not specified
Recipient: Not specified
Date: 05/23/96
B-::
-------
IDAHO NATIONAL ENGINEERING LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR THE
REMEDIAL INVESTIGATION/FEASIBILITY STUDY OF OU 9-04 ANL-W
OL/09/98
ADMINISTRATIVE RECORD VOLUME I
FTLE NUMBER
AR1.7
INITIAL ASSESSMENTS
Document #: 5469
Title: ANL-01, Industrial Waste Pond and Cooling Tower Blowdown Ditches (3), OU 9-04
Author: N/A
Recipient: N/A
Date: 01/26/89
Document It: 5470
Title: ANL-01A, Main Cooling Tower Blowdown Ditch, OU 9-04
Author: N/A
Recipient: N/A
Date: 01/26/89
Document!: 5474
Tide: ANL-09, ANL Interceptor Canal, OU 9-04
Author: N/A
Recipient: N/A
Date: 10/17/86
Document!: 5499
Tide: ANL-35, Industrial Waste Lift Station Discharge Ditch, OU 9-04
Author: N/A
Recipient: N/A
Date: 07/14/87
Document * : 5501
Tide: ANL-53, Cooling Tower Riser Pits, OU 9-04
Author: N/A
Recipient: -N/A
Date: 04/01/90
-------
REMEDIAL INVESTIGATION/FEASIBILITY STUDY OF OU 9-04 01/09/98
FTLE NTTMHER
AR3.1 SAMPLING AND ANALYSIS PLAN*
* Document*: W7500-4234-NP-01, Rev. 1
Tide: Sampling and Analysis Plan for Operable Units 9-01, 9-03, and 9-04 at the Idaho
National Engineering Laboratory: Track 1 Sampling Track 2 Sampling^ and RI/FS
Screening Sample Collection
Author Lee, S.D.
Recipient: Not specified
Date: 11/11/94
This document can be found in OU 9-03, Volume II
ADMINISTRATIVE RECORD VOLUME II
AR3.3 WORK PLAN
4 Document»: W7500-0000-ES-03, Vol. I
Tide: Comprehensive RI/FS Final Work Plan for Waste Area Group 9
Author: Lee, S.D.; Martin, CJ.; Rood, S.M.; VanHorn, R.L.; Hampton,. N.L.
Recipient: Not specified
Date: 08/02/96
ADMINKT9ATTVK KRmRD VOLUME 777
* Document i: W7500-0000-ES-03, Vol. D
Tide: Comprehensive RI/FS Final Work Plan for Waste Area Group 9
Author: Lee, S.D.; Martin, CJ.; Rood, S.M.; VanHorn, R.L.; Hampton, N.L.
Recipient: Not specified
Date: 08/02796
AR3.10 SCOPE OF WORK
Document f: W750O4248-ES-02, Rev. 2
Tide: Final Scope of Work for the Waste Area Group 9 Comprehensive Remedial
Investigation/Feasibility Study at the Idaho National Engineering Laboratory
Author: Lee, S.D.
Recipient: Not specified
Date: 11/09/95
B-24
-------
REMEDIAL INVESTIGATION/FEASIBILITY STUDY OF OU 9-04 01/09/98
JggfflgP VQLUMF
FTLE NUMBER
AR3.L2 RI/FS REPORTS
* Document i: W7500-0000-ES-02, Rev. 2
Tide: Comprehensive Remedial Investigation/Feasibility Study for Argoone National
Laboratory-West Operable Unit 9-04 at the Idaho National Engineering aod
Environmental Laboratory (FINAL), Vol. I
Author: Lee, S.D.; Robe, M.J.; Rood, A.S.; Stepan, I.E.
Recipient: N6t specified
Date: 12/01/97
ADMINKTTtATTVK RECORD VOLUME V
* Document I: W7500-0000-ES-02, Rev. 2
Title: Comprehensive Remedial Investigation/Feasibility Study for Argonne National
Laboratory-West Operable Unit 9-04 at the Idaho National Engineering and
Environmental Laboratory (FINAL). Vol. n
Author: Lee, S.D.; Robe, MJ.; Rood, A.S.; Stepan, I.E.
Recipient: Not specified
Date: 12/01/97
AR4J PROPOSED PLAN
* Document f : 10441
Title: Proposed Plan for Waste Area Group 9 - Argonne National Laboratory- West. Idaho
National Engineering and Environmental Laboratory
Author: Lee, S.D.
Recipient: Not specified
Date: 01/01/98
NOTE: Sampling data can be examined at Argoone National Laboratory-West.
B-25
-------
IDAHO NATIONAL ENGINEERING AND ENVIRONMENTAL LABORATORY
ADMINISTRATIVE RECORD FILE INDEX FOR
THE INITIAL ASSESSMENTS FOR THE ARGONNE NATIONAL LABORATORY-WEST WAG 9
08/16/93
FILE NUMBER
AR1.7 INITIAL ASSESSMENTS
* Document *: 5469
Title: ANL-01, Industrial Waste Pond and Cooling Tower Slowdown Ditches (3),
OU 9-04
Author: N/A
Recipient: N/A
Date: 01/26/89
* . Document t: 5470
Title: ANL-01 A, Main Cooling Tower Slowdown Ditch, OU 9-04
Author: N/A
Recipient: N/A
Date: 01/26/89
* Document f: 5471
Title: ANL-04, ANL Sewage Lagoons. OU 9-01
Author: N/A
Recipient: N/A
Date: 10/15/86
* Document f: 5472
Title: ANL-05, ANL Open Burn Pits 11. t2. and *3. OU 9-03
Author: N/A
Recipient: N/A
Date: 10/15/86
Document f: 5473
Title: ANL-08, EBR-II Leach Pit (Radioactive), OU 9-02
Author: -N/A
Recipient: N/A
Date: 10/24/86
' Document f: 5474
Title: ANL-09, ANL Interceptor Canal, OU 9-04
Author: N/A
Recipient: N/A
Date: 10/17/86
B-26
-------
INITIAL ASSESSMENTS FOR ANL-W WAG 9 08/16/93
FILP NUMBER
AR1.7 INITIAL ASSESSMENTS (continued)
4 Document t: 5475
Title: ANL-10. Dry Wells Between T-1 and ZPPR Mound
Author: N/A
Recipient: N/A
Date: 10/08/86
* Document t: 5476
Title: ANL-11, Waste Retention Tank 783 (Never Used)
Author: N/A
Recipient: N/A
Date: 09/09/86
» Document f: 5477
Title: ANL-12. Suspect Waste Retention Tank 783 (Removed 1979)
Author: N/A
Recipient: N/A
Date: 10/14/86
* Document *: 5478
Title: ANL-14, Suspect Tank and Drain Fields (2) by 753 (Tank Removed 1979)
Author: N/A
Recipient: N/A
Date: 10/05/86
* Document f: 5479
Title: ANL-15, Dry Well by 768
Author: N/A
Recipient: N/A
Date: 09/15/86
* Document f: 5480
Title: "ANL-16. Dry Well By 759 (2)
Author: N/A
Recipient: N/A
Date: 09/30/86
B--1
-------
INITIAL ASSESSMENTS FOR ANL-W WAG 9 08/16/93
FILE NUMBER
AH 1.7 INITIAL ASSESSMENTS (continued)
* Document f: 5481
Title: ANL-17, Dry Well By 720
Author: N/A
Recipient: N/A
Date: 10/06/86
» Document *: 5482
Title: ANL-18, Septic Tank and Drain Reid by 789 (Removed 1979)
Author: N/A
Recipient: N/A
Date: 09/30/86
» Document t: 5483
Title: ANL-19, Sludge Pit W of T-7 (Imhoff Tank) (Riled in 1979). OU 9-OV
Author: N/A
Recipient: N/A
Date: 10/21/86
* Document *: 5484
Title: ANL-20, Septic Tank and Leach Reid by 793
Author: N/A
Recipient: N/A
Date: 10/05/86
» Document *: 5485
Title: ANL-21. TREAT Suspect Waste Tank and Leaching Field (Non-
Radioactive)
Author: N/A
Recipient: N/A
Date: 10/02786
* Document f: 5486
Title: ANL-22. TREAT Septic Tank and Leaching Reid
Author: N/A
Recipient: N/A
Date: 10/03/86
B-28
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INITIAL ASSESSMENTS FOR ANL-W WAG 9 08/16/93
PILE NUMBER
AR1.7 INITIAL ASSESSMENTS (continued)
» Document 8: 5487
Title: ANL-23, TREAT Seepage Pit and Septic Tank W of 720 (Filled 1980)
Author: N/A
Recipient: N/A
Date: 10/05/86
A Document f: 5488
Title: ANL-24, Lab and Office Acid Neutralization Tank
Author: N/A
Recipient: N/A
Date: 09/30/86
4 Document *: 5489
Title: ANL-25. Interior Building Coffin Neutralization Tank
Author: N/A
Recipient: N/A
Date: 09/30/86
* Document f: 5490
Title: ANL-26, Critical Systems Maintenance Degreasing Unit
Author: N/A
Recipient: N/A
Date: 10/05/86
* Document *: 5491
Title: ANL-27, Plant Services Degreasing Unit
Author: N/A
Recipient: N/A
Date: 09/30/86
* Document f: 5492
Title: ANL-28. EBR-II Sump (Regeneration), OU 9-01
Author: N/A
Recipient: N/A
Date: 09/30/86
B-29
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INITIAL ASSESSMENTS FOR ANL-W WAG 9 8/16/93
PILE NUMBER
AR1.7 INITIAL ASSESSMENTS (continued)
» Document *: 5493
Title: ANL-29, Industrial Waste Uft Station. OU 9-01
Author: N/A
Recipient: N/A
Date: 10/23/86
* Document *: 5494
Title: ANL-30, Sanitary Waste Lift Station, OU 9-01
Author: N/A
Recipient: N/A
Date: 10/08/86
* Document f: 5495
Title: ANL-31, Industrial/Sanitary Waste Lift Station (Industrial Side Not Used),
OU9-O3
Author: N/A
Recipient: N/A
Date: 10/22/86
* Document #: 5496
Title: ANL-32, TREAT Control Building 721 Septic tank and Leach Field
(Present)
Author: N/A
Recipient: N/A
Date: 09/30/86
* Document f: 5497
Title: ANL-33, TREAT Control Building 721 Septic Tank and Seepage Pit
(Removed 1978)
Author: N/A
Recipient: N/A
Date: 10/03/86
* Document f: 5498
Title: ANL-34, Fuel Oil Spill by Building 755, OU 9-01
Author: N/A
Recipient: N/A
Date: 10/14/86
B-30
-------
INITIAL ASSESSMENTS FOR ANL-W WAG 9 8/16/93
FILE NUMBER
AR1.7 INITIAL ASSESSMENTS (continued)
» Document *: 5499
Title: ANL-35, Industrial Waste Lift Station Discharge Ditch, OU 9-04
Author: N/A
Recipient: N/A
Date: .07/14/87
» Document f: 5500
Title: ANL-36, TREAT Photo Processing Discharge Ditch, OU 9-01
Author: N/A
Recipient: N/A
Date: 07/21/87
* Document *: 5501
Title: ANL-53, Cooling tower Riser Pits, OU 9-04
Author: N/A
Recipient: N/A
Date: 04/01/90
AR6.1 COOPERATIVE AGREEMENTS
Document f: ERD1-070-9 !
Title: Pre-signature Implementation of the CERCLA Interagency Agreement
Action Plan
Author: EPA, Findley, C.E.
Recipient: DOE, Solecki, J.E.
Date: 04/19/91
* Document *: 3205*
Title: U.S. DOE INEL Federal Facility Agreement and Consent Order
Author: N/A
Recipient: N/A
Date: "07/22/91
* Document 9: 2919* »
Title: INEL Action Plan For Implementation of the Federal Facility Agreement
and Consent Order
Author: N/A
Recipient: N/A
Date: ,07/22/91
B-31
-------
INITIAL ASSESSMENTS FOR ANL-W WAG 9
8/16/93
FILE NUMBER
AR6.1
COOPERATIVE AGREEMENTS (continued)
Document*: 1088-06-29-120'
Title: U.S. DOE INEL Federal Facility Agreement and Consent Order
Author: N/A
Recipient: N/A
Date: 12/04/91
Document #: 3298*
Title: Response to Comments on the Idaho National Engineering Laboratory
Federal Facility Agreement and Consent Order
Author: N/A
Recipient: N/A
Date: 02/21/92
Document f: DOE/ID-10340(92)
Title: Response to Comments on the Idaho National Engineering Laboratory
Federal Facility Agreement and Consent Order
Author: N/A
Recipient: N/A
Date: 02/21/92
AR9.1
NOTICES ISSUED
Document f:
Title:
Author:
Recipient:
Date:
Document t:
Title:
Author:
Recipient:
Date:
Document f:
Title:
Author:
Recipient:
Date:
AM/SES-ESD-92-256'
Natural Resource Trustee Notification
Pitrolo. A.A.
Andrus, C.D.
07/07/92
AM/SES-ESD-92-257*
Natural Resource Trustee Notification
Pitrolo, A.A.
Polityka, C.
07/07/92
AM/SES-ESD-92-258*
Natural Resource Trustee Notification
Pitrolo, A.A.
Edmo, K.
07/07/92
B-32
-------
INITIAL ASSESSMENTS FOR ANL-W WAG 9
8/16/93
FILE NUMBER
AR9.1
NOTICES ISSUED (continued)
Document #: AM/SES-ESD-93-007'
Title: Invitation to Natural Trustee Representatives to Discuss Natural
Resources and Environmental Restoration at the INEL
Author: Hinman, M.B.
Recipient: Addressee List
Date: 01/25/93
Document *: AM/SES-ESD-93-097*
Title: Agenda for Meeting of Potential Natural Resource Trustees' on March 17,
1993
Author: Twitchell. R.L.
Recipient: Addressee List
Date: 03/02/93
Document f: AM/SES-ESD-93-159*
Title: INEL Natural Resource Trustee Meeting 'Group Memory" March 17, 1993
Author: Hinman, M.B.
Recipient: Addressee List
Date: 03/30/93
Document *: AM/SES-ESD-93-162*
Title: Department of Energy Idaho Field Office (DOE-ID) Proposal
Consultation and Coordination between Natural Resource Trustees
Author: . Hinman, M.B.
Recipient: Addressee List
Date: 04/02/93
Document *: AM/SES-ESO-93-276*
for
Title:
Author:
Recipient:
Date:
Document *:
Title:
Author:
Recipient:
Date:
Department of Energy Idaho Field Office (DOE-ID) Action Item Report to
Potential Natural Resource Trustees
Hinman, M.B.
'Addressee List
06/16/93
5337
Natural Resource Trustee Representation Designation
Andrus, C.D., Governor
Pitrolo, A.A.
08/11/92
B-33
-------
INITIAL ASSESSMENTS FOR ANL-W WAG 9 8/16/93
Pit P NUMBER
AR9.1 NOTICES ISSUED (continued)
» Document *: 5338*
Title: Response to Natural Resource Notification
Author: Polityka. C.S.
Recipient: Pitrolo, A.A.
Date: 08/28/92
AR11.1 EPA GUIDANCE
* Document f: 5163, Revision 3*
Title: Administrative Record List of Guidance Documents
Author: EPA
Recipient: N/A
Date: 08/12/92
Document filed in IN EL Federal Facility Agreement and Consent Order (FFA/CO)
Administrative Record Binder
B-34
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